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SunTrust Banks Inc.

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Industry Electrical Equipment & Parts
Employees 10,000+
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FY2017 Annual Report · SunTrust Banks Inc.
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 Annual 
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The 
Way

SunTrust Banks, Inc. is one of the nation’s largest and strongest financial services companies, with total assets of $206 billion and 
total deposits of $161 billion as of December 31, 2017. Most importantly, we are an organization driven by purpose and a personal 
touch. We are passionate about Lighting the Way to Financial Well-Being. Helping instill a sense of confidence in the financial 
circumstances of clients, communities, teammates and shareholders is at the center of everything we do.

We deliver a full suite of products and financial services designed to help serve the needs of our consumer, business, corporate 
and institutional clients. Our businesses are organized into two segments: Consumer, which includes Consumer Banking, 
Consumer Lending, Private Wealth Management and Mortgage; and Wholesale, which includes Corporate and Investment 
Banking, Commercial and Business Banking, Commercial Real Estate, and Treasury and Payment Solutions.

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(Dollars in millions and shares in thousands, except per share data)
Year ended December 31
For the Year
Net income
Net income available to common shareholders
Total revenue
Total revenue — full-time equivalent (FTE)1,2
Noninterest expense
Per Common Share
Net income — diluted
Dividends declared
Common stock closing price
Book value
Tangible book value1
Financial Ratios
Return on average total assets
Return on average common shareholders’ equity
Return on average tangible common shareholders’ equity1
Net interest margin
Net interest margin — FTE1,2
Efficiency ratio
Tangible efficiency ratio — FTE1,2
Adjusted tangible efficiency ratio — FTE1,2
CET1 (Basel III)
At December 31
Total assets
Loans
Deposits
Total shareholders’ equity
Common shares outstanding
Full-time equivalent employees

2017

$2,273
2,179
8,987
9,132
5,764

$4.47
1.32
64.59
47.94
34.82

1.11%
9.72
13.39
3.06
3.14
64.14
62.30
61.04
9.74

2016

$1,878 
1,811
8,604
8,742
5,468

$3.60
1.00 
54.85
45.38
32.95

0.94%
7.97
10.91
2.92
3.00
63.55
61.99
61.99
9.59

2015

$1,933
1,863
8,032
8,174
5,160

$3.58
0.92
42.84
43.45 
31.45

1.02%
8.46
11.75
2.82
2.91
64.24
62.64
62.64
9.96

$205,962
143,181
160,780
25,154
470,931
23,785

$204,875 
143,298
160,398
23,618
491,188 
24,375

$190,817
136,442
149,830
23,437
508,712
24,043

1 See reconciliation of non-U.S. GAAP measures in Table 30, “Selected Financial Data and Reconcilement of Non-U.S. GAAP Measures,” in the MD&A section (Item 7) of the Company’s 2017 Annual Report on Form 10-K.
2 The Company presents Total revenue — FTE, Net interest margin — FTE, Tangible efficiency ratio — FTE and Adjusted tangible efficiency ratio — FTE on a fully taxable-equivalent (FTE) basis. The FTE basis adjusts for the 
tax-favored status of net interest income from certain loans and investments using a federal tax rate of 35% and state income taxes, where applicable, to increase tax-exempt interest income to a taxable-equivalent basis. The 
Company believes the FTE basis is the preferred industry measurement basis for these measures and that it enhances comparability of net interest income arising from taxable and tax-exempt sources. Total revenue — FTE is 
calculated as Net interest income — FTE plus noninterest income. Net interest margin — FTE is calculated by dividing annualized net interest income — FTE by average total earning assets.

 
 
 
7Confidence 
Starts Here

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TO MY FELLOW OWNERS, 

I have been chairman & CEO since 2011, and for each of the past six 
years, we have been able to deliver good news about the progress 
we’re making as a Company, our performance, and most importantly, 
the value we’ve delivered to you, our owners. In fact, if you’ve been 
an owner of the Company for the last six years, the cumulative return 
on your investment is 306%, and better yet, we’ve outperformed our 
peer group in five of those six years. But even if you just became an 
owner in 2017, you still benefited from our outperformance—our total 
shareholder return (TSR) was 20% (approximately 700 basis points 
higher than the median of our peer group).

WILLIAM H. ROGERS, JR.
Chairman & Chief Executive Officer
SunTrust Banks, Inc.

SunTrust is where I’ve been for my entire 
career, and we’ve gone through some 
challenging times as a Company. When 
I became CEO in June of 2011, we were 
digging out of the Great Recession and 
saw many banks around us fail to survive. 
It was a particularly traumatic time in the 
history of our country.   

Despite this, our team understood the 
underlying potential of this great Company 
and was committed to turning the tide. We 
developed three primary strategies of 
(1) growing and deepening client 
relationships; (2) improving efficiency; 
and (3) optimizing the balance sheet to 
enhance returns. Since then, our strategic 
focus has been consistent, which also 
helped our execution against these 
strategies—we learn from our mistakes, 
we course correct and we continue to 
progress toward our ultimate goal of being 
America’s best financial services company.  

Total Shareholder Return1

SUNTRUST

PEER MEDIAN2

2012

2013

2014

2015

2016

2017

Cumulative 
Return

61%

31%

16%

5%

31%

20%

306%

22%

37%

9%

(2)%

30%

13%

183%

As I reflect upon our journey since then, I cannot 
help but be incredibly proud of what we have 
accomplished. For each of the past six years, 
we’ve grown the earnings of the Company, 
we’ve improved our efficiency and we’ve been 
able to increase our capital returns to owners (all 
of which has resulted in the shareholder returns 
you see in the table above).

Our improved financial performance is 
not the only measure of our success. 
We fundamentally believe purpose and 
performance are inextricably linked, 
and I am equally proud of the way that 
we’ve evolved into a purpose-oriented 
Company.

Today, our purpose of Lighting the Way 
to Financial Well-Being for our clients, 
teammates and communities is truly the 
heartbeat of the Company—it is at the 
center of everything we do. This purpose 
was the catalyst for the onUp Movement, 
which we launched in 2016 to help all 
Americans move from financial stress to 
financial confidence. I’ll touch more on our 
purpose later, but if you haven’t already 
done so, please visit onUp.com (and 
better yet, take The onUp Challenge!). 

1Source: Bloomberg. Dividends assumed to be reinvested in security.
2Peer group in 2017 was BAC, BBT, CFG, FITB, HBAN, KEY, MTB, PNC, RF, USB, WFC. Peer group from 2012–2016 was BBT, CMA, COF, FITB, KEY, MTB, PNC, 
RF, USB, WFC. Cumulative return based on current peer group.

3

We fundamentally believe purpose and performance are 
inextricably linked, and I am proud of the way that we’ve 
evolved into a purpose-oriented Company.

INVESTMENT THESIS 

we evolve and adapt to changing client 

the size and locations of our branch 

preferences (particularly in an increasingly 

network while also modernizing our 

I meet with many of our owners 

digital world), maintain our competitive 

remaining branches and ensuring they are 

throughout the year, and while discussion 

advantage (including in differentiated 

staffed with talented professionals. We 

topics and questions evolve over time, 

businesses like SunTrust Robinson 

then deploy the savings from our branch 

what has not changed is their core 

Humphrey and LightStream) and better 

network (which is down by 24% over the 

investment thesis in SunTrust. Our 

diversify our revenue mix. Even going 

last six years) into our digital capabilities, 

owners have invested in SunTrust for 

back to the Great Recession, we remained 

with increased emphasis on our mobile 

three primary reasons: (1) we have a 

disciplined around investing in growth 

capabilities. Take a look at pages 12-13 

strong and diverse franchise and are 

to position the Company for long-

of the report and you’ll see some of the 

focused on investing in growth; (2) 

term success. This strategy has yielded 

key features we added in 2017, including 

we have demonstrated success in 

positive results and was a key contributor 

enhanced payment capabilities through 

improving our efficiency and returns 

to the solid 4% revenue growth we 

the Zelle® network, in addition to a sneak 

but have potential for significant future 

delivered in 2017.  

preview of what’s to come in 2018.  

improvements; and (3) we have a strong 

capital position, particularly in the 

Today more than ever, we must invest in 

context of our lower relative risk profile, 

new technologies, focus on innovation 

which has enabled us to return increasing 

and ensure that we remain agile. As a 

amounts of capital back to our owners.  

Company, we are making significant 

investments in technology, and I have 

Our financial performance has directly 

no doubt this will continue to be one 

supported this investment thesis.  

of the largest, if not the largest, area of 

As you saw, 2017 marked our sixth 

investment for the Company over the 

consecutive year of higher earnings per 

medium term.

share, improved efficiency and higher 

capital returns. In addition to those, 

The world of traditional branch banking 

Adjusted Earnings 
Per Share3

.

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4 $
7
2
9 $

.

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9
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6
3
$

.

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there’s much more that we accomplished 

is changing at a rapid pace. Our clients 

At a high level, our digital strategy within 

in 2017.  

don’t need to have a branch right around 

Consumer is to meet our clients where 

STRONG & DIVERSE 
FRANCHISE; INVESTING 
IN GROWTH 

the corner anymore, but they do need 

they are. We serve them when, where and 

to have a mobile app that is easy to 

how they choose, and make banking easy 

use and can fulfill the majority of the 

for them. Our Mobile App and broader 

tasks that once required a trip to the 

digital platform (mobile, tablet, online) 

branch. Branches still play a meaningful 

should be our clients’ financial home—

Our strategy and investment thesis have 

role—45% of our clients come into a 

their one-stop shop for understanding 

been consistent, but that’s not to say we 

branch each month; at the same time, 

and managing their finances, which 

aren’t constantly evolving as a Company. 

our mobile sign-ons were up 20% in 2017. 

ultimately supports our purpose of 

We have been and will continue to make 

For this reason, our approach is balanced. 

enabling financial confidence.  

investments in growth to ensure that 

We will continue to thoughtfully optimize 

32012, 2013, 2014 and 2017 values represent adjusted earnings per share. The impact of excluding discrete items was ($1.40), $0.33, $0.01 and ($0.39) for 2012, 
2013, 2014 and 2017, respectively.

4

In the same way that traditional branch 

the first banks to partner with GreenSky, 

the wealth-management needs of clients 

banking is changing, so is the world of 

and it has been a great partnership thus 

across the spectrum.  

consumer lending. Clients don’t want to 

far—plus there is potential for more.   

go into a branch, fill out a lot of paperwork 

Our Consumer leadership team spent 

for their loan application and then have 

The final piece of consumer lending is 

a significant part of 2017 integrating 

to wait weeks to get the results. When 

mortgage, and frankly, our mortgage 

the Mortgage business into Consumer 

it comes to lending, clients want three 

application process is not nearly as 

and “wiring” the entire ecosystem 

things: (1) simplicity; (2) speed; and (3) 

user-friendly as LightStream and 

appropriately so that the right teammate 

privacy. Through LightStream, our online 

GreenSky (in part due to heightened 

is delivering the right solution at the right 

lending platform, we provide just that. 

regulatory expectations for mortgage 

time. We have a great team in place; we 

LightStream provides funding for the 

lending). So this is an area where we’ve 

have a clear strategy; we are in the right 

majority of consumer purchases: cars, 

made significant investments. In 2016, 

consumer businesses; and we are in some 

boats, weddings, home improvement 

we introduced a new back-end loan 

of the highest growth markets in the 

projects, debt consolidation, medical 

origination system, and in 2018, we’ll 

country (many of which will benefit from 

bills and so much more. Better yet, the 

be rolling out a new, fully digitized 

tax reform). All in all, Consumer is a great 

application takes the average client less 

front-end mortgage application which 

business today, and I’m confident it will 

than 20 minutes to complete, and in 

will significantly improve the 

be even better in the years to come. 

many cases we are able to provide same-

client experience. 

day funding. This platform, which we 

Our other business segment, Wholesale, 

acquired in 2012, has been a key area 

While technology has been a key area 

is broken into three primary lines of 

of investment for the Company. We 

of investment in Consumer, we’re also 

business: Corporate and Investment 

strongly believe we have a head start in 

investing in our talent. Specifically, 

Banking (also known as SunTrust 

this space, but we must make consistent 

we’ve made significant investments 

Robinson Humphrey, or STRH), 

investments to keep up with the pace of 

in our wealth management business—

Commercial Banking and Commercial 

innovation and fully capitalize upon the 

hiring new advisors, training our 

Real Estate. This segment has an 

competitive advantage that LightStream 

existing advisors and even expanding 

undeniable competitive advantage—

provides. We’re also gaining great national 

into new markets. In 2017, we added 

we bring big-bank capabilities to 

recognition for this platform. In December, 
U.S. News & World Report named 
LightStream one of the Best Personal 

approximately 130 new advisors, some 

middle-market clients in a team-oriented 

of whom are in our new offices in Dallas, 

manner. Said differently, we’re a big 

Houston and New York City. We also 

bank with a boutique feel. The numbers 

Loan Companies of 2017. 

introduced a new RESERVE segment, 

speak for themselves—we’re gaining 

which provides a truly differentiated 

market share and growing this business 

In addition to LightStream, we also have 

service to clients with $5–$25 million of 

at an impressive rate. In fact, in 2017, 

a partnership with GreenSky, which 

managed assets. This is an attractive 

investment banking income was up 21% 

provides point-of-sale financing for 

value proposition for our clients, and 

and delivered record performance for 

home improvement projects. GreenSky 

we added more than 200 clients to 

the 10th consecutive year.  STRH also 

works with home improvement providers 

the RESERVE segment in 2017. Wealth 

received some notable awards this year, 

(contractors or corporations) and 

management has always been a key 

including the recognition of M&A Middle 

provides an easy-to-use platform and 

business for us, and in this highly 

Markets Investment Bank of the Year by 

process to apply for financing. A key part 

competitive industry, we want to ensure 

Atlas Awards.  

of the model is the funding—and that’s 

that we have the right team, the right 

where we come in. SunTrust was one of 

technology and the right model to serve 

2017 marked our sixth consecutive year of higher earnings per share, 
improved efficiency and higher capital returns.  

5

In 2017 alone, we removed another 100 basis points from our 
adjusted tangible efficiency ratio, improving it to 61%.

I mentioned earlier that we’ve been very 

either came directly from STRH or have 

and has enhanced payments and liquidity 

disciplined about investing for growth 

a background in investment banking. 

management tools and capabilities. There 

regardless of the economic environment.  

Next, we worked hard to train our existing 

is more work to be done, but this was 

STRH is a prime example of this—we were 

bankers on how to best cover their clients. 

an important first step. We’re working 

actively growing a capital markets business 

We taught them how to partner with the 

on improving our real-time payments 

and hiring talented teammates in 2006–

industry and corporate finance experts to 

capabilities for corporate clients and 

2009, right in the middle of the Great 

tailor solutions for our clients. While it has 

advancing their mobile options as well.  

Recession. Because of that commitment, 

only been a few years, the early results 

we have created what we believe is 

are very encouraging. When we are able 

Overall, Wholesale had a great year in 

the leading middle-market corporate 

to bring product and industry expertise to 

2017, delivering record revenue and net 

and investment bank. In addition, our 

our clients, we grow the average revenue 

income, in addition to improved efficiency. 

leadership team has been stable, and 

per client by eight times (where these 

More importantly, this business has a 

collectively, they have an average of 11 

capabilities are applicable).   

significant runway for growth. We have a 

years at SunTrust.  

great team in place, we have the full set of 

Until 2017, our Commercial Banking 

capital markets capabilities and we have 

STRH is a great business, and it’s been 

business focused on covering clients in 

a proven competitive advantage. We will 

in a steady growth mode for a long 

markets where we have a branch banking 

continue to invest in our talent, products 

time now. I am confident this growth 

presence. However, many commercial 

and technology to ensure our Wholesale 

will sustain as we continue to deepen 

clients do not need a branch, and given 

segment can realize its full potential.  

relationships with existing clients and 

the competitive advantage we were 

acquire new clients. But there’s a second, 

creating, we asked ourselves an 

The investments we’ve made in growth 

more recent leg of our growth strategy—

appropriate question: Why is Commercial 

across the Company have greatly 

bring the product and industry expertise, 

Banking only in the Southeast and Mid-

diversified both our revenue mix and our 

the coverage model (which we call the 

Atlantic? There was no longer a good 

balance sheet. We benefited from this 

OneTeam Approach®) and the discipline 

answer to this question, and thus we 

diversity in 2017 in a couple of ways. First, 

from STRH and export this into our 

opened three new commercial banking 

mortgage revenues declined significantly 

Commercial Banking and Commercial Real 

offices in Texas and Ohio. Even though 

as refinancing volumes were down given 

Estate businesses. We’re effectively taking 

we’ve only been in these new markets for 

the rise in interest rates. However, we were 

the STRH playbook and bringing it to the 

a few months, we’ve already generated 

still able to deliver 4% revenue growth 

rest of Wholesale to meet more of our 

new business, and I’m confident this 

due to growth from other areas, including 

clients’ needs beyond traditional lending 

expansion will be a contributor to 

investment banking and traditional net 

and deposit solutions.    

Wholesale’s growth going forward.  

interest income (which benefits from 

rising rates). Secondly, within a matter of 

We started on this journey back in 2014 

As with Consumer, investments in 

weeks, Hurricane Harvey and Hurricane 

by creating industry-specialty groups 

technology are also a key area of 

Irma came through our markets, causing 

that are most relevant to clients in our 

focus in Wholesale. Our treasury and 

significant damage throughout Texas and 

markets (ports and logistics, aging services 

payments capabilities are key to our 

the Southeast. While we expect to incur 

and not-for-profit healthcare are just a few 

future success.  We have a new online 

some losses (for which we’ve already 

examples). We also put the right leadership 

treasury management platform, SunView, 

reserved), this only had a modest impact 

team in place. The vast majority of our 

which we introduced in 2017. SunView 

to our financial performance. Ten years 

market presidents in Commercial Banking 

provides an improved client experience 

ago, at a time when we were much more 

6

concentrated in Florida and Georgia, with 

There are a few key actions we took in 

introduced new loan-origination systems 

a different risk profile, it wouldn’t have 

2017 in connection with our efficiency 

in Commercial Banking and Mortgage. In 

been as good of a story. All in all, our 

objectives.  In February, we decided to 

doing so, we’ve significantly modernized 

intentional focus on investing in growth 

consolidate our mortgage business, which 

our loan-origination process and ultimately 

while also ensuring we have adequate 

historically had been a separate segment, 

improved loan-cycle origination times. 

diversity has significantly reduced our 

into Consumer. This provides us with 

Importantly, these core systems are also 

earnings volatility, further benefiting our 

opportunities to streamline operations and 

cloud-based, thereby improving our agility 

clients and owners.  

creates greater alignment among all the 

and efficiency. And finally, we continue to 

IMPROVING EFFICIENCY 
& RETURNS 

consumer-facing channels. We also created 

invest in self-service channels like mobile, 

an Efficiency Office, and this team’s work 

which lowers our overall cost to serve and 

has enabled a heightened focus and rigor 

makes it easier for clients to complete 

around driving and sustaining efficiency in 

routine transactions.   

As you can see, we have a number of 

order to position the Company for long-

growth initiatives across the Company 

term growth and success. Additionally, we 

Third, we continue to look for opportunities 

and have been disciplined about making 

took several charges in the second half 

to reduce our real estate footprint, both 

consistent long-term investments. The 

of 2017, which accelerated our progress 

in the branches and in our corporate and 

goal has been and continues to be that 

against certain efficiency initiatives.  

operations centers. We’ve taken out about 

we remove less productive expenses 

a fourth of our branch network over the 

and redeploy them into client-focused 

At a high level, there are four primary areas 

last six years, and we’ve also significantly 

opportunities (though that is always easier 

where we have the most opportunity to 

reduced our corporate workspace. Over the 

said than done).  

improve efficiency. 

past year, we removed 674,000 square 

feet, and over the past six years, we have 

In 2011, our efficiency ratio was 72% and 

First, we continue to optimize our human 

taken out 3.4 million square feet from 

we set a goal of improving it to be below 

capital. We are very focused on right-

our real estate footprint (about 30%) and 

60%. Over the past six years, we’ve made 

sizing the chassis of the organization to 

expect further reductions in the next few 

significant progress toward this goal 

ensure our businesses are appropriately 

years—good for our owners and good for 

(which we now expect to achieve by 2019). 

staffed. We went through a significant 

sustainability. 

In 2017 alone, we removed another 100 

organizational design process in 2017 and 

basis points from our adjusted tangible 

executed both a severance and a voluntary 

And finally, we remain focused on managing 

efficiency ratio, improving it to 61%. 

retirement program to manage our staffing 

our supplier relationships. We are not just 

%
5

.
1
7

Adjusted Tangible 
Efficiency Ratio4

model. At the same time, we continue 

working to maximize our internal resources— 

to make investments in our organization 

we also want to maximize our external 

by training our existing teammates and 

resources. We have and will continue to 

%
9
6
6

.

%
3
5
6

.

%
3
3
6

.

%
6
2
6

.

%
0
2
6

.

%
0
.
1
6

bringing in new talent.  

look for opportunities to optimize vendors, 

renegotiate contracts and bring services 

Second, we are leveraging the investments 

in-house when appropriate. 

we’ve made in technology. We are 

making significant investments in various 

Now, more than ever, there is a culture of 

forms of automation (robotics, artificial 

continuous improvement ingrained within 

intelligence, machine learning, better end-

our organization. It is this discipline, this 

to-end processes) which improves our 

emphasis on executional excellence and 

effectiveness and allows our teammates 

this heightened set of expectations which 

to focus on higher value-added work. 

will enable us to realize our long-term 

’11

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Additionally, over the past two years, we 

profitability potential.  

42012, 2013, 2014 and 2017 values represent the adjusted efficiency ratio and adjusted tangible efficiency ratio. Adjusted figures are intended to provide 
management and investors information on trends that are more comparable across periods and potentially more comparable across institutions.

7

 
INCREASED CAPITAL 
RETURNS TO OWNERS 

I am a strong believer in the CCAR process 

Experience. The onUp Experience is a space 

and the regulatory requirements related 

that we designed specifically for SunTrust 

to capital. Today, the industry is in a much 

Park, which uses fun and interactive 

As owners, I am sure you will agree 

better position to absorb losses and 

baseball-themed games to engage with 

with me that one of our biggest 

withstand a significant economic downturn. 

fans and encourage them to learn more 

accomplishments in 2017 was the 54% 

I am also a strong believer that capital, on 

about gaining financial confidence.  

increase in the dividend and 38% increase 

a fundamental basis, exists to support risk. 

in our share buyback program. This was 

Therefore, a bank’s capital profile should be 

In 2017, as an extension of onUp, we 

the sixth consecutive year in which we’ve 

commensurate to its risk profile. Given this, 

launched Momentum onUp®, which aims to 

increased our capital returns, and we 

we think we can reduce our fully phased-in 

help companies equip their employees with 

brought our total payout ratio up to 89% 

Basel III Common Equity Tier 1 ratio from 

the tools for financial success. This actually 

for the 2017 calendar year.  

9.6% to between 8-9% over the next couple 

began as a program for our own teammates 

What’s equally encouraging is that we 

continue to perform very well in the 

Federal Reserve’s stress test. Relative to 

of years.  

OUR PURPOSE

in 2015. We felt it was so successful for us 

that we decided to offer the program to 

our corporate clients and their employees 

(at no profit to SunTrust). We already have 

our peers, we consistently have among 

I said earlier in this letter that our purpose is 

more than 70 companies signed up, and 

the lowest loss rates, which is further 

at the center of all that we do. We are 

more than 30,000 of their employees have 

validation of our underwriting discipline 

passionate about promoting financial 

completed the program. The feedback has 

and portfolio diversity. I talked earlier 

well-being for our clients, communities 

been tremendous—99.5% of participants 

about our emphasis on having a diverse 

and teammates. There is no denying that 

tell us they would recommend Momentum 

balance sheet and business mix, which 

financial stress takes a huge toll on so many 

onUp to others.  

not only allows us to deliver consistent 

people—it is a burden on their relationships, 

results, but is also a key contributor to our 

it keeps them from being as productive at 

There’s much more that we accomplished 

strong performance in CCAR. In fact, the 

work and it ultimately prevents them from 

related to our purpose in 2017, specifically 

standard deviation of our CCAR loss rates 

fully enjoying the moments that matter. It 

the work we’ve done in our communities to 

is just five basis points, which is by far the 

is our fundamental belief that banks have a 

build financial confidence, but I’d encourage 

lowest among our peers. This ultimately 

tremendous opportunity and responsibility 

you to read more on pages 16–37.   

allows us to more fully leverage your 

to promote and enable financial confidence.  

capital investment in us.  

Total Payout Ratio

%
3
7

%
2
6

%
8
4

%
6
2

%
% 1
8

1

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IN CONCLUSION 

It is because of this belief that we launched 

onUp in 2016. This is a movement we 

To conclude, I want to comment on the 

%
9
8

began to help people start the conversation 

broader momentum that America has right 

about money and take steps toward 

now. There are certainly skeptics out there 

increasing financial confidence. We built 

who feel that we are due for a downturn, 

a valuable resource center at onUp.com 

and while they do have valid points, I am 

and we continue to add new tools, articles 

personally encouraged by the underlying 

and calculators for anyone’s use—not just 

strength of the economy, and I believe it 

SunTrust clients. In March, we celebrated the 

can sustain. We are in the eighth year of 

grand opening of SunTrust Park, the new 

economic expansion, and while that is 

home of the Atlanta Braves. SunTrust Park 

longer than the average expansionary period, 

is not just a ballpark—it is an impressive 

our rate of improvement has been slower 

mixed-use development with restaurants, 

than average—and I believe this country has 

retail, office space and the new The onUp 

more runway. 

8

If you just isolate tax reform in itself, this is 

encouraging to see our net interest margin 

representing the interests of our clients, 

a very positive tailwind for the economy. 

improve by 14 basis points in 2017, and the 

owners and teammates throughout their 

Not only are we boosting the earnings 

upward trajectory should continue in 2018 

tenures here. One of our Company’s 

power of corporations and creating more 

(though likely not at the same pace as the 

strengths is the depth and breadth of 

capacity for investments, but we’re also 

prior two years).  

encouraging many companies to bring 

our team, and our succession planning 

and leadership development process, 

more of their business back to the U.S. 

All in all, this is an exciting time for the 

which will help us build upon these 

I truly believe that tax reform will serve as a 

American economy and a particularly 

leaders’ success.

catalyst for increased capital expenditures. 

exciting time for our industry. For 

This is where I think many companies 

SunTrust specifically, we are poised to see 

I also want to thank our teammates for 

have been holding back—they haven’t 

outsized benefits from economic growth 

all that you accomplished in 2017—it is 

had the confidence to make incremental 

and tax reform given our market position 

because of your passion for promoting 

investments in their business. Instead, 

in the high-growth Southeast and 

financial confidence, helping our clients 

most have focused on paying down debt 

Mid-Atlantic markets, the many organic 

achieve smart growth and providing for a 

and repurchasing shares. We’ve seen it in 

growth initiatives across the Company 

superior client experience that we are on 

our corporate lending activity; paydowns 

and finally, our culture of continuous 

our way to becoming the best American 

were elevated and production was down 

improvement across the organization. 

financial services company. We collectively 

in 2017, which resulted in below-average 

continue to raise the bar, and you continue 

corporate loan growth.  

To conclude, I want to thank some key 

to rise to the occasion. Together, we are 

leaders in the Company. Anil Cheriyan, our 

making a difference in the lives of our 

The improving rate environment provides 

Chief Information Officer; Ray Fortin, our 

clients, communities and owners.  

another positive backdrop for the banking 

General Counsel and Corporate Secretary; 

industry. The Federal Reserve has begun 

Tom Freeman, our Efficiency & Strategic 

And finally, thank you to our Board of 

normalizing interest rates, which has 

Partnerships Executive; and Aleem Gillani, 

Directors. Your dedication, wisdom, 

helped reverse the trend of abnormally 

our Chief Financial Officer, are retiring this 

experience and expertise has been 

low levels of net interest margins for the 

year. Together they have nearly 60 years 

and will continue to be instrumental in 

industry. While our net interest margins 

at SunTrust, and I thank each of them 

strengthening our financial performance 

may not return to pre-crisis levels, it was 

for their dedication and commitment to 

and long-term potential.  

2017 was a great year for SunTrust, and 2018 has the potential to be significantly better. 
Thank you for your ownership in SunTrust. As stewards of your capital, we are committed to 
continuing to generate value for you.   

WILLIAM H. ROGERS, JR.
CHAIRMAN AND CHIEF EXECUTIVE OFFICER 
SUNTRUST BANKS, INC.
FEBRUARY 16, 2018

9

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Impact In
 2017

Another way we live our purpose is through our 
commitment to conducting business in a way that is 
socially and environmentally responsible. A steering group 
of SunTrust teammates is helping us explore more ways 
to foster sustainable communities and enhance our focus 
on corporate social responsibility, including corporate 
governance and more comprehensive reporting. Here are 
just a few ways we were able to make an impact in 2017.

10

 
2.5MORE TH AN

MILLION  PA RTICIPA NTS 
IN THE onUp MOVEMENT

221,600

TEAMMATE 
VOLUNTEER HOURS 

$274

MILLION IN  M ORTGAG E 
LOANS TO VETERANS

WE  H E LPE D  M O R E  TH A N

17,000

LOW- TO  MODE R ATE-INCOME 
H O USE H O LDS 
QUALIFY FOR A MORTGAGE

$16.9

MILLION  IN  CONTRIBUTIONS TO
NONPROFITS AND COMMUNITY 
ORGANIZATIONS

APPROXIM ATE LY

3,500

TE AMM ATES  PA RTICIPATE 
IN EIGHT INCLUSION 
NETWORKS

1,500

ACRES  OF  TREES PL ANTE D 
BY  LIG HTSTRE AM , 
ONE TREE FOR 
EVERY NEW LOAN

11

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 The Client 
Experience

Investing in our digital platforms and client-friendly technology remains central to our 
strategy to make banking easier for clients and to support their financial well-being.

ENHANCING OUR MOBILE FUNCTIONALITY 

We’re focused on adding mobile capabilities to the Mobile App that make it easier for clients to achieve 
financial confidence. In 2017, we added a few key features: 

PERSON-TO-PERSON 
PAYMENTS
A simple and secure way to send 
or request money using only a 
phone number or email address, 
with Zelle

BETTER CARD 
SECURITY
Quickly lock and unlock your 
credit card through our 
Mobile App, reducing 
fraud risk

TRACK YOUR 
CREDIT SCORE 
View your FICO® Score online 
or through the Mobile App

SAVINGS AND 
REWARDS 
Get custom offers based on your 
spending history and preferences 
with new SunTrust Deals

12

IN 2018, clients will see a noticeable change when 
logging onto suntrust.com as we transition to a 
new Enterprise Client Portal. This new, flexible 
foundation for our digital experiences will provide 
clients the following key benefits:

HOLISTIC, TAILORED USER EXPERIENCES 
Provides a consolidated relationship view in the SunTrust Online Banking 
and Mobile Banking experiences

INTEGRATED PLANNING TOOLS
Enables clients to establish a plan, set goals and track progress while also 
providing valuable financial well-being resources

EASE OF USE
An intuitive and simple user experience based on industry-leading API and 
cloud technology

ACCESSIBILITY
A consistent user experience on any device or screen size, using responsive design

13

 Our 
Progress

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Our awards are a reflection of what we value most: making a difference 
in the lives of our clients, communities and teammates. Of all of our 
accomplishments, we take great pride in providing the best possible 
client experience and giving back to those we are privileged to serve. 

14

 
SUNTRUST WAS PROUD TO BE 
RECOGNIZED IN 2017 BY:

GLO BAL FINA NCE  MAGA Z IN E
Best Bank in the Southeast 

Best U.S. Regional Middle Market 
Treasury & Cash Management Provider 

G RE E NWICH  A SSOCIATES
5 Excellence Awards and 4 Best Brand 
Awards for small business banking

3 Best Brand Awards for 
middle market banking

Excellence Award for Overall Satisfaction 
in Wealth Management and Personal 
Investment Services

JAV E LIN
Online Banking Award

SUNTRUST WAS HONORED 
FOR ITS CORPORATE SOCIAL 
RESPONSIBILITY IN 2017 BY:

THE WOMEN’ S FORUM OF  NE W YORK
2017 Corporate Champion for Board Diversity 

FINANCIAL  SERV ICES  ROUNDTABLE
Corporate Social Responsibility Leadership Award 

THE   PRES IDE NT’ S   VOLUNTE E R 
SERV ICE  AWARD
Third-time recipient of the Advancing 
Financial Literacy Award for providing more 
than 15,000 volunteer hours to Junior 
Achievement (JA) during the 
2015–2016 school year

LIGHTSTREAM WAS 
HONORED BY:

SUNTRUST ROBINSON HUMPHREY 
WAS RECOGNIZED BY:

U. S . NE WS   & WORLD REPORT
2017 Top Lender for Very Good Credit, Low 
APR and No Origination Fees

Best Personal Loan Company

LE NDING  TRE E
Top 3 in Customer Satisfaction in 
Auto Financing, Q3

MERG ER &  ACQU ISITION 
ATL A S AWARDS
USA Outstanding M&A Middle Markets 
Investment Bank of the Year

USA M&A Large Deal of the Year Award

Americas Telecom M&A Deal of the Year Award

Gold Standard of Performance

15

Fewer than 1 in 4 Americans rate 
their financial confidence as high. 
SunTrust is here to help.

onUp UPDATES 16

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 The onUp
Movement

The onUp Movement is the manifestation of everything that drives us. It makes 
our purpose of Lighting the Way to Financial Well-Being tangible, and in its 
second year, the movement has helped more than 2.5 million participants gain 
confidence in their finances. 

INSPIRING FINANCIAL CONFIDENCE

Our research1 shows that Americans at all income 
levels can improve their financial confidence.

•  Fewer than 1 in 4 Americans rate their 

financial confidence as high

•  8 out of 10: How people with high financial

 confidence rate their happiness 
•  4 out of 10: How people with very low 

financial confidence rate their happiness

UNDERSTANDING FINANCIAL 
BEHAVIORS

•  37% of Americans feel like they are living 

paycheck to paycheck 

•  About one-third of people spend according 

KNOWING OUR PURPOSE IS A 
COMPETITIVE ADVANTAGE

SunTrust is in a position to help Americans gain 
control of their finances and take positive steps 
forward to reach their goals. From our Wholesale 
relationship managers to Private Wealth Management 
advisors, to bankers in branches and corporate 
functions teammates, everyone understands that 
providing each client with the right knowledge and 
support they need to achieve financial well-being is 
our No. 1 goal. That’s what the onUp Movement is all 
about—and what sets us apart from other banks.

to a formal budget

18SUN_10846129_2018 Annual Report    AD: Ally Hill • BL: Megan  Griswold
DIGITAL VERSION
•  About 50% of Americans don’t have $2,000 
final size: 8.25" x 10.75"
scale: 100%

• 

on hand for emergencies 
19% of Americans who are employed full-time 
do not have any retirement savings

Release Date: 2/16/2018 
Notes:  Prints 4/C

x

Original Artwork

1The quarterly SunTrust Financial Confidence Poll is conducted online using a nationally representative sample of 2,500 adults. The 
survey was collected from December 14–22 for Q4 2017.

onUp UPDATES

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onUp UPDATES 18

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Confidence 
With SunTrust

Through our extensive research, we know that a great majority of Americans experience 
financial stress. That’s why SunTrust is committed to being a part of the solution. The 
onUp Movement is our call to action, providing inspiration, education and resources to 
help everyone take a step in the right financial direction.

BRINGING THE onUp EXPERIENCE TO 
SUNTRUST PARK 

TAKING onUp ON THE ROAD 

Building on the momentum of the onUp Movement, 
onUp on tour traveled to more than 45 cities throughout 
the Southeast and Mid-Atlantic region to thank teammates, 
celebrate the onUp Movement and encourage even more 
people to take control of their finances. 

Traveled to communities from June through October 2017 
Completed 65 stops across SunTrust markets 

• 
• 
•  Reached nearly 30,000 people

Our partnership with the Atlanta Braves is more than a 
naming rights sponsorship. SunTrust Park allows us to 
connect with people where they live, work and play all year 
round at The Battery Atlanta, including millions of baseball 
fans from across the country. And through The onUp 
Experience at the entrance of SunTrust Park, we’re able to 
engage visitors with a range of interactive games and 
activities while seeding conversations about building 
financial confidence.

MAKING FINANCES FUN AT onUp.com

onUp.com continues to be an online destination for free 
financial tips, tools and resources. In 2017, we added 
gamification to the lineup. Through The onUp Challenge, 
finances are turned into an online gaming adventure, 
providing a fun, informative way for players to 
make real progress toward their goals.

onUp UPDATES

19

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Communities 

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NEW SUNTRUST FINANCIAL 
CONFIDENCE CENTER HELPS PEOPLE 
GAIN FINANCIAL CONFIDENCE

“Living on a fixed income can be a challenge,” says Carla 
Lewis. “I wanted to take charge of my finances so my family 
wouldn’t have to worry anymore.”

Crosstown Concourse, formerly a historic Sears building 
in Memphis, Tennessee, is a 1.5 million square-foot 
space that was dormant for more than 20 years. Today, 
it’s a revitalized mixed-use development dedicated to 
the cultivation of health and well-being for the community. 
Crosstown Concourse features retail stores and restaurants; 
fitness, health, arts, education and office space; and 
270 apartments.

SunTrust Commercial Real Estate led the financing for 
the $200 million transformation of the site. Through its 
subsidiary, SunTrust Community Capital, the bank also 
led a $56 million New Markets Tax Credit transaction and 
participated as an investor.

But that isn’t the only contribution SunTrust made to this 
community. The bank knew this location would be the ideal 
setting for a hub where people could come together to 
socialize, collaborate and obtain education and resources to 
improve their financial well-being.  

That goal led Ms. Lewis to the SunTrust Financial 
Confidence Center on its grand opening day in 
August 2017. In partnership with Operation HOPE, the 
center offers free advice and resources to help people 
build financial confidence.

“I’m legally blind, live with my mother, and my daughter 
has a learning disability, which requires her to be 
homeschooled,” explains Ms. Lewis. “My mother and I 
attended a financial workshop at the center and learned 
how to create a budget. That’s something we hadn’t done 
before.” After completing the workshop, Ms. Lewis and her 
mother also signed up for financial counseling.

“The counseling helped tremendously,” says Ms. Lewis. 
“The counselors went over all of our finances and 
discovered that I could save money on my health insurance. 
And with their help, I received a refund on premiums I had 
paid. I used that money to open a savings account. And I 
now have more affordable insurance.”

Ms. Lewis is on an 18-month credit recovery plan that will 
pay off her balances and raise her credit score. She had a
goal to take charge of her finances and is now on her way
to a life well spent.

Image: 
The SunTrust Financial 
Confidence Center at 
Crosstown Concourse

COMMUNITIES 20

 
COMMUNITIES 21

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Stronger
 Together 

Linton Allen, a founder of SunBank (a SunTrust 
predecessor), once said, “When you build your 
community, you build your bank.” Our actions, 
grants and investments are all designed to build 
financial confidence and enhance our communities.

GROWING THE SUNTRUST FOUNDATION 

Since its inception in 2008, the SunTrust Foundation has 
provided grants totaling more than $128 million to not-for-profit 
organizations across the Southeast and Mid-Atlantic. 
Throughout 2017, the Foundation focused on giving in four 
strategic financial well-being areas to help put people on 
the path to financial confidence:

• 
• 
• 
• 

Financial Education
Financial Counseling
Career Readiness and Workforce Development
Small Business and Entrepreneurship

COMMUNITIES 22

2017 SUNTRUST FOUNDATION GIVING

$16.9 million 

IN TOTAL G IVING IN 2017 
the highest in SunTrust Foundation’s history

$250,000 

to help low-income women build small 
businesses to create better lives for their families 
G R A M E E N  A M E R I C A

$700,000 

in free financial education, advice and tools 
to help families achieve financial stability

CLE ARPOINT’ S  HISPANIC CE NTER 
FOR  FINANCIAL  E XCE LLE NCE 

$380,000 

for Destination Graduation, impacting the 
financial and academic future of students at 
Seminole State College

HE ART  OF  FLORIDA  UNITED WAY 

$540,000 

to provide financial specialists, complete a 
Financial Planning Toolkit app and host 
Special Needs Workshops  

AUTISM  SPE AKS 

$150,000 

to expand the nationally recognized “The 
Law and Your Community” program to 
Baltimore, Richmond and Atlanta 

NATIONAL ORGANIZ ATION OF 
B L ACK   L AW   E NFORCE ME NT 
E XECUTIVES  (N OBLE)

HELPING OUR 
COMMUNITIES IN CRISIS

HOSTING THE LIGHTING 
THE WAY AWARDS 

BRINGING LEADERS 
TOGETHER 

The SunTrust Foundation is dedicated 
to helping our neighbors when natural 
disasters strike. Through the American 
Red Cross, we donated $50,000 to 
pick up the pieces after devastating 
tornados hit Southwest Georgia in 
February and $600,000 to help 
communities affected by Hurricanes 
Harvey and Irma quickly get access to 
resources, stay safe and rebuild.

Expanding the impact of these awards 
into their second year, the SunTrust 
Foundation provided grants totaling 
$800,000 to 30 nonprofit organizations 
that have a specific focus in one or 
more of the Foundation’s four strategic 
financial well-being areas to allow them 
to further their local efforts. 

In October 2017, the SunTrust 
Foundation hosted a National 
Financial Well-Being Summit at 
SunTrust Park, convening top thought 
leaders from nonprofit organizations 
and higher education across the nation 
to discuss ways to lead more people 
on the path to financial well-being.

COMMUNITIES

23

TOur SunTrust 
Community

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SunTrust teammates never shy from Lighting the Way to Financial Well-Being 
in tangible ways. Here are just a few ways we were able to give back in 2017.

COMMUNITIES 24

 
2017 SUNTRUST BANK INVESTMENTS

$50 million

INCREMENTAL CONTRIBUTION TO SUNTRUST FOUNDATION TO SUPPORT
OUR COMMUNITIES’ LONG-TERM FINANCIAL WELL-BEING EFFORTS

$24.4 billion

IN MORTGAGES, HELPING HOMEOWNERS ACHIEVE THEIR DREAMS

$3.8 billion

LOANS AND INVESTMENTS IN 
AFFORDABLE HOUSING AND 
COMMUNITY DEVELOPMENT 

$270 million

IN SMALL BUSINESS 
ADMINISTRATION LOANS FUNDED

OPENING OUR FIRST FINANCIAL 
CONFIDENCE CENTER 

PUTTING AN EMPHASIS 
ON GIVING BACK 

Ms. Lewis, whose story we shared on page 20, is one of 
many who have found confidence in their finances at the 
first Financial Confidence Center at the Crosstown Concourse 
development opened in Memphis. In partnership with 
Operation HOPE, the center offers advice and resources to 
help community members build financial confidence. The 
center is designed to provide financial literacy information 
and classes to the community at no charge, as well as offer 
one-on-one counseling on the topics of credit, money 
management and small business ownership. 

RAISING MILLIONS FOR UNITED WAY

Teammates and retirees raised nearly $6.7 million to help our 
neighbors find jobs, overcome obstacles and gain financial 
know-how during our annual United Way campaign.

Teammates logged 221,600 hours of volunteer time and 
worked with more than 2,800 nonprofit organizations to 
complete more than 38,000 community service activities 
and give back in ways that support their passions.

SUPPORTING OUR VETERANS

Helping those who served so bravely for our country is 
important to us. We increased our veteran hiring by nearly 
30 percent. SunTrust also placed three families in 
mortgage-free homes in 2017. 

COMMUNITIES

25

Our Team’s 
Confidence

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“My wife and I were in the midst of a financial heart attack,” says SunTrust teammate 
Andre Dyer. They owed $25,000 in credit card debt, and their credit scores were in the 
500s. Even worse, they were facing foreclosure on their home. 

Despite their financial stress, the couple constantly put on a brave face to shield their two 
daughters. “We did an incredible job of keeping them away from the heat, but it took a 
toll,” he says. To avoid foreclosure, Andre’s mother loaned him money from her retirement 
savings, but she also issued a warning. “She said, ‘I can’t keep doing this,’ and that 
statement—oh man, I was in a deep hole. I knew something had to change.”

DIGGING OUT FROM DEBT 

His first step was an honest conversation with his wife 
and a close friend who could help them develop an action 
plan. One thing was clear: Andre needed to shelve his 
unpredictable real estate gig in favor of a new career that 
offered a steady income. Two months later, he landed a role 
at SunTrust.

Andre had a plan for how to spend each dollar before his 
first paycheck came in. He used a spreadsheet to track the 
couple’s credit cards, bills and loans, and he prioritized how 
they’d pay them back.

“As fast as the money came in, it went back out to pay 
off our debts,” he says. 

The family’s influx of income and spending discipline—
partially learned through the SunTrust financial fitness 
program Momentum onUp—allowed the Dyers to make 
huge strides. They paid off the majority of their debts. 
“After the steps I took through Momentum onUp, 

we can finally breathe,” he says. “The constant stress 
gave way to financial confidence.” And Andre found that 
budgeting became second nature. They celebrated when 
they paid off their last credit card and shifted their money 
toward savings instead.

Today, the Dyers have a strong nest egg and an emergency 
fund to help with the unexpected. They’re also contributing 
toward their younger daughter’s college tuition, and Andre’s 
proud to say that their older daughter will graduate from 
college without any debt to her name.

“Sometimes my wife and I will talk about buying a new car 
or remodeling the house, but our conversations are different 
than they were a few years ago,” he says. “Now we think: 
‘What happens if we encounter an emergency?’ Remodels 
and new cars can wait. I never want to feel that stress again, 
and it feels good to work for a company whose purpose is 
aligned with my values.”

Image: 
Andre Dyer, 
SunTrust Teammate

COMMUNITIES 26

After the steps I took through Momentum 
onUp, we can finally breathe. The constant 
stress gave way to financial confidence.

TEAMMATES

27

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 With Teammates

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We’re practicing our purpose with our teammates by ensuring they have the tools and 
resources they need to continue their own journey toward financial confidence.  

BUILDING MOMENTUM onUp FOR 
TEAMMATES

Momentum onUp for Teammates is a financial wellness 
program that provides a values-based approach to achieving 
financial goals, complete with curriculum, videos, calculators 
and tools to help.

• 

• 

16,000+ active teammates participate in 
Momentum onUp for Teammates 
77% of Momentum onUp for Teammates 
participants feel more in control of their finances1 
•  SunTrust paid out nearly $9 million to more than 
12,000 teammates who completed steps in 
Momentum onUp for Teammates, to use for their 
emergency savings account

SunTrust also provided a series of three Momentum onUp 
Boot Camps for Teammates with young adults, children 
and aging loved ones. Combined, more than 9,000 
teammates participated.

RECOGNIZING PURPOSE AMBASSADORS

Approximately 425 top-performing teammates representing 
all levels of the organization serve as our Purpose 
Ambassadors. These highly engaged teammates share best 
practices and light the way for others—inside and outside 
of the bank. They’ve taken our financial fitness program, 
Momentum onUp, and are trained to talk about money, share 
insights with their colleagues, families and communities, and 
spread the onUp Movement.

INVESTING TAX REFORM SAVINGS

To support the financial wellness of our teammates, SunTrust 
made the following commitments:

•  A minimum wage increase to $15 per hour 
• 

Increased base pay for certain other nonexempt 
teammates, primarily those making between 
$15–$20 per hour

•  A one-time, one percent of 401(k) eligible wages 
will be contributed to retirement savings for all 
eligible teammates, in addition to the company’s 
6% match opportunity 

•  A $1,000 financial incentive for all teammates who 
complete both phases of SunTrust Momentum 
onUp for Teammates, including past graduates 

1Based on SunTrust Teammate Financial Well-Being Survey, May 2017.

TEAMMATES 28

 
TEAMMATES 29

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Very Best

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SUPPORTING OUR 
PHYSICAL WELL-BEING 

SunTrust supports the physical well-being of teammates 
by providing fitness perks, gym membership discounts, 
on-site health clinics, health screenings and a little extra 
nudge from partners like RedBrick Health, who provide 
top-notch guidance and support. Every year, teammates 
get a one-time $50 credit toward an already discounted 
Fitbit, and they can purchase up to two more discounted 
Fitbit devices for friends or family.

CEO Action for Diversity & InclusionTM, the largest 
CEO-driven business commitment to advance diversity 
and inclusion within the workplace.

•  Approximately 3,500 teammates participate 

• 

in eight inclusion teammate networks 
125 teammates serve as leaders 
of inclusion teammate networks

SunTrust remains committed to talent diversity 
across all levels.

LEADING INCLUSIVITY

WOMEN

MINORITY

SunTrust promotes inclusive behaviors that inspire 
a commitment to our purpose, influence a more 
engaged culture and positively influence teammates,
communities and clients.

Our teammate networks are open to all teammates 
seeking to understand different backgrounds, experiences, 
identities and ideas. And SunTrust is one of more than 
150 Fortune 500 companies that signed on to the 

Board of Directors

Executive and Senior Managers

First and Middle Managers

Professionals

All Others

Total

23%

38%

51%

53%

73%

61%

31%

18%

32%

36%

50%

41%

Source: January 2018 board data, and October 2017 teammate data produced in 
a matter consistent with EEO-1 reporting with aggregation across EEO-1 ethnicity 
categories. “All others” includes technicians, sales workers, administrative support 
workers, operatives and service workers.

TEAMMATES 30

 
SunTrust promotes inclusive behaviors 
that positively influence teammates, 
communities and clients.

TEAMMATES

31

TEAMMATES 32

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Learning
Opportunities

Our dedication to improving financial well-being starts with our own teammates. SunTrust 
is committed to delivering programs that provide opportunities for professional growth and 
development that help encourage progress on the journey to financial confidence.

CONTINUING EDUCATION

IMPROVING TEAMMATE ENGAGEMENT

We have a 93 percent participation rate in our annual 
teammate engagement survey, approaching the results for 
the most engaged companies globally. That helps us make 
SunTrust a great place to work.

When our teammates are engaged in their careers, 
their passion helps drive innovation and improve client 
satisfaction. That’s why we make every effort to improve 
the teammate experience, and it’s paying off. 

We encourage teammates to invest in their professional 
development and continuous learning. One way we make 
it easy for teammates to do this is through Teammate 
Learning Week, a week full of learning opportunities that 
allow teammates to dedicate time to their journey of 
continuous improvement.

• 

• 

12,555 enrollments (more than doubled from 
2016)
140+ sessions covering 70+ topics, from risk-
management practices to purpose-driven 
leadership and information security

Through the SunTrust Foundation, college scholarships 
were provided to the children of teammates for the 
sixth consecutive year.

TEAMMATES

33

Momentum onUp helps employees establish 
financial goals, start an emergency savings fund 
and navigate their expenses and spending habits.

CLIENTS 34

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To Our Clients

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Momentum onUp helped move our corporate clients and their employees toward financial 
confidence in a big way in 2017. Broadly launched in June at no profit to SunTrust, more 
than 70 large and small companies are now participating. The program’s on-site sessions 
and online resources help employees establish financial goals, start an emergency savings 
fund and navigate their expenses and spending habits. Many companies are also offering 
incentives for their employees to complete the program, ranging from $100 to $1,000.

OF THOSE EMPLOYEES SURVEYED 
FOLLOWING THE PROGRAM, THEY ARE 
SHOWING POSITIVE RESULTS:1

•  Employees living by a budget increased from 
43% to 87%, and those with an emergency 
savings improved from 68% to 98%
•  On average, employees increased their 

retirement contributions by 35%
•  More than 99% of participants would 
recommend the program to others

RECEIVING POSITIVE FEEDBACK

One of our partners for 2017 is Gas South. Based in 
Atlanta, Georgia, Gas South is a natural gas provider that 
serves approximately 290,000 residential, commercial 
and governmental customers throughout Georgia and 
Florida. They’re equipping their team members with the 
tools they need to be successful in their personal lives, 
which is then reflected back on their work productivity, 
satisfaction and overall happiness.

“Since introducing the program six months ago, more than 
75 percent of our employees have registered to participate, 
and roughly 40 percent have completed the requirements 
to receive our $200 incentive,” shared Kevin Greiner, CEO 
of Gas South. “Our employees are not just registering; 
they’re completing the activities—including the videos, 
quizzes and checklists.

“We’ve been delighted to hear the positive reactions of 
our team. Many have remarked that this is the type of 
program that makes Gas South a special company that 
really cares for its employees. We set a goal to have 
100 percent participation, and we are well on our way.”

Kevin continued, “Everyone can set goals to improve their 
financial well-being. I love how the Momentum onUp 
platform helps me keep better track of all my family’s 
finances and highlights where we are spending money. 
This helps us have honest conversations on whether we 
are meeting our savings goals and spending our money on 
the things that are most important to us.” 

1Based on the aggregate results of participating companies including but not limited to: Georgia Power Company, Waffle House, City Electric Supply, 
22squared, Delta Air Lines, Gas South, 1-800 Contacts, Genuine Parts Company, Home Depot, McKee Foods, United Rentals, Havertys Furniture and Luck 
Companies. Results may vary based on company, industry and which program the company employs.

CLIENTS

35

 
I

N

GHow We Light
The Way

W
O
H
S

Throughout 2017, we worked 
diligently to help our clients in 
all lines of business gain the 
financial confidence they need to 
keep moving forward.

CLIENTS 36

IMPROVING AND EXPANDING OUR 
CONSUMER EXPERIENCE

ENHANCING OUR 
WHOLESALE SERVICES

CONDUC TE D  MORE  TH AN  T WO  MILLION 
CLIE NT CON VE RSATIONS 
to understand their unique needs and guide them to 
make confident financial decisions. 

INVESTME NT  BA NKING
  ACHIE V ED  ITS 10TH 
CONSECUTIVE  RECORD  YE AR , 
and revenue was up 21% versus 2016.

E XPANDED  SERV ICE S FOR  SM A LL 
BUSINESS CLIE NTS 
with the launch of Simple Business Checking, 
a solution designed to help these clients begin 
their small business journey. 

E XPANDE D  PRIVATE 
WE A LTH  M A N AG E M E NT 
services into Texas and New York.

COMPLE TE D MORE TH AN 16,000 
SUMMIT VIE W®  FINANCIAL PL ANS 
to build our clients’ confidence now and into the future.

L AUNCHE D  ZE LLE ,
giving clients access to a new person-to-person 
payments network to more quickly and easily send 
and receive money. 

COMME RCIAL BANKING
opened new offices in Cincinnati and Cleveland, Ohio, 
as well as Dallas–Fort Worth, Texas.

TRE A SURY  &   PAY M E NT  S O LUTIO N S 
L AUNCHED  SUNVIE W ONLINE 
TRE A SURY  M A N AG E R  (OTM),
an enhanced online platform for business clients to 
manage everything from payroll to cash flow. More than 
50% of OTM clients are on the new SunView platform.

REDUCE D  LOAN  ORIG INATION TIMES 
AND IMPROVED  TR ANSPARENC Y
with nCino, our new loan origination platform, for 
Commercial Banking, Commercial Real Estate 
and Private Wealth Management. This provides a 
significantly improved experience for both clients and 
teammates.

E NH A NCE D  ONLINE  A ND 
MOBILE  BA NKING 
by adding one-time passcodes to strengthen security 
by protecting clients’ information during authentication. 
We also introduced the ability for clients to turn credit 
cards on and off to help reduce credit card fraud.

18SUN_10846129_2018 Annual Report    AD: Ally Hill • BL: Megan  Griswold
DIGITAL VERSION
final size: 8.25" x 10.75"
scale: 100%

FOSTERED  PRODUC TIVE  DIALOGUE
through two joint client networking events for our 
commercial banking business owners and private equity 
clients in CIB, hosted by Commercial Banking and 
Investment Banking (SunTrust Robinson Humphrey).

Release Date: 2/16/2018 
Notes:  Prints 4/C

UNVE ILED THE MEDIC AL 
PRO FE SS I O N A L S   M O RTGAG E 
as an extension of our Doctor Loan Program. We 
introduced a new, affordable Medical Professional  
Mortgage tailored to meet the specific needs of all 
medical practitioners.

x

Original Artwork

CLIENTS

37

 
BOARD OF DIRECTORS

EXECUTIVE OFFICERS

William H. Rogers, Jr.1 
Chairman and Chief Executive Officer

William H. Rogers, Jr.  
Chairman and Chief
Executive Officer

Dallas S. Clement2,4
Executive Vice President and Chief Financial 
Officer, Cox Enterprises, Atlanta, Georgia

Jorge Arrieta
General Auditor

Paul R. Garcia2,3
Former Chairman and Chief Executive Officer, 
Global Payments Inc., Atlanta, Georgia

Margaret L. Callihan
Chief Human Resources Officer

M. Douglas Ivester1,3,4
President, Deer Run Investments, LLC, 
Atlanta, Georgia

Kyle Prechtl Legg1,2,3
Former President and Chief Executive Officer, 
Legg Mason Capital Management, 
Baltimore, Maryland

Donna S. Morea3,5
Chief Executive Officer, Adesso Group, 
Royal Oak, Maryland

David M. Ratcliffe1,3,5
Retired Chairman, President and Chief 
Executive Officer, Southern Company, 
Atlanta, Georgia

Agnes Bundy Scanlan4,5
Senior Advisor for Treliant Risk Advisors

Frank P. Scruggs , Jr.3,5
Partner, Berger Singerman LLP, 
Ft. Lauderdale, Florida

Scott E. Case  
Chief Information Officer

Mark A. Chancy
Vice Chairman & 
Co-Chief Operating Officer

Hugh S. (Beau) Cummins, III
Co-Chief Operating Officer

L. Allison Dukes 
Chief Financial Officer

Ellen M. Fitzsimmons 
General  Counsel  and 
Corporate Secretary

Jerome T. Lienhard, II
Chief Risk Officer

OPERATING COUNCIL

Mark A. Chancy
Vice Chairman & 
Co-Chief Operating Officer 

Reggie Davis
Head of Business Banking/Metro Mkt.

Arnold Evans
Enterprise Ethics Officer

Kathy Farrell
Head of Commercial Real Estate

John Gregg
Head of Corporate & Investment Banking

Susan Johnson
Chief Marketing Officer

John Knott
Head of Corporate Strategy

Ellen Koebler
Head of Consumer Solutions

Dan Massey
Chief Technology Officer, 
Wholesale Segment 

Michael Maza 
Head of Treasury & Payment Solutions

Ken Meyer
Chief Technology Officer, 
Consumer Segment

Tom Parks
Head of Consumer & 
Small Business Solutions

Bruce L. Tanner4,5
Executive Vice President and Chief Financial 
Officer, Lockheed Martin Corporation, 
Bethesda, Maryland

Hugh S. (Beau) Cummins, III
Co-Chief Operating Officer

Akhila Rao
LightStream Strategy Manager

Vickie Brown
Head of Efficiency Office

Ameet Shetty
Chief Data & Analytics Officer

Steve Voorhees4,5
Chief Executive Officer, 
WestRock, Atlanta, Georgia 

Thomas R. Watjen1,2,4
Former Chairman of the Board, 
Unum Group, Chattanooga, Tennessee

Dr. Phail Wynn , Jr.1,2,4
Vice President, Durham and Regional Affairs, 
Duke University, Durham, North Carolina

1 Executive Committee
2 Audit Committee
3 Compensation Committee
4 Governance and Nominating Committee
5 Risk Committee

Jason Cagle
Commercial Banking Executive

Joe Thompson
Head of Private Wealth Management 

Todd Chamberlain
Head of Mortgage Banking

Ameesh Vakharia
Omni Channel Executive

Debbie Crowder
Head of Branch Banking

Ankur Vyas
Director of Investor Relations and 
Assistant Treasurer

Woody Woodring
Chief Credit Officer

38

Shareholder 
Information

QUARTERLY COMMON STOCK PRICES 
AND DIVIDENDS 

CREDIT RATINGS
Ratings as of December 31, 2017.

The quarterly high, low and close prices of the SunTrust 
common stock for each quarter of 2017 and 2016 and 
the dividends paid per share are shown below.

Quarter Ended
2017
December 31
September 30
June 30
March 31
2016
December 31
September 30
June 30
March 31

Market Price

High

Low

Close

Dividends
Paid

$66.62
60.04
58.75
61.69

$56.48
44.61
44.32
42.04

$56.30
51.96
52.69
52.71

$43.41
38.75
35.10
31.07

$64.59
59.77
56.72
55.30

$54.85
43.80
41.08
36.08

$0.40
0.40
0.26
0.26

$0.26
0.26
0.24
0.24

Moody’s

Standard 
& Poor’s

Fitch

Bank Level
Long-term ratings 

Deposits
Senior debt
Subordinated debt 
Short-term ratings

A1
Baa1
Baa1
P-1

Corporate Level
Long-term ratings 
Senior debt
Subordinated debt
Preferred stock

Baa1
Baa1
Baa3

A-
A-
BBB+
A-2

BBB+
BBB
BB+

A
A-
BBB+
F1

A-
BBB+
BB

Ratings Outlook

Stable

Positive

Stable

NOTICE OF ANNUAL MEETING

INVESTOR RELATIONS WEBSITE 

CLIENT INFORMATION

The Annual Meeting of Shareholders will be 
held on Tuesday, April 24, 2018 at 9:30 a.m. 
EST in Suite 105 on the first floor of SunTrust 
Plaza Garden Offices, 303 Peachtree Center 
Avenue, Atlanta, Georgia.

To find the latest investor information 
about SunTrust, including stock quotes, 
news releases, corporate governance 
information and financial data, go to 
investors.suntrust.com. 

STOCK TRADING

ANALYST INFORMATION 

SunTrust Banks, Inc. common stock is traded 
on the New York Stock Exchange (NYSE) under 
the symbol STI. 

SHAREHOLDER SERVICES

Registered shareholders of SunTrust Banks, 
Inc. who wish to change the name, address or 
ownership of common stock, or to report lost 
certificates or consolidate accounts, should 
contact our transfer agent:
Computershare 
P.O. Box 30170
College Station, TX  77842-3170
866.299.4214 
www.computershare.com

For general shareholder information, contact 
Investor Relations at 877.930.8971.

Analysts, investors and others 
seeking additional financial information should 
contact:
 Ankur Vyas
Director of Investor Relations 
and Assistant Treasurer
SunTrust Banks, Inc.
P.O. Box 4418
Mail Code: GA-ATL-645
Atlanta, GA 30302-4418
877.930.8971

If you wish to contact Investor Relations 
via email, please use the “Contact IR” link 
on the Investor Relations website at
investors.suntrust.com.

For assistance with SunTrust products 
and services, call 800.SUNTRUST or 
visit suntrust.com.   

WEBSITE ACCESS TO 
UNITED STATES SECURITIES 
AND EXCHANGE
COMMISSION FILINGS 

All reports filed electronically by SunTrust 
Banks, Inc. with the United States Securities 
and Exchange Commission, including the 
annual report on Form 10-K, quarterly 
reports on Form 10-Q, current event 
reports on Form 8-K and amendments to 
those reports filed or furnished pursuant 
to Sections 13(a) or 15(d) of the Exchange 
Act, are accessible as soon as reasonably 
practicable at no cost on the Investor 
Relations website at 
investors.suntrust.com. 

39

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 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, 2017

Commission file number 001-08918

SunTrust Banks, Inc.

(Exact name of registrant as specified in its charter)

Georgia
(State or other jurisdiction of incorporation or organization)

58-1575035
(I.R.S. Employer Identification No.)

303 Peachtree Street, N.E., Atlanta, Georgia 30308
(Address of principal executive offices) (Zip Code)

Registrant’s telephone number, including area code:  (800) 786-8787

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

Title of Each Class

Common Stock
Depositary Shares, Each Representing 1/4000th Interest in a Share of Perpetual Preferred Stock, Series A
5.853% Fixed-to-Floating Rate Normal Preferred Purchase Securities of SunTrust Preferred Capital I (representing

interests in shares of Perpetual Preferred Stock, Series B)

Depositary Shares, Each Representing 1/4000th Interest in a Share of Perpetual Preferred Stock, Series E
Warrants to Purchase Common Stock at $44.15 per share, expiring November 14, 2018, Series B
Warrants to Purchase Common Stock at $33.70 per share, expiring December 31, 2018, Series A

Name of Exchange on Which Registered
New York Stock Exchange
New York Stock Exchange

New York Stock Exchange

New York Stock Exchange
New York Stock Exchange
New York Stock Exchange

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

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities 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 (§229.405 of this chapter) 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, smaller reporting company, or an emerging 
growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and “emerging growth company” in Rule 
12b-2 of the Exchange Act.

Large accelerated filer

Accelerated filer

Non-accelerated filer

  (Do not check if a smaller reporting company)

Smaller reporting company

Emerging growth company

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or 

revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act.    

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

    No  

The aggregate market value of the voting and non-voting common stock held by non-affiliates at June 30, 2017 was approximately $26.8 billion based on the 
New York Stock Exchange closing price for such shares on that date. For purposes of this calculation, the registrant has assumed that all of its directors and 
executive officers are affiliates.

At February 16, 2018, 468,300,176 shares of the registrant’s common stock, $1.00 par value, were outstanding.

Pursuant to Instruction G of Form 10-K, information in the registrant’s Definitive Proxy Statement for its 2018 Annual Shareholder’s Meeting, which it will 

file with the SEC no later than April 24, 2018 (the “Proxy Statement”), is incorporated by reference into Items 10-14 of Part III of this Form 10-K.

DOCUMENTS INCORPORATED BY REFERENCE

TABLE OF CONTENTS

GLOSSARY OF DEFINED TERMS

PART I

Item 1.
Item 1A.
Item 1B.
Item 2.
Item 3.
Item 4.

Business
Risk Factors
Unresolved Staff Comments
Properties
Legal Proceedings
Mine Safety Disclosures

PART II

Item 5.
Item 6.
Item 7.
Item 7A.
Item 8.

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 Operation
Quantitative and Qualitative Disclosures About Market Risk
Financial Statements and Supplementary Data

Auditor's Reports
Consolidated Statements of Income
Consolidated Statements of Comprehensive Income
Consolidated Balance Sheets
Consolidated Statements of Shareholders’ Equity
Consolidated Statements of Cash Flows
Notes to Consolidated Financial Statements
Note 1 - Significant Accounting Policies
Note 2 - Acquisitions/Dispositions
Note 3 - Federal Funds Sold and Securities Financing Activities
Note 4 - Trading Assets and Liabilities and Derivative Instruments
Note 5 - Securities Available for Sale
Note 6 - Loans
Note 7 - Allowance for Credit Losses
Note 8 - Premises and Equipment
Note 9 - Goodwill and Other Intangible Assets
Note 10 - Certain Transfers of Financial Assets and Variable Interest Entities
Note 11 - Borrowings and Contractual Commitments
Note 12 - Net Income Per Common Share
Note 13 - Capital
Note 14 - Income Taxes
Note 15 - Employee Benefit Plans
Note 16 - Guarantees
Note 17 - Derivative Financial Instruments 
Note 18 - Fair Value Election and Measurement
Note 19 - Contingencies
Note 20 - Business Segment Reporting
Note 21 - Accumulated Other Comprehensive Loss
Note 22 - Parent Company Financial Information

Item 9.
Item 9A.
Item 9B.

Changes in and Disagreements With Accountants on Accounting and Financial Disclosure
Controls and Procedures
Other Information

PART III

Item 10.
Item 11.
Item 12.
Item 13.
Item 14.

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 Accountant Fees and Services

PART IV

Item 15.

Exhibits, Financial Statement Schedules

SIGNATURES

Page
i

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8
20
20
20
20

21
21
23
25
72
72
72
74
75
76
77
78
79
79
90
90
92
93
97
105
106
107
110
113
115
115
118
120
126
128
138
153
155
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160
163
163
163

164
164
164
164
164
164

165
165

170

GLOSSARY OF DEFINED TERMS

2017 Tax Act — Tax Cuts and Jobs Act of 2017.
ABS — Asset-backed securities.
ACH — Automated clearing house.
AFS — Available for sale.
AIP — Annual Incentive Plan.
ALCO — Asset/Liability Committee.
ALM — Asset/Liability Management.
ALLL — Allowance for loan and lease losses.
AML — Anti-money laundering.
AOCI — Accumulated other comprehensive income.
APIC — Additional paid-in capital.
ASC — Accounting Standards Codification. 
ASU — Accounting Standards Update. 
ATE — Additional termination event.
ATM — Automated teller machine.
Bank — SunTrust Bank.
Basel III — the Third Basel Accord, a comprehensive set of 

reform measures developed by the BCBS.

BCBS — Basel Committee on Banking Supervision.
BHC — Bank holding company.
BHC Act — Bank Holding Company Act of 1956.
Board — the Company’s Board of Directors.
bps — Basis points.
BRC — Board Risk Committee.
CC — Capital Committee.
CCAR — Comprehensive Capital Analysis and Review. 
CCB — Capital conservation buffer.
CD — Certificate of deposit.
CDR — Conditional default rate.
CDS — Credit default swaps.
CECL — Current expected credit loss.
CET1 — Common Equity Tier 1 Capital.
CEO — Chief Executive Officer.
CFO — Chief Financial Officer.
CFPB — Consumer Financial Protection Bureau.
CFTC — Commodity Futures Trading Commission.
CIB — Corporate and investment banking. 
C&I — Commercial and industrial.
Class A shares — Visa Inc. Class A common stock. 
Class B shares — Visa Inc. Class B common stock.
CLO — Collateralized loan obligation.
CME — Chicago Mercantile Exchange.
Company — SunTrust Banks, Inc.
CP — Commercial paper.
CPP — Capital Purchase Program established by the U.S. 

Treasury.

CPR — Conditional prepayment rate.
CRA — Community Reinvestment Act of 1977.
CRE — Commercial real estate.
CRO — Chief Risk Officer.
CSA — Credit support annex.
DDA — Demand deposit account.
DIF — Deposit Insurance Fund.
Dodd-Frank Act — Dodd-Frank Wall Street Reform and 

Consumer Protection Act of 2010.

DOJ — Department of Justice.
DTA — Deferred tax asset.

DTL — Deferred tax liability.
DVA — Debit valuation adjustment.
EBPC — Enterprise Business Practices Committee.
EORO — Enterprise Operational Risk Officer.
EPS — Earnings per share.
ER — Enterprise Risk.
ERC — Enterprise Risk Committee.
ERISA — Employee Retirement Income Security Act of 1974. 
Exchange Act — Securities Exchange Act of 1934.
Fannie Mae — Federal National Mortgage Association.
FASB — Financial Accounting Standards Board.
Form 8-K and tax reform-related items — items announced in 
the Company's Form 8-K filed with SEC on December 4, 2017 
and items related to the enactment of the 2017 Tax Act during 
the fourth quarter of 2017.

Freddie Mac — Federal Home Loan Mortgage Corporation.
FDIC — Federal Deposit Insurance Corporation.
Federal Reserve — Federal Reserve System.
Fed Funds — Federal funds.
FFIEC — Federal Financial Institutions Examination Council.
FHA — Federal Housing Administration.
FHLB — Federal Home Loan Bank. 
FICA — Federal Insurance Contributions Act. 
FICO — Fair Isaac Corporation.
FINRA — Financial Industry Regulatory Authority.
Fitch — Fitch Ratings Ltd. 
FRB — Federal Reserve Board.
FTE — Fully taxable-equivalent.
FVO — Fair value option. 
GFO — GFO Advisory Services, LLC.
Ginnie Mae — Government National Mortgage Association.
GLBA — Gramm-Leach-Bliley Act.
GSE — Government-sponsored enterprise.
HAMP — Home Affordable Modification Program.
HRA — Health Reimbursement Account.
HUD — U.S. Department of Housing and Urban Development.
IPO — Initial public offering.
IRLC — Interest rate lock commitment.
IRS — Internal Revenue Service.
ISDA — International Swaps and Derivatives Association.
LCH — LCH.Clearnet Limited.
LCR — Liquidity coverage ratio.
LGD — Loss given default.
LHFI — Loans held for investment.
LHFS — Loans held for sale.
LIBOR — London InterBank Offered Rate. 
LOCOM — Lower of cost or market.
LTI — Long-term incentive. 
LTV— Loan to value.
MasterCard — MasterCard International.
MBS — Mortgage-backed securities. 
MD&A — Management’s Discussion and Analysis of Financial 

Condition and Results of Operation.

MI — Mortgage insurance. 
Moody’s — Moody’s Investors Service. 
MRA — Master Repurchase Agreement.
MRM — Market Risk Management.

i

MRMG — Model Risk Management Group.
MSR — Mortgage servicing right. 
MVE — Market value of equity.
NCF — National Commerce Financial Corporation.
NOL — Net operating loss.
NOW — Negotiable order of withdrawal account.
NPA — Nonperforming asset.
NPL — Nonperforming loan.
NPR — Notice of proposed rulemaking.
NSFR — Net stable funding ratio.
NYSE — New York Stock Exchange.
OCC — Office of the Comptroller of the Currency.
OCI — Other comprehensive income.
OFAC — Office of Foreign Assets Control.
OREO — Other real estate owned.
OTC — Over-the-counter.
OTTI — Other-than-temporary impairment.
PAC — Premium Assignment Corporation.
Parent Company — SunTrust Banks, Inc. (the parent Company 

of SunTrust Bank and other subsidiaries).
Patriot Act — The USA Patriot Act of 2001.
PD — Probability of default.
Pillar — substantially all of the assets of the operating 

subsidiaries of Pillar Financial, LLC.

PMC — Portfolio Management Committee.
PPA — Personal Pension Account.
PPNR — Pre-provision net revenue.
PWM — Private Wealth Management.
REIT — Real estate investment trust.
ROA — Return on average total assets. 
ROE — Return on average common shareholders’ equity.
ROTCE — Return on average tangible common shareholders' 

equity.

RSU — Restricted stock unit. 
RWA — Risk-weighted assets. 
S&P — Standard and Poor’s. 
SBA — Small Business Administration. 
SBFC — SunTrust Benefits Finance Committee.
SEC — U.S. Securities and Exchange Commission. 
SERP — Supplemental Executive Retirement Plan. 
STAS — SunTrust Advisory Services, Inc. 
STCC — SunTrust Community Capital, LLC.
STIS — SunTrust Investment Services, Inc. 
STM — SunTrust Mortgage, Inc. 
STRH — SunTrust Robinson Humphrey, Inc. 
SunTrust — SunTrust Banks, Inc. 
TDR — Troubled debt restructuring. 
TRS — Total return swaps.
U.S. — United States.
U.S. GAAP — Generally Accepted Accounting Principles in the 

U.S.

U.S. Treasury — the U.S. Department of the Treasury. 
UPB — Unpaid principal balance.
UTB — Unrecognized tax benefit.
VA —Veterans Administration.
VAR —Value at risk.
VEBA — Voluntary Employees' Beneficiary Association.
VI — Variable interest. 
VIE — Variable interest entity.
Visa — the Visa, U.S.A. Inc. card association or its affiliates, 

collectively.

Visa Counterparty — a financial institution that purchased the 

Company's Visa Class B shares.

VOE — Voting interest entity.

ii

PART I

Item 1. 

BUSINESS

located 

General
SunTrust  Banks,  Inc.  (“we,”  “us,”  “our,”  “SunTrust,”  or  “the 
Company”) is a leading provider of financial services, with our 
in  Atlanta,  Georgia.  Our  principal 
headquarters 
subsidiary is SunTrust Bank (“the Bank”). The Company was 
incorporated in the State of Georgia in 1984 and offers a full line 
of  financial  services  for  consumers,  businesses,  corporations, 
institutions, and not-for-profit entities, both through its branches 
(located primarily in Florida, Georgia, Virginia, North Carolina, 
Tennessee,  Maryland,  South  Carolina,  and  the  District  of 
Columbia)  and  through  other  national  delivery  channels. The 
Bank offers deposit, credit, and trust and investment services to 
its clients through a selection of full-, self-, and assisted-service 
channels,  including  branch,  call  center,  Teller  Connect™ 
machines, ATMs, online, mobile, and tablet. Other subsidiaries 
provide capital markets, mortgage banking, securities brokerage, 
investment  banking,  and  wealth  management  services.  At 
December 31, 2017, the Company had total assets of $206 billion 
and total deposits of $161 billion.

We operate two business segments: Consumer and Wholesale, 
with our functional activities included in Corporate Other.

information 

Additional 
regarding  our  businesses  and 
subsidiaries is included in the information set forth in Item 7, 
MD&A, as well as Note 20, “Business Segment Reporting,” to 
the Consolidated Financial Statements in this Form 10-K.

Regulation and Supervision
We  are  limited  under  the  BHC Act  to  banking,  managing  or 
controlling  banks,  and  other  activities  that  the  FRB  has 
determined to be closely related to banking. The Company, a 
BHC, elected to become a financial holding company pursuant 
to the GLBA, allowing it to engage in a broader range of activities 
that are (i) financial in nature or incidental to financial activities 
or (ii) complementary to a financial activity and do not pose a 
substantial  risk  to  the  safety  and  soundness  of  depository 
institutions or the financial system in general. These expanded 
services include securities underwriting and dealing, insurance 
underwriting,  merchant  banking,  and  insurance  company 
portfolio  investment,  and  are  subject  to  the Volcker  Rule  and 
other restrictions discussed below.

As  a  financial  holding  company,  the  Company  and  its 
banking  subsidiary  are  required  to  be  “well  capitalized”  and 
“well managed” while maintaining at least a “satisfactory” CRA 
rating. In the event of noncompliance, the Federal Reserve may, 
among other things, limit the Company’s ability to conduct these 
broader financial activities or,  if the  deficiencies persist,  may 
require  the  Company  to  divest  its  banking  subsidiary. 
Furthermore, if the Company does not have a satisfactory CRA 
rating,  it  may  not  commence  any  new  financial  activities, 
although the Company will still be allowed to engage in activities 
closely related to banking.

The Federal Reserve regulates BHCs under the BHC Act, 
with residual supervisory authority over “functionally regulated” 
subsidiaries such as the Company's broker-dealer and investment 

1

adviser subsidiaries. Our non-banking subsidiaries are regulated 
by various other regulatory bodies with supervisory authority 
over the particular activities of those subsidiaries. For example, 
STRH and STIS are broker-dealers registered with the SEC and 
members  of  FINRA,  and  STAS  is  an  investment  advisor 
registered  with  the  SEC.  STIS  is  also  an  insurance  agency 
registered with state insurance commissions.

The Bank is an FDIC-insured commercial bank chartered 
under the laws of the State of Georgia and is a member of the 
Federal Reserve System. In addition to regulation by the FRB, 
the  Bank  and  the  Company  are  regulated  by  the  Georgia 
Department  of  Banking  and  Finance.  The  FDIC  also  has 
jurisdiction  over  certain  activities  of  the  Bank  as  an  insured 
depository institution. As a Georgia-chartered commercial bank, 
the Bank's powers are limited to activities permitted by Georgia 
and federal banking laws. Generally, the Bank may engage in all 
usual banking activities such as taking deposits, lending money, 
issuing  letters  of  credit,  currency  trading,  and  offering  safe 
deposit box services.

As  an  umbrella  supervisor  under  the  GLBA's  system  of 
functional regulation, the  FRB  requires that financial holding 
companies  operate  in  a  safe  and  sound  manner  so  that  their 
financial condition does not threaten the viability of affiliated 
depository institutions. 

The  Dodd-Frank Act,  among  other  things,  implemented 
changes that affected the oversight and supervision of financial 
institutions, provided for a new resolution procedure for large 
financial  companies,  created  the  CFPB,  introduced  more 
stringent regulatory capital requirements and significant changes 
in the regulation of OTC derivatives, reformed the regulation of 
credit  rating  agencies,  increased  controls  and  transparency  in 
corporate  governance  and  executive  compensation  practices, 
incorporated the Volcker Rule, required registration of advisers 
to certain private funds, and influenced significant changes in 
the  securitization  market.  Dodd-Frank  Act  requirements 
typically  apply  to  BHCs  with  greater  than  $10  billion  of 
consolidated assets, and the requirements increase at certain asset 
size thresholds (most notably, $50 billion of consolidated assets 
and $250 billion of consolidated assets).

Enhanced Prudential Standards
BHCs with consolidated assets of $50 billion or more are subject 
to enhanced prudential standards and capital requirements. The 
Dodd-Frank  Act  directs  the  FRB  to  establish  heightened 
prudential standards for (i) risk-based capital requirements and 
leverage limits, (ii) liquidity risk management requirements, (iii) 
overall  risk  management  requirements,  (iv)  stress  testing,  (v) 
resolution  planning,  (vi)  credit  exposure  and  concentration 
limits,  and  (vii)  early  remediation  actions  that  must  be  taken 
under certain conditions in the early stages of financial distress.
the  FRB  adopted  a  final  rule 
implementing  the  enhanced  liquidity  and  risk  management 
requirements;  it  requires  greater  supervision  and  oversight  of 
liquidity and general risk management by boards of directors and 
includes  capital  planning  and  stress  testing  requirements.  In 

In  February  2014, 

addition, the rule requires publicly traded U.S. BHCs with total 
consolidated assets of $10 billion or more to establish enterprise-
wide  risk  committees.  The 
liquidity  risk  management 
requirements are in addition to those imposed by the LCR rule. 

Enhanced Capital Standards 
In July 2013, the U.S. banking regulators promulgated final rules 
substantially implementing the Basel III capital framework and 
various Dodd-Frank Act provisions (the “Capital Rules”). The 
Capital Rules increased regulatory capital requirements of U.S. 
banking organizations and revised the level at which the Bank 
becomes subject to corrective action as described in the “prompt 
corrective action” section below. The “Collins” amendment to 
the  Dodd-Frank  Act  required  federal  banking  regulators  to 
impose a generally applicable leverage capital ratio regardless 
of  institution  size  and  to  phase  out  certain  “hybrid”  capital 
elements from Tier 1 capital treatment. The Company became 
subject to the Capital Rules on January 1, 2015. For additional 
information  regarding  the  Capital  Rules,  including  recent 
updates and/or changes to the rules and related requirements, 
refer to the "Capital Resources" section of Item 7, MD&A, in 
this Form 10-K. 

Distributions
There are various legal and regulatory limits on the extent to 
which the Bank may pay dividends or otherwise supply funds to 
its Parent Company. Federal and state bank regulatory agencies 
have the authority to prevent the Bank from paying dividends or 
engaging in any other activity that, in the opinion of the agency, 
would constitute an unsafe or unsound practice. Restrictions on 
capital  distributions,  share  repurchases  and  redemptions,  and 
discretionary bonus payments to executive officers are imposed 
on banks that are unable to sustain the capital conservation buffer 
above the minimum CET1, Tier 1, and Total capital ratios. The 
capital conservation buffer is a buffer above the minimum levels 
designed to ensure that banks remain well-capitalized, even in 
adverse economic scenarios.

See  additional  discussion  of  Basel  III  in  the  "Capital 

Resources" section of Item 7, MD&A, in this Form 10-K.

Mandatory Liquidity Coverage Ratio (“LCR”); Net Stable 
Funding Ratio (“NSFR”) 
In  September  2014,  the  FRB,  OCC,  and  the  FDIC  approved 
rulemaking  that  established,  for  the  first  time,  a  quantitative 
minimum  LCR  for  large,  internationally  active  banking 
organizations, and a less stringent LCR (“modified LCR”) for 
BHCs  with  less  than  $250  billion  in  total  assets,  such  as  the 
Company.  The  LCR  requires  a  banking  entity  to  maintain 
sufficient liquidity to withstand an acute 30-day liquidity stress 
scenario. The LCR became effective for the Company on January 
1, 2016, with a minimum requirement of 90% of high-quality, 
liquid assets to total net cash outflows; full compliance of 100% 
was required beginning January 1, 2017. The Company has met 
LCR  requirements  within  the  regulatory  timelines  and  at 
December 31,  2017,  its  LCR  was  above  the  100%  regulatory 
requirement.

On December 19, 2016, the FRB published the final rule, 
promulgated  as  Regulation  WW,  which  will  require  us  to 
information,  with  certain 
publicly  disclose  qualitative 

2

qualifications and permitted limitations related to information 
that  is  proprietary  or  confidential  to  the  Company,  about  (i) 
certain  components  of  our  LCR  calculation  in  a  standardized 
tabular format (LCR disclosure template) and (ii) factors that 
have significant effect on the LCR, to facilitate an understanding 
of our calculations and results. The rule aims to promote market 
discipline  by  providing  the  public  with  comparable  liquidity 
information about covered companies. The disclosures must be 
made on a covered company's public internet site or in a public 
financial  or  regulatory  report.  The  disclosures  must  remain 
available to the public for at least five years from the time of 
initial disclosure. Covered companies subject to modified LCR, 
including  the  Company,  will  be  required  to  comply  with 
disclosure requirements beginning on October 1, 2018.

On May 3, 2016, the FRB, OCC, and the FDIC proposed a 
rule to implement the NSFR. The proposal would require large 
U.S. banking organizations to maintain a stable funding profile 
over a one-year horizon. The FRB proposed a modified NSFR
requirement for bank holding companies with greater than $50 
billion but less than $250 billion in total consolidated assets and 
less than $10 billion in total on balance sheet foreign exposure. 
As proposed, the rule would require us to publicly disclose our 
NSFR and the components of the NSFR each calendar quarter. 
The agencies intend the NSFR to complement the LCR, liquidity 
risk  management,  and  stress  testing  requirements  under  the 
FRB's Regulation YY (enhanced prudential standards for BHCs 
with  total  consolidated  assets  of  $50  billion  or  more).  The 
proposed  rule  contains  an  implementation  date  of  January 1, 
2018; however, a final rule has not yet been issued.

See  additional  discussion  of  the  LCR  and  NSFR  in  the 
"Liquidity Risk Management" section of Item 7, MD&A, in this 
Form 10-K. 

Capital Planning; Stress Testing
Pursuant to the Dodd-Frank Act, BHCs are required to conduct 
company-run stress tests and to perform supervisory stress tests 
directed by the FRB. BHCs with more than $10 billion in total 
consolidated assets must conduct an annual company-run stress 
test,  and  those  with  total  consolidated  assets  exceeding  $50 
billion  must  conduct  an  additional  mid-cycle  stress  test.  For 
company-run stress tests, BHCs use the same planning horizon, 
capital action assumptions, and scenarios as those used in the 
supervisory  stress  tests.  Stress  testing  is  designed  to  assess 
whether the covered Company's capital is sufficient to absorb 
losses during stressful conditions, while meeting obligations to 
creditors  and  counterparties,  and,  to  the  extent  applicable, 
continuing to serve as credit intermediaries. 

The Company also is subject to supervisory stress testing 
requirements under the FRB's Capital Plan Rule, which the FRB
implements  as  part  of  its  CCAR  process.  CCAR  is  a  broad 
supervisory program that includes stress testing and assesses a 
covered  company’s  practices  for  determining  capital  needs, 
including  its  risk  measurement  and  management  practices, 
capital planning and decision-making, and associated internal 
controls and governance. The Company is required to publish a 
summary  of  the  results  of  its  annual  stress  test,  and  the  FRB
publishes  the  results  of  the  stress  testing  under  adverse  and 
severely adverse scenarios. 

The Capital Plan Rule finalized in late 2011 requires a U.S. 
BHC with consolidated assets of $50 billion or more to develop 
and maintain a capital plan that is reviewed and approved by its 
board  of  directors  or  a  committee  thereof.  Capital  plans  are 
intended  to  allow  the  FRB  to  assess  the  BHC’s  systems  and 
processes of incorporating forward-looking projections of assets 
and liabilities, revenues and losses, and to monitor and maintain 
their internal capital adequacy. Under the Capital Plan Rule, each 
capital plan must address, among other capital actions, projected 
capital ratios under stress scenarios, planned dividends and other 
capital distributions, and share repurchases over a minimum nine 
quarter planning horizon. Prior to executing a capital plan, a non-
objection notification must be received from the FRB. If the FRB 
objects  to  our  capital  plan,  we  may  not  make  certain  capital 
distributions until the FRB's non-objection to the distribution is 
received.

In January 2017, the FRB released a final rule that revises 
capital  plan  and  stress  test  rules,  whereby  certain  BHCs, 
including  the  Company,  with  less  than  $250  billion  in  total 
consolidated assets will no longer be subject to the qualitative 
component  of  the  FRB’s  annual  CCAR.  The  final  rule  also 
modifies  certain  regulatory  reports  to  collect  additional 
information on nonbank assets and to reduce reporting burdens 
for large and noncomplex firms. 

For additional information regarding Capital Planning and 
Stress Testing, refer to the "Capital Resources" section of Item 
7, MD&A, in this Form 10-K.

Regulatory Regime for Swaps
The  Dodd-Frank  Act  established  a  new  comprehensive 
regulatory regime for the OTC swaps market, aimed at increasing 
transparency  and  reducing  systemic  risk  in  the  derivatives 
markets, including requirements for central clearing, exchange 
trading,  capital,  margin,  reporting,  and  recordkeeping.  The 
Dodd-Frank Act requires that certain swap dealers register with 
one or both of the SEC and CFTC, depending on the nature of 
the swaps business. The Bank provisionally registered with the 
CFTC  as  a  swaps  dealer,  subjecting  the  Bank  to  new 
requirements  under  this  regulatory  regime  including  trade 
reporting  and  record  keeping  requirements,  business  conduct 
requirements (including daily valuations, disclosure of material 
risks associated with swaps and disclosure of material incentives 
and  conflicts  of  interest),  mandatory  clearing  and  exchange 
trading requirements for certain standardized swaps designated 
by the CFTC, and increased capital requirements established by 
the  FRB.  Subject  to  the  SEC's  finalization  of  certain  rules 
applicable to security-based swaps, the Bank expects to register 
with the SEC as a security-based swap dealer. Such registration 
will subject the Bank’s security-based swaps business to similar 
Dodd-Frank  Act  requirements,  including  trade  reporting, 
business  conduct  standards,  recordkeeping,  and  potentially 
mandatory  clearing  and  exchange  requirements.  In  2020,  our 
derivatives business involving uncleared swaps is expected to 
become subject to margin requirements established by the FRB, 
which may exceed current market practice.

company's strategy for rapid and orderly resolution in case of 
material financial distress or failure. 

The FRB and FDIC have widely promoted resolution plans 
as core elements of reforms intended to mitigate risks to the U.S. 
financial system, and to end the “too big to fail” status of the 
largest financial institutions. Covered institutions are expected 
to  file  their  resolution  plans  annually,  or  at  the  direction  of 
regulators,  regardless  of  the  financial  condition  or  nature  of 
operations  of  the  institution.  Preparation  and  review  of  these 
resolution  plans  is  a  major  undertaking  for  covered  financial 
institutions. If a plan is not credible, the Company and the Bank 
may be restricted in expansionary activities, or be subjected to 
more stringent capital, leverage, or liquidity requirements. The 
Company and the Bank submitted resolution plans to the FRB
and FDIC in December 2015. During 2016, the FRB and FDIC 
waived the covered financial institutions' requirement to file their 
resolution  plans.  The  FRB  and  FDIC  provided  feedback 
regarding the Company's and the Bank's 2015 resolution plans 
during 2017. The Company submitted its updated resolution plan 
to  the  FRB  in  December  2017.  The  Bank  is  developing  its 
resolution plan to be responsive to feedback received and will 
submit its plan to the FDIC in 2018.

The FDIC issued a final rule in November 2016 requiring 
insured  depository  institutions  with  more  than  two  million 
deposit  accounts  to  create  and  maintain  comprehensive  and 
detailed deposit account records to facilitate the determination 
of FDIC insured deposits in the event of a bank failure. Under 
the rule, the FDIC must be able to use the failing bank's systems, 
data, and staff to calculate the insured and uninsured amounts 
for  each  depositor  and  place  holds  on  portions  of  uninsured 
deposits. The Bank will be required to be in compliance with this 
rule by May 2020.

Deposit Insurance 
The  Bank’s  depositors  are  insured  by  the  FDIC  up  to  the 
applicable  limits,  which  is  currently  $250,000  per  account 
ownership type. The FDIC provides deposit insurance through 
the  DIF,  which  the  FDIC  maintains  by  assessing  depository 
institutions,  including  the  Bank,  an  insurance  premium.  The 
Dodd-Frank Act changed the statutory regime governing the DIF. 
By September 30, 2020, the FDIC must increase the amount in 
the deposit insurance fund to 1.35% of insured deposits, impose 
a premium on banks to reach this goal, and offset the effect of 
assessment increases for institutions with less than $10 billion 
in total consolidated assets. In March 2016, the FDIC issued a 
final rule to address this surcharge on banks by collecting those 
premiums from banks with more than $10 billion in consolidated 
assets. This surcharge began in the third quarter of 2016.

Source of Strength
FRB policy requires BHCs to act as a source of financial strength 
to each subsidiary bank and to commit resources to support each 
subsidiary.  This  policy  was  codified  in  the  Dodd-Frank Act, 
though no regulations have been proposed to define the scope 
of this financial support.

Resolution Planning
BHCs with total consolidated assets of $50 billion or more must 
submit  resolution  plans  to  the  FRB  and  FDIC  addressing  the 

Anti-Money Laundering (“AML”), PATRIOT ACT; OFAC 
Sanctions
Anti-money laundering measures and economic sanctions have 

3

long been a matter of regulatory focus in the U.S. The Currency 
and  Foreign  Transactions  Reporting Act  of  1970,  commonly 
referred to as the "Bank Secrecy Act" or "BSA," requires U.S. 
financial institutions to assist U.S. government agencies to detect 
and prevent money laundering by imposing various reporting 
and  recordkeeping  requirements  on  financial  institutions. 
Passage  of  the  Patriot Act  renewed  and  expanded  this  focus, 
extending  greatly  the  breadth  and  depth  of  anti-money 
laundering measures required under the BSA. The Patriot Act 
requires all financial institutions to establish certain anti-money 
laundering compliance and due diligence programs, including 
enhanced  due  diligence  policies,  procedures,  and  controls  for 
certain types of relationships deemed to pose heightened risks. 
In  cooperation  with  federal  banking  regulatory  agencies,  the 
Financial  Crimes  Enforcement  Network  ("FinCEN") 
is 
responsible for implementing, administering, and enforcing BSA 
compliance.

Federal  banking  regulators  and  FinCEN  continue  to 
emphasize their expectation that financial institutions establish 
and  implement  robust  BSA/AML  compliance  programs. 
Consistent  with  this  supervisory  emphasis,  in  August  2014, 
FinCEN  issued  an  advisory  stressing  its  expectations  for 
financial 
institutions’  BSA/AML  compliance  programs, 
including specific governance, staffing and resource allocation, 
and testing and monitoring requirements. Furthermore, FinCEN 
proposed a rule that would require financial institutions to obtain 
beneficial  ownership  information  from  all  legal  entities  with 
which they conduct business.

OFAC  has  primary  responsibility  for  administering  and 
enforcing economic and trade sanctions, which are broad-based 
measures, derived from U.S. foreign policy and national security 
objectives. These sanctions are imposed on designated foreign 
international  narcotics 
terrorists, 
countries  and  persons, 
traffickers,  and  persons  involved  in  activities  relating  to 
proliferation  of  weapons  of  mass  destruction.  While  the 
sanctions laws are separate from the BSA and AML laws, these 
regimes overlap in purpose. All U.S. persons must comply with 
U.S.  sanctions  laws.  The  Company  must  ensure  that  its 
operations,  including  its  provision  of  services  to  clients,  are 
designed to ensure compliance with U.S. sanctions laws. Among 
other  things,  the  Company  must  block  accounts  of,  and 
transactions  with,  sanctioned  persons  and  report  blocked 
transactions after their occurrence.

Over  the  past  several  years,  federal  banking  regulators, 
increased  supervisory  and 
FinCEN,  and  OFAC  have 
enforcement  attention  on  U.S.  anti-money  laundering  and 
sanctions  laws,  as  evidenced  by  a  significant  increase  in 
enforcement activity, including several high profile enforcement 
actions. Several of these actions have addressed violations of 
AML  laws,  U.S.  sanctions  laws,  or  both,  resulting  in  the 
imposition of substantial civil monetary penalties. In both the 
BSA/AML  and  sanctions  areas,  enforcement  actions  have 
increasingly  focused  on  publicly  identifying  individuals  and 
holding  those  individuals,  including  compliance  officers, 
accountable 
in  BSA/AML  compliance 
programs. State attorneys general and the DOJ have also pursued 
enforcement  actions  against  banking  entities  alleged  to  have 
willfully violated AML and U.S. sanctions laws. 

for  deficiencies 

4

Consumer Financial Protection
The  CFPB,  established  by  the  Dodd-Frank  Act,  has  broad 
rulemaking, supervisory, and enforcement powers under various 
federal  consumer  financial  protection  laws.  Furthermore,  the 
CFPB is authorized to engage in consumer financial education, 
track  consumer  complaints,  request  data,  and  promote  the 
availability of financial services to under-served consumers and 
communities.  The  CFPB  has  primary  examination  and 
enforcement authority over institutions with assets of $10 billion 
or more. We are subject to a number of federal and state consumer 
protection laws, including the Equal Credit Opportunity Act, the 
Fair Credit Reporting Act, the Truth in Lending Act, the Truth 
in Savings Act, the Electronic Fund Transfer Act, the Expedited 
Funds Availability Act, the Home Mortgage Disclosure Act, the 
Fair Housing Act, the Real Estate Settlement Procedures Act, the 
Fair Debt Collection Practices Act, the Service Members Civil 
Relief Act, and these laws’ respective state-law counterparts. The 
Company  also  is  subject  to  state  laws  regarding  unfair  and 
deceptive acts and practices. Violations of applicable consumer 
protection laws can result in significant liability from litigation 
brought by customers, including actual damages, restitution, and 
attorneys’  fees.  In  addition,  federal  bank  regulators,  state 
attorneys  general,  and  state  and  local  consumer  protection 
agencies may pursue remedies, such as imposition of regulatory 
sanctions and penalties, restrictions on expansionary activities, 
and requiring customer rescission rights. 

(iv) 

(iii) 

Prompt Corrective Action
The federal banking agencies have broad powers with which to 
require companies to take prompt corrective action to resolve 
problems  of  insured  depository  institutions  that  do  not  meet 
minimum capital requirements. The law establishes five capital 
categories for this purpose: (i) well-capitalized, (ii) adequately 
capitalized, 
significantly 
undercapitalized, 
undercapitalized, and (v) critically undercapitalized. The Capital 
Rules amended the thresholds in the prompt corrective action 
framework  to  reflect  the  higher  capital  ratios  required  in  the 
Capital Rules. Under the Capital Rules, to be considered well-
capitalized, an institution generally must have risk-based Total 
capital  and  Tier  1  capital  ratios  of  at  least  10%  and  6%, 
respectively,  and  must  not  be  subject  to  any  order  or  written 
directive to meet and maintain a specific capital level for any 
capital measure. While the prompt corrective action rules apply 
to banks and not BHCs, the FRB is authorized to take actions at 
the holding company level. The banking regulatory agencies are 
required  to  take  mandatory  supervisory  actions,  and  have  the 
discretion  to  take  other  actions,  as  to  insured  depository 
institutions in the three undercapitalized categories, the severity 
of which depends on the assigned capital category. For example, 
an  insured  depository  institution  is  generally  prohibited  from 
paying dividends or making capital distributions if it would be 
undercapitalized as a result. An undercapitalized institution must 
submit a capital restoration plan, which must be guaranteed up 
to certain amounts by its parent holding company. Significantly 
undercapitalized 
to  various 
requirements and restrictions, such as mandates to sell voting 
stock,  reduce  total  assets,  and  limit  or  prohibit  the  receipt  of 
correspondent  bank  deposits.  Critically  undercapitalized 

institutions  may  be  subject 

institutions  are  subject  to  appointment  of  a  receiver  or 
conservator.

Volcker Rule
Through the “Volcker Rule,” the Dodd-Frank Act amends the 
BHC  Act  by  generally  prohibiting  a  banking  entity  from 
engaging in proprietary trading and investing in, sponsoring, or 
having certain other relationships with, a private equity, hedge 
fund, or certain other types of private funds. The term “banking 
entity”  covers  insured  depository  institutions,  their  holding 
companies, and certain other entities and their affiliates. There 
are limited exceptions to the prohibition on proprietary trading, 
such as trading in certain U.S. government or agency securities, 
engaging in certain underwriting or market-making activities, 
and certain hedging activities. There are also limited exceptions 
to  the  prohibitions  on  certain  activities  with  covered  private 
funds, such as for certain activities in connection with a banking 
entity's  bona  fide  trust,  fiduciary,  or  investment  advisory 
business, as well as in connection with public welfare activities 
including low income housing finance. All permitted activities 
are  subject  to  applicable  federal  or  state  laws,  restrictions  or 
limitations  that  may  be  imposed  by  the  regulator,  including 
capital  and  quantitative  limitations  as  well  as  diversification 
requirements, and must not, among other things, pose a threat to 
the safety and soundness of the banking entity or the financial 
stability  of  the  U.S.  Further,  the  Volcker  Rule's  anti-evasion 
authority  grant  to  the  regulatory  agencies  requires  them  to 
recordkeeping 
impose  extensive 
their 
requirements  on  banking  organizations 
compliance with the Volcker Rule.

internal  controls  and 

to  ensure 

Branching 
The  Dodd-Frank  Act  relaxed  existing  interstate  branching 
restrictions by modifying the federal statute governing de novo 
interstate  branching  by  state  member  banks.  Consequently,  a 
state member bank may open its initial branch in a state outside 
of the bank’s home state by way of an interstate bank branch, so 
long as a bank chartered under the laws of that state would be 
permitted to open a branch at that location.

Restrictions on Affiliate Transactions
There  are  limits  and  restrictions  on  transactions  in  which  the 
Bank and its subsidiaries may engage with the Company and 
other  Company  subsidiaries.  Sections  23A  and  23B  of  the 
Federal  Reserve Act  and  FRB's  Regulation  W,  among  other 
things,  govern  terms  and  conditions  and  limit  the  amount  of 
extensions  of  credit,  and  the  amount  of  collateral  required  to 
secure extensions of credit, by the Bank and its subsidiaries to 
the  Company  and  other  Company  subsidiaries,  and  limit 
purchases of assets by the Bank and its subsidiaries from the 
Company and other Company subsidiaries. The Dodd-Frank Act 
significantly enhanced and expanded the scope and coverage of 
the limitations imposed by Sections 23A and 23B, specifically, 
by including derivative transactions as credit extensions subject 
to  Section  23A  and  23B.  Furthermore,  the  Dodd-Frank  Act 
requires  that  conforming  collateral  be  maintained  for  the 
duration of covered transactions, rather than only at the time of 
the transaction. The FRB has increased its scrutiny of Regulation 
W  transactions,  and  has  supported  its  supervision  over 

5

Regulation W compliance with information received through the 
resolution  planning  process.  The  FRB  has  yet  to  amend 
Regulation W or provide guidance in light of the Dodd-Frank 
Act's changes to Sections 23A and 23B of the Federal Reserve 
Act.

Interchange Rules; “Durbin Amendment”
The Dodd-Frank Act, through a provision known as the “Durbin 
Amendment,”  required  the  FRB  to  establish  a  cap  on  the 
interchange fees that merchants pay banks for electronic clearing 
of debit transactions. In 2011, the FRB issued final rules that 
significantly limit the amount of interchange fees a bank may 
charge for electronic debit transactions.

Incentive Compensation
In  2010,  the  FRB  and  other  regulators  jointly  published  final 
guidance for structuring incentive compensation arrangements 
at financial organizations. The guidance does not set forth any 
formulas  or  pay  caps  but  contains  certain  principles  that 
companies are required to follow with respect to employees and 
groups of employees that may expose the company to material 
amounts of risk. The three primary principles are (i) balanced 
risk-taking incentives, (ii) compatibility with effective controls 
and risk management, and (iii) strong corporate governance. The 
FRB monitors compliance with this guidance as part of its safety 
and soundness oversight.

In  2016,  the  FRB,  SEC,  and  other  regulators  jointly 
published  proposed  rules  on  incentive  compensation  under 
Section 956 of the Dodd-Frank Act. The proposed rules would 
impose  several  substantive  requirements  on  the  form  of  our 
incentive  compensation,  including  (i)  requiring  that  incentive 
compensation  payable  to  a  “senior  executive  officer”  or 
“significant-risk  taker”  be  subject  to  a  7-year  clawback 
requirement;  (ii)  requiring  a  substantial  portion  of  incentive 
compensation  payable  to  a  “senior  executive  officer”  or 
“significant-risk taker” to be deferred and subject to the risk of 
forfeiture;  (iii)  prohibiting  the  acceleration  of  incentive 
compensation that is required to be deferred, other than in the 
event of death or disability; (iv) limiting the amount of incentive 
compensation  payable  to  “senior  executive  officers”  and 
“significant  risk-takers”  for  the  attainment  of  performance 
measures in excess of target measures (to 125% and 150% of 
target  for  “senior  executive  officers”  and  “significant  risk-
takers,” respectively); and (v) requiring the implementation of 
an  independent  risk-monitoring  framework.  In  July  2017,  the 
SEC released its rulemaking agenda and did not include the rules 
under Section 956 of the Dodd-Frank Act. As a result, it is not 
certain when the final rules may be issued.

Privacy and Cyber-Security
We are subject to many U.S. federal, state, and international laws 
and regulations governing requirements for maintaining policies 
and procedures to protect non-public confidential information 
of our customers. The GLBA requires us to periodically disclose 
our  privacy  policies  and  practices  relating  to  sharing  such 
information and permits consumers to opt out of our ability to 
share information with unaffiliated third parties under certain 
circumstances. Other laws and regulations, at both the federal 
and state level, impact our ability to share certain information 

with  affiliates  and  non-affiliates  for  marketing  and/or  non-
marketing  purposes,  or  to  contact  customers  with  marketing 
offers.  The  GLBA  also  requires  banking  institutions  to 
implement a comprehensive information security program that 
includes  administrative,  technical,  and  physical  safeguards  to 
ensure the security and confidentiality of customer records and 
information. These security and privacy policies and procedures, 
for the protection of personal and confidential information, are 
in effect across all businesses and geographic locations. 

Acquisitions
Our ability to grow through acquisitions is limited by various 
regulatory approval requirements. The FRB's prior approval is 
required if we wish to (i) acquire all, or substantially all, of the 
assets of any bank, (ii) acquire direct or indirect ownership or 
control of more than 5% of any class of voting securities of any 
bank or thrift, or (iii) merge or consolidate with any other BHC.
Pursuant  to  the  Riegle-Neal  Interstate  Banking  and 
Branching  Efficiency Act  of  1994,  as  amended  by  the  Dodd-
Frank Act, bank holding companies from any state may acquire 
banks located in any other state, subject to certain conditions, 
including  concentration  limits.  Additionally,  the  BHC  Act 
enumerates the factors the FRB must consider when reviewing 
the merger of BHCs, the acquisition of banks, or the acquisition 
of voting securities of a bank or BHC. These factors include the 
competitive effects of the proposal in the relevant geographic 
markets,  the  financial  and  managerial  resources  and  future 
prospects of the companies and banks involved in the transaction, 
the effect of the transaction on the financial stability of the U.S., 
the organizations’ compliance with anti-money laundering laws 
and regulations, the convenience and needs of the communities 
to be served, and the records of performance, under the CRA, of 
the insured depository institutions involved in the transaction. 
In addition, in cases involving interstate bank acquisitions, the 
FRB must consider the concentration of deposits nationwide and 
in certain individual states. Under the Dodd-Frank Act, a BHC 
is  generally  prohibited  from  merging,  consolidating  with,  or 
acquiring, another company if the resulting company’s liabilities 
upon  consummation  would  exceed  10%  of  the  aggregate 
liabilities  of  the  U.S.  financial  sector,  including  the  U.S. 
liabilities of foreign financial companies.

Competition
We  face  competition  from  domestic  and  foreign  lending 
institutions and numerous other providers of financial services. 
The  Company  competes  using  a  client-centered  model  that 
focuses on working together as OneTeam to deliver high quality 
service,  while  offering  a  broad  range  of  products  and 
services. We believe this approach better positions us to increase 
loyalty and deepen existing relationships, while also attracting 
new customers. Furthermore, the Company maintains a strong 
presence within high-growth Southeast and Mid-Atlantic states, 
thereby enhancing its competitive position. While we believe the 
Company  is  well  positioned  within  the  highly  competitive 
financial services industry, the industry could become even more 
competitive as a result of legislative, regulatory, economic, and 
technological changes, as well as continued consolidation. The 
ability of non-banking financial institutions to provide services 
previously  limited  to  commercial  banks  has  intensified 

6

competition. Because non-banking financial institutions are not 
subject to many of the same regulatory restrictions as banks and 
bank  holding  companies,  they  can  often  operate  with  greater 
flexibility and with lower cost and capital structures. However, 
non-banking financial institutions may not have the same access 
to deposit funds or government programs and, as a result, those 
non-banking financial institutions may elect, as some have done, 
to  become  financial  holding  companies  to  gain  such  access. 
Securities firms and insurance companies that elect to become 
financial  holding  companies  may  acquire  banks  and  other 
financial institutions, which could further alter the competitive 
environment in which we conduct business.

Employees
At  December 31,  2017,  the  Company  had  23,785  full-time 
equivalent employees. None of the domestic employees within 
the Company are subject to a collective bargaining agreement. 
Management  considers  its  employee  relations  to  be  in  good 
standing.

Additional Information
See  also  the  following  additional  information,  which  is 
incorporated herein by reference:  Business Segments (under the 
captions “Business Segments” and “Business Segment Results” 
in Item 7, MD&A, in this Form 10-K, and Note 20, “Business 
Segment Reporting,” to the Consolidated Financial Statements 
in Item 8, Financial Statements and Supplementary Data, of this 
Form  10-K);  Net  Interest  Income  (under  the  captions  “Net 
Interest  Income/Margin  (FTE)”  in  the  MD&A  and  “Selected 
Financial  Data”  in  Item 6);  Securities  (under  the  caption 
“Securities Available for Sale” in the MD&A and Note 5 to the 
Consolidated Financial Statements); Loans and Leases (under 
the  captions  “Loans”,  “Allowance  for  Credit  Losses”,  and 
“Nonperforming  Assets”  in  the  MD&A  and  “Loans”  and 
“Allowance for Credit Losses” in Notes 6 and 7, respectively, to 
the  Consolidated  Financial  Statements);  Deposits  (under  the 
caption  “Deposits”  in  the  MD&A);  Short-Term  Borrowings 
(under the caption “Short-Term Borrowings” in the MD&A and 
Note 11, “Borrowings and Contractual Commitments,” to the 
Consolidated  Financial  Statements);  Trading  Activities  and 
Trading Assets and Liabilities (under the caption “Trading Assets 
and  Liabilities  and  Derivatives”  in  the  MD&A  and  “Trading 
Assets and Liabilities and Derivatives” and “Fair Value Election 
and  Measurement”  in  Notes  4  and  18,  respectively,  to  the 
Consolidated Financial Statements); Market Risk Management 
(under the caption “Market Risk Management” in the MD&A); 
Liquidity Risk Management (under the caption “Liquidity Risk 
Management” in the MD&A); Credit Risk Management (under 
the  caption  “Credit  Risk  Management”  in  the  MD&A);  and 
Operational Risk Management (under the caption “Operational 
Risk Management” in the MD&A).

The Company's Annual Reports on Form 10-K, Quarterly 
Reports  on  Form  10-Q,  Current  Reports  on  Form  8-K,  and 
amendments  to  those  reports  filed  or  furnished  pursuant  to 
Section 13(a) or 15(d) of the Exchange Act are available free of 
charge  on  the  Company's  investor  relations  website  at  http://
investors.suntrust.com, as soon as reasonably practicable after 
the Company electronically files such material with, or furnishes 
it to, the SEC. Furthermore, on the Company's investor relations 

website,  the  Bank  makes  available,  under  the  heading 
"Governance"  its  (i) codes  of  ethics  for  the  Board,  senior 
financial officers, and employees, (ii) its Corporate Governance 
Guidelines, and (iii) the charters of SunTrust Board committees. 
Reports  filed  or  furnished  to  the  SEC  are  available  at  http://

www.sec.gov. The Company's 2017 Annual Report on Form 10-
K is being distributed to shareholders in lieu of a separate annual 
report containing financial statements of the Company and its 
consolidated subsidiaries.

7

Item 1A.  

RISK FACTORS

The risks described in this Form 10-K are not the only risks we 
face. Additional risks that are not presently known or that we 
deem to be immaterial also may have a material adverse effect 
on our financial condition, results of operations, business, and 
prospects.

Regulatory Risks

Current and future legislation and regulation could require 
us to change our business practices, reduce revenue, impose 
additional  costs,  or  otherwise  adversely  affect  business 
operations or competitiveness.

together  with 

As a financial institution, we are subject to extensive state 
and  federal  regulation  in  the  U.S.  and  in  those  jurisdictions 
outside of the U.S. where we conduct certain limited operations. 
This  regulation, 
increased  reporting  and 
significant  existing  and  proposed  legislation  and  regulatory 
requirements,  limit  the  manner  in  which  we  do  business  and 
may restrict our ability to compete in our current businesses; to 
engage in new or expanded business; to offer certain products 
and services; reduce or limit our revenue; subject us to increased 
and  additional  fees,  assessments,  or  taxes;  and  otherwise 
adversely  affect  our  business  and  operations.  Our  failure  to 
comply  with  the  laws,  regulations,  and  rules  governing  our 
business may result in fines, sanctions (including restrictions on 
business  activities),  and  damage  to  reputation.  Further, 
regulators and bank supervisors continue to exercise qualitative 
supervision and regulation of our industry and specific business 
operations  and  related  matters,  such  as  resolution  planning, 
incentive 
AML  and  OFAC  compliance  programs,  and 
compensation. Any failure to satisfy regulators' substantive and 
qualitative expectations may adversely affect our business and 
operations.  Violations  of  laws  and  regulations  or  deemed 
deficiencies in risk management or other qualitative practices 
also may be incorporated into the Company’s bank supervisory 
ratings. A downgrade in these ratings, or other regulatory actions 
and  settlements,  can  limit  the  Company’s  ability  to  pursue 
acquisitions or conduct other expansionary activities for a period 
of  time  and  require  new  or  additional  regulatory  approvals 
before engaging in certain other business activities. 

Also, in general, the amounts paid by financial institutions 
in settlement of proceedings or investigations and the severity 
of other terms of regulatory settlements have been increasing 
dramatically.  In  some  cases,  governmental  authorities  have 
required  criminal  pleas,  admissions  of  wrongdoing,  imposed 
limitations  on  asset  growth,  managerial  changes,  or  other 
extraordinary  terms  as  part  of  such  settlements,  which  could 
have  significant  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. These 
enforcement  trends  also  increase  the  exposure  of  financial 
institutions to civil litigation and reputational damage, leading 
to potential loss of customers. 

As the primary focus of financial services regulation is the 
protection  of  depositors,  FDIC  funds,  consumers,  and  the 

banking system as a whole, and not protection of shareholders, 
this regulation may be adverse to our shareholders' interests.

Legislation or regulation also may impose unexpected or 
unintended  consequences,  the  impact  of  which  is  difficult  to 
predict. Other additional regulation that may be adopted could 
have  a  material  adverse  effect  on  our  business  operations, 
income,  and  competitive  position,  and  other  negative 
consequences.

For  more  detailed  information  regarding  the  regulatory 
framework  to  which  we  are  subject,  and  a  discussion  of  key 
aspects  of  the  Dodd-Frank  Act,  see  the  “Regulation  and 
Supervision” section within Item 1, “Business,” of this Form 
10-K.

We are subject to stringent capital adequacy and liquidity 
requirements and our failure to meet these would adversely 
affect our financial condition.

We, together with our banking subsidiary and broker-dealer 
subsidiaries,  must  satisfy  various  and  substantial  capital  and 
liquidity  requirements,  subject  to  qualitative  and  quantitative 
review and assessment by our regulators. Regulatory capital and 
liquidity requirements limit how we use our capital and manage 
our balance sheet, and can restrict our ability to pay dividends 
or to make stock repurchases.

Additionally, our regulatory requirements increase as our 
size increases. We become subject to enhanced capital and/or 
liquidity requirements after our consolidated assets exceed $250 
billion or our on-balance sheet foreign exposure exceeds $10 
billion, and our regulators may expect us to begin voluntarily 
complying with those requirements as we approach that size.

Market Risks

The monetary and fiscal policies of the federal government 
and its agencies could have a material adverse effect on our 
earnings.

The  Federal  Reserve  regulates  the  supply  of  money  and 
credit in the U.S. Its policies significantly impact the cost of 
funds for lending and investing and the return earned on those 
loans  and  investments,  both  of  which  affect  our  net  interest 
margin. They can also materially affect the value of financial 
assets we hold, such as debt securities, hedging instruments such 
as swaps, and servicing rights. Federal Reserve policies can also 
adversely affect borrowers, potentially increasing the risk that 
they may fail to repay their loans, or could adversely create asset 
bubbles which result from prolonged periods of accommodative 
policy,  and  which  can  in  turn  result  in  volatile  markets  and 
rapidly declining collateral values. Changes in Federal Reserve 
policies  are  beyond  our  control  and  difficult  to  predict; 
consequently, the impact of these changes on our activities and 
results of operations is also difficult to predict. 

Additionally, certain aspects of recent U.S. federal income 
tax reform could have a negative impact on our business. The 
2017  Tax  Act  limited  or  eliminated  certain  income  tax 
deductions, such as the net business interest expense deduction, 
the  home  mortgage  interest  deduction,  and  the  deduction  of 
interest on home equity loans. The limitation or elimination of 

8

these  deductions,  especially  those  that  limit  or  eliminate  the 
deductibility of interest paid on loans, could adversely affect 
demand for certain types of our products, such as home equity 
loans.

Our  financial  results  have  been,  and  may  continue  to  be, 
materially affected by general economic conditions, and a 
deterioration  of  economic  conditions  or  of  the  financial 
markets  may  materially  adversely  affect  our  lending  and 
other businesses and our financial results and condition.

We generate revenue from the interest and fees we charge 
on the loans and other products and services we provide, and a 
substantial amount of our revenue and earnings come from the 
net  interest  income  and  fee  income  that  we  earn  from  our 
consumer  and  wholesale  businesses.  These  businesses  have 
been, and may continue to be, materially affected by the state 
of the U.S. economy. Although the U.S. economy has continued 
to  gradually  improve  from  the  severely  depressed  levels 
experienced  during  the  last  economic  recession,  economic 
growth  has  been  uneven.  In  addition,  financial  uncertainty 
stemming from changes in oil and commodity prices, a strong 
U.S.  dollar,  U.S.  debt  and  budget  matters,  significant  central 
bank stimulus, a changing interest rate environment in the U.S., 
geopolitical  turmoil,  uncertainty  with  regards  to  the  U.S. 
political  landscape  and  impacts  of  any  changes  in  law, 
regulation, and policy, deceleration of economic activity in other 
large countries, as well as the uncertainty surrounding financial 
regulatory reform, have impacted and may continue to impact 
the continuing global economic recovery.

A prolonged period of slow growth in the U.S. economy or 
in  any  regional  markets  that  we  serve,  any  deterioration  in 
economic conditions or the financial markets resulting from the 
above matters, or any other events or factors that may disrupt 
or dampen the economic recovery, could materially adversely 
affect  our  financial  results  and  condition. Also,  any  further 
deterioration  in  global  economic  conditions  could  slow  the 
recovery  of  the  domestic  economy,  negatively  impact  the 
Company’s borrowers or other counterparties that have direct 
or indirect exposure to these regions, and/or contribute to a flat 
yield  curve.  Such  global  disruptions  can  undermine  investor 
confidence,  cause  a  contraction  of  available  credit,  or  create 
market volatility, any of which could have significant adverse 
effects  on  the  Company’s  businesses,  results  of  operations, 
financial condition and liquidity, even if the Company’s direct 
exposure to the affected region is limited. 

Further, if unemployment levels increase or if home prices 
decrease,  we  would  expect  to  incur  higher  charge-offs  and 
provision expense from increases in our allowance for credit 
losses. These conditions may adversely affect not only consumer 
loan performance but also C&I and CRE loans, especially for 
those businesses that rely on the health of industries or properties 
that  may  suffer  from  deteriorating  economic  conditions. The 
ability of these borrowers to repay their loans may be reduced, 
causing us to incur higher credit losses.

A deterioration in business and economic conditions may 
also erode consumer and investor confidence levels and/or result 
in  a  lower  demand  for  loans  by  creditworthy  customers, 
potentially reducing our interest income. It also could adversely 
affect financial results for our fee-based businesses, including 

our  wealth  management,  investment  advisory,  trading,  and 
investment  banking  businesses.  We  earn  fee  income  from 
managing assets for others and providing brokerage and other 
investment advisory and wealth management services. Because 
investment management fees are often based on the value of 
assets under management, a decrease in the market prices of 
those assets could reduce our fee income. Changes in stock or 
fixed income market prices or client preferences could affect 
the trading activity of investors, reducing commissions and other 
fees  we  earn  from  our  brokerage  business.  Poor  economic 
conditions  and  volatile  or  unstable  financial  markets  would 
likely adversely affect our capital markets-related businesses.

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

Market risk refers to potential losses arising from changes 
in  interest  rates,  foreign  exchange  rates,  equity  prices, 
commodity  prices,  and  other  relevant  market  rates  or  prices. 
Interest rate risk, defined as the exposure of net interest income 
and MVE to adverse movements in interest rates, is our primary 
market risk, and mainly arises from the nature of the loans and 
interest-bearing  liabilities  on  our  balance  sheet.  We  are  also 
exposed  to  market  risk  in  our  trading  instruments,  AFS 
investment  portfolio,  residential  MSRs,  loan  warehouse  and 
pipeline, and debt and brokered deposits measured at fair value. 
Our ALCO meets regularly and is responsible for reviewing our 
open  positions  and  establishing  policies  to  monitor  and  limit 
exposure to market risk. The policies established by ALCO are 
reviewed and approved by our Board. See additional discussion 
of  changes  in  market  interest  rates  in  the  "Market  Risk 
Management” section of Item 7, MD&A, in this Form 10-K.

Given our business mix, and the fact that most of our assets 
and liabilities are financial in nature, we tend to be sensitive to 
market  interest  rate  movements  and  the  performance  of  the 
financial  markets.  In  addition  to  the  impact  of  the  general 
economy, changes in interest rates or in valuations in the debt 
or equity markets could directly impact us in one or more of the 
following ways:
•  The  yield  on  earning  assets  and  rates  paid  on  interest-
bearing liabilities may change in disproportionate ways; or
•  The value of certain on-balance sheet and off-balance sheet 
financial instruments that we hold could change adversely.

Our net interest income is the interest we earn on loans, debt 
securities, and other assets we hold less the interest we pay on 
our deposits, long-term and short-term debt, and other liabilities. 
Net interest income is a function of both our net interest margin 
(the difference between the yield we earn on our earning assets 
and the interest rate we pay for deposits and our other sources 
of funding) and the amount of earning assets we hold. Changes 
in either our net interest margin or the amount of earning assets 
we hold could affect our net interest income and our earnings. 
Changes in interest rates can affect our net interest margin. 
Although the yield we earn on our assets and our funding costs 
tend to move in the same direction in response to changes in 
interest rates, one can rise or fall faster than the other, causing 
our net interest margin to expand or contract. When interest rates 

9

rise, our funding costs may rise faster than the yield we earn on 
our assets, causing our net interest margin to contract. Higher 
interest  rates  may  also  tend  to  result  in  lower  mortgage 
production income and elevated charge-offs in certain segments 
of  the  loan  portfolio,  such  as  CRE,  leveraged  lending,  credit 
card, and home equity.

The amount and type of earning assets we hold can affect 
our yield and net interest margin. We hold earning assets in the 
form of loans and investment securities, among other assets. As 
noted above, if economic conditions deteriorate, we may see 
lower demand for loans by creditworthy customers, reducing 
our interest income. In addition, we may invest in lower yielding 
investment securities for a variety of reasons.

Changes in the slope of the yield curve could also reduce 
our  net  interest  margin.  Normally,  the  yield  curve  is  upward 
sloping,  meaning  short-term  rates  are  lower  than  long-term 
rates. The interest we earn on our assets and our costs to fund 
those assets may be affected by changes in market interest rates, 
changes in the slope of the yield curve, and our cost of funding. 
This could lower our net interest margin and our net interest 
income.  We  discuss  these  topics  in  greater  detail  in  the 
“Enterprise  Risk  Management”  and  “Net  Interest  Income/
Margin” sections of Item 7, MD&A, in this Form 10-K.

We assess our interest rate risk by estimating the effect on 
our  earnings  under  various  scenarios  that  differ  based  on 
assumptions  about  the  direction,  magnitude,  and  speed  of 
interest rate changes and the slope of the yield curve. We hedge 
some of that interest rate risk with interest rate derivatives. These 
hedges may not be effective and may cause volatility or losses 
in our net interest income.

Interest  rates  on  our  outstanding  financial  instruments 
to  change  based  on  regulatory 
might  be  subject 
developments,  which  could  adversely  affect  our  revenue, 
expenses, and the value of those financial instruments.

LIBOR and certain other “benchmarks” are the subject of 
recent national, international, and other regulatory guidance and 
proposals  for  reform.  These  reforms  may  cause  such 
benchmarks to perform differently than in the past or have other 
consequences which cannot be predicted. On July 27, 2017, the 
United  Kingdom’s  Financial  Conduct  Authority,  which 
regulates  LIBOR,  publicly  announced  that  it  intends  to  stop 
persuading or compelling banks to submit LIBOR rates after 
2021. It is unclear whether, at that time, LIBOR will cease to 
exist  or  if  new  methods  of  calculating  LIBOR  will  be 
established.  If  LIBOR  ceases  to  exist  or  if  the  methods  of 
calculating LIBOR change from current methods for any reason, 
interest rates on our floating rate obligations, loans, deposits, 
derivatives, and other financial instruments tied to LIBOR rates, 
as  well  as  the  revenue  and  expenses  associated  with  those 
financial instruments, may be adversely affected. Further, any 
uncertainty  regarding  the  continued  use  and  reliability  of 
LIBOR as a benchmark interest rate could adversely affect the 
value  of  our  floating  rate  obligations,  loans,  deposits, 
derivatives, and other financial instruments tied to LIBOR rates.

Our  earnings  may  be  affected  by  volatility  in  mortgage 
production  and  servicing  revenues,  and  by  changes  in 

carrying values of our servicing assets and mortgages held 
for sale due to changes in interest rates.

We earn revenue from originating mortgage loans and from 
fees  for  servicing  loans.  When  rates  rise,  the  demand  for 
mortgage loans usually tends to fall, reducing the revenue we 
receive from loan originations.

in 

interest 

Changes 

rates  can  affect  prepayment 
assumptions, and thus, the fair value of our residential MSRs. 
A servicing right is the right to service a loan (collect principal, 
interest, and escrow amounts) for a fee. When interest rates fall, 
borrowers  are  usually  more  likely  to  prepay  their  loans  by 
refinancing them at a lower rate. As the likelihood of prepayment 
increases, the fair value of our residential MSRs can decrease. 
We regularly evaluate the fair value of our residential MSRs and 
any related hedges, and any net decrease in the fair value reduces 
the fair value of the MSR asset, which in turn reduce earnings 
in the period in which the fair value reduction occurs.

Similarly, we measure at fair value mortgages held for sale 
for  which  an  active  secondary  market  and  readily  available 
market prices exist. Similar to other interest-bearing securities, 
the  value  of  these  mortgages  held  for  sale  may  be  adversely 
affected  by  changes  in  interest  rates.  For  example,  if  market 
interest rates increase relative to the yield on these mortgages 
held for sale and other interests, their fair value may fall. For 
additional information, see the “Enterprise Risk Management
—Other  Market  Risk”  and  “Critical  Accounting  Policies” 
sections of Item 7, MD&A, and Note 9, “Goodwill and Other 
Intangible Assets,” to the Consolidated Financial Statements in 
this Form 10-K.

We  use  financial  instruments,  including  derivatives,  to 
hedge the risk of changes in the fair value of mortgage loans 
held for sale and the fair value of residential MSRs, exclusive 
of  decay. These  hedges  may  not  be  effective  and  may  cause 
volatility,  or  losses,  in  our  net  interest  income,  mortgage 
production and mortgage servicing income. We generally do not 
hedge all of our risk, and we may not be successful in hedging 
any  of  the  risk.  Hedging  is  a  complex  process,  requiring 
sophisticated models and constant monitoring and re-balancing. 
We may use hedging instruments tied to U.S. Treasury rates, 
LIBOR, or Eurodollars that may not perfectly correlate with the 
value or income being hedged. We could incur significant losses 
from our hedging activities. There may be periods where we 
elect  not  to  use  derivatives  and  other  instruments  to  hedge 
interest  rate  risk.  For  additional  information,  see  Note  17, 
“Derivative  Financial  Instruments,”  to  the  Consolidated 
Financial Statements in this Form 10-K.

Disruptions in our ability to access global capital markets 
may adversely affect our capital resources and liquidity.

In managing our consolidated balance sheet, we depend on 
access to global capital markets to provide us with sufficient 
capital resources and liquidity to meet our commitments and 
business needs, and to accommodate the transaction and cash 
management needs of our clients. Other sources of contingency 
funding  available  to  us  include  inter-bank  borrowings, 
repurchase agreements, FHLB capacity, and borrowings from 
the Federal Reserve discount window. Any occurrence that may 
limit our access to the capital markets, such as a decline in the 
confidence of debt investors, our depositors or counterparties 

10

participating in the capital markets, or a downgrade of any of 
our debt ratings, may adversely affect our funding costs and our 
ability to raise funding and, in turn, our liquidity.

Credit Risks

We are subject to credit risk.

When we lend money, commit to lend money or enter into 
a letter of credit or other contract with a counterparty, we incur 
credit risk, which is the risk of losses if our borrowers do not 
repay  their  loans  or  if  our  counterparties  fail  to  perform 
according  to  the  terms  of  their  contracts. A  number  of  our 
products  expose  us  to  credit  risk,  including  loans,  leveraged 
loans,  leases  and  lending  commitments,  derivatives,  trading 
assets, insurance arrangements with respect to such products, 
and assets held for sale. The credit quality of our portfolio can 
have  a  significant  impact  on  our  earnings.  We  estimate  and 
establish reserves for credit risks and credit losses inherent in 
our credit exposure (including unfunded credit commitments). 
This  process,  which  is  critical  to  our  financial  results  and 
condition, 
requires  difficult,  subjective,  and  complex 
judgments,  including  about  how  economic  conditions  might 
impair the ability of our borrowers to repay their loans. As is 
the case with any such assessments, there is always the chance 
that we will fail to identify the proper factors or that we will fail 
to accurately estimate the impacts of factors that we do identify.
We might underestimate the credit losses inherent in our 
loan portfolio and have credit losses in excess of the amount 
reserved. We might increase the allowance because of changing 
economic conditions, including falling real estate or commodity 
prices  and  higher  unemployment,  or  other  factors  such  as 
changes in borrower behavior. As an example, borrowers may 
discontinue making payments on their real estate-secured loans 
if the value of the real estate is less than what they owe, even if 
they are still financially able to make the payments.

Also,  to  the  extent  we  increase  our  consumer  credit 
portfolio,  we  may  be  subject  to  greater  risk  than  we  have 
experienced in the past since such loans typically are unsecured 
and may be subject to greater fraud risk to the extent such loans 
are originated online.

While we believe that our allowance for credit losses was 
appropriate at December 31, 2017, there is no assurance that it 
will be sufficient to cover all incurred credit losses. In the event 
of significant deterioration in economic conditions, we may be 
required  to  increase  reserves  in  future  periods,  which  would 
reduce  our  earnings  and  potentially  capital.  For  additional 
information,  see 
the  “Risk  Management—Credit  Risk 
Management” and “Critical Accounting Policies—Allowance 
for Credit Losses” sections of Item 7, MD&A, in this Form 10-
K.

We may have more credit risk and higher credit losses to the 
extent that our loans are concentrated by loan type, industry 
segment,  borrower  type,  or  location  of  the  borrower  or 
collateral.

Our credit risk and credit losses can increase if our loans 
are concentrated in borrowers engaged in the same or similar 
activities or in borrowers who as a group may be uniquely or 
disproportionately affected by economic or market conditions. 

Deterioration  in  economic  conditions,  housing  conditions,  or 
real estate values in the markets in which we operate could result 
in materially higher credit losses. For additional information, 
see  the  “Loans,”  “Allowance  for  Credit  Losses,”  “Risk 
Management—Credit  Risk  Management,”  and  “Critical 
Accounting Policies—Allowance for Credit Losses” sections of 
Item 7, MD&A, and Notes 6 and 7, “Loans” and “Allowance 
for Credit Losses,” to the Consolidated Financial Statements in 
this Form 10-K.

Liquidity Risks

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

We  sell  most  of  the  mortgage  loans  that  we  originate  to 
reduce our credit risk and to provide funding for additional loans. 
We rely on GSEs to purchase loans that meet their conforming 
loan requirements. Investor demand for nonconforming loans 
has  fallen  sharply,  resulting  in  decreased  origination  of  non-
conforming loans, which reduces our revenue. When we retain 
a loan, not only do we keep the credit risk of the loan, but we 
also  do  not  receive  any  sale  proceeds  that  could  be  used  to 
generate new loans. A persistent lack of liquidity could limit our 
ability to fund and thus originate new mortgage loans, reducing 
the  fees  we  earn  from  originating  and  servicing  loans.  In 
addition,  we  cannot  provide  assurance  that  GSEs  will  not 
materially  limit  their  purchases  of  conforming  loans  due  to 
capital constraints or change their criteria for conforming loans 
(e.g., maximum loan amount or borrower eligibility). Proposals 
have been presented to reform the housing finance market in the 
U.S.,  including  the  role  of  the  GSEs  in  the  housing  finance 
market. The extent and timing of any such regulatory reform of 
the housing finance market and the GSEs, as well as any effect 
on our business and financial results, are uncertain.

Loss of customer deposits could increase our funding costs.
We rely heavily on bank deposits as a low cost and stable 
source of funding for the loans we make. We compete with banks 
and  other  financial  services  companies  for  deposits.  If  our 
competitors raise the rates they pay on deposits, our funding 
costs may increase, either because we raise our rates to avoid 
losing deposits or because we lose deposits and must rely on 
more expensive sources of funding. Also, clients could pursue 
alternatives  to  bank  deposits  if  clients  perceive  alternative 
investments  as  providing  superior  expected  returns.  When 
clients move money out of bank deposits in favor of alternative 
investments,  we  can  lose  a  relatively  inexpensive  source  of 
funds,  increasing  our  funding  costs.  Clients  typically  move 
money from bank deposits to alternatives during a rising interest 
rate  environment,  an  environment  that  the  U.S.  is  currently 
experiencing  and  one  that  is  expected  to  continue  over  the 
medium-term.  Higher  funding  costs  reduce  our  net  interest 
margin and net interest income.

Any reduction in our credit rating could increase the cost of 
our funding from the capital markets.

The rating agencies regularly evaluate us, and their ratings 
are based on a number of factors, including our financial strength 
as  well  as  factors  not  entirely  within  our  control,  including 

11

conditions  affecting  the  financial  services  industry  generally. 
Our failure to maintain those ratings could adversely affect the 
cost and other terms upon which we are able to obtain funding 
and  increase  our  cost  of  capital.  Credit  ratings  are  one  of 
numerous  factors  that  influence  our  funding  costs. A  credit 
downgrade  might  also  affect  our  ability  to  attract  or  retain 
deposits  from  commercial  and  corporate  customers  and  our 
ability to conduct derivatives business with certain clients and 
counterparties and could trigger obligations by us to make cash 
payments  to  certain  clients  and  counterparties.  See  the 
“Liquidity Risk Management” section of Item 7, MD&A, in this 
Form 10-K.

Legal Risks

We are subject to litigation, and our expenses related to this 
litigation may adversely affect our results.

From time to time we are subject to litigation in the course 
of  our  business.  These  claims  and  legal  actions,  including 
supervisory  actions  by  our  regulators,  could  involve  large 
monetary claims and significant defense costs. Both the number 
of cases and our expenses related to those cases increased as a 
result of the Great Recession. The outcome of some of these 
cases is uncertain.

We  establish  reserves  for  legal  claims  when  payments 
associated with the claims become probable and the costs can 
be reasonably estimated. We may incur legal costs for a matter 
even if we have not established a reserve. In addition, the actual 
cost of resolving a legal claim may be substantially higher than 
any amounts reserved for that matter. The ultimate resolution of 
a pending legal proceeding, depending on the remedy sought 
and  granted,  could  materially  adversely  affect  our  results  of 
operations and financial condition.

Substantial legal liability or significant regulatory action 
against us could have material adverse financial effects or cause 
significant reputational harm to us, which in turn could seriously 
harm our business prospects. We may be exposed to substantial 
uninsured liabilities, which could adversely affect our results of 
operations and financial condition. For additional information, 
see  Note  19,  “Contingencies,”  to  the  Consolidated  Financial 
Statements in this Form 10-K.

We  may 
incur  fines,  penalties  and  other  negative 
consequences  from  regulatory  violations,  possibly  even 
inadvertent or unintentional violations.

We maintain systems and procedures designed to ensure 
that we comply with applicable laws and regulations, but there 
can be no assurance that these will be effective. In addition to 
fines and penalties, we may suffer other negative consequences 
from  regulatory  violations  including  restrictions  on  certain 
activities, such as our mortgage business, which may affect our 
relationship with the GSEs and may also damage our reputation, 
and this in turn might materially affect our business and results 
of operations.

Further, some legal/regulatory frameworks provide for the 
imposition of fines or penalties for noncompliance even though 
the noncompliance was inadvertent or unintentional and even 
though there were in place at the time systems and procedures 
designed to ensure compliance. For example, we are subject to 

regulations issued by OFAC that prohibit financial institutions 
from participating in the transfer of property belonging to the 
governments  of  certain  foreign  countries  and  designated 
nationals of those countries. OFAC may impose penalties for 
inadvertent  or  unintentional  violations  even  if  reasonable 
processes are in place to prevent the violations. Additionally, 
federal  regulators  have  pursued  financial  institutions  with 
emerging theories of recovery under the Financial Institutions 
Reform, Recovery, and Enforcement Act of 1989 (“FIRREA”). 
Courts may uphold significant additional penalties on financial 
institutions,  even  where  the  financial  institution  had  already 
reimbursed the government or other counterparties for actual 
losses.

Other Business Risks

We are subject to certain risks related to originating and 
selling  mortgages.  We  may  be  required  to  repurchase 
mortgage loans or indemnify mortgage loan purchasers as 
a result of breaches of representations and warranties, or 
borrower fraud, and this could harm our liquidity, results 
of operations, and financial condition.

We originate and often sell mortgage loans. When we sell 
mortgage  loans,  whether  as  whole  loans  or  pursuant  to  a 
to  make  customary 
required 
securitization,  we  are 
representations  and  warranties  to  the  purchaser  about  the 
mortgage loans and the manner in which they were originated. 
An increase in the number of repurchase and indemnity demands 
from  purchasers  related  to  representations  and  warranties  on 
loans sold could result in an increase in the amount of losses for 
loan repurchases.

Also, the Company bears a risk of loss of up to one-third 
of the incurred losses resulting from borrower defaults for multi-
family commercial mortgage loans that the Company sells to 
Fannie  Mae  (and  that  Pillar  sold  to  Fannie  Mae  prior  to 
SunTrust’s  acquisition  of  Pillar).  See  the  discussion  of 
“Commercial Mortgage Loan Loss Share Guarantee” in Note 
16, “Guarantees,” to the Consolidated Financial Statements in 
this Form 10-K for additional information.

In addition to repurchase claims from the GSEs, we have 
received indemnification claims from, and in some cases, have 
been sued by, non-GSE purchasers of our loans. These claims 
allege that we sold loans that failed to conform to statements 
regarding the quality of the mortgage loans sold, the manner in 
which  the  loans  were  originated  and  underwritten,  and  the 
compliance of the loans with state and federal law. See additional 
discussion 
in  Note  16,  “Guarantees,”  and  Note  19, 
“Contingencies,” to the Consolidated Financial Statements in 
this Form 10-K.

We face risks as a servicer of loans.

We act as servicer and/or master servicer for mortgage loans 
included in securitizations and for unsecuritized mortgage loans 
owned by investors. As a servicer or master servicer for those 
loans,  we  have  certain  contractual  obligations 
the 
securitization trusts, investors or other third parties, including, 
in our capacity as a servicer, foreclosing on defaulted mortgage 
loans  or,  to  the  extent  consistent  with  the  applicable 
investor  agreement,  considering 
securitization  or  other 

to 

12

alternatives to foreclosure such as loan modifications or short 
sales and, in our capacity as a master servicer, overseeing the 
servicing  of  mortgage  loans  by  the  servicer.  Generally,  our 
servicing obligations are set by contract, for which we receive 
a  contractual  fee.  However,  GSEs  can  amend  their  servicing 
guidelines, which can increase the scope or costs of the services 
we are required to perform without any corresponding increase 
in our servicing fee. Further, the CFPB has implemented national 
servicing standards which have increased the scope and costs 
of services which we are required to perform. In addition, there 
has  been  a  significant  increase  in  state  laws  that  impose 
additional servicing requirements that increase the scope and 
cost of our servicing obligations. Also, as a servicer, we advance 
expenses  on  behalf  of  investors  which  we  may  be  unable  to 
collect.

If we commit a material breach of our obligations as servicer 
or master servicer, we may be subject to termination if the breach 
is not cured within a specified period of time following notice, 
which can generally be given by the securitization trustee or a 
specified  percentage  of  security  holders,  causing  us  to  lose 
servicing income. In addition, we may be required to indemnify 
the securitization trustee against losses from any failure by us, 
as  a  servicer  or  master  servicer,  to  perform  our  servicing 
obligations  or  any  act  or  omission  on  our  part  that  involves 
willful misfeasance, bad faith, or gross negligence. For certain 
investors and/or certain transactions, we may be contractually 
obligated  to  repurchase  a  mortgage  loan  or  reimburse  the 
investor for credit losses incurred on the loan as a remedy for 
servicing  errors  with  respect  to  the  loan.  If  we  experience 
increased repurchase obligations because of claims that we did 
not satisfy our obligations as a servicer or master servicer, or 
increased loss severity on such repurchases, we may have to 
materially increase our repurchase reserve.

We also have received indemnification requests related to 
our  servicing  of  loans  owned  or  insured  by  other  parties, 
primarily  GSEs.  Typically,  such  a  claim  seeks  to  impose  a 
compensatory fee on us for departures from GSE service levels. 
In most cases, this is related to delays in the foreclosure process. 
Additionally, we have received indemnification requests where 
an investor or insurer has suffered a loss due to a breach of the 
servicing agreement. While the number of such claims has been 
small,  these  could  increase  in  the  future.  See  additional 
discussion  in  Note  16,  “Guarantees,”  to  the  Consolidated 
Financial Statements in this Form 10-K.

Consumers and small businesses may decide not to use banks 
to complete their financial transactions, which could affect 
net income.

Technology, “FinTech” start-ups, increased use of peer-to-
peer and other technology-based lenders, and other changes now 
allow  parties  to  complete  financial  transactions  and  obtain 
certain loan products without banks. For example, consumers 
and small businesses can pay bills, transfer funds, and borrow 
money without banks. This could result in the loss of fee income, 
the loss of client deposits, and consumer and small business loan 
balances  and  the  income  generated  from  those  deposits  and 
loans.

We have businesses other than banking which subject us to 
a variety of risks.

We are a diversified financial services company, which we 
consider a positive in that it may enhance our growth prospects 
and may reduce our overall volatility. However, this diversity 
subjects  our  earnings  to  a  broader  variety  of  risks  and 
uncertainties than if we were a less diversified company. Other 
businesses  in  addition  to  banking  that  we  operate  include 
investment  banking,  securities  underwriting  and  market 
making, loan syndications, investment management and advice, 
and retail and wholesale brokerage services offered through our 
subsidiaries.  These  businesses  entail  significant  market, 
operational, credit, legal, and other risks that could materially 
adversely impact us and our results of operations.

Negative public opinion could damage our reputation and 
adversely impact business and revenues.

As  a  financial  institution,  our  earnings  and  capital  are 
subject  to  risks  associated  with  negative  public  opinion. The 
reputation of the financial services industry, in general, has been 
damaged as a result of the most recent financial crisis and other 
matters  affecting  the  financial  services  industry,  including 
mortgage foreclosure issues and recent sales-practices scandals. 
Negative  public  opinion  regarding  us  could  result  from  our 
actual or alleged conduct in any number of activities, including 
lending practices, a breach of client information, the failure of 
any product or service sold by us to meet our clients' expectations 
or  applicable  regulatory  requirements,  corporate  governance 
and  acquisitions,  or  from  actions  taken  by  government 
regulators and community organizations in response to those 
activities.  Negative  public  opinion  can  adversely  affect  our 
ability  to  attract  and/or  retain  clients  and  personnel  and  can 
expose us to litigation and regulatory action. Actual or alleged 
conduct by one of our businesses can result in negative public 
opinion about our other businesses. Actual or alleged conduct 
by  another  financial  institution  can  result  in  negative  public 
opinion about the financial services industry in general and, as 
a result, adversely affect us.

We may face more intense scrutiny of our sales, training, 
and incentive compensation practices.

We face increased scrutiny of our consumer sales practices, 
training  practices, 
incentive  compensation  design  and 
governance,  and  quality  assurance  and  customer  complaint 
resolution  practices.  Although  we  have  invested  significant 
resources enhancing these processes in recent years, there can 
be  no  assurance  that  our  processes  or  their  results  will  meet 
regulatory  standards  or  expectations.  Findings  from  self-
identified or regulatory reviews may require responsive actions, 
including  increased  investments  in  compliance  systems  and 
personnel,  or  the  payment  of  fines,  penalties,  increased 
regulatory assessments, or client redress, and may increase legal 
or reputational risk exposures.

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

Third  parties  provide  key  components  of  our  business 
infrastructure, such as banking services, processing, and internet 
connections and network access. Any disruption in such services 

13

provided by these third parties or any failure of these third parties 
to handle current or higher volumes of use could adversely affect 
our  ability  to  deliver  products  and  services  to  clients  and 
otherwise  to  conduct  business.  Technological  or  financial 
difficulties  of  a  third  party  service  provider  could  adversely 
affect our business to the extent those difficulties result in the 
interruption  or  discontinuation  of  services  provided  by  that 
party.  Further,  in  some  instances  we  may  be  responsible  for 
failures  of  such  third  parties  to  comply  with  government 
regulations. We may not be insured against all types of losses 
as a result of third party failures, and our insurance coverage 
may  be  inadequate  to  cover  all  losses  resulting  from  system 
failures  or  other  disruptions.  Failures 
in  our  business 
infrastructure could interrupt the operations or increase the costs 
of doing business.

Competition in the financial services industry is intense and 
we could lose business or suffer margin declines as a result.
We  operate  in  a  highly  competitive  industry  that  could 
become  even  more  competitive  as  a  result  of  reform  of  the 
financial services industry resulting from the Dodd-Frank Act 
and other legislative, regulatory, and technological changes, and 
from continued consolidation. We face aggressive competition 
from other domestic and foreign lending institutions and from 
numerous other providers of financial services. The ability of 
nonbanking financial institutions to provide services previously 
limited  to  commercial  banks  has  intensified  competition. 
Because nonbanking financial institutions are not subject to the 
same  regulatory  restrictions  as  banks  and  bank  holding 
companies, they can often operate with greater flexibility and 
lower cost structures. Securities firms and insurance companies 
that have elected to become financial holding companies can 
offer virtually any type of financial service, including banking, 
securities  underwriting, 
(both  agency  and 
underwriting), and merchant banking, and may acquire banks 
and  other  financial  institutions.  These  new  competitors  have 
significantly changed the competitive environment in which we 
conduct  business.  Some  of  our  competitors  have  greater 
financial resources and/or face fewer regulatory constraints. As 
a result of these various sources of competition, we could lose 
business  to  competitors  or  be  forced  to  price  products  and 
services on less advantageous terms to retain or attract clients, 
either of which would adversely affect our profitability.

insurance 

We  continually  encounter  technological  change  and  must 
effectively develop and implement new technology.

The  financial  services  industry  is  undergoing  rapid 
technological  change  with  frequent  introductions  of  new 
technology-driven products and services. We have invested in 
technology and connectivity to automate functions previously 
performed  manually,  to  facilitate  the  ability  of  customers  to 
engage in financial transactions, and otherwise to enhance the 
customer experience with respect to our products and services. 
On the retail side, this has included developments such as more 
sophisticated  ATMs  and  expanded  access 
to  banking 
transactions through the internet, smart phones, tablets and other 
remote devices. This has allowed us to better serve our clients 
and  to  reduce  costs.  Our  continued  success  depends,  in  part, 
upon our ability to address the needs of our customers by using 

technology  to  provide  products  and  services  that  satisfy 
customer  demands,  including  demands  for  faster  and  more 
secure payment services, to create efficiencies in our operations, 
and  to  integrate  those  offerings  with  legacy  platforms  or  to 
update those legacy platforms. A failure to maintain or enhance 
our  competitive position  with  respect  to  technology,  whether 
because we fail to anticipate customer expectations or because 
our technological developments fail to perform as desired or are 
not rolled out in a timely manner, may cause us to lose market 
share or incur additional expense.

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

Our  success  depends,  in  part,  on  our  ability  to  adapt 
products and services to evolving market and industry standards. 
The widespread adoption of new technologies has required, and 
likely will continue to require, us to make substantial capital 
expenditures to modify or adapt existing products and services 
or  develop  new  products  and  services.  In  addition,  there  is 
increasing pressure to provide products and services at lower 
prices.  This  can  reduce  net  interest  income  and  noninterest 
income from fee-based 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,  any  of  which  would  adversely  affect  our 
profitability.

We  have  in  the  past  and  may  in  the  future  pursue 
acquisitions,  which  could  affect  costs  and  from  which  we 
may not be able to realize anticipated benefits.

We have historically pursued acquisitions, and may seek 
acquisitions in the future. We may not be able to successfully 
identify suitable candidates, negotiate appropriate acquisition 
terms,  complete  proposed  acquisitions,  successfully  integrate 
acquired businesses into the existing operations, or expand into 
new  markets.  Once  integrated,  acquired  operations  may  not 
achieve  levels  of  revenues,  profitability,  or  productivity 
comparable with those achieved by our existing operations, or 
otherwise perform as expected.

Acquisitions involve numerous risks, including difficulties 
in the integration of the operations, technologies, services, and 
products  of  the  acquired  companies,  and  the  diversion  of 
management's attention from other business concerns. We may 
not properly ascertain all such risks prior to an acquisition or 
prior to such a risk impacting us while integrating an acquired 
company. As a result, difficulties encountered with acquisitions 
could have a material adverse effect on our business, financial 
condition, and results of operations.

Furthermore, we must generally receive federal regulatory 
approval before we can acquire a bank or BHC. In determining 
whether to approve a proposed bank acquisition, federal bank 
regulators will consider, among other factors, the effect of the 
acquisition  on  competition, 
future 
prospects,  including  current  and  projected  capital  levels,  the 
integrity  of  management, 
competence,  experience,  and 

financial  condition, 

14

compliance  with  laws  and  regulations,  the  convenience  and 
needs of the communities to be served, including the acquiring 
institution's  record  of  compliance  under  the  CRA,  and  the 
effectiveness of the acquiring institution in combating money 
laundering  activities. We  cannot  be  certain  when  or  if,  or  on 
what terms and conditions, any required regulatory approvals 
will  be  granted.  Consequently,  we  might  be  required  to  sell 
portions of the acquired institution as a condition to receiving 
regulatory approval or we may not obtain regulatory approval 
for a proposed acquisition on acceptable terms or at all, in which 
case we would not be able to complete the acquisition despite 
the time and expenses invested in pursuing it.

We  depend  on  the  expertise  of  key  personnel.  If  these 
individuals  leave  or  change  their  roles  without  effective 
replacements, operations may suffer.

Our success depends, to a large degree, on the continued 
services of executive officers and other key personnel who have 
extensive experience in the industry. We generally do not carry 
key person life insurance on any of our executive officers or 
other  key  personnel.  If  we  lose  the  services  of  any  of  these 
persons and fail to manage a smooth transition to new personnel, 
our business could be adversely impacted.

We may not be able to hire or retain additional qualified 
personnel  and  recruiting  and  compensation  costs  may 
increase as a result of changes in the marketplace, both of 
which may increase costs and reduce profitability and may 
adversely  impact  our  ability  to  implement  our  business 
strategies.

Our success depends upon the ability to attract and retain 
highly motivated, well-qualified personnel. We face significant 
competition  in  the  recruitment  of  qualified  employees.  Our 
ability to execute our business strategy and provide high quality 
service may suffer if we are unable to recruit or retain a sufficient 
number  of  qualified  employees  or  if  the  costs  of  employee 
compensation or benefits increase substantially. Further, in June 
2010, the Federal Reserve and other federal banking regulators 
jointly issued comprehensive final guidance designed to ensure 
that  incentive  compensation  policies  do  not  undermine  the 
safety and soundness of banking organizations by encouraging 
employees to take imprudent risks. This regulation significantly 
affects the amount, form, and context in which we pay incentive 
compensation.  Additionally,  the  Board  of  Governors  of  the 
Federal  Reserve  System,  the  Federal  Deposit  Insurance 
Corporation,  and  the  SEC  have  jointly  proposed  rules  which 
affect  incentive  compensation. These  rules,  if  finalized,  may 
adversely affect us by imposing costs and restrictions on certain 
of  our  businesses  which  are  not  imposed  on  non-bank 
competitors.

Other Risks

Our framework for managing risks may not be effective in 
mitigating risk and loss to us.

Our risk management framework seeks to mitigate risk and 
loss  to  us.  We  have  established  processes  and  procedures 
intended to identify, measure, monitor, report and analyze the 
types of risk to which we are subject, including liquidity risk, 

15

credit  risk,  market  risk,  interest  rate  risk,  operational  risk, 
reputational risk, and legal, model and compliance risk, among 
others. However, as with any risk management framework, there 
are  inherent  limitations  to  our  risk  management  strategies  as 
risks  may  exist,  or  develop  in  the  future,  that  we  have  not 
appropriately anticipated or identified. The most recent financial 
crisis  and  resulting  regulatory  reform  highlighted  both  the 
limitations  of  managing 
the 
importance  and  some  of 
unanticipated risks. If our risk management framework proves 
ineffective,  we  could  suffer  unexpected  losses  and  could  be 
materially adversely affected.

Our controls and procedures may not prevent or detect all 
errors or acts of fraud.

Our  controls  and  procedures  are  designed  to  provide 
reasonable assurance that information required to be disclosed 
by us in reports we file or submit under the Exchange Act is 
accurately accumulated and communicated to management, and 
recorded, processed, summarized, and reported within the time 
periods specified in the SEC's rules and forms. We believe that 
any disclosure controls and procedures or internal controls and 
procedures, no matter how well conceived and operated, can 
provide  only  reasonable,  not  absolute,  assurance  that  the 
objectives of the control system are met, due to certain inherent 
that 
limitations.  These 
judgments  in  decision  making  can  be  faulty,  that  alternative 
reasoned judgments can be drawn, or that breakdowns can occur 
because of a simple error or mistake. Additionally, controls can 
be  circumvented  by  the  individual  acts  of  some  persons,  by 
collusion of two or more people or by an unauthorized override 
of the controls. Accordingly, because of the inherent limitations 
in our control system, misstatements due to error or fraud may 
occur  and  not  be  detected,  which  could  result  in  a  material 
weakness in our internal controls over financial reporting and/
or the restatement of previously filed financial statements.

the  realities 

limitations 

include 

We are at risk of increased losses from fraud.

Criminals  committing  fraud  increasingly  are  using  more 
sophisticated techniques and in some cases are part of larger 
criminal rings, which allow them to be more effective.

Fraudulent activity has taken many forms and escalates as 
more tools for accessing financial services emerge, such as real-
time  payments.  Fraud  schemes  are  broad  and  continuously 
evolving and include such things as debit card/credit card fraud, 
check  fraud,  mechanical  devices  attached  to ATM  machines, 
social  engineering  and  phishing  attacks  to  obtain  personal 
information, or impersonation of our clients through the use of 
falsified  or  stolen  credentials. Additionally,  an  individual  or 
business entity may properly identify themselves, yet seek to 
establish a business relationship for the purpose of perpetrating 
fraud. An emerging type of fraud even involves the creation of 
synthetic identification in which fraudsters “create” individuals 
for  the  purpose  of  perpetrating  fraud. Further,  in  addition  to 
fraud committed against us, we may suffer losses as a result of 
fraudulent  activity  committed  against  third  parties.  Increased 
deployment  of  technologies,  such  as  chip  card  technology, 
defray  and  reduce  aspects  of  fraud;  however,  criminals  are 
turning  to  other  sources  to  steal  personally  identifiable 
information,  such  as  unaffiliated  healthcare  providers  and 

government entities, in order to impersonate the consumer to 
commit  fraud.  Many  of  these  data  compromises  have  been 
widely reported in the media. Further, as a result of the increased 
sophistication of fraud activity, we have increased our spending 
on systems and controls to detect and prevent fraud. This will 
result in continued ongoing investments in the future.

Our  operational  and  communications  systems  and 
infrastructure may fail or may be the subject of a breach or 
cyber-attack that, if successful, could adversely affect our 
business and disrupt business continuity.

We depend on our ability to process, record, and monitor a 
large number of client transactions and to communicate with 
clients and other institutions on a continuous basis. As client, 
industry,  public,  and  regulatory  expectations  regarding 
operational  and  information  security  have  increased,  our 
operational  systems  and 
to  be 
safeguarded and monitored for potential failures, disruptions, 
and  breakdowns,  whether  as  a  result  of  events  beyond  our 
control or otherwise. 

infrastructure  continue 

Our  business,  financial,  accounting,  data  processing,  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 
client  transaction  volume;  electrical  or  telecommunications 
outages;  natural  disasters  such  as  earthquakes,  tornadoes, 
floods, and hurricanes; disease pandemics; events arising from 
local or larger scale political or social matters, including terrorist 
acts; occurrences of employee error, fraud, or malfeasance; and, 
as described below, cyber-attacks. 

Although  we  have  business  continuity  plans  and  other 
safeguards in place, our operations and communications may 
be adversely affected by significant and widespread disruption 
to our systems and infrastructure that support our businesses and 
clients. While we continue to evolve and modify our business 
continuity plans, there can be no assurance in an escalating threat 
environment that they will be effective in avoiding disruption 
and business impacts. Our insurance may not be adequate to 
compensate us  for  all resulting  losses,  and the  cost to  obtain 
adequate coverage may increase for us or the industry.

to  conduct 

technologies 

Security risks for financial institutions such as ours have 
dramatically  increased  in  recent  years  in  part  because  of  the 
proliferation of new technologies, the use of the internet and 
financial 
telecommunications 
transactions,  and  the  increased  sophistication,  resources  and 
activities of hackers, terrorists, activists, organized crime, and 
other external parties, including nation state actors. In addition, 
to access our products and services, clients may use devices or 
software that are beyond our control environment, which may 
provide  additional  avenues  for  attackers  to  gain  access  to 
confidential  information.  Although  we  have  information 
security  procedures  and  controls  in  place,  our  technologies, 
systems,  networks,  and  clients'  devices  and  software  may 
become  the  target  of  cyber-attacks  or  information  security 
breaches that could result in the unauthorized release, gathering, 
monitoring, misuse, loss, change, or destruction of our or our 
information 
clients'  confidential,  proprietary  and  other 
(including personal identifying information of individuals), or 

otherwise  disrupt  our  or  our  clients'  or  other  third  parties' 
business  operations.  Other  U.S.  financial  institutions  and 
financial  service  companies  have  reported  breaches  in  the 
security of their websites or other systems, including attempts 
to shut down access to their networks and systems in an attempt 
to extract compensation from them to regain control. Financial 
institutions, including SunTrust, have experienced distributed 
denial-of-service  attacks,  a  sophisticated  and  targeted  attack 
intended to disable or degrade internet service or to sabotage 
systems.

We and others in our industry are regularly the subject of 
attempts  by  attackers  to  gain  unauthorized  access  to  our 
networks, systems, and data, or to obtain, change, or destroy 
confidential data (including personal identifying information of 
individuals)  through  a  variety  of  means,  including  computer 
viruses, malware, and phishing. In the future, these attacks may 
result  in  unauthorized  individuals  obtaining  access  to  our 
confidential  information  or  that  of  our  clients,  or  otherwise 
accessing,  damaging,  or  disrupting  our 
systems  or 
infrastructure.

We  are  continuously  developing  and  enhancing  our 
controls,  processes,  and  practices  designed  to  protect  our 
systems, computers, software, data, and networks from attack, 
damage, or unauthorized access. This continued development 
and enhancement will require us to expend additional resources, 
including to investigate and remediate any information security 
vulnerabilities  that  may  be  detected.  Despite  our  ongoing 
investments in security resources, talent, and business practices, 
we  are  unable  to  assure  that  any  security  measures  will  be 
effective.

If  our  systems  and  infrastructure  were  to  be  breached, 
damaged, or disrupted, or if we were to experience a loss of our 
confidential  information  or  that  of  our  clients,  we  could  be 
subject to serious negative consequences, including disruption 
of our operations, damage to our reputation, a loss of trust in us 
on the part of our clients, vendors or other counterparties, client 
attrition, reimbursement or other costs, increased compliance 
costs,  significant  litigation  exposure  and  legal  liability,  or 
regulatory fines, penalties or intervention. Any of these could 
materially  and  adversely  affect  our  results  of  operations,  our 
financial condition, and/or our share price.

A disruption, breach, or failure in the operational systems 
and  infrastructure  of  our  third  party  vendors  and  other 
service  providers,  including  as  a  result  of  cyber-attacks, 
could adversely affect our business.

Third  parties  perform  significant  operational  services  on 
our behalf. These third parties with whom we do business or 
that  facilitate  our  business  activities,  including  exchanges, 
clearing  houses,  central  clearing  counterparties,  financial 
intermediaries,  or  vendors  that  provide  services  or  security 
solutions for our operations, could also be sources of operational 
and information security risk to us, including from breakdowns 
or  failures  of  their  own  systems  or  capacity  constraints.  In 
particular, operating our business requires us to provide access 
to  client  and  other  sensitive  Company  information  to  our 
contractors, consultants, and other third parties and authorized 
entities. Controls and oversight mechanisms are in place that 
are designed to limit access to this information and protect it 

16

from unauthorized disclosure, theft, and disruption. However, 
control  systems  and  policies  pertaining  to  system  access  are 
subject to errors in design, oversight failure, software failure, 
human  error,  intentional  subversion  or  other  compromise 
resulting in theft, error, loss, or inappropriate use of information 
or systems to commit fraud, cause embarrassment to us or our 
executives  or  to  gain  competitive  advantage.  In  addition, 
regulators expect financial institutions to be responsible for all 
aspects  of  their  performance,  including  aspects  which  they 
delegate to third parties. If a disruption, breach, or failure in the 
system or infrastructure of any third party with whom we do 
business occurred, our business may be materially and adversely 
affected  in  a  manner  similar  to  if  our  own  systems  or 
infrastructure had been compromised. As has been the case in 
other  major  system  events  in  the  U.S.,  our  systems  and 
infrastructure may also be attacked, compromised, or damaged 
as a result of, or as the intended target of, any disruption, breach, 
or failure in the systems or infrastructure of any third party with 
whom we do business.

Natural disasters and other catastrophic events could have 
a material adverse impact on our operations or our financial 
condition and results.

The occurrence of catastrophic events, such as hurricanes, 
tropical storms, tornados, winter storms, wildfires, earthquakes, 
mudslides,  floods,  and  other  large  scale  catastrophes,  could 
adversely affect our financial condition or results of operations. 
We have significant operations and customers along the Gulf 
and Atlantic coasts as well as other regions of the U.S., which 
could be adversely impacted by hurricanes, tornados, and other 
severe weather in those areas. Unpredictable natural and other 
disasters could have an adverse effect on us in that such events 
could  materially  disrupt  our  operations  or  the  ability  or 
willingness of our customers to access the financial services that 
we offer, including adverse impacts on our borrowers to timely 
repay their loans and the value of any collateral that we hold. 
These events could reduce our earnings and cause volatility in 
our financial results for any fiscal quarter or year and have a 
material adverse effect on our financial condition or results of 
operations.

Although  we  have  business  continuity  plans  and  other 
safeguards in place, our operations and communications may 
be adversely affected by natural disasters or other catastrophic 
events  and  there  can  be  no  assurance  that  such  business 
continuity plans will be effective.

The soundness of other financial institutions could adversely 
affect us.

Our ability to engage in routine funding transactions could 
be adversely affected by the actions and commercial soundness 
of other financial institutions. Financial services institutions 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 industry, including brokers and 
dealers,  central  clearing  counterparties,  commercial  banks, 
investment  banks,  mutual  and  hedge  funds,  and  other 
institutional clients. As a result, defaults by, or even rumors or 
questions about, one or more financial services institutions, or 

the financial services industry generally, in the past have led 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 when 
the collateral held by us cannot be realized or is liquidated at 
prices not sufficient to recover the full amount of our exposure. 
There is no assurance that any such losses would not materially 
and adversely affect our results of 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 
including  financial  statements  and  other 
counterparties, 
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 the information that we rely 
on is not accurate or complete, our decisions about extending 
credit  or  entering  into  other  transactions  with  clients  or 
counterparties could be adversely affected, and we could suffer 
defaults,  credit  losses,  or  other  negative  consequences  as  a 
result.

Our accounting policies and processes are critical to how we 
report our financial condition and results of operation. They 
require management to make estimates about matters that 
are uncertain.

Accounting policies and processes are fundamental to how 
we  record  and  report  our  financial  condition  and  results  of 
operation. Some of these policies require use of estimates and 
assumptions that may affect the value of our assets or liabilities 
and  financial  results.  Several  of  our  accounting  policies  are 
critical  because  they  require  management  to  make  difficult, 
subjective,  and  complex  judgments  about  matters  that  are 
inherently  uncertain  and  because  it  is  likely  that  materially 
different amounts would be reported under different conditions 
or using different assumptions. Pursuant to U.S. GAAP, we are 
required to make certain assumptions and estimates in preparing 
our financial statements, including in determining credit loss 
reserves, reserves related to litigation and the fair value of certain 
assets and liabilities, including the value of goodwill, among 
other items. If assumptions or estimates underlying our financial 
statements are incorrect, or are adjusted periodically, we may 
experience material losses.

Management has identified certain accounting policies as 
being critical because they require management's judgment to 
ascertain the valuations of assets, liabilities, commitments, and 
contingencies. A  variety  of  factors  could  affect  the  ultimate 
value that is obtained either when earning income, recognizing 
an expense, recovering an asset, valuing an asset or liability, or 
recognizing or reducing a liability. We have established detailed 
policies and control procedures that are intended to ensure these 
critical accounting estimates and judgments are well controlled 
and applied consistently. In addition, the policies and procedures 
are  intended  to  ensure  that  the  process  for  changing 
methodologies occurs in an appropriate manner. Because of the 

17

uncertainty  surrounding  our  judgments  and  the  estimates 
pertaining to these matters, we cannot guarantee that we will 
not  be  required  to  adjust  accounting  policies  or  restate  prior 
period financial statements. We discuss these topics in greater 
detail in the "Critical Accounting Policies” section of Item 7, 
MD&A, and Note 1, “Significant Accounting Policies,” to the 
Consolidated Financial Statements in this Form 10-K.

Further, from time to time, the FASB and SEC change the 
financial  accounting  and  reporting  standards  that  govern  the 
preparation of our financial statements. In addition, accounting 
standard  setters  and  those  who  interpret  the  accounting 
their  previous 
standards  may  change  or  even  reverse 
interpretations or positions on how these standards should be 
applied.  Changes  in  financial  accounting  and  reporting 
standards and changes in current interpretations may be beyond 
our control, can be hard to predict and could materially affect 
how we report our financial results and condition. In some cases, 
we  could  be  required  to  apply  a  new  or  revised  standard 
retroactively,  resulting  in  us  restating  prior  period  financial 
accounting 
statements.  We 
pronouncements, including both those which we have already 
adopted in full or in part, and those which we will adopt in the 
future,  at  Note  1,  “Significant  Accounting  Policies,”  to  the 
Consolidated Financial Statements in this Form 10-K. 

recently 

discuss 

issued 

Depressed  market  values  for  our  stock  and  adverse 
economic  conditions  sustained  over  a  period  of  time  may 
require us to write down all or some portion of our goodwill.
Goodwill is tested for impairment by comparing the fair 
value of a reporting unit to its carrying value. If the fair value 
is  greater  than  the  carrying  value,  then  the  reporting  unit’s 
goodwill is not impaired. The fair value of a reporting unit is 
impacted by the reporting unit's expected financial performance 
and  susceptibility  to  adverse  economic,  regulatory,  and 
legislative changes. The estimated fair values of the individual 
reporting units are assessed for reasonableness by reviewing a 
variety of indicators, including comparing these estimated fair 
values to our market capitalization over a reasonable period of 
time.  While  this  comparison  provides  some  relative  market 
information regarding the estimated fair value of the reporting 
units, it is not determinative and needs to be evaluated in the 
context  of  the  current  economic  environment.  However, 
significant and sustained declines in our market capitalization 
could be an indication of potential goodwill impairment. See 
the "Critical Accounting Policies" section of Item 7, MD&A, in 
this Form 10-K for additional information.

Risks Related to Our Common Stock

Our stock price can be volatile.

Our stock price can fluctuate widely in response to a variety 

of factors including, but not limited to:
variations in our quarterly results
• 
changes in market valuations of companies in the financial 
• 
services industry
governmental and regulatory legislation or actions
issuances of shares of common stock or other securities in 
the future
changes in dividends and capital returns

• 
• 

• 

• 
• 
• 

• 

• 

the addition or departure of key personnel
cyclical fluctuations
changes  in  financial  estimates  or  recommendations  by 
securities analysts regarding us or shares of our common 
stock
announcements by us or our competitors of new services 
or technology, acquisitions, or joint ventures
activity  by  short  sellers  and  changing  government 
restrictions on such activity

General  market  fluctuations,  industry  factors,  and  general 
economic and political conditions and events, such as cyber or 
terrorist  attacks,  economic  slowdowns  or  recessions,  interest 
rate changes, credit loss trends, or currency fluctuations, also 
could cause our stock price to decrease regardless of operating 
results. For the above and other reasons, the market price of our 
securities may not accurately reflect the underlying value of our 
securities, and you should consider this before relying on the 
market  prices  of  our  securities  when  making  an  investment 
decision.

We might not pay dividends on our stock.

Holders  of  our  stock  are  only  entitled  to  receive  such 
dividends that our Board declares out of funds legally available 
for such payments. Although we have historically declared cash 
dividends on our stock, we are not required to do so.

The  Federal  Reserve  has  indicated  that  increased  capital 
distributions generally would not be considered prudent in the 
absence of a well-developed capital plan and a capital position 
that would remain strong even under adverse conditions. As a 
result,  any  increase  in  our  dividend  requires  a  non-objection 
from the Federal Reserve.

Additionally, our obligations under the warrant agreements 
that we entered into with the U.S. Treasury as part of the CPP
will increase to the extent that we pay dividends on our common 
stock prior to December 31, 2018 exceeding $0.54 per share per 
quarter, which was the amount of dividends we paid when we 
first participated in the CPP. Specifically, the exercise price and 
the number of shares to be issued upon exercise of the warrants 
will  be  adjusted  proportionately  (that  is,  adversely  to  us)  as 
specified in a formula contained in the warrant agreements.

Our  ability  to  receive  dividends  from  our  subsidiaries  or 
other investments could affect our liquidity and ability to 
pay dividends.

We  are  a  separate  and  distinct  legal  entity  from  our 
subsidiaries, including the Bank. We receive substantially all of 
our  revenue  from  dividends  from  our  subsidiaries  and  other 
investments. These dividends are the principal source of funds 
to pay dividends on our common stock and interest and principal 
on our debt. Various federal and/or state laws and regulations 
limit the amount of dividends that our Bank and certain of our 
nonbank subsidiaries may pay us. Also, our right to participate 
in  a  distribution  of  assets  upon  a  subsidiary's  liquidation  or 
reorganization is subject to the prior claims of the subsidiary's 
creditors. Limitations on our ability to receive dividends from 
our  subsidiaries  could  have  a  material  adverse  effect  on  our 
liquidity and on our ability to pay dividends on our common 
stock.  Additionally,  if  our  subsidiaries'  earnings  are  not 

18

sufficient to make dividend payments to us while maintaining 
adequate capital levels, we may not be able to make dividend 
payments to our common shareholders.

Certain banking laws and certain provisions of our articles 
of incorporation may have an anti-takeover effect.

Provisions  of  federal  banking  laws,  including  regulatory 
approval requirements, could make it difficult for a third party 
to  acquire  us,  even  if  doing  so  would  be  perceived  to  be 
beneficial to our shareholders. Acquisition of 10% or more of 
any  class  of  voting  stock  of  a  bank  holding  company  or 
depository institution, including shares of our common stock, 
generally  creates  a  rebuttable  presumption  that  the  acquirer 
“controls” the bank holding company or depository institution, 
and thus, unless the acquirer is able to rebut this presumption, 
it would be subject to various laws and regulations that bank 

holding companies are subject to. Also, a bank holding company 
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 our bank.

There  also  are  provisions  in  our  amended  and  restated 
articles of incorporation and amended and restated bylaws, such 
as  limitations  on  the  ability  to  call  a  special  meeting  of  our 
shareholders,  that  may  be  used  to  delay  or  block  a  takeover 
attempt.  In  addition,  our  Board  will  be  authorized  under  our 
amended and restated articles of incorporation to issue shares 
of  our  preferred  stock  and  to  determine  the  rights,  terms, 
conditions,  and  privileges  of  such  preferred  stock,  without 
shareholder approval. These provisions may effectively inhibit 
a non-negotiated merger or other business combination.

19

Item 1B. 

UNRESOLVED STAFF COMMENTS

None.

Item 2. 

PROPERTIES

Our principal executive offices are located in SunTrust Plaza, 
Atlanta, Georgia. The 60-story office building is majority-owned 
by  SunTrust  Banks,  Inc.  At  December 31,  2017,  the  Bank 
operated 1,268 full-service banking offices, of which 560 were 
owned  and  the  remainder  were  leased.  Full-service  banking 

offices are located primarily in Florida, Georgia, Virginia, North 
Carolina, Tennessee, Maryland, South Carolina, and the District 
of  Columbia.  See  Note  8,  “Premises  and  Equipment,”  to  the 
Consolidated Financial Statements in Item 8 of this Form 10-K
for additional information regarding our properties.

Item 3. 

LEGAL PROCEEDINGS

The Company and its subsidiaries are parties to numerous claims 
and lawsuits arising in the normal course of its business activities, 
some of which involve claims for substantial amounts. Although 
the ultimate outcome of these suits cannot be ascertained at this 
time, it is the opinion of management that none of these matters, 
when  resolved,  will  have  a  material  effect  on  the  Company’s 

consolidated  results  of  operations,  cash  flows,  or  financial 
condition.  For  additional 
see  Note  19, 
“Contingencies,”  to  the  Consolidated  Financial  Statements  in 
Item 8 of this Form 10-K, which is incorporated by reference 
into this Item 3.

information, 

Item 4. 

MINE SAFETY DISCLOSURES

Not applicable.

20

PART II

Item 5.

MARKET FOR REGISTRANT'S COMMON EQUITY, RELATED STOCKHOLDER MATTERS AND 
ISSUER PURCHASES OF EQUITY SECURITIES

The principal market in which SunTrust common stock is traded 
is  the  NYSE  (symbol  “STI”). For  the quarterly  high and  low 
sales prices of SunTrust common stock for the last two years, 
see Table 30 in Item 7 of this Form 10-K, which is incorporated 
by reference into this Item 5. During the year ended December 
31, 2017, SunTrust paid a quarterly dividend on common stock 
of $0.26 per common share for the first and second quarters and 
$0.40  per  common  share  for  the  third  and  fourth  quarters, 
compared to a quarterly dividend on common stock of $0.24 per 
common share for the first and second quarters of 2016 and $0.26 
per  common  share  for  the  third  and  fourth  quarters  of  2016. 
SunTrust common stock was held by 21,731 holders of record 
at December 31, 2017. See the “Equity Securities” section of 
this Item 5 for information on share repurchase activity, publicly 
announced plans and programs, and the remaining repurchase 
authority under the announced plans and programs.

Please also refer to Item 1, “Business,” for a discussion of 
restrictions that may affect SunTrust's ability to pay dividends, 
Item 1A, “Risk Factors,” for a discussion of some risks related 
to SunTrust's dividends, and the “Capital Resources” section of 
Item 7 for a discussion of dividends paid during the year and 
factors that may affect future levels of dividends.

The information under the caption “Equity Compensation 
Plans” in the Company's definitive Proxy Statement to be filed 
with the SEC is incorporated by reference into this Item 5.

The following graph and table compare the cumulative total 
shareholder return on SunTrust common stock compared to the 
cumulative total return of the S&P 500 Index and the S&P 500 
Banks  Industry  Index  for 
the  five  years  commencing 
December 31, 2012 (at market close) and ending December 31, 
2017.  The  foregoing  analysis  assumes  simultaneous  initial 
investments  of  $100  and  the  reinvestment  of  all  dividends  in 
SunTrust common stock and in each of the above indices.

SunTrust
S&P 500 Index
S&P 500 Banks Industry Index

Cumulative Total Return for the Years Ended December 31

2012
$100.00
100.00
100.00

2013
$131.08
132.04
135.28

21

2014
$151.69
149.89
155.99

2015
$158.43
151.94
157.27

2016
$206.54
169.82
194.35

2017
$248.19
206.49
237.57

Equity Securities 

Issuer purchases of equity securities during the year ended December 31, 2017 are presented in the following table:

January 1 - 31
February 1 - 28
March 1 - 31 2
Total during first quarter of 2017

April 1 - 30
May 1 - 31
June 1 - 30
Total during second quarter of 2017

July 1 - 31
August 1 - 31
September 1 - 30

Total during third quarter of 2017

October 1 - 31
November 1 - 30
December 1 - 31
Total during fourth quarter of 2017

Total Number of
Shares Purchased
—
1,904,300
5,108,154
7,012,454

Average Price
Paid per Share
$—
  59.54
  58.85
  59.04

2,281,000
1,898,455
—
4,179,455

1,721,800
4,045,893
—

5,767,693

—
2,309,008
3,004,832
5,313,840

  57.17
  57.73
  —
  57.42

  57.14
  57.25
  —

  57.22

  —
  59.14
  64.37
  62.10

Common Stock 1

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

—
1,904,300
2,110,532
4,014,832

2,281,000
1,898,455
—
4,179,455

1,721,800
4,045,893
—

5,767,693

—
2,309,008
3,004,832
5,313,840

Total year-to-date 2017

22,273,442

$58.99

19,275,820

Approximate Dollar Value
of Equity that May Yet Be
Purchased Under the Plans
or Programs at Period End
(in millions)
$480
  367
  240
  240

  110
  —
  —
  —

  1,222
  990
  990

  990

  990
  853
  660
  660

$660

1 During the year ended December 31, 2017, no shares of SunTrust common stock were surrendered by participants in SunTrust's employee stock option plans, where 
participants may pay the exercise price upon exercise of SunTrust stock options by surrendering shares of SunTrust common stock that the participant already owns. 
SunTrust considers any such shares surrendered by participants in SunTrust's employee stock option plans to be repurchased pursuant to the authority and terms of 
the applicable stock option plan rather than pursuant to publicly announced share repurchase programs.
2 During March 2017, the Company repurchased $174 million of its outstanding common stock at market value under the 1% of Tier 1 capital de minimis exception 
allowed under the applicable 2016 Capital Plan Rule. This repurchase was incremental to and separate from the $960 million of authorized share repurchases under 
the Company's 2016 capital plan submitted in connection with the 2016 CCAR.

During the second quarter of 2017, the Company completed its 
authorized repurchases of common equity under the 2016 CCAR 
capital plan, which the Company initially announced on June 29, 
2016 and which effectively expired on June 30, 2017.

On June 28, 2017, the Company announced that the Federal 
Reserve had no objections to the repurchase of up to $1.32 billion 
of the Company's outstanding common stock to be completed 
between July 1, 2017 and June 30, 2018, as part of the Company's 
2017 capital plan submitted in connection with the 2017 CCAR. 
During the second half of 2017, the Company repurchased $660 
million of its outstanding common stock at market value as part 
of this publicly announced 2017 capital plan. At December 31, 
2017,  the  Company  had  $660  million  of  remaining  common 
stock repurchase capacity available under its 2017 capital plan 
(reflected in the table above).

At December 31, 2017, a total of 7.1 million Series A and 
B warrants to purchase the Company's common stock remained 
outstanding. The Series A and B warrants have expiration dates 
of December 2018 and November 2018, respectively.

The  Company  did  not  repurchase  any  of  its  Series  A 
Preferred  Stock  Depositary  Shares,  Series  B  Preferred  Stock, 
Series E Preferred Stock Depositary Shares, Series F Preferred 
Stock Depositary Shares, Series G Preferred Stock Depositary 
Shares, or Series H Preferred Stock Depositary Shares during 
the year ended December 31, 2017, and there was no unused 
Board authority to repurchase any shares of Series A Preferred 
Stock  Depositary  Shares,  Series  B  Preferred  Stock,  Series  E 
Preferred  Stock  Depositary  Shares,  Series  F  Preferred  Stock 
Depositary Shares, Series G Preferred Stock Depositary Shares, 
or the Series H Preferred Stock Depositary Shares. As previously 
announced,  the  Company  intends  to  redeem  all  outstanding 
Series E Preferred Stock Depositary Shares on March 15, 2018 
in  accordance  with  the  terms  of  the  Series  E  Preferred  Stock 
Depositary Shares. 

See  Note  13,  "Capital,"  to  the  Consolidated  Financial 
Statements in Item 8 of this Form 10-K for additional information 
regarding the Company's equity securities.

22

Item 6.    SELECTED FINANCIAL DATA

(Dollars in millions and shares in thousands, except per share data)
Summary of Operations:

Interest income
Interest expense
Net interest income
Provision for credit losses
Net interest income after provision for credit losses
Noninterest income
Noninterest expense 1
Income before provision for income taxes
Provision for income taxes 1
Net income attributable to noncontrolling interest
Net income
Net income available to common shareholders
Adjusted net income available to common shareholders 2
Net interest income-FTE 2
Total revenue
Total revenue-FTE 2
Total adjusted revenue-FTE 2
Net income per average common share:

Diluted
Adjusted diluted 2
Basic

Dividends declared per common share
Book value per common share
Tangible book value per common share 2
Market capitalization
Period End Balances:

Total assets
Earning assets
LHFI
ALLL
Consumer and commercial deposits
Long-term debt
Total shareholders’ equity
Selected Average Balances:

Total assets
Earning assets
LHFI
Intangible assets including residential MSRs
Residential MSRs
Consumer and commercial deposits
Long-term debt
Preferred stock
Total shareholders’ equity
Average common shares - diluted
Average common shares - basic

Financial Ratios:

Effective tax rate 1
ROA
ROE
ROTCE 2
Net interest margin
Net interest margin-FTE 2
Efficiency ratio 1
Efficiency ratio-FTE 1, 2
Tangible efficiency ratio-FTE 1, 2
Adjusted tangible efficiency ratio-FTE 1, 2
Total average shareholders’ equity to total average assets
Tangible common equity to tangible assets 2
Common dividend payout ratio

2017

$6,387
754
5,633
409
5,224
3,354
5,764
2,814
532
9
$2,273
$2,179
$2,179
$5,778
8,987
9,132
9,132

$4.47
4.47
4.53
1.32
47.94
34.82
30,417

$205,962
182,710
143,181
1,735
159,795
9,785
25,154

$204,931
184,212
144,216
8,034
1,615
159,549
11,065
1,792
24,301
486,954
481,339

Year Ended December 31
2015

2016

2014

$5,778
557
5,221
444
4,777
3,383
5,468
2,692
805
9
$1,878
$1,811
$1,811
$5,359
8,604
8,742
8,742

$3.60
3.60
3.63
1.00
45.38
32.95
26,942

$204,875
184,610
143,298
1,709
158,864
11,748
23,618

$199,004
178,825
141,118
7,545
1,190
154,189
10,767
1,225
24,068
503,466
498,638

$5,265
501
4,764
165
4,599
3,268
5,160
2,707
764
10
$1,933
$1,863
$1,863
$4,906
8,032
8,174
8,174

$3.58
3.58
3.62
0.92
43.45
31.45
21,793

$190,817
172,114
136,442
1,752
148,921
8,462
23,437

$188,892
168,813
133,558
7,604
1,250
144,202
10,873
1,225
23,346
520,586
514,844

$5,384
544
4,840
342
4,498
3,323
5,543
2,278
493
11
$1,774
$1,722
$1,729
$4,982
8,163
8,305
8,200

$3.23
3.24
3.26
0.70
41.32
29.62
21,978

$190,328
168,678
133,112
1,937
139,234
13,022
23,005

$182,176
162,189
130,874
7,630
1,255
132,012
12,359
800
22,170
533,391
527,500

2013

$5,388
535
4,853
553
4,300
3,214
5,831
1,683
322
17
$1,344
$1,297
$1,476
$4,980
8,067
8,194
8,257

$2.41
2.74
2.43
0.35
38.39
26.79
19,734

$175,335
156,856
127,877
2,044
127,735
10,700
21,422

$172,497
153,728
122,657
7,535
1,121
127,076
9,872
725
21,167
539,093
534,283

19%

30%

28%

22%

19%

1.11
9.72
13.39
3.06
3.14
64.14
63.12
62.30
61.04
11.86
8.21
29.1

0.94
7.97
10.91
2.92
3.00
63.55
62.55
61.99
61.99
12.09
8.15
27.5

1.02
8.46
11.75
2.82
2.91
64.24
63.13
62.64
62.64
12.36
8.67
25.5

0.97
8.10
11.49
2.98
3.07
67.90
66.74
66.44
63.34
12.17
8.44
21.5

0.78
6.38
9.37
3.16
3.24
72.28
71.16
70.89
65.27
12.27
8.50
14.5

23

 
Item 6.    SELECTED FINANCIAL DATA (continued)

Capital Ratios at period end 3: 

CET1 (Basel III)
CET1 - fully phased-in (Basel III) 2
Tier 1 common equity (Basel I)
Tier 1 capital
Total capital
Leverage

2017

9.74%
9.59

N/A

11.15
13.09
9.80

Year Ended December 31
2015

2016

2014

9.59%
9.43

N/A

10.28
12.26
9.22

9.96%
9.80

N/A

10.80
12.54
9.69

N/A
N/A
9.60%
10.80
12.51
9.64

2013

N/A
N/A
9.82%
10.81
12.81
9.58

1 Amortization expense related to qualified affordable housing investment costs is recognized in Provision for income taxes for all periods presented as allowed by 
an accounting standard adopted in 2014. Prior to 2014, these amounts were recognized in Other noninterest expense and have been reclassified for comparability 
as presented. See Table 30 in the MD&A (Item 7) for additional information.
2 See Table 30 in the MD&A (Item 7) for a reconcilement of non-U.S. GAAP measures and additional information.
3 Basel III Final Rules became effective for the Company on January 1, 2015; thus, Basel III CET1 ratios are not applicable ("N/A") in periods ending prior to January 
1, 2015 and Basel I Tier 1 common equity ratio is N/A in periods ending after January 1, 2015. Tier 1 capital, Total capital, and Leverage ratios for periods ended 
prior to January 1, 2015 were calculated under Basel I. The CET1 ratio on a fully phased-in basis at December 31, 2017, 2016, and 2015 is estimated.

24

Item 7.

MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF 
OPERATION

Important Cautionary Statement About Forward-Looking Statements

This  report  contains  forward-looking  statements.  Statements 
regarding:  (i) future levels of capital markets related income, 
commercial  real  estate  related  income,  interest  income,  net 
interest margin, core personnel and other expenses, efficiency, 
the net charge-off ratio, the provision for loan losses, net charge-
offs, capital returns, rates paid on deposits, investments in talent 
and technology, our capital ratios, and share repurchases; (ii) the 
future effects of the 2017 Tax Act and tax reform; (iii) the future 
profitability of our Consumer segment; (iv) the asset sensitivity 
of our balance sheet and our exposure to interest rate risk in future 
periods; (v) the future growth in our Wholesale segment; (vi) the 
future  effective  tax  rate;  (vii)  future  changes  in  the  size  and 
composition  of  the  securities AFS  portfolio;  (viii)  the  future 
effect of the redemption of our Series E Preferred Stock on our 
capital ratios; (ix) future impacts of ASUs not yet adopted; (x) 
future impacts of liabilities arising from legal claims; and (xi) 
future  credit  ratings  and  outlook,  are  forward-looking 
statements. Also, any statement that does not describe historical 
or current facts is a forward-looking statement. These statements 
often  include  the  words  “believe,”  “expect,”  “anticipate,” 
“estimate,” “intend,” “target,” “forecast,” “future,” “strategy,” 
“goal,”  “initiative,”  “plan,”  “opportunity,”  “potentially,” 
“probably,” “project,” “outlook,” or similar expressions or future 
conditional verbs such as “may,” “will,” “should,” “would,” and 
“could.” Such statements are based upon the current beliefs and 
expectations  of  management  and  on  information  currently 
available to management. They speak as of the date hereof, and 
we do not assume any obligation to update the statements made 
herein or to update the reasons why actual results could differ 
from  those  contained  in  such  statements  in  light  of  new 
information or future events.

Forward-looking statements are subject to significant risks 
and uncertainties. Investors are cautioned against placing undue 
reliance on such statements. Actual results may differ materially 
from those set forth in the forward-looking statements. Factors 
that  could  cause  actual  results  to  differ  materially  from  those 
described in the forward-looking statements can be found in Part 
I, Item 1A., "Risk Factors" in this Form 10-K and also include 
risks discussed in this report and in other periodic reports that 
we file with the SEC. Additional factors include:  current and 
future legislation and regulation could require us to change our 
business practices, reduce revenue, impose additional costs, or 
otherwise 
or 
competitiveness; we are subject to stringent capital adequacy and 
liquidity  requirements  and  our  failure  to  meet  these  would 
adversely affect our financial condition; the monetary and fiscal 
policies of the federal government and its agencies could have 
a material adverse effect on our earnings; our financial results 
have been, and may continue to be, materially affected by general 
economic conditions, and a deterioration of economic conditions 
or of the financial markets may materially adversely affect our 
lending  and  other  businesses  and  our  financial  results  and 
condition;  changes  in  market  interest  rates  or  capital  markets 
could adversely affect our revenue and expenses, the value of 
assets and obligations, and the availability and cost of capital 

operations 

adversely 

business 

affect 

and  liquidity;  interest  rates  on  our  outstanding  financial 
instruments  might  be  subject  to  change  based  on  regulatory 
developments,  which  could  adversely  affect  our  revenue, 
expenses,  and  the  value  of  those  financial  instruments;  our 
earnings may be affected by volatility in mortgage production 
and servicing revenues, and by changes in carrying values of our 
servicing assets and mortgages held for sale due to changes in 
interest rates; disruptions in our ability to access global capital 
markets may adversely affect our capital resources and liquidity; 
we are subject to credit risk; we may have more credit risk and 
higher credit losses to the extent that our loans are concentrated 
by loan type, industry segment, borrower type, or location of the 
borrower or collateral; we rely on the mortgage secondary market 
and GSEs for some of our liquidity; loss of customer deposits 
could  increase  our  funding  costs;  any  reduction  in  our  credit 
rating could increase the cost of our funding from the capital 
markets; we are subject to litigation, and our expenses related to 
this  litigation  may  adversely  affect  our  results;  we  may  incur 
fines, penalties and other negative consequences from regulatory 
violations, possibly even inadvertent or unintentional violations; 
we are subject to certain risks related to originating and selling 
mortgages, and may be required to repurchase mortgage loans 
or indemnify mortgage loan purchasers as a result of breaches 
of representations and warranties, or borrower fraud, and this 
could  harm  our  liquidity,  results  of  operations,  and  financial 
condition; we face risks as a servicer of loans; consumers and 
small businesses may decide not to use banks to complete their 
financial transactions, which could affect net income; we have 
businesses other than banking which subject us to a variety of 
risks; negative public opinion could damage our reputation and 
adversely  impact  business  and  revenues;  we  may  face  more 
intense  scrutiny  of  our  sales, 
incentive 
compensation practices; we rely on other companies to provide 
key components of our business infrastructure; competition in 
the  financial  services  industry  is  intense  and  we  could  lose 
business or suffer margin declines as a result; we continually 
encounter  technological  change  and  must  effectively  develop 
and  implement  new  technology;  maintaining  or  increasing 
market  share  depends  on  market  acceptance  and  regulatory 
approval of new products and services; we have in the past and 
may in the future pursue acquisitions, which could affect costs 
and  from  which  we  may  not  be  able  to  realize  anticipated 
benefits; we depend on the expertise of key personnel, and if 
these individuals leave or change their roles without effective 
replacements, operations may suffer; we may not be able to hire 
or  retain  additional  qualified  personnel  and  recruiting  and 
compensation costs may increase as a result of turnover, both of 
which  may  increase  costs  and  reduce  profitability  and  may 
adversely  impact  our  ability  to  implement  our  business 
strategies;  our  framework  for  managing  risks  may  not  be 
effective  in  mitigating  risk  and  loss  to  us;  our  controls  and 
procedures may not prevent or detect all errors or acts of fraud; 
we are at risk of increased losses from fraud; our operational and 
communications systems and infrastructure may fail or may be 
the subject of a breach or cyber-attack that, if successful, could 

training,  and 

25

management  services.  We  operate  two  business  segments: 
Consumer and Wholesale, with functional activities included in 
Corporate Other. See Note 20, "Business Segment Reporting," 
to the Consolidated Financial Statements in this Form 10-K for 
a  description  of  our  business  segments  and  related  business 
segment  structure  realignment  from  three  segments  to  two 
segments in the second quarter of 2017.

This MD&A is intended to assist readers in their analysis of 
the  accompanying  Consolidated  Financial  Statements  and 
supplemental  financial  information.  It  should  be  read  in 
conjunction  with  the  Consolidated  Financial  Statements  and 
Notes to the Consolidated Financial Statements in Item 8 of this 
Form  10-K,  as  well  as  other  information  contained  in  this 
document. When we refer to “SunTrust,” “the Company,” “we,” 
“our,” and “us” in this narrative, we mean SunTrust Banks, Inc. 
and its consolidated subsidiaries. 

In the MD&A, consistent with SEC guidance in Industry 
Guide 3 that contemplates the calculation of tax exempt income 
on a tax equivalent basis, we present net interest income, net 
interest margin, total revenue, and efficiency ratios on an FTE 
basis. The  FTE  basis  adjusts  for  the  tax-favored  status  of  net 
interest  income  from  certain  loans  and  investments  using  a 
federal tax rate of 35% and state income taxes, where applicable, 
to increase tax-exempt interest income to a taxable-equivalent 
basis.  We  believe  this  measure  to  be  the  preferred  industry 
measurement  of  net  interest  income  and  that  it  enhances 
comparability of net interest income arising from taxable and 
tax-exempt  sources. Additionally,  we  present  other  non-U.S. 
in  understanding 
GAAP  metrics 
management’s view of particular financial measures, as well as 
to align presentation of these financial measures with peers in 
the  industry  who  may  also  provide  a  similar  presentation. 
Reconcilements for all non-U.S. GAAP measures are provided 
in Table 30.

to  assist 

investors 

adversely affect our business and disrupt business continuity; a 
disruption,  breach,  or  failure  in  the  operational  systems  and 
infrastructure  of  our  third  party  vendors  and  other  service 
providers, including as a result of cyber-attacks, could adversely 
affect  our  business;  natural  disasters  and  other  catastrophic 
events could have a material adverse impact on our operations 
or  our  financial  condition  and  results;  the  soundness  of  other 
financial institutions could adversely affect us; we depend on the 
accuracy  and  completeness  of  information  about  clients  and 
counterparties; our accounting policies and processes are critical 
to how we report our financial condition and results of operation, 
and they require management to make estimates about matters 
that are uncertain; depressed market values for  our stock and 
adverse economic conditions sustained over a period of time may 
require us to write down all or some portion of our goodwill; our 
stock price can be volatile; we might not pay dividends on our 
stock; our ability to receive dividends from our subsidiaries or 
other investments could affect our liquidity and ability to pay 
dividends; and certain banking laws and certain provisions of 
our articles of incorporation may have an anti-takeover effect.

INTRODUCTION

located 

We  are  a  leading  provider  of  financial  services,  with  our 
in  Atlanta,  Georgia.  Our  principal 
headquarters 
subsidiary, SunTrust Bank, offers a full line of financial services 
for consumers, businesses, corporations, institutions, and not-
for-profit entities, both through its branches (located primarily 
in  Florida,  Georgia,  Virginia,  North  Carolina,  Tennessee, 
Maryland,  South  Carolina,  and  the  District  of  Columbia)  and 
through other national delivery channels. In addition to deposit, 
credit, and trust and investment services offered by the Bank, 
our  other  subsidiaries  provide  capital  markets,  mortgage 
banking, securities brokerage, investment banking, and wealth 

26

EXECUTIVE OVERVIEW

Financial Performance
We delivered another year of strong financial performance in 
2017,  marking  the  sixth  consecutive  year  of  higher  EPS, 
improved  efficiency,  and  increased  capital  returns  for  our 
shareholders. We enjoyed solid revenue growth across both of 
our business segments, led by growth in net interest income as 
well  as  a  significant  year-over-year  increase  in  noninterest 
income for our Wholesale segment. While we benefited from a 
favorable operating environment in 2017, a key driver of our 
performance was our improved executional abilities, as we are 

meeting more client needs and demonstrating solid discipline on 
expenses and returns. Diluted EPS for 2017 was $4.47, up 24% 
relative to 2016. EPS included $0.39 per share in net benefits 
associated  with  Form  8-K  and  tax  reform-related  items
recognized  during  the  fourth  quarter  of  2017,  summarized  in 
Table 1 below. These items included actions we announced in 
our December 4, 2017 Form 8-K as well as the impact of the 
2017 Tax Act,  including  actions  we  took  as  a  result  to  better 
position the Company for improved long-term success.

2017 Financial Highlights: 
•  EPS, efficiency, and capital returns for our shareholders improved for the sixth consecutive year
  Total revenue and net interest income both improved for the third consecutive year
  We generated record investment banking income for the 10th consecutive year—up 21% compared to 2016
  We achieved our 2017 tangible efficiency goal of between 61% and 62%, as reflected in our adjusted tangible efficiency 
ratio* of 61.0% for 2017
  Our strong capital position enabled us to increase our capital returns (which includes dividends and repurchases of common 
stock)—up 47% compared to 2016; we repurchased more than $1.3 billion of our outstanding common stock, resulting in 
a 4% decline in common shares outstanding compared to the prior year, and we increased our quarterly common stock 
dividend by 54%

•  We maintained strong capital ratios that continue to be well above regulatory requirements, with our CET1 and estimated, fully 

phased-in CET1* ratios at 9.74% and 9.59%, respectively, as of December 31, 2017

•  Book value per share was $47.94, and tangible book value per share* was $34.82, both up 6% from the prior year
•  Our LCR was above the regulatory requirement of 100%
•  Average LHFI increased 2% and average consumer and commercial deposits increased 3%, compared to the prior year
•  Our asset quality remained very strong, evidenced by our 0.25% net charge-off ratio, 0.47% NPL ratio, and 1.21% ALLL to period-

end LHFI ratio 

* : See Table 30 in this MD&A for a reconcilement of non-U.S. GAAP measures and additional information

Form 8-K and Tax Reform-related Items Impacting 4th Quarter and Full Year 2017 Results

Table 1

(Dollars in millions)
Form 8-K items previously announced on December 4, 2017:

Gain on sale of Premium Assignment Corporation ("PAC") subsidiary

Net charge related to efficiency actions

Tax impact of above items (tax expense)
SunTrust Mortgage ("STM") state NOL valuation allowance adjustment (tax expense)

Net benefit of Form 8-K items (after-tax)

Tax reform-related items:

Charitable contribution to support financial well-being initiatives
Discretionary 401(k) contribution and other employee benefits
Securities available for sale ("securities AFS") portfolio restructuring losses
Loss arising from anticipated sale of servicing rights
Tax impact of above items (tax benefit)
Revaluation of net deferred tax liability and other discrete tax items (tax benefit)

Net benefit of tax reform-related items (after-tax)

Net benefit of Form 8-K and tax reform-related items (after-tax)

Impacted Line Item in the
Consolidated Statements of Income

Gain on sale of subsidiary
Other staff expense;
Other noninterest expense
Provision for income taxes
Provision for income taxes

Marketing and customer development
Employee compensation and benefits
Net securities (losses)/gains
Mortgage servicing related income
Provision for income taxes
Provision for income taxes

1

1

2

1

$107

(36)

(29)
(27)
$16

($50)
(25)
(109)
(5)
70
291
$172

$188

1 Amounts are calculated using a federal statutory rate of 35% and are adjusted for permanent items, if applicable.
2 Amount does not foot as presented due to rounding.

Total revenue for 2017 increased 4% compared to 2016 driven 
largely  by  higher  net  interest  income  and  strong  investment 
banking and commercial real estate related income. Net interest 
income increased 8% relative to 2016 due to net interest margin 

expansion and growth in average earning assets, partially offset 
by an increase in average interest-bearing liabilities. Noninterest 
income decreased 1% compared to 2016, driven primarily by 
lower  mortgage  production  related  income,  offset  largely  by 

27

higher investment banking and commercial real estate related 
income. Looking to the first quarter of 2018, we expect capital 
markets-related income to rebound and commercial real estate 
related income to decline from a seasonally strong fourth quarter 
of 2017 level. 

Our net interest margin increased 14 basis points compared 
to 2016, driven primarily by higher earning asset yields arising 
from higher benchmark interest rates, continued favorable mix 
shift in earning assets, and lower premium amortization, offset 
partially by higher funding costs. Looking to the first quarter of 
2018, we expect net interest margin to increase up to two basis 
points compared to the fourth quarter of 2017 as the benefit of 
the December Fed Funds rate increase is mostly offset by the 
change in our FTE calculation as a result of the 2017 Tax Act. 
Beyond that, we anticipate that net interest margin trends will 
depend on the interest rate environment; however, we do expect 
some  net  interest  margin  expansion  in  2018  if  interest  rates 
continue to rise. 

During the fourth quarter of 2017, we sold and subsequently 
reinvested  approximately  $3  billion  of  securities AFS  with  a 
similar mix and higher yields (primarily within U.S. Treasury 
securities and agency residential MBS), which we expect will 
increase annual interest income by approximately $20 million 
beginning in 2018, all else being equal. See additional discussion 
related to revenue, noninterest income, and net interest income 
and  margin  in  the  "Noninterest  Income"  and  "Net  Interest 
Income/Margin" sections of this MD&A. Also in this MD&A, 
see  Table  21,  "Net  Interest  Income Asset  Sensitivity,"  for  an 
analysis  of  potential  changes  in  net  interest  income  due  to 
instantaneous moves in benchmark interest rates.

Noninterest expense increased 5% compared to 2016. The 
increase was driven largely by higher personnel expenses and 
higher net occupancy expenses, offset partially by the favorable 
resolution  of  several  legal  matters  during  the  third  quarter  of 
2017. Additionally, noninterest expense for 2017 was negatively 
impacted by $111 million of net Form 8-K and tax reform-related 
items recognized during the fourth quarter of 2017, comprised 
of a $50 million charitable contribution to support financial well-
being initiatives, a $36 million net charge related to efficiency 
actions, and $25 million of discretionary 401(k) contributions 
and other employee benefits. Looking to the first quarter of 2018, 
we  expect  core  personnel  expenses—excluding  the  fourth 
quarter of 2017 tax reform-related personnel expenses of $25 
million—to  increase  by  approximately  $75  million  from  the 
fourth quarter of 2017 due to the typical seasonal increase in 
401(k) and FICA expenses. Though our expense base has and 
will vary from quarter to quarter, we remain focused on managing 
our  expenses  to  provide  funding  for  investments  in  talent, 
technology,  and  improved  product  offerings.  See  additional 
discussion  related  to  noninterest  expense  in  the  "Noninterest 
Expense" section of this MD&A.

For 2017, our efficiency and tangible efficiency ratios were 
63.1% and 62.3%, compared to the prior year ratios of 62.6% 
and 62.0%, respectively. Our current year efficiency ratios were 
negatively  impacted  by  the  Form  8-K  and  tax  reform-related 
items  recognized  during  the  fourth  quarter  of  2017;  when 
excluding  the  impact  of  these  items,  our  adjusted  tangible 
efficiency ratio improved to 61.0% for 2017, compared to 62.0% 
for 2016. Looking to 2018, there will be headwinds to efficiency 
arising from tax reform, attributable to both FTE adjustments, 

28

and the corresponding actions we have taken to invest in our 
people. Despite this, we are confident in our ability to improve 
efficiency in 2018, due to our heightened expense discipline, the 
actions we took in the last two quarters of 2017, and a positive 
economic  and  revenue  outlook.  See  Table  30,  "Selected 
Financial  Data  and  Reconcilement  of  Non-U.S.  GAAP 
Measures," in this MD&A for additional information regarding, 
and  reconciliations  of,  our  tangible  and  adjusted  tangible 
efficiency ratios.

Overall  asset  quality  remained  very  strong  during  2017, 
evidenced  by  our  0.25%  net  charge-off  ratio  and  0.47%  NPL 
ratio. These low levels reflect the relative strength across our 
LHFI  portfolio,  though  we  recognize  that  there  could  be 
variability moving forward and that credit losses will eventually 
normalize. Overall, we expect to operate within a net charge-off 
ratio of between 25 and 35 basis points in 2018. We also forecast 
a  provision  for  loan  losses  that  generally  approximates  net 
charge-offs.  See  additional  discussion  of  our  credit  and  asset 
quality,  in  the  “Loans,”  “Allowance  for  Credit  Losses,”  and 
“Nonperforming Assets” sections of this MD&A.

Average LHFI increased 2% compared to 2016, driven by 
growth across most consumer loan portfolios and in commercial 
construction  loans.  These  increases  were  offset  partially  by 
declines in average residential home equity products and CRE 
loans. Our consumer lending initiatives continue to produce solid 
loan growth through each of our major channels, while furthering 
the positive mix shift within the LHFI portfolio and improving 
our  return  profile.  Looking  ahead,  we  continue  to  have  good 
dialogue with our clients and we believe that tax reform should 
be a catalyst for increased investment and growth. Further, we 
are well positioned to meet our clients' needs, whether through 
lending, capital markets, or other solutions. See additional loan 
discussions in the “Loans,” “Nonperforming Assets,” and "Net 
Interest Income/Margin" sections of this MD&A.

Average consumer and commercial deposits increased 3%
compared to 2016, driven by growth across both of our business 
segments and across most of our product categories, particularly 
NOW accounts and time deposits. Rates paid on our interest-
bearing consumer and commercial deposits increased 12 basis 
points compared to 2016 in response to rising benchmark interest 
rates. The strong deposit growth we have produced over the past 
several  years,  in  addition  to  our  access  to  low-cost  funding, 
enables  us  to  prudently  manage  our  funding  base  and  more 
effectively manage our deposit costs. Looking forward to 2018, 
we continue to be focused on maximizing the value proposition 
of deposits for our clients, outside of the rate paid, by meeting 
more of our clients' needs through strategic investments in talent 
and  technology.  See  additional  discussion  regarding  average 
deposits  in  the  "Net  Interest  Income/Margin"  and  "Deposits" 
sections of this MD&A.

regulatory  capital 

increased  compared 

Capital and Liquidity
Our 
to 
ratios 
December 31, 2016, with a CET1 ratio of 9.74% at December 31, 
2017,  driven  primarily  by  growth  in  retained  earnings. 
Additionally, our CET1 ratio, on a fully phased-in basis, was 
estimated to be 9.59% at December 31, 2017, which is well above 
the regulatory requirement. Our book value and tangible book 
value  per  common  share  both  increased  6%  compared  to 

December 31,  2016,  due  primarily  to  earnings  growth.  See 
additional details related to our capital in Note 13, "Capital," to 
the Consolidated Financial Statements in this Form 10-K. Also 
see Table  30,  "Selected  Financial  Data  and  Reconcilement of 
Non-U.S.  GAAP  Measures,"  in  this  MD&A  for  additional 
information  regarding,  and  reconciliations  of,  tangible  book 
value per common share and our fully phased-in CET1 ratio.

During the year, we increased our quarterly common stock 
dividend by 54%, beginning in the third quarter of 2017, which 
resulted in dividends for 2017 of $1.32 per common share, an 
increase  from  $1.00  per  common  share  in  2016.  We  also 
repurchased  $1.3  billion  of  our  outstanding  common  stock 
during the year, which included $480 million under our 2016 
capital plan, an incremental $174 million pursuant to the 1% of 
Tier 1 capital de minimis exception allowed under the applicable 
2016 Capital Plan Rule, and $660 million in conjunction with 
the 2017 capital plan. Additionally, as previously announced, we 
intend  to  use  proceeds  from  our  November  2017  Series  H 
Preferred  Stock  issuance  to  redeem  all  outstanding  Series  E 
Preferred  Stock  depositary  shares  on  March  15,  2018.  The 
redemption  of  Series  E  Preferred  Stock  depositary  shares  is 
expected to reduce our Tier 1 capital and Total capital ratios by 
approximately 25 basis points, all else being equal. Given our 
strong  capital  position  combined  with  our  improved  earnings 
trajectory, we should have capacity to increase capital returns to 
our owners, the specifics of which will depend upon our rigorous 
capital  planning  process.  See  additional  details  related  to  our 
capital actions and share repurchases in the “Capital Resources” 
section of this MD&A and in Part II, Item 5 of this Form 10-K.

Business Segments Highlights

Consumer
Consumer  continues  to  deliver  healthy  overall  business  and 
revenue momentum. Net interest income increased $233 million, 
or 7%, compared to 2016, resulting from strong loan and deposit 
growth and continued balance sheet optimization. The average 
balance of our LHFI portfolio increased 5% compared to 2016. 
Deposit  growth  continues  to  be  a  key  contributor  to  our  net 
interest income momentum, with average balances up 3% year-
over-year. Noninterest income decreased 8% compared to the 
same period in 2016, due primarily to lower mortgage-related 
income, as a result of lower production volume due to decreased 

refinancing activity. Noninterest expense was relatively stable
compared  to  prior  year  as  a  result  of  our  continued  expense 
management efforts. Overall, we took significant actions in 2017 
to  improve  the  efficiency  and  effectiveness  of  the  Consumer
segment, as evidenced by continued growth in digital channels 
and a 7% year-over-year reduction in our branches. Additionally, 
we have seen positive momentum in our wealth management 
business  as  total  managed  assets  increased  11%  compared  to 
2016. Our solid loan and deposit growth, as well as our continued 
investments in an improved client experience, are expected to 
improve profitability in 2018.

Wholesale 
Wholesale delivered record revenue and net income during 2017 
due to favorable capital market conditions and continued success 
in meeting client needs. Total revenue increased $589 million 
compared  to  2016  due  primarily  to  increases  in  net  interest 
income,  investment  banking  income,  commercial  real  estate 
related income, and a $107 million gain on the sale of PAC. Net 
interest  income  was  a  key  contributor  to  our  strong  revenue 
growth,  up  11%  compared  to  2016  as  a  result  of  higher  loan 
yields.  Investment  banking  income  continues  to  be  a  growth 
driver for us as we continue to have strategic success with new 
and existing Wholesale clients. Noninterest expense increased 
12% compared to the prior year. The year-over-year increase was 
driven  by  higher  compensation  due  to  improved  business 
performance, incremental costs relating to Pillar, and ongoing 
investments  in  technology.  During  2017,  we  also  expanded 
Commercial & Business Banking into new markets in Ohio and 
Texas,  which  allowed  us  to  further  expand  our  differentiated 
value  proposition  to  new  clients.  Overall,  while  market 
conditions  can  drive  quarterly  variability,  our  differentiated 
business model and proven executional abilities in Wholesale
continue to deliver strong results and we expect to see further 
growth in 2018.

Additional information related to our business segments can be 
found  in  Note  20,  "Business  Segment  Reporting,"  to  the 
Consolidated  Financial  Statements  in  this  Form  10-K,  and 
further discussion of our business segment results for the year 
ended  December 31,  2017  and  2016  can  be  found  in  the 
"Business Segment Results" section of this MD&A.

29

Consolidated Daily Average Balances, Income/Expense, and Average Yields Earned/Rates Paid

Table 2

(Dollars in millions)

ASSETS
LHFI: 1
C&I
CRE
Commercial construction
Residential mortgages - guaranteed
Residential mortgages - nonguaranteed
Residential home equity products
Residential construction
Consumer student - guaranteed
Consumer other direct
Consumer indirect
Consumer credit cards
Nonaccrual 2
Total LHFI
Securities AFS:

Taxable
Tax-exempt

Total securities AFS

Fed funds sold and securities borrowed or purchased

under agreements to resell

LHFS
Interest-bearing deposits in other banks
Interest earning trading assets
Total earning assets

ALLL
Cash and due from banks
Other assets
Noninterest earning trading assets and derivative

instruments

Unrealized gains on securities available for sale, net

Total assets

LIABILITIES AND SHAREHOLDERS' EQUITY
Interest-bearing deposits:

NOW accounts
Money market accounts
Savings
Consumer time
Other time

Total interest-bearing consumer and commercial

deposits

Brokered time deposits
Foreign deposits

Total interest-bearing deposits

Funds purchased
Securities sold under agreements to repurchase
Interest-bearing trading liabilities
Other short-term borrowings
Long-term debt

Total interest-bearing liabilities

Noninterest-bearing deposits
Other liabilities
Noninterest-bearing trading liabilities and derivative

instruments

Shareholders’ equity

Total liabilities and shareholders’ equity

Average
Balances

2017
Income/
Expense

Yields/
Rates

Average
Balances

2016
Income/
Expense

Yields/
Rates

Average
Balances

2015
Income/
Expense

Yields/
Rates

$2,286
177
148
16
1,003
470
15
286
406
401
145
32
5,385

761
13
774

9

99
—
120
6,387

$131
157
1
42
57
388

12
4
404
13
15
26
8
288
754

$68,423
5,158
4,011
539
26,392
10,969
346
6,464
8,239
11,492
1,429
754
144,216

30,688
433
31,121

1,215

2,483
25
5,152
184,212
(1,735)
5,123
16,376

903

52
$204,931

$45,009
53,592
6,519
5,626
5,148
115,894

941
421
117,256
1,217
1,558
968
1,591
11,065
133,655
43,655
2,936

384

24,301
$204,931

$2,148
169
94
20
964
484
17
224
313
365
120
21
4,939

645
6
651

1

92
—
95
5,778

$55
107
2
43
39
246

12
1
259
4
7
24
3
260
557

3.34% $68,406
3.43
5,808
3.70
2,898
2.92
575
3.80
25,554
4.28
12,297
4.26
377
4.42
5,551
4.93
6,871
3.49
10,712
10.12
1,188
4.28
881
3.73
141,118

2.48
2.99
2.49

0.69

4.00
1.20
2.33
3.47

28,216
189
28,405

1,241

2,570
24
5,467
178,825
(1,746)
4,999
14,880

1,388

658
$199,004

0.29% $40,949
0.29
53,795
0.02
6,285
0.75
5,852
1.10
3,908
0.34
110,789

1.29
0.86
0.34
1.02
0.92
2.70
0.50
2.60
0.56

926
123
111,838
1,055
1,734
1,025
1,452
10,767
127,871
43,400
3,252

413

24,068
$199,004

3.14% $65,786
6,178
2.92
1,603
3.25
636
3.45
23,759
3.77
13,535
3.94
384
4.39
4,584
4.03
5,344
4.56
10,262
3.40
944
10.10
543
2.43
133,558
3.50

2.29
3.37
2.29

0.10

3.60
0.40
1.73
3.23

26,327
176
26,503

1,147

2,348
22
5,235
168,813
(1,835)
5,614
14,527

1,265

508
$188,892

0.13% $35,161
50,518
0.20
6,165
0.03
6,443
0.73
3,813
1.00
102,100
0.22

1.33
0.42
0.23
0.37
0.42
2.29
0.23
2.42
0.44

888
218
103,206
822
1,821
881
2,135
10,873
119,738
42,102
3,276

430

23,346
$188,892

$1,974
173
50
24
913
501
19
173
230
333
94
22
4,506

587
6
593

—

82
—
84
5,265

$31
85
2
49
39
206

13
—
219
1
4
22
3
252
501

3.00%
2.80
3.12
3.77
3.84
3.70
4.85
3.78
4.30
3.24
10.00
4.13
3.37

2.23
3.70
2.24

—

3.47
0.12
1.62
3.12

0.09%
0.17
0.03
0.77
1.02
0.20

1.41
0.13
0.21
0.11
0.21
2.44
0.16
2.32
0.42

Interest rate spread
Net interest income 3
Net interest income-FTE 3, 4
Net interest margin 5
Net interest margin-FTE 4, 5
1 Interest income includes loan fees of $177 million, $165 million, and $189 million for the years ended December 31, 2017, 2016, and 2015, respectively.
2 Income on consumer nonaccrual loans, if recognized, is recognized on a cash basis.
3 Derivative instruments employed to manage our interest rate sensitivity increased Net interest income by $104 million, $261 million, and $300 million for the years ended December 31, 

3.06%
3.14

$5,221
$5,359

$4,764
$4,906

$5,633
$5,778

2.92%
3.00

2.82%
2.91

2.91%

2.79%

2.70%

2017, 2016, and 2015, respectively. 

4 See Table 30, "Selected Financial Data and Reconcilement of Non-U.S. GAAP Measures," in this MD&A for additional information and reconciliations of non-U.S. GAAP performance 

measures. Approximately 95% of the total FTE adjustment for the years ended December 31, 2017, 2016, and 2015 was attributed to C&I loans.

5 Net interest margin is calculated by dividing annualized Net interest income by average Total earning assets.

30

 
Analysis of Changes in Net Interest Income 1

Table 3

(Dollars in millions)
Increase/(Decrease) in Interest Income:

LHFI:
C&I
CRE
Commercial construction
Residential mortgages - guaranteed
Residential mortgages - nonguaranteed
Residential home equity products
Residential construction
Consumer student - guaranteed
Consumer other direct
Consumer indirect
Consumer credit cards
Nonaccrual
Securities AFS:

Taxable
Tax-exempt

Fed funds sold and securities borrowed or purchased

under agreements to resell

LHFS
Interest earning trading assets

Total increase in interest income

Increase/(Decrease) in Interest Expense:

NOW accounts
Money market accounts
Savings
Consumer time
Other time
Brokered time deposits
Foreign deposits
Funds purchased
Securities sold under agreements to repurchase
Interest-bearing trading liabilities
Other short-term borrowings
Long-term debt

Total increase in interest expense

Increase in Net Interest Income
Increase in Net Interest Income-FTE 2

2017 Compared to 2016
Rate

Net

Volume

2016 Compared to 2015
Rate

Net

Volume

$—
(20)
40
(1)
32
(54)
(2)
39
66
27
24
(3)

60
7

—
(3)
(6)
206

5
—
—
(2)
13
—
2
1
—
(2)
1
8
26

$138
28
14
(3)
7
40
—
23
27
9
1
14

56
—

8
10
31
403

71
50
(1)
1
5
—
1
8
8
4
4
20
171

$180

$232

$138
8
54
(4)
39
(14)
(2)
62
93
36
25
11

116
7

8
7
25
609

76
50
(1)
(1)
18
—
3
9
8
2
5
28
197

$412

$419

$80
(11)
42
(2)
68
(48)
—
39
69
15
25
10

42
1

—
7
4
341

7
6
—
(4)
1
—
—
—
—
3
(1)
(2)
10

$94
7
2
(2)
(17)
31
(2)
12
14
17
1
(11)

16
(1)

1
3
7
172

17
16
—
(2)
(1)
(1)
1
3
3
(1)
1
10
46

$331

$126

$174
(4)
44
(4)
51
(17)
(2)
51
83
32
26
(1)

58
—

1
10
11
513

24
22
—
(6)
—
(1)
1
3
3
2
—
8
56

$457

$453

1 Changes in Net interest income are attributed to either changes in average balances (volume change) or changes in average rates (rate change) for Earning assets 
and sources of funds on which interest is received or paid. Volume change is calculated as change in volume times the previous rate, while rate change is change 
in rate times the previous volume. The rate/volume change, change in rate times change in volume, is allocated between volume change and rate change at the 
ratio each component bears to the absolute value of their total.
2 See Table 30, "Selected Financial Data and Reconcilement of Non-U.S. GAAP Measures," in this MD&A for additional information and reconciliations of Net 
interest income-FTE.

31

 
NET INTEREST INCOME/MARGIN (FTE)

Net interest income was $5.8 billion in 2017, an increase of $419 
million, or 8%, compared to 2016. Net interest margin for 2017 
increased  14  basis  points,  to  3.14%,  compared  to  2016.  The 
increase  was  driven  by  a  24  basis  point  increase  in  average 
earning asset yields. Specifically, average LHFI yields increased 
23 basis points, driven by notable increases in yield on average 
commercial loans, residential home equity products, guaranteed 
student loans, and consumer direct loans. In addition, yields on 
securities AFS  increased  20  basis  points  due  to  shifts  in  the 
portfolio  mix,  lower  premium  amortization,  and  higher 
benchmark interest rates. These increases were offset partially 
by higher rates paid on average interest-bearing liabilities.

Rates paid on average interest-bearing liabilities increased 
12 basis points compared to 2016, driven primarily by increases 
in rates paid on NOW, money market accounts, and time deposits 
as well as short-term borrowings and long-term debt. Compared 
to  2016,  the  average  rate  paid  on  interest-bearing  deposits 
increased 11 basis points.

Average  earning  assets  increased  $5.4  billion,  or  3%, 
compared to 2016, driven primarily by a $3.1 billion, or 2%, 
increase in average LHFI and a $2.7 billion, or 10%, increase in 
average securities AFS. The increase in average LHFI was driven 
by  growth  across  most  consumer  loan  portfolios,  as  well  as 
growth in commercial construction. The growth was offset, in 
part, by declines in residential home equity products and CRE 
loans as paydowns exceeded new originations and draws. See 
the  "Loans"  section  in  this  MD&A  for  additional  discussion 
regarding loan activity.

Average interest-bearing liabilities increased $5.8 billion, 
or 5%, compared to 2016, due primarily to growth in consumer 
and  commercial  deposits  as  well  as  an  increase  in  foreign 
deposits and long-term debt. Average interest-bearing consumer 
and commercial deposits increased $5.1 billion, or 5%, compared 
to 2016, due primarily to growth in NOW and other time account 
balances  resulting  from  continued  success  in  deepening  and 
growing client relationships. Average long-term debt increased 
$298 million, or 3%, compared to 2016, due primarily to our 
senior  note  issuances  under  the  Global  Bank  Note  program, 
offset  by  decreases  in  long-term  FHLB  advances  and  other 
maturities. See the "Borrowings" section of this MD&A as well 
as Note 11, "Borrowings and Contractual Commitments," to the 
Consolidated  Financial  Statements  in  this  Form  10-K  for 
additional information regarding our long-term debt.

We utilize interest rate swaps to manage interest rate risk. 
These  instruments  are  primarily  receive-fixed,  pay-variable 
swaps that synthetically convert a portion of our commercial loan 

portfolio from floating rates, based on LIBOR, to fixed rates. At 
December 31, 2017, the outstanding notional balance of active 
swaps  that  qualified  as  cash  flow  hedges  on  variable  rate 
commercial loans was $12.1 billion, compared to $16.7 billion
at December 31, 2016.

In addition to the income recognized from active swaps, we 
recognize  interest  income  from  terminated  swaps  that  were 
previously  designated  as  cash  flow  hedges  on  variable  rate 
commercial loans.  Interest  income  from  our  commercial loan 
swaps was $89 million in 2017, compared to $244 million in 
2016  due  primarily  to  a  decrease  in  the  notional  balance  of 
qualifying swaps and an increase in LIBOR. As we manage our 
interest rate risk we may continue to purchase additional and/or 
terminate existing interest rate swaps.

Remaining  swaps  on  commercial  loans  have  maturities 
through  2022  and  have  an  average  maturity  of  3.6  years  at 
December 31, 2017. The weighted average rate on the receive-
fixed rate leg of the commercial loan swap portfolio was 1.40%, 
and the weighted average rate on the pay-variable leg was 1.56%, 
at December 31, 2017.

Looking to the first quarter of 2018, we expect net interest 
margin to increase up to two basis points compared to the fourth 
quarter of 2017 as the benefit of the December Fed Funds rate 
increase is mostly offset by the change in our FTE calculation 
as a result of the 2017 Tax Act. Beyond that, we anticipate that 
net  interest  margin  trends  will  depend  on  the  interest  rate 
environment; however, we do expect some net interest margin 
expansion in 2018 if interest rates continue to rise. Additionally, 
during  the  fourth  quarter  of  2017,  we  sold  and  subsequently 
reinvested  approximately  $3  billion  of  securities AFS  with  a 
similar mix and higher yields (primarily within U.S. Treasury 
securities and agency residential MBS), which we expect will 
increase annual interest income by approximately $20 million 
beginning in 2018, all else being equal.

Foregone Interest
Foregone interest income from NPLs reduced net interest margin 
by less than one basis point for the year ended December 31, 
2017. Forgone interest income from NPLs reduced net interest 
margin by one basis point for the year ended December 31, 2016. 
See  additional  discussion  of  our  expectations  of  future  credit 
quality  in  the  “Loans,”  “Allowance  for  Credit  Losses,”  and 
“Nonperforming Assets” sections of this MD&A. In addition, 
Table  2  and  Table  3  in  this  MD&A  contain  more  detailed 
information  regarding  average  balances,  yields  earned,  rates 
paid, and associated impacts on net interest income.

32

NONINTEREST INCOME

(Dollars in millions)
Service charges on deposit accounts
Other charges and fees
Card fees
Investment banking income
Trading income
Trust and investment management income
Retail investment services
Mortgage production related income
Mortgage servicing related income
Gain on sale of subsidiary
Commercial real estate related income 1
Net securities (losses)/gains
Other noninterest income 1
Total noninterest income

Table 4

Year Ended December 31

2017

2016

2015

$603
385
344
599
189
309
278
231
191
107
123
(108)
103
$3,354

$630
380
327
494
211
304
281
366
189
—
69
4
128
$3,383

$622
377
329
461
181
334
300
270
169
—
56
21
148
$3,268

1 Beginning January 1, 2017, we began presenting income related to our Pillar, STCC, and Structured Real Estate businesses as a separate line item on the Consolidated 
Statements of Income titled Commercial real estate related income. For periods prior to January 1, 2017, these amounts were previously presented in Other noninterest 
income and have been reclassified to Commercial real estate related income for comparability.

Noninterest income decreased $29 million, or 1%, compared to 
2016,  driven  primarily  by  lower  mortgage  production  related 
income,  offset  largely  by  higher  investment  banking  and 
commercial real estate related income. Noninterest income for 
2017 was negatively impacted by $7 million of net Form 8-K 
and  tax  reform-related  items  recognized  during  the  fourth 
quarter, comprised of $109 million of securities AFS portfolio 
restructuring losses, a $107 million gain on sale of PAC, and a 
$5  million  loss  arising  from  the  anticipated  sale  of  servicing 
rights.

Client  transaction-related-fees,  which  include  service 
charges on deposit accounts, other charges and fees, and card 
fees, decreased $5 million compared to 2016. This decrease was 
driven primarily by our enhanced posting order process that was 
instituted during the fourth quarter of 2016, offset partially by 
an increase in client transaction-related activity.

Investment banking income increased $105 million, or 21%, 
compared to 2016. This increase was due to strong deal flow 
activity  across  most  product  categories,  particularly  equity 
offerings,  mergers  and  acquisitions  advisory,  and  syndicated 
finance. 

Trading income decreased $22 million, or 10%, compared 
to 2016. This decrease was driven primarily by lower core trading 
revenue during 2017.

Trust  and  investment  management  income  increased  $5 
million, or 2%, compared to 2016. This increase was driven by 
an increase in trust and institutional assets under management 
as well as an increase in trust termination fees.

Mortgage  production  related  income  decreased  $135 
million, or 37%, compared to 2016. This decrease was driven by 
lower  gain  on  sale  margins,  lower  production  volume  due  to 
decreased refinancing activity, and a lower repurchase reserve 
release  during  2017.  Mortgage  application  volume  decreased 
24% and closed loan volume decreased 17% compared to 2016.

Mortgage servicing related income increased $2 million, or 
1%, compared to 2016, driven primarily by higher servicing fees, 
offset  partially  by  lower  net  hedge  performance  and  higher 
servicing  asset  decay.  Mortgage  servicing  related  income  for 
2017 was also negatively impacted by a $5 million tax reform-
related loss arising from the anticipated sale of servicing rights. 
The UPB of mortgage loans in the servicing portfolio was $165.5 
billion  at  December 31,  2017,  compared  to  $160.2  billion  at 
December 31, 2016. 

Gain on sale of subsidiaries totaled $107 million for 2017, 
resulting from our gain from the sale of PAC during the fourth 
quarter of 2017, which was announced in our December 4, 2017 
Form 8-K filed with SEC. For additional information regarding 
the sale of PAC, see Note 2, "Acquisitions/Dispositions," to the 
Consolidated Financial Statements in this Form 10-K. 

Commercial  real  estate  related  income  increased  $54 
million, or 78%, compared to 2016. This increase was due to 
income generated from Pillar, which we acquired in December 
2016, as well as higher structured real estate revenue. Looking 
to the first quarter of 2018, we expect commercial real estate 
related income to decline from a seasonally strong fourth quarter.
Net securities losses totaled $108 million compared to net 
securities gains of $4 million in 2016. Net securities losses for 
2017 were driven by the aforementioned securities restructuring 
losses.  Excluding  the  impact  of  the  restructuring  losses,  net 
securities gains decreased slightly compared to 2016.

Other noninterest income decreased $25 million, or 20%, 
compared to 2016. This decrease was driven primarily by $44 
million  of  net  asset-related  gains  recognized  in  2016,  offset 
partially by $17 million of net gains recognized on the sale of 
leases and commercial LHFS in 2017.

33

 
NONINTEREST EXPENSE

(Dollars in millions)
Employee compensation
Employee benefits

Total personnel expenses

Outside processing and software
Net occupancy expense
Marketing and customer development
Regulatory assessments
Equipment expense
Other staff expense
Amortization
Consulting and legal fees
Operating losses
Other noninterest expense

Total noninterest expense

Table 5

Year Ended December 31

2017

2016

2015

$2,854
403
3,257
826
377
232
187
164
121
75
71
40
414
$5,764

$2,698
373
3,071
834
349
172
173
170
67
49
93
108
382
$5,468

$2,576
366
2,942
815
341
151
139
164
65
40
73
56
374
$5,160

Noninterest expense increased $296 million, or 5%, compared 
to 2016, driven largely by higher personnel expenses and higher 
net  occupancy  expenses,  offset  partially  by  the  favorable 
resolution  of  several  legal  matters  during  the  third  quarter  of 
2017. Additionally, noninterest expense for 2017 was negatively 
impacted by $111 million of net Form 8-K and tax reform-related 
items recognized during the fourth quarter of 2017, comprised 
of a $50 million charitable contribution to support financial well-
being initiatives, a $36 million net charge related to efficiency 
actions, and $25 million of discretionary 401(k) contributions 
and other employee benefits.

Personnel  expenses  increased  $186  million,  or  6%, 
compared to 2016. This increase was due primarily to higher 
employee compensation costs associated with improved revenue 
growth and the incremental compensation costs associated with 
Pillar, which we acquired in December 2016. Personnel expenses 
for 2017 were also negatively impacted by $25 million of tax 
reform-related  discretionary  401(k)  contributions  and  other 
employee benefits recognized during the fourth quarter of 2017. 
When excluding these tax reform-related personnel expenses, 
we expect personnel expenses for the first quarter of 2018 to 
increase by approximately $75 million compared to the fourth 
quarter of 2017 due to the typical seasonal increase in 401(k) 
and FICA expenses.

Outside  processing  and  software  expense  decreased  $8 
million,  or  1%,  compared  to  2016.  This  decrease  was  due 
primarily  to  lower  transaction  volume,  efficiencies  generated 
with third party providers, and insourcing of certain activities, 
offset partially by higher software-related investments.

Net  occupancy  expense  increased  $28  million,  or  8%, 
compared to 2016. This increase was due primarily to a reduction 
in amortized gains from prior sale leaseback transactions.

Marketing  and  customer  development  expense  increased 
$60 million, or 35%, compared to 2016. This increase was due 
primarily  to  a  $50  million  tax  reform-related  charitable 
contribution  during  the  fourth  quarter  of  2017  to  support 
financial well-being initiatives. Excluding the impact of this tax 

reform-related  item,  marketing  and  customer  development 
expense increased slightly compared to 2016 driven by increased 
sponsorship costs.

Regulatory assessments expense increased $14 million, or 
8%, compared to 2016. This increase was driven by the FDIC
surcharge on large banks that became effective in the third quarter 
of  2016,  and  a  larger  assessment  base  attributable  to  balance 
sheet growth.

Other  staff  expense  increased  $54  million,  or  81%, 
compared to 2016. This increase was due to higher severance 
costs  recognized  during  the  second  half  of  2017,  largely  in 
connection  with  the  voluntary  early  retirement  program 
announced in our December 4, 2017 Form 8-K (as part of our 
net charge related to efficiency actions).

Amortization  expense  increased  $26  million,  or  53%, 
compared to 2016. This increase was driven by an increase in 
our community development investments, which are amortized 
over  the  life  of  the  related  tax  credits  that  these  investments 
generate.  See  the  "Community  Development  Investments" 
section of Note 10, "Certain Transfers of Financial Assets and 
Variable  Interest  Entities,"  to  the  Consolidated  Financial 
Statements  in  this  Form  10-K  for  additional  information 
regarding these investments. 

Consulting and legal fees decreased $22 million, or 24%, 
compared to 2016. This decrease was due to lower utilization of 
consulting  services  and  lower  legal  fees  resulting  from  the 
resolution of legal matters.

Operating losses decreased $68 million, or 63%, compared 
to 2016. This decrease was driven by the favorable resolution of 
several legal matters, which aggregated to $58 million during 
the third quarter of 2017.

Other  noninterest  expense  increased  $32  million,  or  8%, 
compared to 2016. This increase was due primarily to software-
related  writedowns  associated  with  ongoing  efficiency 
initiatives, as well as branch and corporate real estate closure 
costs.

34

 
PROVISION FOR INCOME TAXES

LOANS

The provision for income taxes includes federal and state income 
taxes and interest. For the year ended December 31, 2017, the 
provision for income taxes was $532 million, representing an 
effective tax rate of 19%. For the year ended December 31, 2016, 
the provision for income taxes was $805 million, representing 
an effective tax rate of 30%. The decrease in the effective tax 
rate  was  due  primarily  to  the  recognition  of  a  $303  million 
income tax benefit for the estimated impact of the remeasurement 
of our DTAs and DTLs and other tax reform-related items due 
to the enactment of the 2017 Tax Act.

The 2017 Tax Act makes broad changes to the U.S. tax code, 
including reducing the U.S. federal corporate tax rate from 35% 
to 21% effective January 1, 2018, eliminating the deduction for 
FDIC premiums, limiting the deductibility of certain executive 
compensation, and imposing new limitations on NOLs generated 
after December 31, 2017. 
  We recorded an income tax benefit for the remeasurement 
of our estimated DTAs and DTLs of $333 million to reflect the 
newly enacted federal corporate income tax rate of 21%, which 
is  the  rate  at  which  the  deferred  tax  balances  are  expected  to 
reverse  in  the  future.  However,  as  additional  information 
becomes  available  and  additional  analysis  is  completed,  our 
estimate of the DTAs and DTLs may change, which could impact 
the  remeasurement  of  these  deferred  tax  balances.  Any 
adjustment to the remeasurement amount would be recorded as 
an adjustment to the provision for income taxes in 2018 in the 
period the amounts are determined. 

Due to the enactment of the provisions of the 2017 Tax Act, 
we expect that our 2018 effective tax rate will be approximately 
20%.  See  Note  14,  “Income  Taxes,”  to  the  Consolidated 
Financial Statements in this Form 10-K for further information 
related to the provision for income taxes. 

Our disclosures about the credit quality of our loan portfolio and 
the related credit reserves (i) describe the nature of credit risk 
inherent in the loan portfolio, (ii) provide information on how 
we analyze and assess credit risk in arriving at an adequate and 
appropriate ALLL, and (iii) explain changes in the ALLL as well 
as reasons for those changes.

Our  loan  portfolio  consists  of  two  loan  segments: 
Commercial loans and Consumer loans. Loans are assigned to 
these segments based on the type of borrower, purpose, and/or 
our underlying credit management processes. Additionally, we 
further disaggregate each loan segment into loan types based on 
common characteristics within each loan segment.

Commercial Loans
C&I loans include loans to fund business operations or activities, 
loans  secured  by  owner-occupied  properties,  corporate  credit 
cards, and other wholesale lending activities. Commercial loans 
secured by owner-occupied properties are classified as C&I loans 
because  the  primary  source  of  loan  repayment  for  these 
properties is business income and not real estate operations. CRE 
and Commercial construction loans include investor loans where 
repayment is largely dependent upon the operation, refinance, 
or sale of the underlying real estate.

Consumer Loans
Residential mortgages, both guaranteed (by a federal agency or 
GSE) and nonguaranteed, consist of loans secured by 1-4 family 
homes; mostly prime, first-lien loans. Residential home equity 
products consist of equity lines of credit and closed-end equity 
loans secured by residential real estate that may be in either a 
first lien or junior lien position. Residential construction loans 
include 
real  estate  secured  owner-occupied 
construction-to-perm loans and lot loans. 

residential 

Consumer  loans  also  include  Guaranteed  student  loans, 
Indirect loans (consisting of loans secured by automobiles, boats, 
and  recreational  vehicles),  Other  direct  loans  (consisting 
primarily of unsecured loans, direct auto loans, loans secured by 
negotiable  collateral,  and  private  student  loans),  and  Credit 
cards.

35

 
 
 
The composition of our loan portfolio at December 31 is presented in Table 6:

Loan Portfolio by Types of Loans

(Dollars in millions)

Commercial loans:

C&I 1
CRE

Commercial construction

Total commercial loans

Consumer loans:

Residential mortgages - guaranteed
Residential mortgages - nonguaranteed 2
Residential home equity products

Residential construction

Guaranteed student

Other direct

Indirect

Credit cards

Total consumer loans 

LHFI
LHFS 3

2017

2016

2015

2014

Table 6
2013

$66,356

$69,213

$67,062

$65,440

$57,974

5,317

3,804

75,477

560

27,136

10,626

298

6,633

8,729

12,140

1,582

67,704

4,996

4,015

78,224

537

26,137

11,912

404

6,167

7,771

10,736

1,410

65,074

6,236

1,954

75,252

629

24,744

13,171

384

4,922

6,127

10,127

1,086

61,190

6,741

1,211

73,392

632

23,443

14,264

436

4,827

4,573

10,644

901

59,720

5,481

855

64,310

3,416

24,412

14,809

553

5,545

2,829

11,272

731

63,567

$143,181

$143,298

$136,442

$133,112

$127,877

$2,290

$4,169

$1,838

$3,232

$1,699

1 Includes $3.7 billion, $3.7 billion, $3.9 billion, $4.6 billion, and $4.9 billion of lease financing and $778 million, $729 million, $672 million, $687 million, and 
$705 million of installment loans at December 31, 2017, 2016, 2015, 2014, and 2013, respectively.
2 Includes $196 million, $222 million, $257 million, $272 million, and $302 million of LHFI measured at fair value at December 31, 2017, 2016, 2015, 2014, and 
2013, respectively.
3 Includes $1.6 billion, $3.5 billion, $1.5 billion, $1.9 billion, and $1.4 billion of LHFS measured at fair value at December 31, 2017, 2016, 2015, 2014, and 2013, 
respectively.

Table 7 presents maturities and sensitivities of certain LHFI to changes in interest rates:

(Dollars in millions)
Loan Maturity
C&I and CRE 1
Commercial construction

Total

Interest Rate Sensitivity
Selected loans with:

Predetermined interest rates
Floating or adjustable interest rates

Total

At December 31, 2017

Total

Due in 1 Year or
Less

Due After 1 Year
through 5 Years

Due After 5 Years

Table 7

$67,155
3,804
$70,959

$15,713
155
$15,868

$42,182
3,169
$45,351

$3,743
41,608
$45,351

$9,260
480
$9,740

$3,443
6,297
$9,740

1 Excludes $3.7 billion of lease financing and $778 million of installment loans.

36

Table 8 presents our outstanding commercial LHFI by industry:

(Dollars in millions)

Real estate
Consumer products and services
Health care & pharmaceuticals
Automotive
Diversified financials and insurance
Diversified commercial services and supplies
Government
Retail
Capital goods
Media & telecommunication services
Technology (hardware & software)
Energy
Materials
Utilities
Not-for-profits/religious organizations
Transportation
Other

Total commercial LHFI

December 31, 2017

December 31, 2016

Commercial
LHFI

% of Total
Commercial

Commercial
LHFI

% of Total
Commercial

Table 8

$12,905
9,303
8,058
7,444
7,227
3,837
3,438
3,383
3,075
2,979
2,371
2,176
2,044
2,030
1,914
1,795
1,498
$75,477

17%
12
11
10
10
5
5
4
4
4
3
3
3
3
3
2
2
100%

$13,028
9,450
7,437
7,012
8,627
4,149
3,775
3,588
3,226
2,593
3,259
2,584
2,083
2,119
1,768
2,103
1,423
$78,224

17%
12
10
9
11
5
5
5
4
3
4
3
3
3
2
3
2
100%

Table 9 presents our LHFI portfolio by geography (based on the U.S. Census Bureau's classifications of U.S. regions):

(Dollars in millions)

South region:
Florida
Georgia
Virginia
Maryland
North Carolina
Texas
Tennessee
South Carolina
District of Columbia
Other Southern states
Total South region

Northeast region:
New York
Pennsylvania
New Jersey
Other Northeastern states
Total Northeast region

West region:
California
Other Western states
Total West region

Midwest region:

Illinois
Ohio
Missouri
Other Midwestern states
Total Midwest region

Foreign loans
Total

Commercial LHFI

December 31, 2017

Consumer LHFI

Table 9

Total LHFI

Balance

% of Total
Commercial

Balance

% of Total
Consumer

Balance

% of Total
LHFI

$12,792
10,250
6,580
4,104
4,482
3,954
4,101
1,155
1,501
2,791
51,710

4,731
1,458
1,327
2,387
9,903

4,893
2,172
7,065

1,637
718
922
2,211
5,488
1,311
$75,477

17%
14
9
5
6
5
5
2
2
4
69

6
2
2
3
13

6
3
9

2
1
1
3
7
2
100%

37

$13,474
8,462
7,545
6,095
5,354
4,122
2,985
2,385
1,022
2,452
53,896

1,139
1,189
689
895
3,912

3,246
2,235
5,481

922
688
395
2,336
4,341
74
$67,704

20%
12
11
9
8
6
4
4
2
4
80

2
2
1
1
6

5
3
8

1
1
1
3
6
—
100%

$26,266
18,712
14,125
10,199
9,836
8,076
7,086
3,540
2,523
5,243
105,606

5,870
2,647
2,016
3,282
13,815

8,139
4,407
12,546

2,559
1,406
1,317
4,547
9,829
1,385
$143,181

18%
13
10
7
7
6
5
2
2
4
74

4
2
1
2
10

6
3
9

2
1
1
3
7
1
100%

(Dollars in millions)

South region:
Florida
Georgia
Virginia
Maryland
North Carolina
Tennessee
Texas
South Carolina
District of Columbia
Other Southern states
Total South region

Northeast region:
New York
Pennsylvania
New Jersey
Other Northeastern states
Total Northeast region

West region:
California
Other Western states
Total West region

Midwest region:

Illinois
Ohio
Missouri
Other Midwestern states
Total Midwest region

Foreign loans
Total

Commercial LHFI

December 31, 2016

Consumer LHFI

Total LHFI

Balance

% of Total
Commercial

Balance

% of Total
Consumer

Balance

% of Total
LHFI

$13,143
9,991
6,727
4,100
4,211
4,631
3,794
1,707
1,330
3,884
53,518

4,906
1,534
1,353
2,856
10,649

4,137
2,384
6,521

1,614
638
816
2,341
5,409
2,127
$78,224

17%
13
9
5
5
6
5
2
2
5
68

6
2
2
4
14

5
3
8

2
1
1
3
7
3
100%

$13,487
8,124
7,538
5,913
5,154
2,992
3,480
2,322
976
2,130
52,116

1,044
1,089
637
841
3,611

3,338
2,077
5,415

772
622
359
2,110
3,863
69
$65,074

21%
12
12
9
8
5
5
4
1
3
80

2
2
1
1
6

5
3
8

1
1
1
3
6
—
100%

$26,630
18,115
14,265
10,013
9,365
7,623
7,274
4,029
2,306
6,014
105,634

5,950
2,623
1,990
3,697
14,260

7,475
4,461
11,936

2,386
1,260
1,175
4,451
9,272
2,196
$143,298

19%
13
10
7
7
5
5
3
2
4
74

4
2
1
3
10

5
3
8

2
1
1
3
6
2
100%

Loans Held for Investment
LHFI totaled $143.2 billion at December 31, 2017, a decrease 
of $117 million from December 31, 2016, driven by decreases 
in C&I loans and residential home equity products, offset largely 
by growth across most consumer loan types.

Average LHFI during 2017 totaled $144.2 billion, up $3.1 
billion  compared  to  2016,  driven  by  growth  across  most 
consumer  loan  types  and  in  commercial  construction  loans. 
These  increases  were  offset  partially  by  declines  in  average 
residential home equity products and CRE loans. See the "Net 
Interest  Income/Margin"  section  of  this  MD&A  for  more 
information regarding average loan balances.

Commercial  loans  decreased  $2.7  billion,  or  4%,  during 
2017, due to a $2.9 billion, or 4%, decline in C&I loans driven 
by  elevated  paydowns  and  lower  revolver  utilization.  The 
decrease in C&I loans was offset partially by a $321 million, or 
6%, increase in CRE loans due to organic loan production and 
draws on existing commitments.

Consumer loans increased $2.6 billion, or 4%, during 2017, 
driven  by  growth  in  indirect  loans  of  $1.4  billion,  or  13%, 
nonguaranteed  residential  mortgages  of  $999  million,  or  4%, 
other  direct  loans  of  $958  million,  or  12%,  and  guaranteed 
student loans of $466 million, or 8%. These increases were offset 
partially by a $1.3 billion, or 11%, decrease in residential home 
equity  products  as  payoffs  and  paydowns  exceeded  new 
originations and draws during 2017.

38

At December 31, 2017, 41% of our residential home equity 
products were in a first lien position and 59% were in a junior 
lien position. For residential home equity products in a junior 
lien position, we own or service 32% of the loans that are senior 
to the home equity product. Approximately 10% of the home 
equity line portfolio is due to convert to amortizing term loans 
by the end of 2018 and an additional 13% enter the conversion 
phase over the following three years.

We perform credit management activities to limit our loss 
exposure on home equity accounts. These activities may result 
in the suspension of available credit and curtailment of available 
draws of most home equity junior lien accounts when the first 
lien position is delinquent, including when the junior lien is still 
current. We monitor the delinquency status of first mortgages 
serviced by other parties and actively monitor refreshed credit 
bureau scores of borrowers with junior liens, as these scores are 
highly sensitive to first lien mortgage delinquency. The average 
borrower  FICO  score  related  to  loans  in  our  home  equity 
portfolio  was  approximately  770  and  765,  and  the  average 
outstanding loan size was approximately $44,000 and $46,000 
at December 31, 2017 and 2016, respectively. The loss severity 
on home equity junior lien accounts that incurred charge-offs 
was  approximately  76%  and  80%  at  December  31,  2017  and 
2016, respectively.

 
Loans Held for Sale
LHFS decreased $1.9 billion, or 45%, during 2017, driven by 
lower mortgage production relative to 2016.

Asset Quality
Our asset quality metrics were strong during 2017, driven by 
economic  growth,  improved  residential  housing  markets,  and 
significant  progress  in  working  through  remaining  problem 
energy-related exposures, evidenced by our modest net charge-
off and NPL ratios. These levels reflect the relative strength of 
our LHFI portfolio in response to proactive steps we have taken 
over the past several years to de-risk, diversify, and improve the 
quality of our loan portfolio. Our financial results for the second 
half  of  2017  were  impacted  by  hurricanes,  which  caused 
increases in the ALLL to period-end LHFI ratio and the consumer 
provision for loan losses compared to 2016. See the “Allowance 
for  Credit  Losses”  section  of  this  MD&A  for  additional 
information regarding our ALLL and provision for credit losses.
NPAs decreased $178 million, or 19%, during 2017, driven 
primarily by the continued resolution of problem energy-related 
exposures. At December 31, 2017, the ratio of NPLs to period-

end LHFI was 0.47%, a decrease of 12 basis points compared to 
December 31, 2016.

For 2017 and 2016, net charge-offs totaled $367 million and 
$483 million, and the net charge-off ratio was 0.25% and 0.34%, 
respectively.  The  decrease  in  net  charge-offs  was  driven 
primarily by overall asset quality improvements and lower net 
charge-offs  associated  with  energy-related  exposures,  offset 
partially  by  higher  net  charge-offs  associated  with  consumer 
loans. 

Early stage delinquencies were 0.80% and 0.72% of total 
loans  at  December 31,  2017  and  December 31,  2016, 
respectively. Early stage delinquencies, excluding government-
guaranteed loans, were 0.32% and 0.27% at December 31, 2017
and  December 31,  2016,  respectively.  The  increases  in  early 
stage  delinquencies  described  above  resulted  primarily  from 
impacts associated with hurricanes.

Overall, we expect to operate within a net charge-off ratio 
of between 25 and 35 basis points in 2018. We also forecast a 
provision for loan losses that generally approximates net charge-
offs.

39

ALLOWANCE FOR CREDIT LOSSES

The allowance for credit losses consists of the ALLL and the 
reserve  for  unfunded  commitments.  A  rollforward  of  our 
allowance  for  credit  losses  and  summarized  credit  loss 
experience  is  shown  in  Table  10.  See  Note  1,  "Significant 
Accounting  Policies,"  and  Note  7,  "Allowance  for  Credit 

Losses," to the Consolidated Financial Statements in this Form 
10-K, as well as the "Critical Accounting Policies" section of 
this  MD&A  for  further  information  regarding  our  ALLL 
accounting policy, determination, and allocation. 

Summary of Credit Losses Experience

Table 10

(Dollars in millions)
Allowance for Credit Losses
Balance - beginning of period
Provision for unfunded commitments
Provision for loan losses:

Commercial loans
Consumer loans

Total provision for loan losses

Charge-offs:

Commercial loans
Consumer loans

Total charge-offs

Recoveries:

Commercial loans
Consumer loans

Total recoveries

Net charge-offs
Other 1
Balance - end of period

Components:

ALLL
Unfunded commitments reserve 2
Allowance for credit losses

Average LHFI
Period-end LHFI outstanding

Ratios:

ALLL to period-end LHFI 3
ALLL to NPLs 4
Net charge-offs to total average LHFI

Year Ended December 31

2017

2016

2015

2014

2013

$1,776
12

$1,815
4

$1,991
9

$2,094
4

$2,219
5

108
289
397

(167)
(324)
(491)

40
84
124
(367)
(4)
$1,814

$1,735
79
$1,814

$144,216
143,181

329
111
440

(287)
(304)
(591)

35
73
108
(483)
—
$1,776

$1,709
67
$1,776

133
23
156

(117)
(353)
(470)

45
84
129
(341)
—
$1,815

$1,752
63
$1,815

111
227
338

(128)
(479)
(607)

57
105
162
(445)
—
$1,991

$1,937
54
$1,991

197
351
548

(219)
(650)
(869)

66
125
191
(678)
—
$2,094

$2,044
50
$2,094

$141,118
143,298

$133,558
136,442

$130,874
133,112

$122,657
127,877

1.21%
2.59x
0.25%

1.19%
2.03x
0.34%

1.29%
2.62x
0.26%

1.46%
3.07x
0.34%

1.60%
2.12x
0.55%

1 Related to loans disposed in connection with the sale of PAC. For additional information regarding the sale of PAC, see Note 2, "Acquisitions/Dispositions," to the 
Consolidated Financial Statements in this Form 10-K.
2 The unfunded commitments reserve is recorded in Other liabilities in the Consolidated Balance Sheets.
3 $196 million, $222 million, $257 million, $272 million, and $302 million of LHFI measured at fair value at December 31, 2017, 2016, 2015, 2014, and 2013, 
respectively, were excluded from period-end LHFI in the calculation, as no allowance is recorded for loans measured at fair value. We believe that this presentation 
more appropriately reflects the relationship between the ALLL and loans that attract an allowance.
4 $4 million, $3 million, $3 million, $3 million, and $7 million of NPLs measured at fair value at December 31, 2017, 2016, 2015, 2014, and 2013, respectively, were 
excluded from NPLs in the calculation, as no allowance is recorded for NPLs measured at fair value. We believe that this presentation more appropriately reflects 
the relationship between the ALLL and NPLs that attract an allowance.

40

Provision for Credit Losses
The  total  provision  for  credit  losses  includes  the  provision/
(benefit) for loan losses and the provision/(benefit) for unfunded 
commitments. The  provision  for  loan  losses  is  the  result  of  a 
detailed  analysis  performed  to  estimate  an  appropriate  and 
adequate ALLL.  For  2017,  the  total  provision  for  loan  losses 
decreased $43 million compared to 2016, driven primarily by 
lower  net  charge-offs  and  reserves  associated  with  energy-
related  commercial  exposures,  offset  partially  by  increased 
reserves held for hurricane-related losses. 

Our  quarterly  review  processes  to  determine  the  level  of 
reserves  and  provision  are  informed  by  trends  in  our  LHFI 

portfolio  (including  historical  loss  experience,  expected  loss 
calculations,  delinquencies,  performing  status,  size  and 
composition of the loan portfolio, and concentrations within the 
portfolio)  combined  with  a  view  on  economic  conditions.  In 
addition to internal credit quality metrics, the ALLL estimate is 
impacted by other indicators of credit risk associated with the 
portfolio,  such  as  geopolitical  and  economic  risks,  and  the 
increasing  availability  of  credit  and  resultant  higher  levels  of 
leverage for consumers and commercial borrowers.

Allowance for Loan and Lease Losses

ALLL by Loan Segment

(Dollars in millions)
ALLL:

Commercial loans
Consumer loans

Total

Segment ALLL as a % of total ALLL:

Commercial loans
Consumer loans

Total

Segment LHFI as a % of total LHFI:

Commercial loans
Consumer loans

Total

2017

2016

2015

2014

2013

At December 31

Table 11

$1,101
634
$1,735

$1,124
585
$1,709

$1,047
705
$1,752

$986
951
$1,937

$946
1,098
$2,044

63%
37
100%

53%
47
100%

66%
34
100%

55%
45
100%

60%
40
100%

55%
45
100%

51%
49
100%

55%
45
100%

46%
54
100%

50%
50
100%

The ALLL  increased  $26  million,  or  2%,  from  December 31, 
2016, to $1.7 billion at December 31, 2017. The increase was 
due  primarily  to  increased  reserves  held  for  hurricane-related 
losses and lower net charge-offs in 2017. The ALLL to period-
end  LHFI  ratio  (excluding  loans  measured  at  fair  value) 
increased 2 basis points from December 31, 2016, to 1.21% at 

December 31, 2017. The ratio of the ALLL to NPLs (excluding 
NPLs measured at fair value) increased to 2.59x at December 31, 
2017,  compared  to  2.03x  at  December 31,  2016,  reflecting  a 
decrease  in  NPLs  due  primarily  to  the  resolution  of  problem 
energy-related loans as well as an increase in the ALLL.

41

NONPERFORMING ASSETS

Table 12 presents our NPAs at December 31:

(Dollars in millions)
Nonaccrual loans/NPLs:

Commercial loans:

C&I
CRE
Commercial construction
Total commercial NPLs

Consumer loans:

Residential mortgages - nonguaranteed
Residential home equity products
Residential construction
Other direct
Indirect

Total consumer NPLs
Total nonaccrual loans/NPLs 1

OREO 2
Other repossessed assets
Nonperforming LHFS

Total NPAs

Accruing LHFI past due 90 days or more
Accruing LHFS past due 90 days or more

TDRs:

Accruing restructured loans 
Nonaccruing restructured loans 1

Ratios:

2017

2016

2015

2014

2013

Table 12

$215
24
1
240

206
203
11
7
7
434

$674

$57
10
—
$741

$1,405
2

$2,468
286

$390
7
17
414

177
235
12
6
1
431

$845

$60
14
—
$919

$1,288
1

$2,535
306

$308
11
—
319

183
145
16
6
3
353

$672

$56
7
—
$735

$981
—

$2,603
176

$151
21
1
173

254
174
27
6
—
461

$634

$99
9
38
$780

$1,057
1

$2,592
273

$196
39
12
247

441
210
61
5
7
724

$971

$170
7
17
$1,165

$1,228
—

$2,749
391

NPLs to period-end LHFI
NPAs to period-end LHFI, nonperforming LHFS, OREO, and other

repossessed assets

0.47%

0.59%

0.49%

0.48%

0.76%

0.52

0.64

0.54

0.59

0.91

1 Nonaccruing restructured loans are included in total nonaccrual loans/NPLs.
2 Does not include foreclosed real estate related to loans insured by the FHA or guaranteed by the VA. Proceeds due from the FHA and the VA are recorded as a 
receivable in Other assets in the Consolidated Balance Sheets until the property is conveyed and the funds are received. The receivable related to proceeds due from 
the FHA and the VA totaled $45 million, $50 million, $52 million, $57 million, and $88 million at December 31, 2017, 2016, 2015, 2014, and 2013, respectively.

Problem  loans  or  loans  with  potential  weaknesses,  such  as 
nonaccrual loans, loans over 90 days past due and still accruing, 
and TDR loans, are disclosed in the NPA table above. Loans with 
known  potential  credit  problems  that  may  not  otherwise  be 
disclosed  in  this  table  include  accruing  criticized  commercial 
loans, which are disclosed along with additional credit quality 
information in Note 6, “Loans,” to the Consolidated Financial 
Statements  in  this  Form  10-K. At  December 31,  2017  and 
December 31, 2016, there were no known significant potential 
problem loans that are not otherwise disclosed. See the "Critical 
Accounting  Policies"  section  of  this  MD&A  for  additional 
information  regarding  our  policy  on  loans  classified  as 
nonaccrual.

NPAs decreased $178 million, or 19%, during 2017, and the 
ratio of NPLs to period-end LHFI was 0.47% at December 31, 
2017,  down  12  basis  points  from  December 31,  2016.  These 
declines were driven primarily by continued improvements in 
the energy portfolio.

Nonperforming Loans
NPLs at December 31, 2017 totaled $674 million, a decrease of 
$171  million,  or  20%,  from  December 31,  2016,  driven  by  a 
decline in commercial NPLs. 

Commercial NPLs decreased $174 million, or 42%, during 
2017 driven by a $175 million, or 45%, reduction in C&I NPLs 
due primarily to paydowns, sales, and the return to accrual status 
of  certain  energy-related  NPLs.  Additionally,  commercial 
construction NPLs decreased $16 million, or 94%, due to the 
sale of an NPL in the third quarter of 2017. The decrease in C&I 
and commercial construction NPLs was offset partially by an 
increase in CRE NPLs of $17 million due to the downgrade of 
one borrower.

Consumer  NPLs  increased  $3  million,  or  1%,  from 
December 31, 2016, due primarily to an increase in residential 
mortgage and indirect NPLs, offset largely by lower inflows of 
new residential home equity NPLs. 

42

Interest income on consumer nonaccrual loans, if received, 
is recognized on a cash basis. Interest income on commercial 
nonaccrual  loans  is  not  generally  recognized  until  after  the 
principal amount has been reduced to zero. We recognized $32 
million and $21 million of interest income related to nonaccrual 
loans  (which  includes  out-of-period  interest  for  certain 
commercial  nonaccrual 
loans)  during  2017  and  2016, 
respectively.  If  all  such  loans  had  been  accruing  interest 
according to their original contractual terms, estimated interest 
income  of  $43  million  and  $48  million  would  have  been 
recognized during 2017 and 2016, respectively.

Other Nonperforming Assets
OREO decreased $3 million, or 5%, during 2017 to $57 million 
at December 31, 2017. Sales of OREO resulted in proceeds of 
$60 million and $59 million during 2017 and 2016, resulting in 
net gains of $10 million and $11 million, respectively, inclusive 
of valuation reserves.

Most  of  our  OREO  properties  are  located  in  Florida, 
Georgia, Virginia, and Maryland. Residential and commercial 
real estate properties comprised 90% and 6%, respectively, of 
the $57 million in total OREO at December 31, 2017, with the 
remainder related to land. Upon foreclosure, the values of these 
properties were re-evaluated and, if necessary, written down to 
their then-current estimated fair value less estimated costs to sell. 
Any  further  decreases  in  property  values  could  result  in 
additional losses as they are regularly revalued. See the "Non-
recurring  Fair  Value  Measurements"  section  within  Note  18, 
"Fair  Value  Election  and  Measurement,"  to  the  Consolidated 
Financial  Statements  in  this  Form  10-K  for  additional 
information.

Gains and losses on the sale of OREO are recorded in other 
noninterest expense in the Consolidated Statements of Income. 
Sales  of  OREO  and  the  related  gains  or  losses  are  highly 
dependent on our disposition strategy. We are actively managing 
and disposing of these assets to minimize future losses and to 
maintain compliance with regulatory requirements.

Accruing loans past due 90 days or more included LHFI and 
LHFS, and totaled $1.4 billion and $1.3 billion at December 31, 
2017  and  2016,  respectively.  Of  these,  98%  and  97%  were 
government-guaranteed  at  December  31,  2017  and  2016, 
respectively. Accruing LHFI past due 90 days or more increased 
$117  million,  or  9%,  during  2017,  driven  by  a  $101  million 
increase in guaranteed student loans and a $19 million increase 
in  guaranteed  residential  mortgages,  offset  slightly  by  a  $5 
million decrease in C&I loans.

Restructured Loans
To  maximize  the  collection  of  loan  balances,  we  evaluate 
troubled  loans  on  a  case-by-case  basis  to  determine  if  a  loan 
modification is appropriate. We pursue loan modifications when 
there  is  a  reasonable  chance  that  an  appropriate  modification 
would allow our client to continue servicing the debt. For loans 
secured by residential real estate, if the client demonstrates a loss 
of  income  such  that  the  client  cannot  reasonably  support  a 
modified loan, we may pursue short sales and/or deed-in-lieu 
arrangements.  For 
income  producing 
loans  secured  by 
commercial  properties,  we  perform  an  in-depth  and  ongoing 
programmatic  review  of  a  number  of  factors,  including  cash 

flows,  loan  structures,  collateral  values,  and  guarantees  to 
identify  loans  within  our  income  producing  commercial  loan 
portfolio that are most likely to experience distress. 

Based on our review of the aforementioned factors and our 
assessment of overall risk, we evaluate the benefits of proactively 
initiating discussions with our clients to improve a loan’s risk 
profile. In some cases, we may renegotiate terms of their loans 
so that they have a higher likelihood of continuing to perform. 
To date, we have restructured loans in a variety of ways to help 
our clients service their debt and to mitigate the potential for 
additional  losses.  The  restructuring  methods  offered  to  our 
clients primarily include an extension of the loan's contractual 
term and/or a reduction in the loan's original contractual interest 
rate. In limited circumstances, loan modifications that forgive 
contractually specified unpaid principal balances may also be 
offered. For residential home equity lines nearing the end of their 
draw period and for commercial loans, the primary restructuring 
method is an extension of the loan's contractual term.

Loans  with  modifications  deemed 

to  be  economic 
concessions  resulting  from  borrower  financial  difficulties  are 
reported as TDRs. Accruing loans may retain accruing status at 
the time of restructure and the status is determined by, among 
other  things,  the  nature  of  the  restructure,  the  borrower's 
repayment history, and the borrower's repayment capacity.

Nonaccruing  loans  that  are  modified  and  demonstrate  a 
sustainable  history  of  repayment  performance  in  accordance 
with  their  modified  terms,  typically  six  months,  are  usually 
reclassified  to  accruing  TDR  status.  Generally,  once  a  loan 
becomes  a TDR,  we  expect  that  the  loan  will  continue  to  be 
reported as a TDR for its remaining life, even after returning to 
accruing status (unless the modified rates and terms at the time 
of modification were available in the market at the time of the 
modification, or if the loan is subsequently remodified at market 
rates).  Some  restructurings  may  not  ultimately  result  in  the 
complete collection of principal and interest (as modified by the 
terms of the restructuring), culminating in default, which could 
result 
losses.  These  potential 
incremental losses are factored into our ALLL estimate. The level 
of  re-defaults  will  likely  be  affected  by  future  economic 
conditions. See Note 6, “Loans,” to the Consolidated Financial 
Statements in this Form 10-K for additional information.

in  additional 

incremental 

At December 31, 2017, our total TDR portfolio totaled $2.8 
billion and was comprised of $2.7 billion, or 97%, of consumer 
loans (predominantly first and second lien residential mortgages 
and  home  equity  lines  of  credit)  and  $70  million,  or  3%,  of 
commercial  loans.  Total  TDRs  decreased  $87  million  from 
December 31, 2016, driven by a $67 million, or 3%, reduction 
in  accruing TDRs  due  primarily  to  paydowns  and  payoffs  of 
nonguaranteed residential mortgages during 2017. Nonaccruing 
TDRs decreased $20 million, or 7%, from December 31, 2016.
Generally, interest income on restructured loans that have 
met  sustained  performance  criteria  and  returned  to  accruing 
status is recognized according to the terms of the restructuring. 
Such  interest  income  recognized  was  $108  million  and  $112 
million for 2017 and 2016, respectively. If all such loans had 
been  accruing  interest  according  to  their  original  contractual 
terms,  estimated  interest  income  of  $130  million  and  $138 
million  for  2017  and  2016,  respectively,  would  have  been 
recognized.

43

SELECTED FINANCIAL INSTRUMENTS MEASURED AT FAIR VALUE

The following is a discussion of the more significant financial 
assets and financial liabilities that are measured at fair value on 
the  Consolidated  Balance  Sheets  at  December  31,  2017  and 
2016.  For  a  complete  discussion  of  our  financial  instruments 
measured at fair value and the methodologies used to estimate 
the fair values of our financial instruments, see Note 18, “Fair 
Value Election and Measurement,” to the Consolidated Financial 
Statements in this Form 10-K.

Trading Assets and Liabilities and Derivative Instruments
Trading  assets  and  derivative  instruments  decreased  $974 
million, or 16%, compared to December 31, 2016. This decrease 
was  due  primarily  to  decreases  in  U.S.  Treasury  securities, 
trading loans, derivative instruments, federal agency securities, 
municipal securities, and CP, offset partially by an increase in 
agency MBS. These changes were driven by normal activity in 
the trading portfolio product mix as we manage our business and 

continue  to  meet  our  clients'  needs.  Trading  liabilities  and 
derivative instruments decreased $68 million, or 5%, compared 
to December 31, 2016, driven by a decrease in U.S. Treasury
securities, offset in part by increases in corporate and other debt 
securities,  derivative  instruments,  and  equity  securities.  For 
composition  and  valuation  assumptions  related  to  our  trading 
products,  as  well  as  additional  information  on  our  derivative 
instruments,  see  Note  4,  “Trading Assets  and  Liabilities  and 
Derivative  Instruments,”  Note  17,  “Derivative  Financial 
Instruments,”  and 
the  “Trading  Assets  and  Derivative 
Instruments and Securities Available for Sale” section of Note 
18, “Fair Value Election and Measurement,” to the Consolidated 
Financial Statements in this Form 10-K. Also, for a discussion 
of market risk associated with our trading activities, refer to the 
“Market  Risk  Management—Market  Risk  from  Trading 
Activities” section of this MD&A.

Securities Available for Sale

(Dollars in millions)
U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency residential
MBS - non-agency commercial
ABS
Corporate and other debt securities
Other equity securities 1
Total securities AFS

December 31, 2017

Amortized
Cost

Unrealized
Gains

Unrealized
Losses

Fair
Value

Table 13

$4,361
257
618
22,616
2,121
55
862
6
17
472
$31,385

$2
3
7
222
3
4
7
2
—
—
$250

$32
1
8
134
38
—
3
—
—
3
$219

$4,331
259
617
22,704
2,086
59
866
8
17
469
$31,416

1 At December 31, 2017, the fair value of other equity securities was comprised of the following:  $15 million of FHLB of Atlanta stock, $403 million of Federal 
Reserve Bank of Atlanta stock, $49 million of mutual fund investments, and $2 million of other.

(Dollars in millions)
U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency residential
MBS - non-agency commercial
ABS
Corporate and other debt securities
Other equity securities 1
Total securities AFS

December 31, 2016

Amortized
Cost

Unrealized
Gains

Unrealized
Losses

Fair
Value

$5,486
310
279
22,379
1,263
71
257
8
34
642
$30,729

$5
5
5
311
2
3
—
2
1
1
$335

$86
2
5
254
39
—
5
—
—
1
$392

$5,405
313
279
22,436
1,226
74
252
10
35
642
$30,672

1 At December 31, 2016, the fair value of other equity securities was comprised of the following:  $132 million of FHLB of Atlanta stock, $402 million of Federal 
Reserve Bank of Atlanta stock, $102 million of mutual fund investments, and $6 million of other.

44

 
 
(Dollars in millions)
U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency residential
ABS
Corporate and other debt securities
Other equity securities 1
Total securities AFS

December 31, 2015

Amortized
Cost

Unrealized
Gains

Unrealized
Losses

Fair
Value

$3,460
402
156
22,508
369
92
11
37
533
$27,568

$3
10
8
393
4
2
2
1
1
$424

$14
1
—
146
4
—
1
—
1
$167

$3,449
411
164
22,755
369
94
12
38
533
$27,825

1 At December 31, 2015, the fair value of other equity securities was comprised of the following:  $32 million of FHLB of Atlanta stock, $402 million of Federal 
Reserve Bank of Atlanta stock, $93 million of mutual fund investments, and $6 million of other.

Maturity Distribution of Debt Securities Available for Sale

Table 14

(Dollars in millions)
Amortized Cost 1:

U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency residential
MBS - non-agency commercial
ABS
Corporate and other debt securities

Total debt securities

Fair Value 1:

U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency residential
MBS - non-agency commercial
ABS
Corporate and other debt securities

Due in 1 Year
or Less

Due After 1
Year through
5 Years

December 31, 2017
Due After 5
Years through
10 Years

Due After 10
Years

Total

$—
121
6
2,686
—
—
—
—
7
$2,820

$—
123
6
2,748
—
—
—
—
7
$2,884

$2,322
46
49
7,937
315
55
12
6
10
$10,752

$2,305
47
52
7,980
308
59
12
8
10
$10,781

$2,039
4
149
11,781
1,547
—
813
—
—
$16,333

$2,026
4
153
11,763
1,525
—
816
—
—
$16,287

$—
86
414
212
259
—
37
—
—
$1,008

$—
85
406
213
253
—
38
—
—
$995

$4,361
257
618
22,616
2,121
55
862
6
17
$30,913

$4,331
259
617
22,704
2,086
59
866
8
17
$30,947

—%

Total debt securities
Weighted average yield 2:
U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency residential
MBS - non-agency commercial
ABS
Corporate and other debt securities

1.99%
3.96
3.75
2.80
2.44
5.50
3.18
2.16
2.79
2.71%
1 The amortized cost and fair value of investments in debt securities are presented based on remaining contractual maturity, with the exception of MBS and ABS, 
which are based on estimated average life. Actual cash flows may differ from contractual maturities because borrowers may have the right to call or prepay obligations 
with or without penalties.
2 Weighted average yields are based on amortized cost and presented on an FTE basis.

1.82%
3.19
4.78
2.46
1.97
5.50
2.26
1.95
2.50
2.34%

2.19%
2.91
3.77
2.92
2.49
—
3.18
7.20
—
2.81%

2.81
3.57
3.28
2.76
—
3.42
—
—
3.23%

5.10
6.31
3.27
—
6.00
—
—
3.19
3.36%

Total debt securities

—%

45

 
The securities AFS portfolio is managed as part of our overall 
liquidity management and ALM process to optimize income and 
portfolio value over an entire interest rate cycle while mitigating 
the associated risks. Changes in the size and composition of the 
portfolio  reflect  our  efforts  to  maintain  a  high  quality,  liquid 
portfolio,  while  managing  our  interest  rate  risk  profile.  The 
amortized cost of the portfolio increased $656 million during the 
year  ended  December  31,  2017,  due  primarily  to  increased 
holdings  of  agency  residential  and  commercial  MBS,  non-
agency  commercial  MBS,  and  municipal  securities,  offset 
largely by a decline in U.S. Treasury securities and a reduction 
in other equity securities due to decreased holdings of FHLB of 
Atlanta stock and mutual fund investments. The fair value of the 
securities AFS  portfolio  increased  $744  million  compared  to 
December 31,  2016,  due  primarily  to  the  aforementioned 
changes in the portfolio mix and an $88 million increase in net 
unrealized gains. At December 31, 2017, the overall securities 
AFS portfolio was in a $31 million net unrealized gain position, 
compared  to  a  net  unrealized  loss  position  of  $57  million  at 
December 31, 2016.

During the fourth quarter of 2017, we sold and subsequently 
reinvested  approximately  $3  billion  of  securities AFS  with  a 
similar mix and higher yields (primarily within U.S. Treasury 
securities and agency residential MBS), resulting in net realized 
losses of $109 million for the fourth quarter of 2017. We expect 
this  repositioning  to  increase  annual  interest  income  by 
approximately  $20  million  beginning  in  2018,  all  else  being 
equal. For the year ended December 31, 2017, we recorded $108 
million in net realized losses related to the sale of securities AFS, 
compared to net realized gains of $4 million and $21 million for 
the  years  ended  December 31,  2016  and  2015,  respectively. 
OTTI credit losses recognized in earnings for both the year ended 
December 31, 2017 and 2015 were immaterial and there were 
no OTTI credit losses recognized in earnings for the year ended 
December  31,  2016.  For  additional  information  on  our 
accounting  policies,  composition,  and  valuation  assumptions 
related to the securities AFS portfolio, see Note 1, "Significant 
Accounting Policies," to our 2016 Annual Report on Form 10-
K, as well as Note 5, "Securities Available for Sale," and the 
“Trading  Assets  and  Derivative  Instruments  and  Securities 
Available for Sale” section of Note 18, “Fair Value Election and 
Measurement,” to the Consolidated Financial Statements in this 
Form 10-K.

For the year ended December 31, 2017, the average yield 
on the securities AFS portfolio was 2.49%, compared to 2.29% 
for the year ended December 31, 2016. The increase in average 
yield was due primarily to shifts in portfolio mix, lower premium 
amortization, and higher benchmark interest rates in the current 

year.  See  additional  discussion  related  to  average  yields  on 
securities AFS in the "Net Interest Income/Margin" section of 
this MD&A.

 The securities AFS portfolio had an effective duration of 
4.5  years  at  December 31,  2017  compared  to  4.6  years  at 
December 31,  2016.  Effective  duration  is  a  measure  of  price 
sensitivity of a bond portfolio to an immediate change in market 
interest rates, taking into consideration embedded options. An 
effective duration of 4.5 years suggests an expected price change 
of approximately 4.5% for a 100 basis point instantaneous and 
parallel change in market interest rates.

The credit quality and liquidity profile of the securities AFS 
portfolio  remained  strong  at  December 31,  2017  and, 
consequently, we believe that we have the flexibility to respond 
to  changes  in  the  economic  environment  and  take  actions  as 
opportunities arise to manage our interest rate risk profile and 
balance liquidity risk against investment returns. Over the longer 
term, the size and composition of the securities AFS portfolio 
will reflect balance sheet trends, our overall liquidity objectives, 
and interest rate risk management objectives. Accordingly, the 
size  and  composition  of  the  securities  AFS  portfolio  could 
change over time.

Federal Home Loan Bank and Federal Reserve Bank Stock
We previously acquired capital stock in the FHLB of Atlanta as 
a precondition for becoming a member of that institution. As a 
member, we are able to take advantage of competitively priced 
advances as a wholesale funding source and to access grants and 
low-cost 
loans  for  affordable  housing  and  community 
development projects, among other benefits. At December 31, 
2017, we held a total of $15 million of capital stock in the FHLB
of Atlanta, a decrease of $117 million compared to December 31, 
2016 due to a decline in long-term FHLB advances over the same 
period.  See  additional  information  regarding  changes  in  our 
long-term debt in the "Borrowings" section of this MD&A. For 
the  years  ended  December  31,  2017,  2016,  and  2015,  we 
recognized  dividends  related  to  FHLB  capital  stock  of  $6 
million, $5 million, and $11 million, respectively.

Similarly,  to  remain  a  member  of  the  Federal  Reserve 
System, we are required to hold a certain amount of capital stock, 
determined as either a percentage of the Bank’s capital or as a 
percentage of total deposit liabilities. At December 31, 2017, we 
held $403 million of Federal Reserve Bank of Atlanta stock, an 
increase of $1 million compared to December 31, 2016. For the 
years ended December 31, 2017, 2016, and 2015, we recognized 
dividends related to Federal Reserve Bank of Atlanta stock of 
$9 million, $8 million, and $24 million, respectively.

46

DEPOSITS

Composition of Average Deposits

(Dollars in millions)
Noninterest-bearing deposits
Interest-bearing deposits:

NOW accounts
Money market accounts
Savings
Consumer time
Other time

Total consumer and commercial deposits

Brokered time deposits
Foreign deposits

Total deposits

Year Ended December 31
2016
$43,400

2017
$43,655

2015
$42,102

45,009
53,592
6,519
5,626
5,148
159,549
941
421
$160,911

40,949
53,795
6,285
5,852
3,908
154,189
926
123
$155,238

35,161
50,518
6,165
6,443
3,813
144,202
888
218
$145,308

Table 15

% of Total Deposits
2016

2017

2015

27%

28%

29%

28
33
4
4
3
99
1
—
100%

26
35
4
4
2
99
1
—
100%

24
35
4
4
3
99
1
—
100%

During 2017, we experienced continued deposit growth across 
most of our product categories, while maintaining a favorable 
deposit mix. See Table 2, Table 3, and the "Net Interest Income/
Margin"  section  in  this  MD&A  for  additional  information 
regarding average deposit balances, rates paid, and associated 
impacts on net interest income. See Note 5, "Securities Available 
for Sale," to the Consolidated Financial Statements in this Form 
10-K  for  information  regarding  collateral  pledged  to  secure 
public deposits.

Average consumer and commercial deposits increased $5.4 
billion, or 3%, compared to 2016, driven by broad-based growth 
across both of our business segments, which reflects success in 
deepening and growing client relationships. Consumer deposit 
growth  was  driven  by  targeted  client  outreach,  improved 
execution  across  our  branch  network,  leveraging  new  pricing 
capabilities, and a daily focus on meeting our clients' deposit 

needs  across  all  channels.  Commercial  deposit  growth  was 
driven by our continued focus on meeting client needs through 
the deployment of new deposit product offerings combined with 
the growth of our liquidity specialist team, which attracted new 
deposits and business relationships. 

Consumer and commercial deposit growth remains one of 
our key areas of focus. During 2017, we continued to deepen our 
relationships  with  existing  clients,  grow  our  client  base,  and 
increase deposits, while managing the rates we paid for deposits. 
We  maintained  pricing  discipline  through  a  judicious  use  of 
competitive  rates  in  select  products  and  markets.  Looking 
forward to 2018, we continue to be focused on maximizing the 
value proposition of deposits for our clients, outside of the rate 
paid,  by  meeting  more  of  our  clients'  needs  through  strategic 
investments in talent and technology.

Contractual maturities of time deposits in denominations of $100,000 or more at December 31, 2017 are presented in Table 16:

(Dollars in millions)
Remaining Contractual Maturity:

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

Total

Consumer and
Other Time

Brokered Time

Total

Table 16

$609
521
1,103
4,004
$6,237

$37
27
41
880
$985

$646
548
1,144
4,884
$7,222

Refer to the "Contractual Obligations" section of this MD&A and Note 11, "Borrowings and Contractual Commitments," to the 
Consolidated Financial Statements in this Form 10-K for additional information regarding time deposit maturities.

47

 
BORROWINGS

Short-Term Borrowings

Short-term  borrowings  at  December  31  consisted  of  the 
following:

(Dollars in millions)
Funds purchased
Securities sold under agreements to

repurchase

Other short-term borrowings

Total short-term borrowings

Table 17

2016

$2,116

1,633
1,015

$4,764

2017

$2,561

1,503
717

$4,781

Our short-term borrowings at December 31, 2017 increased $17 
million  from  December 31,  2016,  driven  by  a  $445  million 
increase in funds purchased, offset largely by decreases of $298 
million  and  $130  million  in  other  short-term  borrowings  and 
securities sold under agreements to repurchase, respectively. The 
reduction in other short-term borrowings was due to decreases 
in  master  notes  outstanding,  dealer  collateral  held,  and  other 
borrowings  in  connection  with  the  December  2016  Pillar 
acquisition  of  $133  million,  $83  million,  and  $81  million, 
respectively.

Long-Term Debt

Long-term debt at December 31 consisted of the following:

(Dollars in millions)
Parent Company Only:

Senior, fixed rate
Senior, variable rate
Subordinated, fixed rate
Junior subordinated, variable rate

Total

Less: Debt issuance costs

Total Parent Company debt

Subsidiaries 1:

Senior, fixed rate 2
Senior, variable rate
Subordinated, fixed rate

Total

Less: Debt issuance costs
Total subsidiaries debt

Total long-term debt 3

Table 18

2017

2016

$3,379
267
200
628
4,474
8
4,466

3,609
512
1,206
5,327
8
5,319

$3,818
314
200
627
4,959
9
4,950

2,539
2,613
1,651
6,803
5
6,798

$9,785

$11,748

1 77% and 88% of total subsidiary debt was issued by the Bank as of December 
31, 2017 and 2016, respectively.
2 Includes leases and other obligations that do not have a stated interest rate.
3 Includes $530 million and $963 million of long-term debt measured at fair value 
at December 31, 2017 and 2016, respectively.

During the year ended December 31, 2017, our long-term debt 
decreased by $2.0 billion, or 17%. This decrease was driven by 
$2.8 billion of FHLB advance terminations and maturities, $1.5 
billion  of  senior  note  maturities,  and  $188  million  of 

48

subordinated  note  maturities.  Partially  offsetting 
these 
reductions were our issuances of $1.0 billion of 3-year fixed rate 
senior notes, $300 million of 3-year floating rate senior notes, 
and $1.0 billion of 5-year fixed rate senior notes under our Global 
Bank Note program, as well as an increase in direct finance leases 
of $212 million during the year ended December 31, 2017. 

In the first quarter of 2018, we issued $500 million of 5-
year senior notes that pay a fixed annual coupon rate of 3.00% 
under our Global Bank Note program. We may call these notes 
beginning on August 2, 2018 under a "make-whole" provision, 
and they mature on February 2, 2023. Also in the first quarter of 
2018,  we  issued  $750  million  of  3-year  fixed-to-floating  rate 
senior notes under our Global Bank Note program. The notes 
pay a fixed annual coupon rate of 2.59% until January 29, 2020 
and pay a floating coupon rate of 3-month LIBOR plus 29.75 
basis points thereafter. We may call these notes beginning on 
January 29, 2020, and they mature on January 29, 2021. Similar 
to  our  debt  issuances  in  2017,  these  issuances  allowed  us  to 
supplement our funding sources at favorable borrowing rates and 
pay down maturing borrowings.

CAPITAL RESOURCES

Regulatory Capital
Our  primary  federal  regulator,  the  Federal  Reserve,  measures 
capital  adequacy  within  a  framework 
that  sets  capital 
requirements relative to the risk profiles of individual banks. The 
framework assigns risk weights to assets and off-balance sheet 
risk exposures according to predefined classifications, creating 
a base from which to compare capital levels. We measure capital 
adequacy using the standardized approach to the FRB's Basel III
Final Rule. Basel III capital categories are discussed below.

CET1 is limited to common equity and related surplus (net 
of treasury stock), retained earnings, AOCI, and common equity 
minority  interest,  subject  to  limitations.  Certain  regulatory 
adjustments  and  exclusions  are  made  to  CET1,  including 
removal of goodwill, other intangible assets, certain DTAs, and 
certain defined benefit pension fund net assets. Further, banks 
employing the standardized approach to Basel III were granted 
a  one-time  permanent  election  to  exclude  AOCI  from  the 
calculation of regulatory capital. We elected to exclude AOCI 
from the calculation of our CET1. 

Tier  1  capital  includes  CET1,  qualified  preferred  equity 
instruments, qualifying minority interest not included in CET1, 
subject to limitations, and certain other regulatory deductions. 
Tier 2 capital includes qualifying portions of subordinated debt, 
trust preferred securities and minority interest not included in 
Tier 1 capital, ALLL up to a maximum of 1.25% of RWA, and 
a  limited  percentage  of  unrealized  gains  on  equity  securities. 
Total capital consists of Tier 1 capital and Tier 2 capital. 

To be considered "adequately capitalized," we are subject 
to  minimum  CET1, Tier  1  capital,  and Total  capital  ratios  of 
4.5%, 6%, and 8%, respectively, plus, in 2017 and 2016, CCB
amounts of 1.25% and 0.625%, respectively, are required to be 
maintained  above  the  minimum  capital  ratios.  The  CCB  will 
continue to increase each year through January 1, 2019, when 
the  CCB  amount  will  be  fully  phased-in  at  2.5%  above  the 
minimum  capital  ratios.  The  CCB  places  restrictions  on  the 
amount  of  retained  earnings  that  may  be  used  for  capital 

distributions  or  discretionary  bonus  payments  as  risk-based 
capital ratios approach their respective “adequately capitalized” 
minimum capital ratios plus the CCB. To be considered “well-
capitalized,”  Tier  1  and  Total  capital  ratios  of  6%  and  10%, 
respectively, are required.

We are also subject to a Tier 1 leverage ratio requirement, 
which measures Tier 1 capital against average total assets less 
certain deductions, as calculated in accordance with regulatory 
guidelines. The minimum leverage ratio threshold is 4% and is 
not subject to the CCB.

A transition period applies to certain capital elements and 
risk weighted assets, where phase-in percentages are applicable 
in  the  calculations  of  capital  and  RWA.  One  of  the  more 
significant transitions required by the Basel III Final Rule relates 
to the risk weighting applied to MSRs, which will impact the 
CET1 ratio during the transition period when compared to the 
CET1  ratio  that  is  calculated  on  a  fully  phased-in  basis. 
Specifically, the fully phased-in risk weight of MSRs is 250%, 
while the risk weight to be applied during the transition period 
is 100%.

In the third quarter of 2017, the OCC, the FRB, and the FDIC 
("the federal banking agencies") issued two NPRs in an effort to 
simplify certain aspects of the capital rules. In August 2017, a 

Transitions  NPR  was  issued,  which  would  extend  certain 
transition provisions currently in the capital rules for banks with 
less than $250 billion in total consolidated assets. In September 
2017, a Simplifications NPR was issued, which would apply a 
simpler treatment for certain exposures and capital calculations 
for banks with less than $250 billion in total consolidated assets. 
The Simplifications NPR also includes certain clarifications and 
technical amendments to the capital rules.

In November 2017, the federal banking agencies finalized 
a rule extending the existing capital requirements for MSRs and 
certain other items. The rule was finalized to prevent different 
rules  from  taking  effect  while  the  federal  banking  agencies
consider a broader simplification of the capital rules. The final 
rule  applies  only  to  banks  that  are  not  subject  to  advanced 
approach capital rules, which are generally banks with less than 
$250 billion in total consolidated assets and less than $10 billion 
in total foreign exposure. The rule became effective on January 
1, 2018. The transition period was previously applicable from 
January  1,  2015  through  December  31,  2017,  but  with  the 
finalization  of  the  aforementioned  Transitions  NPR,  the 
transition period has been extended into 2018. 

Table  19  presents  the  Company's  transitional  Basel  III 

regulatory capital metrics.

Regulatory Capital Metrics 1

(Dollars in millions)

Regulatory capital:

CET1

Tier 1 capital

Total capital

Assets:

RWA

Average total assets for leverage ratio

Risk-based ratios:

CET1
CET1 - fully phased-in 2
Tier 1 capital

Total capital

Leverage

Total shareholders’ equity to assets

December 31,
2017

December 31,
2016

December 31,
2015

Table 19

$17,141

19,622

23,028

$175,950

200,141

$16,953

18,186

21,685

$176,825

197,272

$16,421

17,804

20,668

$164,851

183,763

9.74%

9.59%

9.96%

9.59

11.15

13.09

9.80

12.21

9.43

10.28

12.26

9.22

11.53

9.80

10.80

12.54

9.69

12.28

1 We calculated these measures based on the methodology specified by our primary regulator, which may differ from the calculations used by other financial services 
companies that present similar metrics.
2 The CET1 ratio on a fully phased-in basis at December 31, 2017 is estimated. See Table 30, "Selected Financial Data and Reconcilement of Non-U.S. GAAP 
Measures," in this MD&A for a reconciliation of our transitional CET1 ratio to our fully phased-in, estimated CET1 ratio.

All of our capital ratios increased compared to December 31, 
2016,  driven  primarily  by  growth  in  retained  earnings  and  a 
decrease in RWA due to decreased off-balance sheet exposures. 
In addition, the Tier 1 capital and Total capital ratios were both 
favorably impacted by our Series G and Series H preferred stock 
issuances  in  2017,  detailed  in  the  "Capital  Actions"  section 
below. At December 31, 2017, our capital ratios were well above 
current regulatory requirements.

Our estimate of the fully phased-in CET1 ratio of 9.59% at 
December 31,  2017  considers  a  250%  risk-weighting  for 
residential and commercial mortgage servicing rights, which is 
the primary driver for the difference in the transitional CET1 

ratio  compared  to  the  estimated  fully  phased-in  ratio  at 
December 31,  2017.  Our  estimated  fully  phased-in  ratio  is  in 
excess of the 4.5% minimum CET1 ratio, and is also in excess 
of the 7.0% limit that includes the minimum level of 4.5% plus 
the 2.5% fully phased-in CCB. See Table 30 , "Selected Financial 
Data and Reconcilement of Non-U.S. GAAP Measures," in this 
MD&A for a reconciliation of our fully phased-in CET1 ratio. 
Also  see  Note  13,  "Capital,"  to  the  Consolidated  Financial 
Statements  in  this  Form  10-K  for  additional  information 
regarding  our  regulatory  capital  adequacy  requirements  and 
metrics.

49

Capital Actions
We declared and paid common dividends of $634 million, or 
$1.32 per common share, during the year ended December 31, 
2017, compared to $498 million, or $1.00 per common share, 
during the year ended December 31, 2016. Additionally, we paid 
dividends on our preferred stock of $94 million, $66 million, and 
$64 million during the years ended December 31, 2017, 2016, 
and 2015, respectively.

Various regulations administered by federal and state bank 
regulatory authorities restrict the Bank's ability to distribute its 
retained earnings. At December 31, 2017, 2016, and 2015, the 
Bank's capacity to pay cash dividends to the Parent Company 
under these regulations totaled approximately $2.5 billion, $2.5 
billion, and $2.7 billion, respectively.

During  the  first  quarter  of  2017,  we  repurchased  $414 
million of our outstanding common stock, which included $240 
million  under  our  2016  capital  plan  and  an  incremental  $174 
million pursuant to the 1% of Tier 1 capital de minimis exception 
allowed under the applicable 2016 Capital Plan Rule. During the 
second  quarter  of  2017,  we  repurchased  an  additional  $240 
million of our outstanding common stock at market value, which 
completed  our  authorized  $960  million  of  common  equity 
repurchases as approved by the Board in conjunction with the 
2016 capital plan. 

In the second quarter of 2017, we announced capital plans 
in response to the Federal Reserve's review of and non-objection 
to our 2017 capital plan submitted in conjunction with the 2017 
CCAR. Our 2017 capital plan includes increases in our share 
repurchase  program  and  quarterly  common  stock  dividend, 
while  maintaining  our  level  of  preferred  stock  dividends. 
Specifically, the 2017 capital plan authorized the repurchase of 
up  to  $1.32  billion  of  our  outstanding  common  stock  to  be 
completed  between  the  third  quarter  of  2017  and  the  second 
quarter  of  2018,  as  well  as  a  54%  increase  in  our  quarterly 
common stock dividend from $0.26 per share to $0.40 per share, 
beginning in the third quarter of 2017. During the second half 
of  2017,  we  repurchased  $660  million  of  our  outstanding 
common stock at market value as a part of this 2017 capital plan. 
In the first half of 2018, we expect to repurchase approximately 
$660 million of additional outstanding common stock at market 
value,  which  would  complete  our  repurchase  of  authorized 
shares as approved by the Board in conjunction with the 2017 
capital plan. We currently plan to submit our 2018 capital plan 
for review by the Federal Reserve in conjunction with the 2018 
CCAR in April 2018.

In  May  2017,  we  issued  depositary  shares  representing 
ownership interest in 7,500 shares of Perpetual Preferred Stock, 
Series G, with no par value and $100,000 liquidation preference 
per share (the "Series G Preferred Stock"). As a result of this 
issuance,  we  received  net  proceeds  of  approximately  $743 
million after the underwriting discount, but before expenses. The 
Series G Preferred Stock has no stated maturity and will not be 
subject  to  any  sinking  fund  or  other  obligation  to  redeem, 
repurchase,  or  retire  the  shares.  Dividends  for  the  shares  are 
noncumulative and, if declared, will be payable semi-annually 
beginning on December 15, 2017 through June 15, 2022 at a rate 
per  annum  of  5.05%,  and  payable  quarterly  beginning  on 
September 15, 2022 at a rate per annum equal to the three-month 
LIBOR plus 3.10%. By its terms, we may redeem the Series G 
Preferred Stock on any dividend payment date occurring on or 

50

after June 15, 2022 or at any time within 90 days following a 
regulatory capital event, at a redemption price of $100,000 per 
share plus any declared and unpaid dividends. Except in certain 
limited  circumstances,  the  Series  G  Preferred  Stock  does  not 
have any voting rights.

In  November  2017,  we 

issued  depositary  shares 
representing  ownership  interest  in  5,000  shares  of  Perpetual 
Preferred  Stock,  Series  H,  with  no  par  value  and  $100,000
liquidation preference per share (the "Series H Preferred Stock"). 
The Series H Preferred Stock has no stated maturity and will not 
be  subject  to any  sinking  fund  or  other  obligation to  redeem, 
repurchase,  or  retire  the  shares.  Dividends  for  the  shares  are 
noncumulative and, if declared, will be payable semi-annually 
beginning on June 15, 2018 through December 15, 2027 at a rate 
per annum of 5.125%, and payable quarterly beginning on March 
15, 2028 at a rate per annum equal to the three-month LIBOR 
plus 2.79%. By its terms, we may redeem the Series H Preferred 
Stock  on  any  dividend  payment  date  occurring  on  or  after 
December 15, 2027 or at any time within 90 days following a 
regulatory capital event, at a redemption price of $100,000 per 
share plus any declared and unpaid dividends. Except in certain 
limited  circumstances,  the  Series  H  Preferred  Stock  does  not 
have any voting rights. As a result of this issuance, we received 
net  proceeds  of  approximately  $496  million  after 
the 
underwriting discount, but before expenses, and we intend to use 
the net proceeds for general corporate purposes, including the 
previously  announced  redemption  of  all  outstanding  5.875% 
Series E Preferred Stock depositary shares on March 15, 2018. 
The redemption of Series E Preferred Stock depositary shares is 
expected to reduce our Tier 1 capital and Total capital ratios by 
approximately 25 basis points, all else being equal. See Part II, 
Item 5 of this Form 10-K for additional information regarding 
our  share  repurchase  activity,  and  Note  13,  "Capital,"  to  the 
Consolidated  Financial  Statements  in  this  Form  10-K  for 
additional information regarding our capital actions. 

Given  our  strong  capital  position  combined  with  our 
improved  earnings  trajectory,  we  should  have  capacity  to 
increase capital returns to our owners, the specifics of which will 
depend upon our rigorous capital planning process.

CRITICAL ACCOUNTING POLICIES

Our significant accounting policies are integral to understanding 
our financial performance and are described in detail in Note 1, 
“Significant Accounting Policies,” to the Consolidated Financial 
Statements  in  this  Form  10-K.  We  have  identified  certain 
accounting  policies  as  being  critical  because  (1)  they  require 
judgment about matters that are highly uncertain and (2) different 
estimates  that  could  be  reasonably  applied  would  result  in 
materially different outcomes with respect to the recognition and 
measurement  of  certain  assets,  liabilities,  commitments,  and 
contingencies,  with  corresponding  impacts  on  earnings.  Our 
accounting and reporting policies are in accordance with U.S. 
GAAP, and they conform to general practices within the financial 
services  industry.  We  have  established  detailed  policies  and 
control procedures that are intended to ensure that these critical 
accounting estimates are well controlled and applied consistently 
from  period  to  period,  and  that  the  process  for  changing 

methodologies occurs in an appropriate manner. The following 
is a description of our current critical accounting policies.

Contingencies
We  face  uncertainty  with  respect  to  the  outcomes  of  various 
contingencies, including the allowance for credit losses and legal 
and regulatory matters.

Allowance for Credit Losses
The allowance for credit losses is composed of the ALLL and 
the reserve for unfunded commitments. The ALLL represents 
our estimate of probable losses inherent in the LHFI portfolio 
based on current economic conditions. The ALLL is increased 
by the provision for loan losses and reduced by loan charge-offs, 
net of recoveries. The ALLL is determined based on our review 
of certain LHFI that are individually evaluated for impairment 
and  pools  of  LHFI  with  similar  risk  characteristics  that  are 
evaluated on a collective basis. Our loss estimate includes an 
assessment of internal and external influences on credit quality 
that may not be fully reflected in the historical loss, risk-rating, 
or other indicative data.

Large commercial nonaccrual loans and certain commercial 
and consumer loans whose terms have been modified in a TDR, 
are  reviewed  to  determine  the  amount  of  specific  allowance 
required in accordance with applicable accounting guidance. For 
this purpose, we consider the most probable source of repayment, 
including the present value of the loan's expected future cash 
flows,  the  fair  value  of  the  underlying  collateral less  costs  of 
disposition,  or  the  loan's  estimated  market  value.  We  use 
assumptions and methodologies that are relevant to assess the 
extent of impairment in the portfolio and employ judgment in 
assigning  or  estimating  internal  risk  ratings,  market  and 
collateral values, discount rates, and loss rates.

General  allowances  are  established  for  loans  and  leases 
grouped into pools that have similar characteristics. The ALLL 
Committee estimates probable losses by evaluating quantitative 
and qualitative factors for each loan portfolio segment, including 
net charge-off trends, internal risk ratings, changes in internal 
risk ratings, loss forecasts, collateral values, geographic location, 
delinquency rates, nonperforming and restructured loan status, 
origination  channel,  product  mix,  underwriting  practices, 
industry conditions, and economic trends. In addition to these 
factors, the consumer and residential portfolio segments consider 
borrower  FICO  scores  and  the  commercial  portfolio  segment 
considers single name borrower concentration.

Estimated collateral values are based on appraisals, broker 
price  opinions,  automated  valuation  models,  other  collateral-
specific  information,  and/or  relevant  market  information, 
supplemented  when  applicable  with  valuations  performed  by 
internal valuation professionals. Their values reflect an orderly 
disposition, inclusive of marketing costs. In limited instances, 
we adjust externally provided appraisals for justifiable and well 
supported reasons, such as an appraiser not being aware of certain 
collateral-specific factors or recent sales information. Appraisals 
generally represent the “as is” value of the collateral but may be 
adjusted based on the intended disposition strategy. 

Our  determination  of  the ALLL  for  commercial  loans  is 
sensitive  to  the  assigned  internal  risk  ratings  and  inherent 

expected  loss  rates. A  downgrade  of  one  level  in  the  PD  risk 
ratings for all commercial loans and leases would have increased 
the ALLL by approximately $474 million at December 31, 2017. 
If the estimated loss severity rates for the entire commercial loan 
portfolio were increased by 10%, the ALLL for the commercial 
portfolio  would  increase  by  approximately  $107  million  at 
December 31, 2017. 

The  allowance  for  consumer  loans  is  also  sensitive  to 
changes  in  estimated  loss  severity  rates.  If  the  estimated  loss 
severity rates for these loans increased by 10%, the total ALLL 
for the consumer portfolio would increase by approximately $46 
million  at  December 31,  2017.  These  sensitivity  analyses  are 
intended to provide insights into the impact of adverse changes 
in risk rating and estimated loss severity rates and do not imply 
any expectation of future deterioration in the risk ratings or loss 
rates. Given current processes employed, management believes 
the  risk  ratings  and  inherent  loss  rates  currently  assigned  are 
appropriate. It is possible that others, given the same information, 
could reach different conclusions that could be material to our 
financial statements. 

In addition to the ALLL, we estimate probable losses related 
to unfunded lending commitments, such as letters of credit and 
binding  unfunded  loan  commitments.  Unfunded  lending 
commitments  are  analyzed  and  segregated  by  risk  using  our 
internal  risk  rating  scale.  These  risk  classifications,  in 
combination  with  probability  of  commitment  usage,  and  any 
other pertinent information, are utilized in estimating the reserve 
for unfunded lending commitments.

Our  financial  results  are  affected  by  the  changes  in  the 
allowance for credit losses. This process involves our analysis 
of complex internal and external variables, and it requires that 
we exercise judgment to estimate an appropriate allowance for 
credit losses. Changes in the financial condition of individual 
borrowers,  economic  conditions,  or  the  condition  of  various 
markets  in  which  collateral  may  be  sold  could  require  us  to 
significantly decrease or increase the level of the allowance for 
credit  losses.  Such  an  adjustment  could  materially  affect  net 
income.  For  additional  discussion  of  the  ALLL  see  the 
“Allowance  for  Credit  Losses”  and  “Nonperforming Assets” 
sections  in  this  MD&A  as  well  as  Note  1,  “Significant 
Accounting Policies,” Note 6, “Loans,” and Note 7, “Allowance 
for Credit Losses,” to the Consolidated Financial Statements in 
this Form 10-K.

Legal and Regulatory Matters
We are parties to numerous claims and lawsuits arising in the 
course of our normal business activities, some of which involve 
claims for substantial amounts, and the outcomes of which are 
not  within  our  complete  control  or  may  not  be  known  for 
prolonged periods of time. Management is required to assess the 
probability of loss and amount of such loss, if any, in preparing 
our financial statements.

We evaluate the likelihood of a potential loss from legal or 
regulatory  proceedings  to  which  we  are  a  party. We  record  a 
liability for such claims only when a loss is considered probable 
and  the  amount  can  be  reasonably  estimated.  The  liability  is 
recorded in Other liabilities in the Consolidated Balance Sheets 
and the related expense is recorded in the applicable category of 
Noninterest expense, depending on the nature of the legal matter, 

51

in the Consolidated Statements of Income. Significant judgment 
may  be  required  in  determining  both  probability  of  loss  and 
whether an exposure is reasonably estimable. Our estimates are 
subjective  based  on  the  status  of  the  legal  or  regulatory 
proceedings, the merits of our defenses, and consultation with 
in-house and outside legal counsel. In many such proceedings, 
it  is  not  possible  to  determine  whether  a  liability  has  been 
incurred or to estimate the ultimate or minimum amount of that 
liability  until  the  matter  is  close  to  resolution. As  additional 
information becomes available, we reassess the potential liability 
related to pending claims and may revise our estimates.

Due to the inherent uncertainties of the legal and regulatory 
processes in the jurisdictions in which we operate, our estimates 
may  be  materially  different  than  the  actual  outcomes,  which 
could have material effects on our business, financial condition, 
and results of operations. See Note 19, “Contingencies,” to the 
Consolidated Financial Statements in this Form 10-K for further 
discussion.

Estimates of Fair Value
The objective of a fair value measurement is to use market-based 
inputs or assumptions, when available, to estimate the price that 
would be received to sell an asset or paid to transfer a liability 
in  an  orderly  transaction  between  market  participants  at  the 
measurement  date.  When  observable  market  prices  from 
transactions for identical assets or liabilities are not available, 
we evaluate pricing for similar assets or liabilities. If observable 
market  prices  for  such  assets  or  liabilities  are  unavailable  or 
impracticable  to  obtain,  we  employ  other  techniques  for 
estimating fair value (for example, obtaining third party price 
quotes or using modeling techniques such as discounted cash 
flows).  The  resulting  valuation  may  include  significant 
judgments, particularly when the market for an asset or liability 
is not active.

Fair  value  measurements  for  assets  and  liabilities  that 
include significant inputs that are not observable in the market 
are classified as level 3 measurements in the fair value hierarchy. 
We have instituted various processes and controls surrounding 
these  measurements  to  ensure  appropriate  methodologies  are 
utilized. We continue to maintain a cross-functional approach 
when estimating the fair value of these difficult to value financial 
instruments. This includes input from not only the related line 
of  business,  but  also  from  risk  management  and  finance,  to 
ultimately arrive at an appropriate estimate of the instrument's 
fair value. This process often involves the gathering of multiple 
sources of information, including broker quotes, values provided 
by pricing services, trading activity in other similar instruments, 
market indices, and pricing matrices. 

Modeling techniques incorporate our assessments regarding 
assumptions that market participants would use in pricing the 
asset  or  the  liability,  including  assumptions  about  the  risks 
inherent in a particular valuation technique. These assessments 
are subjective; the use of different assumptions could result in 
material changes to these fair value measurements. We employed 
significant unobservable inputs when estimating the fair value 
of certain trading assets and derivatives, IRLCs, securities AFS, 
residential  LHFS,  LHFI  accounted  for  at  fair  value,  and 
residential MSRs.

52

We record all single-family residential MSRs at fair value 
on a recurring basis. The fair value of residential MSRs is based 
on  discounted  cash  flow  analyses  and  can  vary  significantly 
quarter  to  quarter  as  market  conditions  and  projected  interest 
rates  change.  We  provide  disclosure  of  the  key  economic 
assumptions  used  to  measure  residential  MSRs,  including  a 
sensitivity analysis to adverse changes to these assumptions, in 
Note  9,  “Goodwill  and  Other  Intangible  Assets,”  to  the 
Consolidated  Financial  Statements  in  this  Form  10-K.  This 
sensitivity analysis does not take into account hedging activities 
discussed in the “Other Market Risk” section of this MD&A.

Overall,  the  financial  impact  of  the  level  3  financial 
instruments did not have a material impact on our liquidity or 
capital. Table 20 discloses assets and liabilities measured at fair 
value  on  a  recurring  basis  that  are  classified  as  level  3 
measurements.

Level 3 Assets and Liabilities

Table 20

(Dollars in millions)

Assets:
Trading assets and derivative instruments 1
Securities AFS

Residential LHFS

LHFI

Residential MSRs

Total level 3 assets

Total assets

Total assets measured at fair value on a

recurring basis

Level 3 assets as a % of total assets

Level 3 assets as a % of total assets

measured at fair value on a recurring basis

Liabilities:

Trading liabilities and derivative instruments

Total level 3 liabilities

Total liabilities

Total liabilities measured at fair value on a

recurring basis

Level 3 liabilities as a % of total liabilities

Level 3 liabilities as a % of total liabilities

measured at fair value on a recurring basis

1 Includes IRLCs.

December 31

2017

2016

$16

490

—

196

1,710

$2,412

$28

633

12

222

1,572

$2,467

$205,962

$204,875

39,992

42,073

1.2%

6.0%

$16

$16

1.2%

5.9%

$22

$22

$180,808

$181,257

2,049

2,392

—%

0.8%

—%

0.9%

Level 3 trading assets and derivative instruments decreased by 
$12  million  during  the  year  ended  December 31,  2017,  due 
primarily to the transfer of certain derivative instruments that are 
not  actively  traded  in  the  market.  Level  3  securities  AFS 
decreased by $143 million during the year ended December 31, 
2017, due primarily to the sale of FHLB of Atlanta stock as well 
as the continued paydowns and sales on securities AFS. For a 
detailed discussion regarding level 2 and 3 financial instruments 
and  valuation  methodologies  for  each  class  of  financial 
instrument,  see  Note  18,  “Fair  Value  Election  and 
Measurement,” and Note 1, “Significant Accounting Policies,” 
to the Consolidated Financial Statements in this Form 10-K.

Goodwill
At December 31, 2017, our reporting units were Consumer and 
Wholesale. See Note 20, "Business Segment Reporting," to the 
Consolidated Financial Statements in this Form 10-K for further 
discussion of our reportable business segments. We conduct a 
goodwill  impairment  test  at  the  reporting  unit  level  at  least 
annually as of October 1, or more frequently as events occur or 
circumstances change that would more-likely-than-not reduce 
the fair value of a reporting unit below its carrying amount. Based 
on  our  annual  goodwill  impairment  test  at  October  1,  2017, 
October 1, 2016, and October 1, 2015, we determined that for 
each  of  our  reporting  units'  with  goodwill  balances,  the  fair 
values  were  in  excess  of  their  respective  carrying  values; 
therefore,  no  goodwill  impairment  was  recognized.  For 
additional  information,  see  Note  1,  “Significant  Accounting 
Policies,” and Note 9, “Goodwill and Other Intangible Assets,” 
to the Consolidated Financial Statements in this Form 10-K.

In the analysis as of October 1, 2017, the carrying value of 
equity of the reporting units, as well as Corporate Other, was 
determined by allocating our total equity to each reporting unit 
based  on  RWA  using  our  actual Tier  1  capital  ratio  as  of  the 
measurement date. Tier 1 capital was utilized as it most closely 
aligns with equity as reported under U.S. GAAP. Appropriate 
adjustments were made to each reporting unit’s allocation using 
Tier 1 capital to conform with U.S. GAAP equity, namely to add 
back equity tied to goodwill and other intangible assets. We view 
this approach of determining the reporting units' carrying values 
based on regulatory capital as an objective measurement of the 
equity  that  a  market  participant  would  require  to  operate  the 
reporting units.

The goodwill impairment analysis estimates the fair value 
of equity using discounted cash flow analyses. The inputs and 
assumptions specific to each reporting unit are incorporated in 
the  valuations,  including  projections  of  future  cash  flows, 
discount rates, and an estimated long-term growth rate. We assess 
the reasonableness of the estimated fair value of the reporting 
units by comparing implied valuation multiples with valuation 
multiples  from  guideline  companies  and  by  comparing  the 
aggregate estimated fair value of the reporting units to our market 
capitalization over a reasonable period of time. Significant and 
sustained  declines  in  our  market  capitalization  could  be  an 
indication of potential goodwill impairment.

Multi-year  financial  forecasts  are  developed  for  each 
reporting unit by considering several key business drivers such 
as new business initiatives, client service and retention standards, 
market  share  changes,  anticipated  loan  and  deposit  growth, 
forward interest rates, historical performance, and industry and 
economic  trends,  among  other  considerations  that  a  market 
participant  would  consider  in  valuing  the  reporting  units. 
Discount rates are estimated based on the Capital Asset Pricing 
Model, which considers the risk-free interest rate, market risk 
premium,  beta,  size  premiums,  and 
risk 
adjustments specific to a particular reporting unit. The discount 
rates are also calibrated based on risks related to the projected 
cash flows of each reporting unit.

idiosyncratic 

The estimated fair values of the reporting units are highly 
sensitive  to  changes  in  these  estimates  and  assumptions; 
therefore, in some instances, changes in these assumptions could 
impact whether the fair value of a reporting unit is greater than 

53

its carrying value. We perform sensitivity analyses around these 
assumptions  in  order  to  assess  the  reasonableness  of  the 
assumptions, and the resulting estimated fair values. Ultimately, 
potential future changes in these assumptions may impact the 
estimated fair value of a reporting unit and cause the fair value 
of the reporting unit to be below its carrying value. Additionally, 
the carrying value of a reporting unit's equity could change based 
on market conditions, asset growth, preferred stock issuances, 
or the risk profile of those reporting units, which could impact 
whether  or  not  the  fair  value  of  a  reporting  unit  is  less  than 
carrying value.

Income Taxes
We are subject to income tax laws of the U.S., its states, and the 
municipalities where we conduct business. We estimate income 
tax  expense  based  on  amounts  expected  to  be  owed  to  these 
various tax jurisdictions. The estimated income tax expense or 
benefit is reported in the Consolidated Statements of Income.

Accrued taxes represent the net estimated amount due to or 
to be received from tax jurisdictions either currently or in the 
future and are reported in Other liabilities or Other assets on the 
Consolidated Balance Sheets. In estimating accrued taxes, we 
assess the appropriate tax treatment of transactions and filing 
positions  after  considering  statutes,  regulations, 
judicial 
precedent, and other pertinent information. The income tax laws 
are  complex  and  subject  to  different  interpretations  by  the 
taxpayer  and  the  relevant  government  taxing  authorities. 
Significant judgment is required in determining the tax accruals 
and  in  evaluating  our  tax  positions,  including  evaluating 
uncertain tax positions. Changes in the estimate of accrued taxes 
occur periodically due to changes in tax rates, interpretations of 
tax laws, the status of examinations by the tax authorities, and 
newly enacted statutory, judicial, and regulatory guidance that 
could impact the relative merits and risks of tax positions. These 
changes, when they occur, impact tax expense and can materially 
affect our operating results. We review our tax positions quarterly 
and  make  adjustments  to  accrued  taxes  as  new  information 
becomes available.

Deferred income tax assets represent amounts available to 
reduce income taxes payable in future years. Such assets arise 
due to temporary differences between the financial reporting and 
the tax bases of assets and liabilities, as well as from NOL and 
tax credit carryforwards. We regularly evaluate the realizability 
of DTAs. A valuation allowance is recognized for a DTA if, based 
on the weight of available evidence, it is more-likely-than-not 
that  some  portion  or  all  of  the  DTA  will  not  be  realized.  In 
determining  whether  a  valuation  allowance  is  necessary,  we 
consider the level of taxable income in prior years to the extent 
that carrybacks are permitted under current tax laws, as well as 
estimates of future pre-tax and taxable income and tax planning 
strategies that would, if necessary, be implemented. We currently 
maintain a valuation allowance for certain state carryforwards 
and  certain  other  state  DTAs.  Since  we  expect  to  realize  our 
remaining  federal  and  state  DTAs,  no  valuation  allowance  is 
deemed necessary against these DTAs at December 31, 2017. 
For additional income tax information, refer to the "Provision 
for  Income Taxes"  section  in  this  MD&A  as  well  as  Note  1, 
“Significant  Accounting  Policies,”  and  Note  14,  “Income 

Taxes,” to the Consolidated Financial Statements in this Form 
10-K.

Employee Benefit Plans
We maintain various pension and other postretirement benefit 
plans for employees who meet certain requirements. Continued 
changes  in  the  size  and  characteristics  of  the  workforce  or 
changes in the plan's design could result in a partial settlement 
of the pension plan. If lump sum payments were to exceed the 
total  of  interest  cost  and  service  cost  for  the  year,  settlement 
accounting  would  require  immediate  recognition  through 
earnings of any net actuarial gain or loss recorded in AOCI based 
on  the  fair  value  of  plan  assets  and  plan  obligations  prior  to 
settlement, and recognition of any related settlement costs.

We utilize a full yield curve approach to estimate the service 
and interest cost components of net periodic benefit expense for 
pension  and  other  postretirement  benefit  plans  by  applying 
specific spot rates along the yield curve used in the determination 
of the benefit obligation to the relevant projected cash flows. For 
additional information on our pension and other postretirement 
benefit plans see Note 1, “Significant Accounting Policies,” and 
Note  15,  “Employee  Benefit  Plans,”  to  the  Consolidated 
Financial Statements in this Form 10-K.

ENTERPRISE RISK MANAGEMENT

In the normal course of business, we are exposed to various risks. 
We have established an ER framework to identify and manage 
these risks and support key business objectives. Underlying this 
framework  are  limits,  metrics,  policies,  procedures,  and 
processes designed to effectively identify, monitor, and manage 
risk in line with our overall risk appetite. Our risk management 
philosophy  is  not  to  eliminate  risk  entirely  but  rather  to  only 
accept risks that can be effectively managed and balanced with 
acceptable  returns  while  also  meeting  regulatory  and  safety/
soundness objectives.

The Board is responsible for establishing our desired overall 
risk  appetite  and  for  oversight  of  risk  and  risk  management 
processes through the BRC. The BRC reports to and assists the 
Board in overseeing and reviewing information regarding, but 
not limited to, ER management (i.e., credit, market, liquidity, 
operational, 
technology,  compliance,  and  strategic  risk), 
enterprise  capital  adequacy,  liquidity  adequacy,  and  material 
regulatory matters. The CRO provides overall vision, direction, 
and leadership regarding our ER management framework and 
risk management culture. The CRO reports directly to the CEO 
and the BRC.

ER  establishes  sound  risk  and  governance  frameworks, 
policies,  procedures,  and  processes  that  focus  on  identifying, 
measuring, analyzing, managing, and reporting the risks that we 
face. ER fulfills its independent risk oversight responsibilities 
by  developing,  deploying,  and  monitoring  enterprise-wide 
frameworks  and  policies  to  manage  risk.  At  its  core,  ER's 
objective is to deliver sophisticated risk management capabilities 
throughout the organization that:
•  Align risk taking with the risk appetite established by the 

Board,

54

• 

• 

Identify, measure, analyze, manage, escalate, and report risk 
at the transaction, portfolio, and enterprise levels,
Support client facing businesses as they seek to balance risk 
taking with business and safety/soundness objectives.

Promote sound processes and regulatory compliance,

•  Optimize decision making,
• 
•  Maximize shareholder value, and
• 

Support our purpose of Lighting the Way to Financial Well-
Being,  support  our  performance  promise  of  Leading  the 
Movement  for  Financial  Well-Being,  and  conform  to  our 
guiding principles of Client First, One Team, Executional 
Excellence, and Profitable Growth.

Our risk management culture operates within the context of our 
broader,  purpose-driven  corporate  culture.  Risk  awareness 
within our culture informs the manner in which teammates act 
in  the  absence  of  specific  guidance.  SunTrust  teammates  are 
expected to: 
• 
•  Exhibit  strong  personal  and  professional  risk  leadership, 

Put the client first,

integrity, and ethics in all business dealings,

•  Understand 

risks  encountered  and  demonstrate  a 
commitment to managing risks through individual actions,
•  Demonstrate  honesty,  fairness,  and  respect  in  all  internal 

and external interactions, and

•  Emphasize the importance of executional excellence in all 

activities.

Our  ER  structure  and  processes  are  founded  upon  a 
comprehensive  risk  management  roles  and  responsibilities 
framework,  which  is  critical  to  ensuring  that  we  proactively 
identify, measure, monitor, escalate, report, and control risks on 
an ongoing basis. The risk management roles and responsibilities 
framework delineates accountabilities across four dimensions.
•  Risk  Takers/Owners  develop 

to  drive 
opportunities;  operate  within  the  policies,  standards,  and 
limits set by Risk Oversight; and escalate changes in the 
business  or  the  risk  environment  that  could  affect  risk 
appetite.

strategies 

•  Business Managers and Risk Administrators provide input 
to  and  accept  articulation  of  risk  appetite  in  policies  and 
limits; identify, assess, and manage the risks the business 
takes or is exposed to while conducting its activities; apply 
and  operate  controls;  and  provide  business  analyses  and 
support. 

•  Risk Oversight provides credible, independent challenge to 
risk  takers;  establishes  the  risk  appetite  framework  and 
facilitates risk appetite expression by the Board; sets limits 
to  the  business;  evaluates/approves  limit  exceptions;  sets 
risk management policies, standards, tools, methodologies, 
and programs; and independently monitors and reports on 
our aggregate portfolio view of risks.

•  Risk Assurance provides independent assessments of risk 
management  and  the  internal  control  framework  and 
systems 
include 
compliance with policies and standards, effectiveness of the 
independent risk management function, and completeness 
and accuracy of information. 

the  Board.  These  assessments 

to 

In  practice,  risk  measurement  activities  occur  at  all  pertinent 
levels  of  the  organization,  including  at  the  business  segment, 
corporate  functions,  and  enterprise-wide  levels.  ER  uses  a 
variety  of  tools,  reports,  and  analyses  to  evaluate  specific 
exposures in order to:
• 
• 

Provide a holistic view of risks,
Present quantitative and qualitative assessments of current 
risks,  which  may  be  predictive  of  future  risk  trends  and 
levels, and
Promote  transparency  by  fostering  direct  communication 
between Executive Management/Board and key executives/
Risk Managers.

• 

ER  governance  is  supported  by  a  number  of  chartered  risk-
focused  senior  management  committees.  These  “executive 
committees”  are  responsible  for  ensuring  effective  risk 
measurement and management within their respective areas of 
authority, and include the ERC, ALCO, CC, PMC, and EBPC.
•  ERC  is  chaired  by  the  CRO  and  supports  the  CRO  in 
identifying, measuring, and managing the Bank’s aggregate 
risk profile. ERC maintains a comprehensive perspective of 
existing  and  prospective  risks;  the  effectiveness  of  risk 
management  frameworks,  policies  and  activities;  and  the 
execution of risk management processes.

•  ALCO  is  chaired  by  the  CFO  and  ensures  that  proper 
measurement,  monitoring,  management,  and  control 
processes are in place to achieve our ALM and Liquidity 
Risk Management goals. 

•  CC is also chaired by the CFO and ensures that the proper 
measurement,  monitoring,  management,  and  control 
processes are in place to achieve our strategic capital goals, 
while also continuing to manage our risk-capital balance to 
meet  regulatory  capital  adequacy  and  stakeholder  return 
expectations. 
PMC is chaired by the Wholesale Segment Executive and 
facilitates  the  development  of  portfolio  strategy  that 
addresses  capital  utilization,  balance  sheet  optimization, 
and risk concentrations. 

• 

•  EBPC is chaired by the Chief Human Resources Officer and 
is in place to assess and make determinations regarding our 
business practices to ensure alignment with core purpose, 
principles, and values, and to share best practices. EBPC 
also  serves  as  the  forum  for  enterprise  reputational  risk 
exposures.

The CEO, CFO, and CRO are members of each of these executive 
committees. Additionally, other executive and senior officers are 
members of these committees based upon their responsibilities 
and subject matter expertise.

ER  continually  refines  our  risk  governance  structures, 
frameworks and management limits, policies, procedures, and 
processes 
in  our  operating 
environment and/or corporate goals and strategies.

to  reflect  ongoing  changes 

Credit Risk Management
Credit risk refers to the potential for economic loss arising from 
the failure of clients to meet their contractual agreements on all 
credit instruments, including on-balance sheet exposures from 
loans, leases, and investment securities, as well as contingent 

exposures  including  unfunded  commitments,  letters  of  credit, 
credit  derivatives,  and  counterparty  risk  under  derivative 
products. As credit risk is an essential component of many of the 
products and services we provide to our clients, the ability to 
accurately  measure  and  manage  credit  risk  is  integral  to 
maintaining the long-run profitability and capital adequacy of 
our  business.  We  commit 
to  maintain  and  enhance  a 
comprehensive credit system to meet business requirements and 
comply with evolving regulatory standards. 

and 

governance 

frameworks 

ER  establishes  and  oversees  adherence  to  the  credit  risk 
management 
policies, 
independently measures, analyzes, and reports on loan portfolio 
and risk trends, and actively participates in the formulation of 
our  credit  strategies.  Credit  risk  officers  and  supporting 
teammates within our lines of business are direct participants in 
the  origination,  underwriting,  and  ongoing  management  of 
credit. They work to promote an appropriate balance between 
our risk management and business objectives through adherence 
to  established  policies,  procedures,  and  standards. Credit 
Review, one of our independent assurance functions, regularly 
assesses and reports on business unit and enterprise asset quality, 
and  the  integrity  of  our  credit  processes. Additionally,  total 
borrower exposure limits and concentration risks are established 
and monitored. Credit risk may be mitigated through purchase 
of credit loss protection via third party insurance and/or use of 
credit derivatives such as CDS.

Borrower/counterparty  (obligor)  risk  and  facility  risk  is 
evaluated using our risk rating methodology, which is utilized 
in all lines of business. We use various risk models to estimate 
both  expected  and  unexpected  loss,  which  incorporates  both 
internal and external default and loss experience. To the extent 
possible, we collect and use internal data to ensure the validity, 
reliability,  and  accuracy  of  our  risk  models  used  in  default, 
severity, and loss estimation.

Operational Risk Management
We face ongoing and emerging risks and regulations related to 
the activities that surround the delivery of banking and financial 
products, and we depend on our ability to process, record, and 
monitor a large number of client transactions on a continuous 
basis. As the potential for operational loss remains elevated and 
as  client,  public,  and  regulatory  expectations  regarding 
operational  and  information  security  have  increased,  we 
continue  to  enhance  our  efforts  to  safeguard  and  monitor  our 
operational systems and infrastructure.

Our business activities and operations rely on our systems, 
computers,  software,  data,  networks,  the  internet,  and  digital 
applications, as well as the systems and infrastructure of third 
parties. Our business, financial, accounting, data processing, or 
other systems and infrastructure may stop operating properly or 
become disabled or damaged as a result of a number of factors 
and influences that are wholly or partially beyond our control, 
such as potential failures, disruptions, and breakdowns, whether 
as a result of human error or intentional attack, as well as market 
conditions, fraudulent activities, natural disasters, electrical or 
telecommunications  outages,  political  or  social  matters 
including  terrorist  acts,  country  risk,  vendor  risk,  legal  risk, 
cyber-attacks,  and  other  security  risks.  The  use  of  digital 
technologies introduces cyber-security risk that can manifest in 

55

the  form  of  information  theft,  criminal  acts  by  individuals, 
groups, or nation states, or other disruptions to our Company's, 
clients', or third parties' business operations. We use a wide array 
of  techniques  to  secure  our  operations  and  proprietary 
information  such  as  Board  approved  policies  and  programs, 
network  monitoring,  access  controls,  dedicated  security 
personnel, and defined insurance instruments, as well as consult 
with third-party data security experts.

the  Board,  and  our 

To  control  cyber-security  risk,  we  maintain  an  active 
information security program that is designed to conform with 
FFIEC guidance. This information security program is aligned 
with  our  operational  risks  and  is  overseen  by  executive 
management, 
independent  audit 
function. This  program  continually  monitors  and  evaluates 
threats, events, and the performance of its business operations 
and continually adapts and modifies its risk reduction activities 
accordingly. We also utilize appropriate cyber-security insurance 
that  controls  against  certain  losses,  expenses,  and  damages 
associated with cyber risk. 

Further,  we  recognize  our  role  in  the  overall  national 
payments system, and we have adopted the National Institute of 
Standards and Technology's Cyber Security Framework. We also 
fully  participate  in  the  federally  recognized  financial  sector 
information  sharing  organization  structure,  known  as  the 
Financial  Services  Information  Sharing  and Analysis  Center. 
Digital  technology  is  constantly  evolving,  and  new  and 
unforeseen threats and actions by others may disrupt operations 
or result in losses beyond our risk control thresholds. Although 
we invest substantial time and resources to manage and reduce 
cyber risk, it is not possible to completely eliminate this risk. 

We believe that effective management of operational risk, 
defined as the risk of loss resulting from inadequate or failed 
internal processes, people, and systems, or from external events, 
plays  a  major  role  in  both  the  level  and  the  stability  of  our 
profitability.  Our  Enterprise  Operational  Risk  Management 
function  oversees  an  enterprise-wide  framework  intended  to 
identify, assess, control, monitor, and report on operational risks. 
These processes support our goals to minimize future operational 
losses and strengthen our performance by maintaining sufficient 
capital to absorb operational losses that are incurred. 

Operational Risk Management is overseen by our EORO. 
The  operational  risk  governance  structure 
includes  an 
operational  risk  manager  and  support  staff  assigned  to  each 
business segment and corporate function. These risk managers 
are responsible for oversight of risk management within their 
areas in compliance with ER's policies and procedures.

Market Risk Management
Market  risk  refers  to  potential  losses  arising  from  changes  in 
interest rates, foreign exchange rates, equity prices, commodity 
prices, and other relevant market rates or prices. Interest rate risk, 
defined  as  the  exposure  of  net  interest  income  and  MVE  to 
changes in interest rates, is our primary market risk and mainly 
arises  from  changes  in  the  structure  and  composition  of  our 
balance sheet. Variable rate loans, prior to any hedging related 
actions, were approximately 58% of total loans at December 31, 
2017, and after giving consideration to hedging related actions, 
were approximately 48% of total loans. Approximately 5% of 

our variable rate loans at December 31, 2017 had coupon rates 
that were equal to a contractually specified interest rate floor. In 
addition to interest rate risk, we are also exposed to market risk 
in our trading instruments measured at fair value. Our ALCO
meets regularly and is responsible for reviewing our ALM and 
liquidity  risk  position  in  conformance  with  the  established 
policies and limits designed to measure, monitor, and control 
market risk.

Market Risk from Non-Trading Activities
The primary goal of interest rate risk management is to control 
exposure to interest rate risk within policy limits approved by 
the Board. These limits reflect our appetite for interest rate risk 
over both short-term and long-term horizons. No limit breaches 
occurred during the year ended December 31, 2017. 

The major sources of our non-trading interest rate risk are 
timing differences in the maturity and repricing characteristics 
of assets and liabilities, changes in the absolute level and shape 
of the yield curve, as well as the embedded optionality in our 
products and related customer behavior. We measure these risks 
and  their  impact  by  identifying  and  quantifying  exposures 
through  the  use  of  sophisticated  simulation  and  valuation 
models,  which,  as  described  in  additional  detail  below,  are 
employed  by  management  to  understand  net  interest  income 
sensitivity and MVE sensitivity. These measures show that our 
interest  rate  risk  profile  is  modestly  asset  sensitive  at 
December 31, 2017. 

MVE and net interest income sensitivity are complementary 
interest  rate  risk  metrics  and  should  be  viewed  together.  Net 
interest income sensitivity captures asset and liability repricing 
differences  for  one  year,  inclusive  of  forecast  balance  sheet 
changes,  and  is  considered  a  shorter  term  measure.  MVE
sensitivity  captures  the  change  in  the  discounted  net  present 
value of all on- and off-balance sheet items and is considered a 
longer term measure.

Positive  net  interest  income  sensitivity  in  a  rising  rate 
environment indicates that over the forecast horizon of one year, 
asset  based  interest  income  will  increase  more  quickly  than 
liability  based 
to  balance  sheet 
composition. A  negative  MVE  sensitivity  in  a  rising  rate 
environment  indicates  that  the  value  of  financial  assets  will 
decrease more than the value of financial liabilities. 

interest  expense  due 

One  of  the  primary  methods  that  we  use  to  quantify  and 
manage interest rate risk is simulation analysis, which we use to 
model net interest income from assets, liabilities, and derivative 
positions under various interest rate scenarios and balance sheet 
structures. This analysis measures the sensitivity of net interest 
income  over  a  two-year  time  horizon,  which  differs  from  the 
interest rate sensitivities in Table 21, which reflect a one-year 
time horizon. Key assumptions in the simulation analysis (and 
in the valuation analysis discussed below) relate to the behavior 
of interest rates and spreads, the changes in product balances, 
and  the  behavior  of  loan  and  deposit  clients  in  different  rate 
environments. This analysis incorporates several assumptions, 
the  most  significant  of  which  relate  to  the  repricing  and 
behavioral fluctuations of deposits with indeterminate or non-
contractual maturities.

As  the  future  path  of  interest  rates  is  not  known,  we  use 
simulation analysis to project net interest income under various 

56

scenarios including implied forward, deliberately extreme, and 
other  scenarios  that  are  unlikely.  The  analyses  may  include 
different  scenarios  including  rapid  and  gradual  ramping  of 
interest rates, rate shocks, basis risk analysis, and yield curve 
twists. Specific strategies are also analyzed to determine their 
impact on net interest income levels and sensitivities.

The sensitivity analysis presented in Table 21 is measured 
as  a  percentage  change  in  net  interest  income  due  to 
instantaneous  moves  in  benchmark  interest  rates.  Estimated 
changes below are dependent upon material assumptions such 
as those previously discussed.

Net Interest Income Asset Sensitivity

Table 21

Estimated % Change in
Net Interest Income Over 12 Months 1

December 31, 2017

December 31, 2016

Rate Change
2.4%
+200 bps
1.4%
+100 bps
(1.0)%
 -50 bps
1 Estimated % change of net interest income is reflected on a non-FTE basis.

3.3%
1.9%
(2.7)%

Net  interest  income  asset  sensitivity  at  December 31,  2017 
decreased compared to December 31, 2016, driven primarily by 
growth in fixed rate consumer loans and a decrease in floating 
rate commercial loans. See additional discussion related to net 
interest income in the "Net Interest Income/Margin" section of 
this MD&A. 

We  also  perform  valuation  analyses,  which  we  use  for 
discerning  levels  of  risk  present  in  the  balance  sheet  and 
derivative positions that might not be taken into account in the 
net interest income simulation horizon. Whereas a net interest 
income simulation highlights exposures over a relatively short 
time horizon, our valuation analysis incorporates all cash flows 
over  the  estimated  remaining  life  of  all  balance  sheet  and 
derivative positions. 

The  valuation  of  the  balance  sheet,  at  a  point  in  time,  is 
defined as the discounted present value of asset and derivative 
cash flows minus the discounted present value of liability cash 
flows, the net of which is referred to as MVE. The sensitivity of 
MVE to changes in the level of interest rates is a measure of the 
longer-term  repricing  risk  and  embedded  optionality  in  the 
balance  sheet.  Similar  to  the  net  interest  income  simulation, 
MVE uses instantaneous changes in rates. However, MVE values 
only  the  current  balance  sheet  and  does  not  incorporate 
originations  of  new/replacement  business  or  balance  sheet 
growth that are used in the net interest income simulation model. 
As with the net interest income simulation model, assumptions 
about the timing and variability of balance sheet cash flows are 
critical  in  the  MVE  analysis.  Significant  MVE  assumptions 
include those that drive prepayment speeds, expected changes 
in balances, and pricing of the indeterminate deposit portfolios. 
At  December 31,  2017,  the  MVE  profile  in  Table  22 
indicates a decline in net balance sheet value due to instantaneous 
upward changes in rates. This MVE sensitivity is reported for 
both upward and downward rate shocks. 

Market Value of Equity Sensitivity

Table 22

Estimated % Change in MVE

December 31, 2017

December 31, 2016

Rate Change
+200 bps
+100 bps
 -50 bps

(7.6)%
(3.3)%
0.8%

(9.1)%
(4.2)%
1.5%

The  decrease  in  MVE  sensitivity  at  December  31,  2017
compared to December 31, 2016 was due to lower balance sheet 
duration, driven primarily by a decline in our outstanding active 
notional balance of receive-fixed, pay-variable commercial loan 
swaps, as well as tighter spreads on loans. While an instantaneous 
and  severe  shift  in  interest  rates  was  used  in  this  analysis  to 
provide an estimate of exposure under these rate scenarios, we 
believe that a gradual shift in interest rates would have a much 
more modest impact.

Since MVE measures the discounted present value of cash 
flows over the estimated lives of instruments, the change in MVE
does not directly correlate to the degree that earnings would be 
impacted  over  a  shorter  time  horizon  (i.e.,  the  current  year). 
Furthermore, MVE does not take into account factors such as 
future balance sheet growth, changes in product mix, changes in 
yield  curve  relationships,  and  changing  product  spreads  that 
could mitigate the impact of changes in interest rates. The net 
interest income simulation and valuation analyses do not include 
actions that management may undertake to manage this risk in 
response to anticipated changes in interest rates.

Market Risk from Trading Activities 
We manage market risk associated with trading activities using 
a  comprehensive  risk  management  approach,  which  includes 
VAR  metrics,  stress  testing,  and  sensitivity  analyses.  Risk 
metrics are measured and monitored on a daily basis at both the 
trading  desk  and  at  the  aggregate  portfolio  level  to  ensure 
exposures are in line with our risk appetite. Our risk measurement 
for covered positions subject to the Market Risk Rule takes into 
account trading exposures resulting from interest rate risk, equity 
risk,  foreign  exchange  rate  risk,  credit  spread  risk,  and 
commodity price risk. 

For  trading  portfolios,  VAR  measures  the  estimated 
maximum  loss  from  one  or  more  trading  positions,  given  a 
specified  confidence  level  and  time  horizon. VAR  results  are 
monitored daily against established limits. For risk management 
purposes, our VAR calculation is based on a historical simulation 
and measures the potential trading losses using a one-day holding 
period at a one-tail, 99% confidence level. This means that, on 
average, trading losses could exceed VAR one out of 100 trading 
days or two to three times per year. Due to inherent limitations 
of the VAR methodology, such as the assumption that past market 
behavior is indicative of future market performance, VAR is only 
one of several tools used to manage market risk. Other tools used 
to actively manage market risk include scenario analysis, stress 
testing, profit and loss attribution, and stop loss limits.

57

 
In addition to VAR, as required by the Market Risk Rule 
issued  by  the  U.S.  banking  regulators,  we  calculate  Stressed 
VAR, which is used as a component of the total market risk capital 
charge. We calculate the Stressed VAR risk measure using a ten-
day  holding  period  at  a  one-tail,  99%  confidence  level  and 
employ a historical simulation approach based on a continuous 
twelve-month historical window selected to reflect a period of 
significant  financial  stress  for  our  trading  portfolio.  The 
historical  period  used  in  the  selection  of  the  stress  window 
encompasses  all  recent  financial  crises.  Our  Stressed  VAR 
calculation uses the same methodology and models as regular 
VAR, which is a requirement under the Market Risk Rule. Table 
23 presents VAR and Stressed VAR for the year ended December 
31,  2017  and  2016,  as  well  as  VAR  by  Risk  Factor  at 
December 31, 2017 and 2016.

Value at Risk Profile

Table 23

Year Ended December 31

2017

2016

(Dollars in millions)

VAR (1-day holding period):

Period end
High
Low
Average

Stressed VAR (10-day holding period):

Period end
High
Low
Average

VAR by Risk Factor at period end (1-day holding period):

Equity risk
Interest rate risk
Credit spread risk

VAR total at period end (1-day diversified)

$1
2
3
2

trading  portfolio,  measured 

is 
The 
predominantly  comprised  of  four  sub-portfolios  of  covered 
positions:  (i)  credit  trading,  (ii)  fixed  income  securities,  (iii) 
interest rate derivatives, and (iv) equity derivatives. The trading 
portfolio  also  contains  other  sub-portfolios,  including  foreign 

terms  of  VAR, 

in 

$2
3
1
2

$52
110
22
54

$3
4
1
3

$37
118
8
37

$1
2
5
3

exchange  rate  and  commodity  derivatives;  however,  these 
trading risk exposures are not material. Our covered positions 
originate  primarily  from  underwriting,  market  making  and 
associated risk mitigating hedging activity, and other services 
for our clients. The trading portfolio's VAR profile, as illustrated 
in Table 23, is influenced by a variety of factors, including the 
size and composition of the portfolio, market volatility, and the 
correlation between different positions. Average daily VAR as 
well as period end VAR decreased for the year ended December 
31, 2017 compared to the same period in 2016. These decreases 
were driven primarily by lower levels of market volatility during 
2017, offset partially by the impact of higher balance sheet usage 
in  our  credit  trading  portfolio  as  a  result  of  favorable  market 
conditions and strong client demand. Average Stressed VAR as 
well as period end Stressed VAR, which are not influenced by 
current levels of market volatility, increased for the year ended 
December 31, 2017 compared to the same period in 2016. These 
increases were driven by the aforementioned increase in balance 
sheet  usage  in  our  credit  trading  portfolio,  as  well  as  higher 
stressed  exposures  associated  with  our  equity  derivatives 
portfolio.  Nonetheless,  our  Stressed  VAR  remains  within 
historical ranges. The trading portfolio of covered positions did 
not contain any correlation trading positions or on- or off-balance 
sheet securitization positions during the year ended December 
31, 2017 or 2016.

In accordance with the Market Risk Rule, we evaluate the 
accuracy  of  our  VAR  model  through  daily  backtesting  by 
comparing aggregate daily trading gains and losses (excluding 
fees, commissions, reserves, net interest income, and intraday 
trading)  from  covered  positions  with  the  corresponding  daily 
VAR-based measures generated by the model. As illustrated in 
the following graph for the twelve months ended December 31, 
2017,  there  were  no  firmwide  VAR  backtesting  exceptions 
during  this  period.  The  total  number  of  VAR  backtesting 
exceptions  over  the  preceding  twelve  months  is  used  to 
determine the multiplication factor for the VAR-based capital 
requirement  under 
the  Market  Risk  Rule.  The  capital 
multiplication  factor  increases  from  a  minimum  of  three  to  a 
maximum of four, depending on the number of exceptions. There 
was  no  change  in  the  capital  multiplication  factor  over  the 
preceding twelve months.

58

We have valuation policies, procedures, and methodologies for 
all covered positions. Additionally, trading positions are reported 
in accordance with U.S. GAAP and are subject to independent 
price  verification.  See  Note  17,  "Derivative  Financial 
Instruments"  and  Note  18,  "Fair  Value  Election  and 
Measurement" to the Consolidated Financial Statements in this 
Form 10-K, as well as the "Critical Accounting Policies" MD&A 
section of this Form 10-K for discussion of valuation policies, 
procedures, and methodologies. 

Model risk management:  Our approach regarding the validation 
and evaluation of the accuracy of our internal models, external 
models, and associated processes, includes developmental and 
implementation  testing  as  well  as  ongoing  monitoring  and 
maintenance  performed  by  the  various  model  developers,  in 
conjunction with model owners. Our MRMG is responsible for 
the independent model validation of all trading risk models. The 
includes  evaluation  of  all  model 
validation 
documentation as well as model monitoring and maintenance 
plans.  In  addition,  the  MRMG  performs  its  own  independent 
testing. We regularly review the performance of all trading risk 
models through our model monitoring and maintenance process 
to  preemptively  address  emerging  developments  in  financial 
markets, assess evolving modeling approaches, and to identify 
potential model enhancement. 

typically 

Stress testing:  We use a comprehensive range of stress testing 
techniques  to  help  monitor  risks  across  trading  desks  and  to 
augment standard daily VAR and other risk limits reporting. The 
stress testing framework is designed to quantify the impact of 
extreme, but plausible, stress scenarios that could lead to large 
unexpected losses. Our stress tests include historical repeats and 

simulations  using  hypothetical  risk  factor  shocks. All  trading 
positions within each applicable market risk category (interest 
rate risk, equity risk, foreign exchange rate risk, credit spread 
risk,  and  commodity  price  risk)  are 
in  our 
comprehensive  stress  testing  framework.  We  review  stress 
testing  scenarios  on  an  ongoing  basis  and  make  updates  as 
necessary  to  ensure  that  both  current  and  emerging  risks  are 
captured appropriately.

included 

Trading portfolio capital adequacy:  We assess capital adequacy 
on a regular basis, which is based on estimates of our risk profile 
and  capital  positions  under  baseline  and  stressed  scenarios. 
Scenarios consider significant risks, including credit risk, market 
risk, and operational risk. Our assessment of capital adequacy 
arising from market risk includes a review of risk arising from 
material  portfolios  of  covered  positions.  See  the  “Capital 
Resources” section in this MD&A for additional discussion of 
capital adequacy.

Liquidity Risk Management
Liquidity risk is the risk of being unable, at a reasonable cost, to 
meet  financial  obligations  as  they  come  due.  We  manage 
liquidity risk consistent with our ER management practices in 
order to mitigate our three primary liquidity risks: (i) structural 
liquidity  risk,  (ii)  market  liquidity  risk,  and  (iii)  contingency 
liquidity risk. Structural liquidity risk arises from our maturity 
transformation activities and balance sheet structure, which may 
create differences in the timing of cash inflows and outflows. 
Market liquidity risk, which we also describe as refinancing or 
refunding risk, constitutes the risk that we could lose access to 
the  financial  markets  or  the  cost  of  such  access  may  rise  to 
undesirable levels. Contingency liquidity risk arises from rare 

59

and  severely  adverse  liquidity  events;  these  events  may  be 
idiosyncratic or systemic, or a combination thereof.

is  consistent  with  applicable  policies,  procedures,  laws,  and 
regulations.

We mitigate these risks utilizing a variety of tested liquidity 
management techniques in keeping with regulatory guidance and 
industry  best  practices.  For  example,  we  mitigate  structural 
liquidity risk by structuring our balance sheet prudently so that 
we  fund  less  liquid  assets,  such  as  loans,  with  stable  funding 
sources, such as consumer and commercial deposits, long-term 
debt,  and  capital.  We  mitigate  market  liquidity  risk  by 
maintaining diverse borrowing resources to fund projected cash 
needs  and  structuring  our 
to  avoid  maturity 
concentrations. We test contingency liquidity risk from a range 
of potential adverse circumstances in our contingency funding 
scenarios. These  scenarios  inform  the  amount  of  contingency 
liquidity sources we maintain as a liquidity buffer to ensure we 
can  meet  our  obligations  in  a  timely  manner  under  adverse 
contingency liquidity events. 

liabilities 

Governance.  We  maintain  a  comprehensive  liquidity  risk 
governance structure in keeping with regulatory guidance and 
industry best practices. Our Board, through the BRC, oversees 
liquidity  risk  management  and  establishes  our  liquidity  risk 
appetite via a set of cascading risk limits. The BRC reviews and 
approves  risk  policies  to  establish  these  limits  and  regularly 
reviews  reports  prepared  by  senior  management  to  monitor 
compliance with these policies. The Board charges the CEO with 
determining  corporate  strategies  in  accordance  with  its  risk 
appetite and the CEO is a member of our ALCO, which is the 
executive  level  committee  with  oversight  of  liquidity  risk 
management. The ALCO regularly monitors our liquidity and 
compliance  with  liquidity  risk  limits,  and  also  reviews  and 
approves liquidity management strategies and tactics.

Management  and  Reporting  Framework.  Corporate Treasury, 
under the oversight of the ALCO, is responsible for managing 
consolidated liquidity risks we encounter in the course of our 
business.  In  so  doing,  Corporate  Treasury  develops  and 
implements  short-term  and  long-term  liquidity  management 
strategies,  funding  plans,  and  liquidity  stress  tests,  and  also 
monitors  early  warning  indicators;  all  of  which  assist  in 
identifying, measuring, monitoring, reporting, and managing our 
liquidity  risks.  Corporate  Treasury  primarily  monitors  and 
manages liquidity risk at the Parent Company and Bank levels 
as the non-bank subsidiaries are relatively small and ultimately 
rely upon the Parent Company as a source of liquidity in adverse 
environments.  However,  Corporate  Treasury  also  monitors 
liquidity developments of, and maintains a regular dialogue with, 
our other legal entities.

MRM conducts independent oversight and governance of 
liquidity risk management activities. For example, MRM works 
with Corporate Treasury to ensure our liquidity risk management 
practices  conform  to  applicable  laws  and  regulations  and 
evaluates  key  assumptions  incorporated  in  our  contingency 
funding scenarios.

Further,  the  internal  audit  function  performs  the  risk 
assurance  role  for  liquidity  risk  management.  Internal  audit 
conducts an independent assessment of the adequacy of internal 
controls, 
including  procedural  documentation,  approval 
processes, reconciliations, and other mechanisms employed by 
liquidity risk management and MRM to ensure that liquidity risk 

LCR requirements under Regulation WW require large U.S. 
banking organizations to hold unencumbered high-quality liquid 
assets  sufficient  to  withstand  projected  30-day  total  net  cash 
outflows, each as defined under the LCR rule. At December 31, 
2017, our LCR calculated pursuant to the rule was above the 
100% minimum regulatory requirement.

On  December 19,  2016,  the  FRB  published  a  final  rule 
implementing public disclosure requirements for BHCs subject 
to the LCR that will require them to publicly disclose quantitative 
and  qualitative  information  regarding  their  respective  LCR 
calculations on a quarterly basis. We will be required to begin 
disclosing elements under this final rule after October 1, 2018.
On May 3, 2016, the FRB, OCC, and the FDIC issued a joint 
proposed  rule  to  implement  the  NSFR.  The  proposal  would 
require  large  U.S.  banking  organizations  to  maintain  a  stable 
funding profile over a one-year horizon. The FRB proposed a 
modified  NSFR  requirement  for  BHCs  with  greater  than  $50 
billion but less than $250 billion in total consolidated assets, and 
less than $10 billion in total on balance sheet foreign exposure. 
The  proposed  NSFR  requirement  seeks 
to  (i)  reduce 
vulnerability  to  liquidity  risk  in  financial  institution  funding 
structures  and  (ii)  promote  improved  standardization  in  the 
measurement, management and disclosure of liquidity risk. The 
proposed  rule  contains  an  implementation  date  of  January 1, 
2018; however, a final rule has not yet been issued.

Uses of Funds. Our primary uses of funds include the extension 
of  loans  and  credit,  the  purchase  of  investment  securities, 
working capital, and debt and capital service. The Bank borrows 
from the money markets using instruments such as Fed Funds, 
Eurodollars, and securities sold under agreements to repurchase. 
At  December 31,  2017,  the  Bank  retained  a  material  cash 
position in its Federal Reserve account. The Parent Company 
also retained material cash position in its account with the Bank 
in  accordance  with  our  policies  and  risk  limits,  discussed  in 
greater detail below.

Sources of Funds. Our primary source of funds is a large, stable 
deposit base. Core deposits, predominantly made up of consumer 
and  commercial  deposits  originated  primarily  from  our  retail 
branch network and Wholesale client base, are our largest and 
most cost-effective source of funding. Total deposits increased 
to $160.8 billion at December 31, 2017, from $160.4 billion at 
December 31, 2016. 

We  also  maintain  access  to  diversified  sources  for  both 
secured and unsecured wholesale funding. These uncommitted 
sources  include  Fed  Funds  purchased  from  other  banks, 
securities sold under agreements to repurchase, FHLB advances, 
and  Global  Bank  Notes. Aggregate  borrowings  decreased  to 
$14.6  billion  at  December 31,  2017,  from  $16.5  billion  at 
December 31, 2016.

As  mentioned  above,  the  Bank  and  Parent  Company 
maintain programs to access the debt capital markets. The Parent 
Company maintains an SEC shelf registration from which it may 
issue senior or subordinated notes and various capital securities, 
such as common or preferred stock. Our Board has authorized 
the issuance of up to $5.0 billion of such securities under the 
SEC shelf registration, of which $1.7 billion and $3.0 billion of 

60

issuance capacity remained available at December 31, 2017 and 
December 31, 2016, respectively. The reduction in our SEC shelf 
registration issuance capacity during the year ended December 
31, 2017 was driven by the Parent Company's May 2017 issuance 
of  $750  million  of  Perpetual  Preferred  Stock,  Series  G  and 
November 2017 issuance of $500 million of Perpetual Preferred 
Stock,  Series  H.  See  the  "Capital  Resources"  section  of  this 
MD&A for additional information regarding our stock issuances. 
The  Bank  maintains  a  Global  Bank  Note  program  under 
which  it  may  issue  senior  or  subordinated  debt  with  various 
terms. In January 2017, the Bank issued $1.0 billion of 3-year 
fixed rate senior notes and $300 million of 3-year floating rate 
senior notes under this program. In July 2017, we issued $1.0 
billion of 5-year senior notes that pay a fixed annual coupon rate 
of 2.45% under our Global Bank Note program. At December 31, 
2017, the Bank retained $35.1 billion of remaining capacity to 
issue notes under the Global Bank Note program. See the “Recent 
Developments”  section  below  for  a  description  of  issuances 
subsequent to December 31, 2017 under this program.

Our  issuance  capacity  under  these  Bank  and  Parent 
Company programs refers to authorization granted by our Board, 
which is a formal program capacity and not a commitment to 
purchase by any investor. Debt and equity securities issued under 
these programs are designed to appeal primarily to domestic and 
investor 
international 
demand  for  these  securities  depends  upon  numerous  factors, 
including,  but  not  limited  to,  our  credit  ratings,  investor 
perception of financial market conditions, and the health of the 
banking sector. Therefore, our ability to access these markets in 
the future could be impaired for either idiosyncratic or systemic 
reasons.

investors.  Institutional 

institutional 

We assess liquidity needs that may occur in both the normal 
course of business and during times of unusual, adverse events, 
considering  both  on  and  off-balance  sheet  arrangements  and 
commitments  that  may  impact  liquidity  in  certain  business 
environments. We have contingency funding scenarios and plans 
that  assess  liquidity  needs  that  may  arise  from  certain  stress 
events  such  as  severe  economic  recessions,  financial  market 
disruptions, and credit rating downgrades. In particular, a ratings 
downgrade could adversely impact the cost and availability of 
some of our liquid funding sources. Factors that affect our credit 
ratings include, but are not limited to, the credit risk profile of 
our assets, the adequacy of our ALLL, the level and stability of 
our earnings, the liquidity profile of both the Bank and the Parent 

Company, the economic environment, and the adequacy of our 
capital base. 

As illustrated in Table 24, S&P assigned a “Positive” outlook 
on our credit rating, while both Moody’s and Fitch maintained 
“Stable” outlooks. Future credit rating downgrades are possible, 
although  not  currently  anticipated  given  these  “Positive”  and 
“Stable” credit rating outlooks.

Credit Ratings and Outlook

Table 24

December 31, 2017

Moody’s

S&P

Fitch

SunTrust Banks, Inc.:

Senior debt

Preferred stock

SunTrust Bank:

Long-term deposits

Short-term deposits

Senior debt

Outlook

Baa1

Baa3

BBB+

BB+

A1

P-1

Baal

Stable

A-

A-2

A-

Positive

Stable

A-

BB

A

F1

A-

Our investment portfolio is a use of funds and we manage the 
portfolio  primarily  as  a  store  of  liquidity,  maintaining  the 
majority of our securities in liquid and high-grade asset classes, 
such as agency MBS, agency debt, and U.S. Treasury securities; 
nearly all of these securities qualify as high-quality liquid assets 
under  the  U.S.  LCR  Final  Rule. At  December 31,  2017,  our 
securities  AFS  portfolio  contained  $26.8  billion  of 
unencumbered high-quality, liquid securities at market value.

As  mentioned  above,  we  evaluate  contingency  funding 
scenarios to anticipate and manage the likely impact of impaired 
capital markets access and other adverse liquidity circumstances. 
Our contingency plans also provide for continuous monitoring 
of  net  borrowed  funds  dependence  and  available  sources  of 
contingency  liquidity.  These  contingency  liquidity  sources 
include  available  cash  reserves,  the  ability  to  sell,  pledge,  or 
borrow  against  unencumbered  securities  in  our  investment 
portfolio, the capacity to borrow from the FHLB system or the 
Federal  Reserve  discount  window,  and  the  ability  to  sell  or 
securitize certain loan portfolios. Table 25 presents period end 
and average balances of our contingency liquidity sources for 
2017 and 2016. These sources exceed our contingency liquidity 
needs as measured in our contingency funding scenarios.

Contingency Liquidity Sources

Table 25

(Dollars in billions)

Excess reserves

Free and liquid investment portfolio securities

Unused FHLB borrowing capacity

Unused discount window borrowing capacity

Total

As of

Average for the Year Ended ¹ 

December 31, 2017 December 31, 2016 December 31, 2017 December 31, 2016

$2.6

26.8

23.8

18.2

$71.4

$2.5

27.6

21.8

17.0

$68.9

$2.9

27.4

22.2

17.6

$70.1

$2.9

24.8

22.1

17.2

$67.0

1 Average based upon month-end data, except excess reserves, which is based upon a daily average.

61

 
Parent  Company  Liquidity.  Our  primary  measure  of  Parent 
Company liquidity is the length of time the Parent Company can 
meet  its  existing  and  forecasted  obligations  using  its  cash 
resources. We measure and manage this metric using forecasts 
from  both  normal  and  adverse  conditions.  Under  adverse 
conditions, we measure how long the Parent Company can meet 
its  capital  and  debt  service  obligations  after  experiencing 
material attrition of short-term unsecured funding and without 
the support of dividends from the Bank or access to the capital 
markets.  In  accordance  with  these  risk  limits  established  by 
ALCO  and  the  Board,  we  manage  the  Parent  Company’s 
liquidity by structuring its net maturity schedule to minimize the 
amount of debt maturing within a short period of time. A majority 
of  the  Parent  Company’s  liabilities  are  long-term  in  nature, 
coming from the proceeds of issuances of our capital securities 
and 
the 
long-term  senior  and  subordinated  notes.  See 
“Borrowings”  section  of  this  MD&A,  as  well  as  Note  11, 
“Borrowings  and  Contractual  Commitments,” 
the 
Consolidated Financial Statements in this Form 10-K for further 
information regarding our debt.

to 

We  manage  the  Parent  Company  to  maintain  most  of  its 
liquid assets in cash and securities that it can quickly convert 
into  cash.  Unlike  the  Bank,  it  is  not  typical  for  the  Parent 
Company to maintain a material investment portfolio of publicly 
traded securities. We manage the Parent Company cash balance 
to provide sufficient liquidity to fund all forecasted obligations 
(primarily debt and capital service) for an extended period of 
months in accordance with our risk limits.

The primary uses of Parent Company liquidity include debt 
service, dividends on capital instruments, the periodic purchase 
of investment securities, loans to our subsidiaries, and common 
share repurchases. See further details of the authorized common 
share  repurchases  in  the  “Capital  Resources”  section  of  this 
MD&A  and  in  Part  II,  Item  2,  “Unregistered  Sales  of  Equity 
Securities  and  Use  of  Proceeds”  in  this  Form  10-K. We  fund 
corporate  dividends  with  Parent  Company  cash,  the  primary 
sources of which are dividends from our banking subsidiary and 

proceeds from the issuance of debt and capital securities. We are 
subject to both state and federal banking regulations that limit 
our  ability  to  pay  common  stock  dividends  in  certain 
circumstances.

Recent Developments. In the first quarter of 2018, we issued $500 
million of 5-year senior notes that pay a fixed annual coupon 
rate of 3.00% under our Global Bank Note program. We may 
call these notes beginning on August 2, 2018 under a "make-
whole" provision, and they mature on February 2, 2023. Also in 
the first quarter of 2018, we issued $750 million of 3-year fixed-
to-floating  rate  senior  notes  under  our  Global  Bank  Note 
program. The notes pay a fixed annual coupon rate of 2.59% 
until January 29, 2020 and pay a floating coupon rate of 3-month 
LIBOR  plus  29.75  basis  points  thereafter. We  may  call  these 
notes beginning on January 29, 2020, and they mature on January 
29, 2021. These issuances allowed us to supplement our funding 
sources  at  favorable  borrowing  rates  and  pay  down  maturing 
borrowings.

Other Liquidity Considerations. As presented in Table 26, we 
had  an  aggregate  potential  obligation  of  $87.4  billion  to  our 
clients  in  unused  lines  of  credit  at  December 31,  2017. 
Commitments to extend credit are arrangements to lend to clients 
who have complied with predetermined contractual obligations. 
We  also  had  $2.6  billion  in  letters  of  credit  outstanding  at 
December 31, 2017, most of which are standby letters of credit, 
which require that we provide funding if certain future events 
occur. Approximately  $238  million  of  these  letters  supported 
variable rate demand obligations at December 31, 2017. Unused 
commercial lines of credit decreased slightly since December 31, 
2016,  driven  by  revolver  utilization.  Residential  mortgage 
commitments  also  decreased  since  December 31,  2016,  due 
primarily  to  reduced  IRLC  volume  during  the  year  ended 
December 31, 2017. Additionally, unused CRE lines of credit 
decreased modestly since December 31, 2016, driven primarily 
by increased utilization of existing CRE lines of credit.

Unfunded Lending Commitments

(Dollars in millions)
Unused lines of credit:

Commercial
Residential mortgage commitments 1
Home equity lines
CRE 2
Credit card

Total unused lines of credit

Letters of credit:

Financial standby

Performance standby
Commercial

Total letters of credit

As of

Average for the Three Months Ended

December 31, 2017

December 31, 2016

December 31, 2017

December 31, 2016

Table 26

$59,625

3,036
10,086
4,139
10,533
$87,419

$2,453

125
14
$2,592

$59,803

4,240
10,336
4,468
9,798
$88,645

$2,777

130
19
$2,926

$59,120

3,556
10,101
3,963
10,488
$87,228

$2,633

121
16
$2,770

$58,865

5,864
10,353
4,386
9,726
$89,194

$2,716

131
19
$2,866

1 Includes residential mortgage IRLCs with notional balances of $1.7 billion and $2.6 billion at December 31, 2017 and 2016, respectively.
2 Includes commercial mortgage IRLCs and other commitments with notional balances of $240 million and $395 million at December 31, 2017 and 2016, respectively.

62

Other Market Risk
Other  sources  of  market  risk  include  the  risk  associated  with 
holding loans, securities designated for sale, and mortgage loan 
commitments, as well as the risk associated with our investment 
in  servicing  rights.  We  manage  the  risks  associated  with 
mortgage LHFS and our IRLCs on mortgage loans intended for 
sale.  The  mortgage  LHFS  and  IRLCs  consist  of  fixed  and 
adjustable rate residential and commercial mortgage loans. The 
risk associated with mortgage LHFS and IRLCs is the potential 
change in interest rates between the time the customer locks the 
rate on the anticipated loan and the time the loan is sold, which 
is typically 30-150 days.

We  manage  interest  rate  risk  predominantly  with  interest 
rate  swaps,  futures,  and  forward  sale  agreements,  where  the 
changes  in  value  of  the  instruments  substantially  offset  the 
changes  in  value  of  mortgage  LHFS  and  IRLCs.  IRLCs  on 
mortgage  loans  intended  for  sale  are  classified  as  derivative 
instruments  and  are  not  designated  for  hedge  accounting 
purposes.

All  servicing  rights  are  initially  measured  at  the  present 
value of future net cash flows that are expected to be received 
from  the  associated  servicing  portfolio.  The  initial  value  of 
servicing  rights  is  highly  dependent  upon  the  assumed 
prepayment speed of the servicing portfolio, which is driven by 
the level of certain key interest rates, primarily the current 30-
year  mortgage  rate.  Future  expected  net  cash  flows  from 
servicing a loan in the servicing portfolio would not be realized 
if the loan pays off earlier than anticipated.

We measure our residential MSRs at fair value on a recurring 
basis and hedge the risk associated with changes in fair value. 
Residential  MSRs  totaled  $1.7  billion  and  $1.6  billion  at 
December 31, 2017 and 2016, respectively, and are managed and 
monitored as part of a comprehensive risk governance process, 
which includes established risk limits.

We originated residential MSRs with fair values at the time 
of origination of $394 million and $312 million during 2017 and 
2016, respectively. Additionally, we purchased residential MSRs 
with a fair value of approximately $200 million during the year 
ended December 31, 2016. No residential MSRs were purchased 
during the year ended December 31, 2017. 

We recognized mark-to-market decreases in the fair value 
of residential MSRs of $248 million and $245 million during 
2017 and 2016, respectively. Changes in fair value include the 
UPB  decay  resulting  from  the  realization  of  monthly  net 
servicing cash flows as well as credit decay resulting from shifts 
in the underlying loans delinquency status. We recognized net 
losses related to residential MSRs, inclusive of fair value changes 
and related hedges, of $212 million and $175 million during 2017 
and 2016, respectively. Compared to the prior year, the increase 
in net losses related to residential MSRs was primarily driven 
by  higher  decay  combined  with  a  decrease  in  net  hedge 
performance in the current periods. All other servicing rights, 
which include commercial mortgage and consumer indirect loan 
servicing rights, are not measured at fair value on a recurring 

basis,  and  therefore,  are  not  subject  to  the  same  market  risks 
associated with residential MSRs.

We held a total net book value of approximately $22 million
and  $21  million  of  non-public  equity  exposures  (direct 
investments)  and  other  equity-related 
investments  at 
December 31, 2017 and 2016, respectively. We generally hold 
these investments as long-term investments. If conditions in the 
market deteriorate, these long-term investments and other assets 
could incur impairment charges.

OFF-BALANCE SHEET ARRANGEMENTS

In the ordinary course of business we engage in certain activities 
that  are  not  reflected  in  our  Consolidated  Balance  Sheets, 
generally referred to as "off-balance sheet arrangements." These 
activities involve transactions with unconsolidated VIEs as well 
as other arrangements, such as commitments and guarantees, to 
meet the financing needs of our clients and to support ongoing 
operations.  Additional  information  regarding  these  types  of 
activities is included in the "Liquidity Risk Management" section 
of  this  MD&A,  as  well  as  in  Note  10,  "Certain  Transfers  of 
Financial  Assets  and  Variable  Interest  Entities,"  Note  11, 
"Borrowings  and  Contractual  Commitments,"  and  Note  16, 
"Guarantees," to the Consolidated Financial Statements in this
Form 10-K.

and 

investments, 

Contractual Obligations
In the normal course of business, we enter into certain contractual 
obligations, including obligations to make future payments on 
our  borrowings,  partnership 
lease 
arrangements, as well as commitments to lend to clients and to 
fund  capital  expenditures  and  service  contracts.  Table  27
presents our significant contractual obligations at December 31, 
2017,  except  for  UTBs  (discussed  below),  short-term 
borrowings  (presented  in  the  "Borrowings"  section  of  this 
MD&A),  and  pension  and  other  postretirement  benefit  plans, 
disclosed  in  Note  15,  "Employee  Benefit  Plans,"  to  the 
Consolidated  Financial  Statements  in  this  Form  10-K.  For 
additional 
lending 
information  regarding  our  unfunded 
commitments,  time  deposits,  operating  leases,  and  long-term 
debt, refer to the "Liquidity Risk Management" and "Deposits" 
sections  of  this  MD&A,  as  well  as  Note  8,  "Premises  and 
Equipment,"  and  Note  11,  "Borrowings  and  Contractual 
Commitments," to the Consolidated Financial Statements in this
Form 10-K.

At December 31, 2017, we had UTBs of $141 million, which 
represent a reserve for tax positions that we have taken or expect 
to be taken in our tax returns, and which ultimately may not be 
sustained  upon  examination  by  taxing  authorities. Since  the 
ultimate  amount  and  timing  of  any  future  tax  settlements  are 
uncertain,  UTBs  have  been  excluded  from  Table  27. See 
additional  discussion  in  Note  14,  "Income  Taxes,"  to  the 
Consolidated Financial Statements in this Form 10-K.

63

(Dollars in millions)
Contractual Obligations:

Unfunded lending commitments
Consumer and other time deposits 1
Brokered time deposits 1
Long-term debt 1, 2
Operating leases
Purchase obligations 3
Commitments to fund partnership investments 4

Total

Less than 1
year

$25,265
4,720
105
1,235
205
278
690
$32,498

Payments Due by Period at December 31, 2017
More than 5
years

3-5 years

1-3 years

$23,421
3,890
432
2,327
378
336
—
$30,784

$29,259
1,451
372
2,981
318
98
—
$34,479

$12,066
2,015
76
3,258
657
247
—
$18,319

Table 27

Total

$90,011
12,076
985
9,801
1,558
959
690
$116,080

1 Amounts do not include interest.
2 Amounts do not include deduction of related debt issuance costs of $16 million.
3 For legally binding purchase obligations of $5 million or more, amounts include either termination fees under the associated contracts when early termination 
provisions exist, or the total potential obligation over the full contractual term for noncancelable purchase obligations. Payments made towards the purchase of 
goods or services under these contracts totaled $395 million in 2017.
4 Commitments to fund investments in affordable housing and other partnerships do not have defined funding dates as certain criteria must be met before we are 
obligated to fund. Accordingly, these commitments are considered to be due on demand for presentation purposes. See Note 10, "Certain Transfers of Financial 
Assets and Variable Interest Entities," to the Consolidated Financial Statements in this Form 10-K for additional information.

BUSINESS SEGMENTS

See Note 20, "Business Segment Reporting," to the Consolidated 
Financial Statements in this Form 10-K for a description of our 
business segments, basis of presentation, internal management 
reporting  methodologies,  and  business  segment  structure 

realignment from three segments to two segments in the second 
quarter of 2017. Table 28 presents net income for our reportable 
business segments:

Net Income by Business Segment

Table 28

(Dollars in millions)
Consumer
Wholesale

Corporate Other
Reconciling Items 1
Total Corporate Other

Consolidated Net Income

Year Ended December 31
2016

2017

2015

$871
1,373

199
(170)
29
$2,273

$965
979

160
(226)
(66)
$1,878

$1,081
1,053

184
(385)
(201)
$1,933

1 Reflects differences between net income reported for each business segment using management accounting practices and U.S. GAAP. Prior period information has 
been restated to reflect changes in internal reporting methodology. See additional information in Note 20, "Business Segment Reporting," to the Consolidated 
Financial Statements in this Form 10-K.

Table 29 presents average LHFI and average deposits for our reportable business segments for the years ended December 31: 

Average LHFI and Deposits by Business Segment

(Dollars in millions)
Consumer
Wholesale
Corporate Other

2017
$72,622
71,521
73

Average LHFI
2016
$69,455
71,600
63

2015
$65,637
67,872
49

Table 29

Average Consumer
and Commercial Deposits
2016
$99,424
54,713
52

2017
$102,820
56,618
111

2015
$93,789
50,373
41

64

 
BUSINESS SEGMENT RESULTS

Year Ended December 31, 2017 versus 2016 

Consumer
Consumer reported net income of $871 million for the year ended 
December 31, 2017, a decrease of $94 million, or 10%, compared 
2016. The decrease was driven primarily by higher provision for 
credit losses and lower noninterest income, offset partially by 
higher net interest income.

Net interest income was $3.7 billion, an increase of $233 
million, or 7%, compared to 2016, driven by growth in average 
LHFI and deposit balances as well as improved deposit spreads. 
Net interest income related to deposits increased $201 million, 
or 10%, driven by a 13 basis point increase in deposit spread and 
a $3.4 billion, or 3%, increase in average deposit balances. Net 
interest income related to LHFI increased $55 million, or 4%, 
driven primarily by growth in average LHFI balances.

Provision for credit losses was $368 million, an increase of 
$196 million compared to 2016, driven by lower ALLL release 
in 2017. Net charge-offs increased by $12 million in response to 
higher loan balances.

Total  noninterest  income  was  $1.9  billion,  a  decrease  of 
$162 million, or 8%, compared to 2016. The decrease was driven 
primarily  by  lower  mortgage-related  income  associated  with 
reduced  refinancing  activity  and  lower  service  charges  on 
deposits  due  to  the  enhanced  posting  order  process  instituted 
during the fourth quarter of 2016.

Total noninterest expense was $3.8 billion, an increase of 
$46 million, or 1%, compared to 2016. The increase was due to 
increased  expenses  associated  with  corporate  support  and 
technology,  occupancy  and  branch  network-related  activities, 
and  marketing  investments,  offset  partially  by  lower  staff 
expense, lower outside processing costs, and accrual reversals 
related to the favorable resolution of previous legal matters.

Wholesale
Wholesale reported net income of $1.4 billion for the year ended 
December  31,  2017,  an  increase  of  $394  million,  or  40%, 
compared to 2016. The increase was due to higher net interest 
income,  noninterest  income,  and  lower  provision  for  credit 
losses, offset partially by higher noninterest expense.

Net interest income was $2.4 billion, an increase of $235 
million, or 11%, compared to 2016, driven primarily by higher 
deposit  balances  and  improved  spreads  on  both  loans  and 
deposits. Net interest income related to deposits increased $157 
million, or 20%, as a result of higher benchmark interest rates 
and higher average deposits. Average deposit balances increased 
by $1.9 billion, or 3%, as a result of a $3.3 billion increase in 
interest-bearing transaction accounts and a $700 million increase 
in CDs, offset largely by a $1.3 billion decrease in money market 
accounts  and  a  $763  million  decrease  in  noninterest-bearing 
DDAs. Although average LHFI was relatively flat, net interest 
income related to LHFI increased $51 million, or 4%, as a result 
of improved loan spreads.

Provision for credit losses was $41 million, a decrease of 
$231 million, or 85%, compared to 2016. The decrease was due 
primarily  to  lower  nonperforming  loans  and  lower  energy-
related net charge-offs.

65

Total noninterest income was $1.7 billion, an increase of 
$354  million,  or  26%,  compared  to  2016.  The  increase  was 
driven primarily by higher investment banking income, which 
increased $105 million, or 21%, the $107 million gain on sale 
of PAC (see Table 1 for a summary of Form 8-K and tax reform-
related items), and $70 million of fee income from Pillar with 
the remainder of the increase attributable to higher tax credits 
and other loan related fees. These increases were offset partially 
by declines in trading income and structured real estate gains. 

to 

Total noninterest expense was $1.9 billion, an increase of 
$193 million, or 12%, compared to 2016. The increase was due 
the  Pillar  acquisition,  higher  employee 
primarily 
compensation  costs  attributable 
improved  business 
to 
performance and ongoing investment in technology, as well as 
higher  amortization  expense  associated  with  STCC  tax  credit 
investments, partially offset by lower operating losses.

Corporate Other
Corporate Other net income was $199 million for the year ended 
December  31,  2017,  an  increase  of  $39  million,  or  24%, 
compared to 2016. The increase in net income was due primarily 
to lower provision for income taxes in 2017 as a result of Form 
8-K and tax reform-related items.

Net  interest  income  was  a  net  expense  of  $41  million,  a 
decrease of $144 million compared to 2016. The decrease was 
driven by lower commercial loan-related swap income due to 
higher  LIBOR  rates. Average  long-term  debt  increased  $154 
million,  or  2%,  compared  to  2016,  driven  by  balance  sheet 
management activities. 

Total noninterest income was a net expense of $33 million, 
a decrease of $171 million compared to 2016. The decrease was 
due to the $109 million securities AFS portfolio restructuring 
loss (see Table 1 for a summary of Form 8-K and tax reform-
related  items)  and  a  gain  on  the  sale-leaseback  of  one  of  our 
office buildings in the second quarter of 2016.

Total noninterest expense was $73 million, an increase of 
$60 million compared to 2016. The increase was due primarily 
to higher severance costs in 2017.

Year Ended December 31, 2016 versus 2015 

Consumer
Consumer reported net income of $965 million for the year ended 
December  31,  2016,  a  decrease  of  $116  million,  or  11%, 
compared 2015. The decrease was driven primarily by higher 
provision for credit losses and higher noninterest expense, offset 
partially by higher net interest income and higher noninterest 
income.

Net interest income was $3.5 billion, an increase of $140 
million, or 4%, compared to 2015, driven by growth in average 
loan  and  deposit  balances  and  favorable  deposit  mix,  offset 
partially by lower loan and deposit spreads. Net interest income 
related to deposits increased $94 million, or 5%, driven by a $5.6 
billion, or 6%, increase in average deposit balances. Net interest 
income related to LHFI increased $30 million, or 2%, driven by 
a $3.8 billion, or 6%, increase in average LHFI. Average LHFI 
growth  was  driven  by  residential  mortgages,  other  direct, 

guaranteed  student,  indirect,  and  credit  card  loans,  offset 
partially by declines in home equity products.

Provision for credit losses was $172 million, an increase of 
$145 million compared to 2015. The increase was driven by loan 
growth and lower ALLL release in 2016.

Total noninterest income was $2.0 billion, an increase of 
$69 million, or 4%, compared to 2015. The increase was driven 
by  higher  mortgage-related  income.  Mortgage  production 
related income increased $96 million compared to 2015, due to 
higher  production  volume  and  higher  gain  on  sale  margins. 
Mortgage  servicing  related  income  increased  $19  million,  or 
12%, driven primarily by higher servicing fees and favorable net 
hedge  performance,  offset  partially  by  higher  decay  expense. 
Service charges on deposit accounts, card and ATM fee income 
also increased, offset by declines in wealth management-related 
income of $49 million, or 8%, due to lower transactional volumes 
and certain asset impairment charges recognized in 2016.

Total noninterest expense was $3.8 billion, an increase of 
$165 million, or 5%, compared to 2015. The increase was driven 
by  higher  corporate  support  costs,  operating  losses,  and 
marketing investments.

Wholesale
Wholesale reported net income of $979 million for the year ended 
December 31, 2016, a decrease of $74 million, or 7%, compared 
to 2015. The decrease in net income was attributable to higher 
provision  for  credit  losses  and  noninterest  expense,  offset 
partially by higher net interest income and noninterest income.
Net  interest  income  was  $2.2  billion,  an  increase  of  $98 
million, or 5%, compared to 2015, driven primarily by higher 
average  deposit  balances.  Deposit  related  net  interest  income 
increased  $64  million  as  average  deposit  balances  grew  $4.3 
billion,  or  9%,  driven  primarily  by  higher  interest-bearing 
transaction  and  money  market  accounts. Average  loans  grew 
$3.7  billion,  or  5%,  led  primarily  by  growth  in  C&I  loans; 
however,  net  interest  income  growth  related  to  loans  was 
mitigated due to lower loan spreads.

Provision for credit losses was $272 million, an increase of 
$135 million, or 99%, compared to 2015. The increase was due 
primarily to higher energy-related charge-offs and loan growth.
Total noninterest income was $1.4 billion, an increase of 
$71 million, or 6%, compared to 2015. The increase was driven 
primarily  by  higher  investment  banking  income  and  trading 
income,  which  increased  $33  million  and  $44  million, 
respectively, as well as by higher tax credit-related income.

Total noninterest expense was $1.7 billion, an increase of 
$153 million, or 10%, compared to 2015. The increase was due 
primarily to higher employee compensation expense attributable 
to improved business performance and ongoing investments in 
talent,  higher  amortization  expense  associated  with  our  new 
market  tax  credit  investments,  and  increased  investments  in 
technology. 

Corporate Other
Corporate Other net income was $160 million for the year ended 
December 31, 2016, a decrease of $24 million, or 13%, compared 
to 2015. The decrease in net income was due primarily to lower 
net interest income in 2016.

Net  interest income was  $103  million,  a  decrease of  $52 
million, or 34%, compared to 2015. The decrease was driven 

primarily  by  lower  spreads  on  MBS  securities  and  lower 
commercial loan-related swap income. Average long-term debt 
decreased  $175  million,  or  2%,  and  average  short-term 
borrowings decreased $349 million, or 18%, compared to 2015, 
driven by balance sheet management activities. 

Total noninterest income was $138 million, an increase of 
$1 million, or 1%, compared to 2015. The increase was driven 
primarily by the gain on the sale-leaseback of one of our office 
buildings in 2016, offset partially by certain gains recognized in 
2015,  including  gains  from  the  disposition  of  the  affordable 
housing partnership, $16 million of gains related to the sale of 
securities, and $14 million of trading income related to the mark-
to-market valuation.

Total noninterest expense decreased $4 million compared 

to 2015, driven primarily by lower allocated expenses.

FOURTH QUARTER 2017 RESULTS

Quarter Ended December 31, 2017 vs. Quarter Ended 
December 31, 2016

We reported net income available to common shareholders of 
$710 million in the fourth quarter of 2017, an increase of $262 
million, or 58%, compared to the same period in 2016. Earnings 
per  average  common  diluted  share  were  $1.48  for  the  fourth 
quarter of 2017, compared to $0.90 for the fourth quarter of 2016. 
The current quarter was favorably impacted by $0.39 per share 
of  net  discrete  benefits  in  connection  with  Form  8-K  and  tax 
reform-related items.

In the fourth quarter of 2017, net interest income was $1.5 
billion, an increase of $95 million compared to the same period 
in 2016. The increase was driven by higher earning asset yields 
and growth of $1.8 billion in average earning assets. Net interest 
margin increased 17 basis points to 3.17% for the fourth quarter 
of 2017, compared to the same period in 2016. The increase was 
driven  primarily  by  higher  earning  asset  yields  arising  from 
higher benchmark interest rates, continued positive mix shift in 
earning assets, and lower premium amortization in the securities 
AFS portfolio, offset partially by higher rates paid on interest-
bearing liabilities.

The provision for credit losses was $79 million in the fourth 
quarter of 2017, a decrease of $22 million compared to the same 
period in 2016, due to lower net charge-offs.

Total  noninterest  income  was  $833  million  in  the  fourth 
quarter of 2017, an increase of $18 million compared to the same 
period in 2016, driven largely by higher commercial real estate 
related and wealth management related income as well as the 
gain  from  the  sale  of  PAC,  offset  partially  by  securities AFS 
portfolio restructuring losses.

Trading  income  was  $41  million  in  the  fourth  quarter  of 
2017, a decrease of $17 million compared to the same period in 
2016, due to lower core trading revenue and higher counterparty 
credit valuation reserve in the current quarter.

Mortgage production related income was $61 million in the 
fourth quarter of 2017, a decrease of $17 million compared to 
the fourth quarter of 2016, due to lower production volume and 
a lower repurchase reserve release during the current quarter.
Mortgage servicing related income was $43 million for the fourth 
quarter of 2017, an increase of $18 million compared to the same 

66

period  in  2016,  due  to  higher  net  hedge  performance,  lower 
servicing asset decay, and higher servicing fees during the current 
quarter.

Trust and investment management income was $80 million 
in the fourth quarter of 2017, an increase of $7 million compared 
to  the  same  period  in  2016,  due  to  an  increase  in  trust  and 
institutional  assets  under  management  as  well  as  trust 
termination fees received during the current quarter.

Commercial real estate related income was $62 million in 
the fourth quarter of 2017, an increase of $29 million compared 
to  the  fourth  quarter  of  2016,  driven  by  revenue  from  Pillar, 
which  we  acquired  in  December  2016,  in  addition  to  higher 
structured real estate and tax credit-related income earned during 
the current quarter.

Net securities loss was $109 million in the fourth quarter of 
2017. There were no securities (losses)/gains recognized in the 
fourth quarter of 2016. The current quarter loss was due to the 
restructuring of the securities AFS portfolio.

Other  noninterest  income  was  $134  million  in  the  fourth 
quarter of 2017, an increase of $105 million compared to the 
same period in 2016. The increase was due primarily to the $107 
million gain from the sale of PAC during the current quarter, as 
announced in the December 4, 2017 Form 8-K. Excluding the 
impact of the pre-tax gain from the sale of PAC, other noninterest 
income was relatively stable compared to the fourth quarter of 
2016.

Total  noninterest  expense  was  $1.5  billion  in  the  fourth 
quarter of 2017, an increase of $123 million compared to the 
same period in 2016. The increase was due primarily to the net 
impact  of  $111  million  related  to  Form  8-K  and  tax  reform-
related  items  ($50  million  charitable  contribution  to  support 
financial well-being initiatives, $36 million net charge related to 
efficiency  actions,  and  $25  million  discretionary  401(k) 
contribution and other employee benefits). Excluding the impact 
of these items, noninterest expense increased slightly compared 
to the fourth quarter of 2016.

Employee  compensation  and  benefits  expense  was  $803 
million in the fourth quarter of 2017, an increase of $41 million 

compared to the same period in 2016, due primarily to the tax 
reform-related  discretionary  401(k)  contribution  and  other 
employee benefits of $25 million as well as incremental costs 
related to Pillar.

Marketing  and  customer  development  expense  was  $104 
million in the fourth quarter of 2017, an increase of $52 million 
compared  to  fourth  quarter  of  2016,  due  primarily  to  the  tax 
reform-related charitable contribution of $50 million to support 
financial well-being initiatives. Excluding the impact of this tax 
reform-related  item,  marketing  and  customer  development 
expense was stable compared to the fourth quarter of 2016.

Amortization expense was $25 million in the fourth quarter 
of 2017, an increase of $11 million compared to the same period 
in 2016, due primarily to an increase in amortizable community 
development  investments.  These  investments  generate  tax 
credits that reduce the provision for income taxes over time.

Other noninterest expense was $170 million in the fourth 
quarter of 2017, an increase of $16 million compared to the fourth 
quarter of 2016. The increase was driven primarily by the $36 
million net charge related to efficiency actions, as announced in 
the December 4, 2017 Form 8-K. This included severance costs 
in  connection  with  the  voluntary  early  retirement  program, 
branch  and  corporate  real  estate  closure  costs,  and  software 
write-downs. 

In the fourth quarter of 2017, we recognized a benefit for 
income taxes of $74 million compared to a provision of $193 
million in the fourth quarter of 2016. The tax provision for the 
current quarter includes a $303 million income tax benefit due 
primarily to the impact of the remeasurement of our estimated 
DTAs and DTLs and other tax reform-related items due to the 
enactment of the 2017 Tax Act. The effective tax rate for the 
fourth quarter of 2017 was (11)% compared to 29% in the fourth 
quarter  of  2016.  Excluding  the  impact  of  Form  8-K  and  tax 
reform-related items, the effective tax rate was 30% for the fourth 
quarter of 2017.

67

Selected Financial Data and Reconcilement of Non-U.S. GAAP Measures

Table 30

(Dollars in millions and shares in thousands,
except per share data)
Selected Quarterly Financial Data
Summary of Operations:

Interest income
Interest expense
Net interest income
Provision for credit losses
Net interest income after provision for

credit losses
Noninterest income
Noninterest expense

Income before (benefit)/provision for

income taxes

(Benefit)/provision for income taxes
Net income attributable to noncontrolling

interest
Net income
Net income available to common

shareholders

Net interest income-FTE 1
Total revenue
Total revenue-FTE 1
Net income per average common share:

Diluted
Basic

Dividends declared per common share

Book value per common share
Tangible book value per common share 2
Market capitalization
Market price per common share:

High
Low
Close

Selected Average Balances:

Total assets
Earning assets
LHFI
Intangible assets including residential

MSRs

Residential MSRs
Consumer and commercial deposits
Preferred stock
Total shareholders’ equity
Average common shares - diluted
Average common shares - basic
Financial Ratios (Annualized):

ROA
ROE
ROTCE 3
Net interest margin
Net interest margin-FTE 1
Efficiency ratio 4
Efficiency ratio-FTE 1, 4
Tangible efficiency ratio-FTE 1, 4, 5
Adjusted tangible efficiency 

ratio-FTE 1, 4, 5, 6

Total average shareholders’ equity to total

average assets

Tangible common equity to tangible 

assets 7

Common dividend payout ratio

December 31

2017
September 30

Three Months Ended

2016

June 30

March 31

December 31

September 30

June 30

March 31

$1,640
206
1,434
79

1,355

833
1,520

668

(74)

2

$740

$710

$1,472
2,267
2,305

$1.48
1.50

0.40

47.94

34.82

$1,635
205
1,430
120

1,310

846
1,391

765

225

2

$538

$512

$1,467
2,276
2,313

$1.06
1.07

0.40

47.16

34.34

$1,583
180
1,403
90

1,313

827
1,388

752

222

2

$528

$505

$1,439
2,230
2,266

$1.03
1.05

0.26

46.51

33.83

$1,528
162
1,366
119

1,247

847
1,465

629

159

2

$468

$451

$1,400
2,213
2,247

$0.91
0.92

0.26

45.62

33.05

$1,492
149
1,343
101

1,242

815
1,397

660

193

2

$465

$448

$1,377
2,158
2,192

$0.90
0.91
0.26

45.38
32.95

$1,451
143
1,308
97

1,211

889
1,409

691

215

2

$474

$457

$1,342
2,197
2,231

$0.91
0.92
0.26

46.63
34.33

$1,424
136
1,288
146

1,142

898
1,345

695

201

2

$492

$475

$1,323
2,186
2,221

$0.94
0.95
0.24

46.14
33.98

$1,411
129
1,282
101

1,181

781
1,318

644

195

2

$447

$430

$1,318
2,063
2,099

$0.84
0.85
0.24

44.97
32.89

30,417

28,451

27,319

26,860

26,942

21,722

20,598

18,236

$66.62
56.30
64.59

$205,219
184,306
144,039

8,077

1,662
160,745
2,236
24,806
480,359
474,300

1.43%
12.54
17.24
3.09
3.17
67.03
65.94

64.84

59.85

12.09

8.21

26.8

$60.04
51.96
59.77

$58.75
52.69
56.72

$61.69
52.71
55.30

$205,738
184,861
144,706

$204,494
184,057
144,440

$204,252
183,606
143,670

8,009

1,589
159,419
1,975
24,573
483,640
478,258

8,024

1,603
159,136
1,720
24,139
488,020
482,913

8,026

1,604
158,874
1,225
23,671
496,002
490,091

0.93%
8.19
11.28
3.02
3.09
66.20
65.19

64.60

64.60

11.59

8.06

28.3

1.04%
9.03
12.45
3.07
3.15
61.12
60.14

59.21

59.21

11.94

8.10

37.2

1.03%
9.08
12.51
3.06
3.14
62.24
61.24

60.59

60.59

11.80

8.11

24.8

68

$56.48
43.41
54.85

$203,146
182,475
142,578

7,654

1,291
157,996
1,225
24,044
497,055
491,497

0.91%
7.85
10.76
2.93
3.00
64.74
63.73
63.08

63.08

11.84

8.15

28.5

$44.61
38.75
43.80

$44.32
35.10
41.08

$42.04
31.07
36.08

$201,476
180,523
142,257

$198,305
178,055
141,238

$193,014
174,189
138,372

7,415

1,065
155,313
1,225
24,410
500,885
496,304

7,543

1,192
154,166
1,225
24,018
505,633
501,374

7,569

1,215
149,229
1,225
23,797
509,931
505,482

0.94%
7.89
10.73
2.88
2.96
64.13
63.14
62.54

62.54

12.12

8.57

28.2

1.00%
8.43
11.54
2.91
2.99
61.53
60.56
60.05

60.05

12.11

8.85

25.3

0.93%
7.71
10.60
2.96
3.04
63.89
62.81
62.33

62.33

12.33

8.85

28.2

Selected Financial Data and Reconcilement of Non-U.S. GAAP Measures (continued)

December 31

2017
September 30

Three Months Ended

2016

June 30

March 31

December 31

September 30

June 30

March 31

Selected Quarterly Financial Data (continued)
Capital Ratios at period end 8:

CET1
CET1 - fully phased-in
Tier 1 capital
Total capital
Leverage

9.74%
9.59
11.15
13.09
9.80

9.62%
9.48
10.74
12.69
9.50

9.68%
9.53
10.81
12.75
9.55

9.69%
9.54
10.40
12.37
9.08

9.59%
9.43
10.28
12.26
9.22

9.78%
9.66
10.50
12.57
9.28

9.84%
9.73
10.57
12.68
9.35

9.90%
9.77
10.63
12.39
9.50

(Dollars in millions, except per share data)
Reconcilement of Non-U.S. GAAP Measures - Quarterly
Net interest margin
Impact of FTE adjustment
Net interest margin-FTE 1

3.09%
0.08
3.17%

December 31

Efficiency ratio 4
Impact of FTE adjustment
Efficiency ratio-FTE 1, 4
Impact of excluding amortization related to
intangible assets and certain tax credits

Tangible efficiency ratio-FTE 1, 4, 5
Impact of excluding Form 8-K and other

items

Adjusted tangible efficiency ratio-FTE 1, 4, 5, 6

ROE

Impact of removing average intangible assets
other than residential MSRs and other
servicing rights from average common
shareholders' equity, and removing related
pre-tax amortization expense from net
income available to common shareholders

ROTCE 3

Net interest income
FTE adjustment
Net interest income-FTE 1
Noninterest income
Total revenue-FTE 1

Total shareholders’ equity
Goodwill, net of deferred taxes 9
Other intangible assets (including residential

MSRs and other servicing rights)

Residential MSRs and other servicing rights
Tangible equity 7
Noncontrolling interest
Preferred stock
Tangible common equity 7

Total assets
Goodwill
Other intangible assets (including residential

MSRs and other servicing rights)

Residential MSRs and other servicing rights

Tangible assets
Tangible common equity to tangible assets 7
Tangible book value per common share 2

2017
September 30

Three Months Ended

2016

June 30

March 31

December 31

September 30

June 30

March 31

3.07%
0.08
3.15%

61.12%
(0.98)
60.14

(0.93)

59.21

—

3.06%
0.08
3.14%

62.24%
(1.00)
61.24

(0.65)

60.59

—

3.02%
0.07
3.09%

66.20%
(1.01)
65.19

(0.59)

64.60

—

2.93%
0.07
3.00%

64.74%
(1.01)
63.73

(0.65)

63.08

—

2.88%
0.08
2.96%

64.13%
(0.99)
63.14

(0.60)

62.54

—

2.91%
0.08
2.99%

61.53%
(0.97)
60.56

(0.51)

60.05

—

2.96%
0.08
3.04%

63.89%
(1.08)
62.81

(0.48)

62.33

—

59.21%

60.59%

64.60%

63.08%

62.54%

60.05%

62.33%

9.03%

9.08%

8.19%

7.85%

7.89%

8.43%

7.71%

67.03%
(1.09)
65.94

(1.10)

64.84

(4.99)

59.85%

12.54%

4.70

17.24%

3.42

3.43

3.09

12.45%

12.51%

11.28%

2.91

10.76%

2.84

3.11

2.89

10.73%

11.54%

10.60%

$1,434
38
1,472
833
$2,305

$25,154
(6,168)

(1,791)

1,776
18,971
(103)
(2,475)
$16,393

$1,430
37
1,467
846
$2,313

$24,522
(6,084)

(1,706)

1,690
18,422
(101)
(1,975)
$16,346

$1,403
36
1,439
827
$2,266

$24,477
(6,085)

(1,689)

1,671
18,374
(103)
(1,975)
$16,296

$1,366
34
1,400
847
$2,247

$23,484
(6,086)

(1,729)

1,711
17,380
(101)
(1,225)
$16,054

$1,343
34
1,377
815
$2,192

$23,618
(6,086)

(1,657)

1,638
17,513
(103)
(1,225)
$16,185

$1,308
34
1,342
889
$2,231

$24,449
(6,089)

(1,131)

1,124
18,353
(101)
(1,225)
$17,027

$1,288
35
1,323
898
$2,221

$24,464
(6,091)

(1,075)

1,067
18,365
(103)
(1,225)
$17,037

$1,282
36
1,318
781
$2,099

$24,053
(6,094)

(1,198)

1,189
17,950
(101)
(1,225)
$16,624

$205,962
(6,331)

$208,252
(6,338)

$207,223
(6,338)

$205,642
(6,338)

$204,875
(6,337)

$205,091
(6,337)

$198,892
(6,337)

$194,158
(6,337)

(1,791)

1,776

(1,706)

1,690

(1,689)

1,671

(1,729)

1,711

(1,657)

1,638

(1,131)

1,124

(1,075)

1,067

(1,198)

1,189

$199,616

$201,898

$200,867

$199,286

$198,519

$198,747

$192,547

$187,812

8.21%

$34.82

8.10%

8.11%

8.06%

$34.34

$33.83

$33.05

8.15%

$32.95

8.57%

8.85%

8.85%

$34.33

$33.98

$32.89

69

Selected Financial Data and Reconcilement of Non-U.S. GAAP Measures (continued)

(Dollars in millions, except per share data)

2017

2016

2015

2014

2013

Year Ended December 31

Reconcilement of Non-U.S. GAAP Measures - Annual
Net interest margin

Impact of FTE adjustment
Net interest margin-FTE 1
Efficiency ratio 4, 10
Impact of FTE adjustment
Efficiency ratio-FTE 1, 4, 10
Impact of excluding amortization related to intangible assets and certain tax credits
Tangible efficiency ratio-FTE 1, 4, 5, 10
Impact of excluding Form 8-K and other items
Adjusted tangible efficiency ratio-FTE 1, 4, 5, 6, 10
ROE

Impact of removing average intangible assets other than residential MSRs and other
servicing rights from average common shareholders' equity, and removing related
pre-tax amortization expense from net income available to common shareholders
ROTCE 3
Net interest income

FTE adjustment
Net interest income-FTE 1
Noninterest income
Total revenue-FTE 1
Impact of excluding Form 8-K items
Total adjusted revenue-FTE 1, 6
Net income available to common shareholders

Impact of excluding Form 8-K and other items
Adjusted net income available to common shareholders 6
Noninterest income

Impact of excluding Form 8-K items
Adjusted noninterest income 6
Noninterest expense 10
Impact of excluding Form 8-K and other items
Adjusted noninterest expense 6, 10
Diluted net income per average common share

Impact of excluding Form 8-K and other items
Adjusted diluted net income per average common share 6
At December 31:

Total shareholders’ equity
Goodwill, net of deferred taxes 9
Other intangible assets (including residential MSRs and other servicing rights)

Residential MSRs and other servicing rights
Tangible equity 7
Noncontrolling interest

Preferred stock
Tangible common equity 7
Total assets

Goodwill

Other intangible assets (including residential MSRs and other servicing rights)

Residential MSRs and other servicing rights

Tangible assets
Tangible common equity to tangible assets 7
Tangible book value per common share 2

3.06%

0.08

3.14%

64.14%

(1.02)

63.12

(0.82)

62.30

(1.26)

61.04%

9.72%

3.67

13.39%

2.92%

0.08

3.00%

63.55%

(1.00)

62.55

(0.56)

61.99

—

61.99%

7.97%

2.94

10.91%

2.82%

0.09

2.91%

64.24%

(1.11)

63.13

(0.49)

62.64

—

62.64%

8.46%

3.29

11.75%

2.98%

0.09

3.07%

67.90%

(1.16)

66.74

(0.30)

66.44

(3.10)

63.34%

8.10%

3.39

11.49%

3.16%

0.08

3.24%

72.28%
(1.12)
71.16
(0.27)
70.89
(5.62)
65.27%

6.38%

2.99

9.37%

$5,633

$5,221

$4,764

$4,840

$4,853

145

5,778

3,354

9,132

—

$9,132

$2,179

—

$2,179

$3,354

—

$3,354

$5,764

—

$5,764

$4.47

—

$4.47

138

5,359

3,383

8,742

—

$8,742

$1,811

—

$1,811

$3,383

—

$3,383

$5,468

—

$5,468

$3.60

—

$3.60

142

4,906

3,268

8,174

—

$8,174

$1,863

—

$1,863

$3,268

—

$3,268

$5,160

—

$5,160

$3.58

—

$3.58

142

4,982

3,323

8,305

(105)

$8,200

$1,722

7

$1,729

$3,323

(105)

$3,218

$5,543

(324)

$5,219

$3.23

0.01

$3.24

$25,154

$23,618

$23,437

$23,005

(6,168)

(1,791)

1,776

18,971

(103)

(2,475)

(6,086)

(1,657)

1,638

17,513

(103)

(1,225)

(6,097)

(1,325)

1,316

17,331

(108)

(1,225)

(6,123)

(1,219)

1,206

16,869

(108)

(1,225)

$16,393

$205,962

$16,185

$204,875

$15,998

$190,817

$15,536

$190,328

(6,331)

(1,791)

1,776

(6,337)

(1,657)

1,638

(6,337)

(1,325)

1,316

(6,337)

(1,219)

1,206

$199,616

$198,519

$184,471

$183,978

127

4,980

3,214

8,194

63

$8,257

$1,297

179

$1,476

$3,214

63

$3,277

$5,831
(419)
$5,412

$2.41

0.33

$2.74

$21,422
(6,183)
(1,334)
1,300

15,205
(119)
(725)
$14,361

$175,335
(6,369)
(1,334)
1,300

$168,932

8.21%

8.15%

8.67%

8.44%

8.50%

$34.82

$32.95

$31.45

$29.62

$26.79

70

Selected Financial Data and Reconcilement of Non-U.S. GAAP Measures (continued)

Reconciliation of fully phased-in CET1 Ratio 8
CET1

Less:

Servicing rights
Other 11

CET1 - fully phased-in

(Dollars in millions)

Reconciliation of PPNR 12
Income before provision for income taxes

Provision for credit losses

Less:

Net securities losses

PPNR

December 31, 2017

December 31, 2016

9.74%

(0.14)

(0.01)

9.59%

9.59%

(0.13)
(0.03)
9.43%

Year Ended
December 31, 2017
$2,814

409

(108)

$3,331

1 We present Net interest income-FTE, Total revenue-FTE, Net interest margin-FTE, Efficiency ratio-FTE, Tangible efficiency ratio-FTE, Adjusted tangible efficiency 
ratio-FTE, and Total adjusted revenue-FTE on a fully taxable-equivalent ("FTE") basis. The FTE basis adjusts for the tax-favored status of Net interest income from 
certain loans and investments using a federal tax rate of 35% and state income taxes, where applicable, to increase tax-exempt interest income to a taxable-equivalent 
basis. We believe the FTE basis is the preferred industry measurement basis for these measures and that it enhances comparability of Net interest income arising 
from taxable and tax-exempt sources. Total revenue-FTE is calculated as Net interest income-FTE plus Noninterest income. Net interest margin-FTE is calculated 
by dividing annualized Net interest income-FTE by average Total earning assets.
2 We present Tangible book value per common share, which removes the after-tax impact of purchase accounting intangible assets, Noncontrolling interest, and 
Preferred stock from shareholders' equity. We believe this measure is useful to investors because, by removing the amount of intangible assets that result from 
merger and acquisition activity, and removing the amounts of noncontrolling interest and preferred stock that do not represent our common shareholders' equity, it 
allows investors to more easily compare our capital position to other companies in the industry. 
3 We present ROTCE, which removes the after-tax impact of purchase accounting intangible assets from average common shareholders' equity and removes the 
related intangible asset amortization from Net income available to common shareholders. We believe this measure is useful to investors because, by removing the 
amount of intangible assets that result from merger and acquisition activity and related amortization expense (the level of which may vary from company to company), 
it allows investors to more easily compare our ROTCE to other companies in the industry who present a similar measure. We also believe that removing these items 
provides a more relevant measure of our Return on average common shareholders' equity. This measure is utilized by management to assess our profitability. 
4 Efficiency ratio is computed by dividing Noninterest expense by Total revenue. Efficiency ratio-FTE is computed by dividing Noninterest expense by Total revenue-
FTE.
5 We present Tangible efficiency ratio-FTE and Adjusted tangible efficiency ratio-FTE, which exclude amortization related to intangible assets and certain tax credits. 
We believe these measures are useful to investors because, by removing the impact of amortization (the level of which may vary from company to company), it 
allows investors to more easily compare our efficiency to other companies in the industry. Tangible efficiency ratio-FTE is utilized by management to assess our 
efficiency and that of our lines of business.
6 We present certain income statement categories and also Adjusted tangible efficiency ratio-FTE, Total adjusted revenue-FTE, Adjusted net income available to 
common shareholders, Adjusted noninterest income, Adjusted noninterest expense, and Adjusted diluted net income per average common share, excluding Form 
8-K items and other tax reform-related and legacy mortgage-related items. We believe these measures are useful to investors because it removes the effect of material 
items impacting the periods' results and is more reflective of normalized operations as it reflects results that are primarily client relationship and client transaction 
driven. Removing these items also allows investors to compare our results to other companies in the industry that may not have had similar items impacting their 
results. Additional detail on certain of these items can be found in the Form 8-Ks filed with the SEC on December 4, 2017, January 5, 2015, September 9, 2014, 
July 3, 2014, and October 10, 2013. 
7 We present certain capital information on a tangible basis, including the ratio of Tangible common equity to tangible assets, Tangible equity, and Tangible common 
equity, which removes the after-tax impact of purchase accounting intangible assets. We believe these measures are useful to investors because, by removing the 
amount of intangible assets that result from merger and acquisition activity (the level of which may vary from company to company), it allows investors to more 
easily compare our capital position to other companies in the industry. These measures are utilized by management to analyze capital adequacy.
8 The CET1 ratio on a fully phased-in basis at December 31, 2017 and 2016 is estimated and is presented to provide investors with an indication of our capital adequacy 
under the future CET1 requirements.
9 Net of deferred tax liabilities of $163 million, $254 million, $253 million, and $252 million at December 31, 2017, September 30, 2017, June 30, 2017, and March 
31, 2017, respectively. Net of deferred tax liabilities of $251 million, $248 million, $246 million, and $243 million at December 31, 2016, September 30, 2016, 
June 30, 2016, and March 31, 2016, respectively.Net of deferred tax liabilities of $240 million, $214 million, and $186 million at December 31, 2015, 2014, 2013, 
respectively. 
10 Amortization expense related to qualified affordable housing investment costs is recognized in Provision for income taxes for all periods presented as allowed by 
an accounting standard adopted in 2014. Prior to the first quarter of 2014, these amounts were recognized in Other noninterest expense, and therefore, for comparative 
purposes, $49 million of amortization expense was reclassified to Provision for income taxes for the year ended December 31, 2013.
11 Primarily includes the deduction from capital of certain carryforward DTAs, the overfunded pension asset, and other intangible assets.
12 We present the reconciliation of PPNR because it is a performance metric utilized by management and in certain of our compensation plans. PPNR impacts the 
level of awards if certain thresholds are met. We believe this measure is useful to investors because it allows investors to compare our PPNR to other companies in 
the industry who present a similar measure.

71

Item 7A.

QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK

See the “Enterprise Risk Management” section of the MD&A in this Form 10-K, which is incorporated herein by reference.

Item 8.

FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA

Report of Ernst & Young LLP, Independent Registered Public Accounting Firm

To the Shareholders and the Board of Directors of SunTrust Banks, Inc.

Opinion on the Financial Statements

We have audited the accompanying consolidated balance sheets of SunTrust Banks, Inc. (the Company) as of December 31, 2017 
and 2016, and the related consolidated statements of income, comprehensive income, shareholders' equity and cash flows for each 
of the three years in the period ended December 31, 2017, and the related notes (collectively referred to as the “financial statements”). 
In our opinion, the financial statements present fairly, in all material respects, the consolidated financial position of SunTrust Banks, 
Inc. at December 31, 2017 and 2016, and the consolidated results of its operations and its cash flows for each of the three years in 
the period ended December 31, 2017, 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) 
(PCAOB), the Company’s internal control over financial reporting as of December 31, 2017, 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 23, 2018 expressed an unqualified opinion thereon.

Basis for Opinion

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 are a public accounting firm registered with the PCAOB and are required to be independent 
with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the 
Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the 
audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error 
or fraud. Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether 
due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, 
evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting 
principles  used  and  significant  estimates  made  by  management,  as  well  as  evaluating  the  overall  presentation  of  the  financial 
statements. We believe that our audits provide a reasonable basis for our opinion.

/s/ Ernst & Young LLP

We have served as the Company’s auditor since 2007. 

Atlanta, Georgia
February 23, 2018

72

Report of Ernst & Young LLP, Independent Registered Public Accounting Firm

To the Shareholders and the Board of Directors of SunTrust Banks, Inc.

Opinion on Internal Control Over Financial Reporting

We have audited SunTrust Banks, Inc.’s internal control over financial reporting as of December 31, 2017, 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). In our opinion, SunTrust Banks, Inc. (the Company) maintained, in all material respects, 
effective internal control over financial reporting as of December 31, 2017, based on the COSO criteria.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), 
the consolidated balance sheets of SunTrust Banks, Inc. as of December 31, 2017 and 2016, and the related consolidated statements 
of income, comprehensive income, shareholders’ equity and cash flows for each of the three years in the period ended December 31, 
2017, and the related notes, of the Company and our report dated February 23, 2018 expressed an unqualified opinion thereon.

Basis for Opinion

The Company’s 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 Management’s Report on Internal 
Control over Financial Reporting appearing under Item 9A. Our responsibility is to express an opinion on the Company’s internal 
control over financial reporting based on our audit. We are a public accounting firm registered with the PCAOB and are required to 
be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations 
of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. 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.

Definition and Limitations of Internal Control Over Financial Reporting

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.

Atlanta, Georgia
February 23, 2018

73

/s/ Ernst & Young LLP

SunTrust Banks, Inc.
Consolidated Statements of Income

(Dollars in millions and shares in thousands, except per share data)
Interest Income

Interest and fees on loans held for investment
Interest and fees on loans held for sale
Interest and dividends on securities available for sale
Trading account interest and other

Total interest income

Interest Expense

Interest on deposits
Interest on long-term debt
Interest on other borrowings
Total interest expense

Net interest income

Provision for credit losses

Net interest income after provision for credit losses

Noninterest Income

Service charges on deposit accounts
Other charges and fees
Card fees
Investment banking income
Trading income
Trust and investment management income
Retail investment services
Mortgage production related income
Mortgage servicing related income
Gain on sale of subsidiary
Commercial real estate related income 1
Net securities (losses)/gains
Other noninterest income 1

Total noninterest income

Noninterest Expense

Employee compensation
Employee benefits
Outside processing and software
Net occupancy expense
Marketing and customer development
Regulatory assessments
Equipment expense
Other staff expense
Amortization
Consulting and legal fees
Operating losses
Other noninterest expense

Total noninterest expense

Income before provision for income taxes
Provision for income taxes
Net income including income attributable to noncontrolling interest
Less:  Net income attributable to noncontrolling interest
Net income
Net income available to common shareholders

Net income per average common share:

Diluted
Basic

Year Ended December 31
2016

2015

2017

$5,385
99
774
129
6,387

404
288
62
754
5,633
409
5,224

603
385
344
599
189
309
278
231
191
107
123
(108)
103
3,354

2,854
403
826
377
232
187
164
121
75
71
40
414
5,764
2,814
532
2,282
9
$2,273
$2,179

$4,939
92
651
96
5,778

259
260
38
557
5,221
444
4,777

630
380
327
494
211
304
281
366
189
—
69
4
128
3,383

2,698
373
834
349
172
173
170
67
49
93
108
382
5,468
2,692
805
1,887
9
$1,878
$1,811

$4,506
82
593
84
5,265

219
252
30
501
4,764
165
4,599

622
377
329
461
181
334
300
270
169
—
56
21
148
3,268

2,576
366
815
341
151
139
164
65
40
73
56
374
5,160
2,707
764
1,943
10
$1,933
$1,863

Dividends declared per common share
Average common shares outstanding - diluted
Average common shares outstanding - basic
1 Beginning January 1, 2017, the Company began presenting income related to the Company's Pillar, STCC, and Structured Real Estate businesses as a separate line 
item on the Consolidated Statements of Income titled Commercial real estate related income. For periods prior to January 1, 2017, these amounts were previously 
presented in Other noninterest income and have been reclassified to Commercial real estate related income for comparability.

$4.47
4.53
1.32
486,954
481,339

$3.60
3.63
1.00
503,466
498,638

$3.58
3.62
0.92
520,586
514,844

See accompanying Notes to Consolidated Financial Statements.

74

SunTrust Banks, Inc.
Consolidated Statements of Comprehensive Income

(Dollars in millions)

Net income

Components of other comprehensive income/(loss):

Change in net unrealized gains/(losses) on securities available for sale, 

net of tax of $29, ($117), and ($93), respectively

Change in net unrealized losses on derivative instruments, 

net of tax of $0, ($145), and ($5), respectively

Change in net unrealized losses on brokered time deposits, 

net of tax of $0, $0, and $0, respectively

Change in credit risk adjustment on long-term debt, 

net of tax of $3, ($1), and $0, respectively

Change related to employee benefit plans, 

net of tax of $138, $52, and ($103), respectively

Total other comprehensive income/(loss), net of tax

Year Ended December 31

  2017 1

2016

2015

$2,273

$1,878

$1,933

61

(87)

—

3

24

1

(197)

(244)

(1)

(2)

88

(356)

(163)

(10)

—

—

(165)

(338)

Total comprehensive income

$2,274

$1,522

$1,595

1 Net of tax amounts include the stranded tax effects resulting from the 2017 Tax Act. See Note 1, “Significant Accounting Policies,” for additional information.

See accompanying Notes to Consolidated Financial Statements.

75

SunTrust Banks, Inc.
Consolidated Balance Sheets

(Dollars in millions and shares in thousands, except per share data)
Assets
Cash and due from banks
Federal funds sold and securities borrowed or purchased under agreements to resell
Interest-bearing deposits in other banks

Cash and cash equivalents

Trading assets and derivative instruments 1
Securities available for sale 2
Loans held for sale ($1,577 and $3,540 at fair value at December 31, 2017 and 2016, respectively)
Loans held for investment 3 ($196 and $222 at fair value at December 31, 2017 and 2016, respectively)
Allowance for loan and lease losses

Net loans held for investment

Premises and equipment, net
Goodwill

Other intangible assets (Residential MSRs at fair value: $1,710 and $1,572 at December 31, 2017 and 2016,

respectively)

Other assets

Total assets

Liabilities
Noninterest-bearing deposits
Interest-bearing deposits (CDs at fair value: $236 and $78 at December 31, 2017 and 2016, respectively)

Total deposits
Funds purchased
Securities sold under agreements to repurchase
Other short-term borrowings
Long-term debt 4 ($530 and $963 at fair value at December 31, 2017 and 2016, respectively)
Trading liabilities and derivative instruments
Other liabilities

Total liabilities

Shareholders’ Equity
Preferred stock, no par value
Common stock, $1.00 par value
Additional paid-in capital
Retained earnings
Treasury stock, at cost, and other 5
Accumulated other comprehensive loss, net of tax

Total shareholders’ equity

Total liabilities and shareholders’ equity

Common shares outstanding 6
Common shares authorized
Preferred shares outstanding
Preferred shares authorized
Treasury shares of common stock

1 Includes trading securities pledged as collateral where counterparties have the right to sell or repledge the collateral
2 Includes securities AFS pledged as collateral where counterparties have the right to sell or repledge the collateral
3 Includes loans held for investment of consolidated VIEs
4 Includes debt of consolidated VIEs
5 Includes noncontrolling interest
6 Includes restricted shares

See accompanying Notes to Consolidated Financial Statements.

76

December 31,

2017

2016

$5,349
1,538
25
6,912
5,093
31,416
2,290
143,181
(1,735)
141,446
1,734
6,331

$5,091
1,307
25
6,423
6,067
30,672
4,169
143,298
(1,709)
141,589
1,556
6,337

1,791
8,949
$205,962

1,657

6,405
$204,875

$42,784
117,996
160,780
2,561
1,503
717
9,785
1,283
4,179
180,808

2,475
550
9,000
17,540
(3,591)
(820)
25,154
$205,962

470,931
750,000
25
50,000
79,133

$1,086
223
179
189
103
9

$43,431
116,967
160,398
2,116
1,633
1,015
11,748
1,351
2,996
181,257

1,225
550
9,010
16,000
(2,346)
(821)
23,618
$204,875

491,188
750,000
12
50,000
58,738

$1,437
—
211
222
103
11

SunTrust Banks, Inc.
Consolidated Statements of Shareholders’ Equity

(Dollars and shares in millions, except per share data)

Balance, January 1, 2015

Net income

Other comprehensive loss

Common stock dividends, $0.92 per share
Preferred stock dividends 2
Repurchase of common stock

Exercise of stock options and stock compensation expense

Restricted stock activity

Amortization of restricted stock compensation

Issuance of stock for employee benefit plans and other

Preferred
Stock

$1,225

Common
Shares
Outstanding

Common
Stock

Additional
Paid-in
Capital

Retained
Earnings

525

$550

$9,089

$13,295

Treasury 
Stock
and Other 1
($1,032)

Accumulated
Other
Comprehensive
Loss

Total

($122)

$23,005

—

—

—

—

—

—

—

—

—

—

—

—

—

(17)

1

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

(18)

23

—

—

1,933

—

(475)

(64)

—

—

(3)

—

—

—

—

—

—

(679)

30

4

16

3

—

(338)

—

—

—

—

—

—

—

1,933

(338)

(475)

(64)

(679)

12

24

16

3

Balance, December 31, 2015

$1,225

509

$550

$9,094

$14,686

($1,658)

($460)

$23,437

Cumulative effect of credit risk adjustment 3
Net income

Other comprehensive loss

Change in noncontrolling interest

Common stock dividends, $1.00 per share
Preferred stock dividends 2
Repurchase of common stock

Repurchase of common stock warrants
Exercise of stock options and stock compensation expense 4
Restricted stock activity 4
Amortization of restricted stock compensation

Balance, December 31, 2016

Net income

Other comprehensive income

Common stock dividends, $1.32 per share
Preferred stock dividends 2
Issuance of preferred stock, Series G and H

Repurchase of common stock

Exercise of stock options and stock compensation expense

Restricted stock activity

Balance, December 31, 2017

—

—

—

—

—

—

—

—

—

—

—

$1,225

—

—

—

—

1,250

—

—

—

—

—

—

—

—

—

(20)

—

1

1

—

491

—

—

—

—

—

(22)

1

1

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

(24)

(40)

(20)

—

5

1,878

—

—

(498)

(66)

—

—

—

(5)

—

—

—

—

(5)

—

—

(806)

—

65

56

2

(5)

—

(356)

—

—

—

—

—

—

—

—

—

1,878

(356)

(5)

(498)

(66)

(806)

(24)

25

31

2

$550

$9,010

$16,000

($2,346)

($821)

$23,618

—

—

—

—

—

—

—

—

—

—

—

—

(11)

—

(15)

16

2,273

—

(634)

(94)

—

—

—

(5)

—

—

—

—

—

(1,314)

36

33

—

1

—

—

—

—

—

—

2,273

1

(634)

(94)

1,239

(1,314)

21

44

$2,475

471

$550

$9,000

$17,540

($3,591)

($820)

$25,154

1 At December 31, 2017, includes ($3,694) million for treasury stock and $103 million for noncontrolling interest.
At December 31, 2016, includes ($2,448) million for treasury stock, ($1) million for the compensation element of restricted stock, and $103 million for noncontrolling interest.
At December 31, 2015, includes ($1,764) million for treasury stock,($2) million for the compensation element of restricted stock, and $108 million for noncontrolling interest.
2 For the year ended December 31, 2017, dividends were $4,056 per share for both Perpetual Preferred Stock Series A and B, $5,875 per share for Perpetual Preferred Stock Series 
E, $5,625 per share for Perpetual Preferred Stock Series F, $3,128 per share for Perpetual Preferred Stock Series G, and $669 per share for Perpetual Preferred Stock Series H.
For the year ended December 31, 2016, dividends were $4,067 per share for both Perpetual Preferred Stock Series A and B, $5,875 per share for Perpetual Preferred Stock Series 
E, and $5,625 per share for Perpetual Preferred Stock Series F.
For the year ended December 31, 2015, dividends were $4,056 per share for both Perpetual Preferred Stock Series A and B, and $5,875 per share for Perpetual Preferred Stock Series 
E, and $6,219 per share for Perpetual Preferred Stock Series F.
3 Related to the Company's early adoption of the ASU 2016-01 provision related to changes in instrument-specific credit risk, beginning January 1, 2016. See Note 1, "Significant 
Accounting Policies," and Note 21, "Accumulated Other Comprehensive Loss," for additional information.
4 Includes a ($4) million net reclassification of excess tax benefits from Additional paid-in capital to Provision for income taxes, related to the Company's adoption of ASU 2016-09.

See accompanying Notes to Consolidated Financial Statements.

77

SunTrust Banks, Inc.
Consolidated Statements of Cash Flows

(Dollars in millions)
Cash Flows from Operating Activities:

Net income including income attributable to noncontrolling interest
Adjustments to reconcile net income to net cash provided by/(used in) operating activities:

Year Ended December 31
2016

2015

2017

$2,282

$1,887

$1,943

Gain on sale of subsidiary
Depreciation, amortization, and accretion
Origination of servicing rights
Provisions for credit losses and foreclosed property
Deferred income tax expense
Stock-based compensation
Net securities losses/(gains)
Net gain on sale of loans held for sale, loans, and other assets
Net decrease/(increase) in loans held for sale
Net decrease/(increase) in trading assets and derivative instruments
Net decrease/(increase) in other assets
Net decrease in other liabilities

Net cash provided by/(used in) operating activities

Cash Flows from Investing Activities:

Proceeds from maturities, calls, and paydowns of securities available for sale
Proceeds from sales of securities available for sale
Purchases of securities available for sale
Net increase in loans, including purchases of loans
Proceeds from sales of loans
Net cash paid for servicing rights
Capital expenditures
Payments related to acquisitions, including contingent consideration, net of cash acquired
Consideration received from sale of subsidiary
Proceeds from the sale of other real estate owned and other assets

Net cash used in investing activities

Cash Flows from Financing Activities:

Net increase in total deposits
Net increase/(decrease) in funds purchased, securities sold under agreements to repurchase, and

other short-term borrowings

Proceeds from issuance of long-term debt
Repayments of long-term debt
Proceeds from the issuance of preferred stock
Repurchase of common stock
Repurchase of common stock warrants
Common and preferred stock dividends paid
Taxes paid related to net share settlement of equity awards
Proceeds from exercise of stock options

Net cash (used in)/provided by financing activities

Net increase/(decrease) in cash and cash equivalents
Cash and cash equivalents at beginning of period
Cash and cash equivalents at end of period

Supplemental Disclosures:
Interest paid
Income taxes paid
Income taxes refunded
Loans transferred from loans held for sale to loans held for investment
Loans transferred from loans held for investment to loans held for sale
Loans transferred from loans held for investment and loans held for sale to other real estate owned
Amortization of deferred gain on sale leaseback of premises
Non-cash impact of debt assumed by purchaser in lease sale

See accompanying Notes to Consolidated Financial Statements.

78

(107)
727
(411)
418
344
160
108
(269)
2,099
834
235
(911)
5,509

4,186
2,854
(8,299)
(2,425)
720
(7)
(410)
—
261
235
(2,885)

382

17
2,844
(4,562)
1,239
(1,314)
—
(723)
(39)
21
(2,135)
489
6,423
$6,912

$730
415
(3)
19
288
57
17
184

—
725
(312)
449
111
126
(4)
(428)
(1,819)
(342)
(800)
(274)
(681)

5,108
197
(8,610)
(9,032)
1,612
(171)
(283)
(211)
—
233
(11,157)

10,568

37

6,705
(3,231)
—
(806)
(24)
(564)
(48)
25
12,662
824
5,599
$6,423

$559
813
(2)
30
360
59
43
74

—
786
(238)
176
21
89
(21)
(323)
1,625
67
(407)
(166)
3,552

5,680
2,708
(9,882)
(5,897)
2,127
(117)
(186)
(30)
—
281
(5,316)

9,263

(4,559)

1,351
(5,684)
—
(679)
—
(539)
(36)
17
(866)
(2,630)
8,229
$5,599

$523
497
(1)
741
1,790
67
54
190

 
Notes to Consolidated Financial Statements

NOTE 1 – SIGNIFICANT ACCOUNTING POLICIES

General 
SunTrust,  one  of  the  nation's  largest  commercial  banking 
organizations, is a financial services holding company with its 
headquarters located in Atlanta, Georgia. Through its principal 
subsidiary,  SunTrust  Bank,  the  Company  offers  a  full  line  of 
financial  services  for  consumers,  businesses,  corporations, 
institutions, and not-for-profit entities, both through its branches 
(located primarily in Florida, Georgia, Virginia, North Carolina, 
Tennessee,  Maryland,  South  Carolina,  and  the  District  of 
Columbia)  and  through  other  national  delivery  channels.  In 
addition  to  deposit,  credit,  and  trust  and  investment  services 
provided by the Bank, the Company's other subsidiaries provide 
capital  markets,  mortgage  banking,  securities  brokerage, 
investment  banking,  and  wealth  management  services.  The 
Company operates and measures business activity across two 
business segments: Consumer and Wholesale, with functional 
activities 
in  Corporate  Other.  For  additional 
information on the Company’s business segments, see Note 20, 
“Business Segment Reporting.”

included 

Principles of Consolidation and Basis of Presentation
The Consolidated Financial Statements have been prepared in 
accordance  with  U.S.  GAAP  and  include  the  accounts  of  the 
Company  and  its  subsidiaries  after  elimination  of  significant 
intercompany  accounts  and  transactions.  In  the  opinion  of 
management,  all  adjustments,  consisting  only  of  normal 
recurring adjustments that are necessary for a fair presentation 
of the results of operations in these financial statements, have 
been made.

The Company holds VIs, which are contractual, ownership 
or other interests that fluctuate with changes in the fair value of 
a VIE's net assets. The Company consolidates a VIE if it is the 
primary beneficiary, which is the party that has both the power 
to direct the activities that most significantly impact the financial 
performance of the VIE and the obligation to absorb losses or 
rights to receive benefits through its VIs that could potentially 
be significant to the VIE. To determine whether or not a VI held 
by the Company could potentially be significant to the VIE, both 
qualitative  and  quantitative  factors  regarding  the  nature,  size, 
and  form  of  the  Company's  involvement  with  the  VIE  are 
considered. The assessment of whether or not the Company is 
the primary beneficiary of a VIE is performed on an ongoing 
basis.  The  Company  consolidates  VOEs  that  are  controlled 
through the Company's equity interests or by other means.

Investments  in  entities  for  which  the  Company  has  the 
ability  to  exercise  significant  influence,  but  not  control,  over 
operating and financing decisions are accounted for using the 
equity method of accounting. These investments are included in 
Other assets in the Consolidated Balance Sheets at cost, adjusted 
to reflect the Company's portion of income, loss, or dividends 
of the investee. Non marketable equity investments that do not 
meet the criteria to be accounted for under the equity method 
and  that  do  not  result  in  consolidation  of  the  investee  are 
accounted for under the cost method of accounting. Cost method 
investments  are  included  in  Other  assets  in  the  Consolidated 
Balance Sheets and dividends received from these investments 
are included as a component of Other noninterest income in the 

79

Consolidated Statements of Income, to the extent the dividends 
are distributed from net accumulated earnings of the investee 
since  the  date  of  acquisition.  Dividends  received  from  these 
investments  in  excess  of  earnings,  subsequent  to  the  date  of 
investment,  are  recorded  as  a  reduction  to  the  cost  of  the 
investment.

Results of operations of acquired entities are included from 
the  date  of  acquisition.  Results  of  operations  associated  with 
entities  or  net  assets  sold  are  included  through  the  date  of 
disposition. The Company reports any noncontrolling interests 
in  its  subsidiaries  in  the  equity  section  of  the  Consolidated 
Balance  Sheets  and  separately  presents  the  income  or  loss 
attributable  to  the  noncontrolling  interest  of  a  consolidated 
subsidiary in its Consolidated Statements of Income. 

Assets and liabilities of acquired entities are accounted for 
under  the  acquisition  method  of  accounting,  whereby  the 
purchase price of an acquired entity is allocated to the estimated 
fair value of the assets acquired and liabilities assumed at the 
date of acquisition. The excess of the purchase price over the 
amount allocated to the assets acquired and liabilities assumed 
is recorded as goodwill.

The preparation of financial statements in conformity with 
U.S.  GAAP  requires  management  to  make  estimates  and 
assumptions that affect the amounts reported in the Consolidated 
Financial  Statements  and  accompanying  Notes;  actual  results 
could vary from these estimates. Certain reclassifications have 
been made to prior period amounts to conform to the current 
period presentation.

The  Company  evaluated  events  that  occurred  between 
December 31,  2017  and  the  date  the  accompanying  financial 
statements were issued, and there were no material events, other 
than  those  already  discussed  in  this  Form  10-K,  that  would 
require  recognition  in  the  Company's  Consolidated  Financial 
Statements or disclosure in the accompanying Notes.

Cash and Cash Equivalents
Cash and cash equivalents include Cash and due from banks, 
Interest-bearing  deposits  in  other  banks,  Fed  Funds  sold,  and 
Securities  borrowed  or  purchased  under  agreements  to  resell. 
Cash and cash equivalents have maturities of three months or 
less, and accordingly, the carrying amount of these instruments 
is deemed to be a reasonable estimate of fair value.

Trading Activities and Securities AFS
Debt securities and marketable equity securities are classified at 
trade  date  as  trading  or  securities  AFS.  Trading  assets  and 
liabilities are measured at fair value with changes in fair value 
recognized within Noninterest income. Securities AFS are used 
as part of the overall asset and liability management process to 
optimize income and market performance over an entire interest 
rate cycle. Interest income and dividends on securities AFS are 
recognized in interest income on an accrual basis. Premiums and 
discounts on debt securities AFS are amortized or accreted as an 
adjustment to yield over the life of the security. The Company 
estimates  principal  prepayments  on  securities AFS  for  which 
prepayments  are  probable  and  the  timing  and  amount  of 
prepayments  can  be  reasonably  estimated.  The  estimates  are 

 
Notes to Consolidated Financial Statements, continued

informed  by  analyses  of  both  historical  prepayments  and 
anticipated  macroeconomic  conditions,  such  as  spot  interest 
rates compared to implied forward interest rates. The estimate 
of prepayments for these debt securities impacts their lives and 
thereby  the  amortization  or  accretion  of  associated  premiums 
and discounts. Securities AFS are measured at fair value with 
unrealized gains and losses, net of any tax effect, included in 
AOCI as a component of shareholders’ equity. Realized gains 
and losses, including OTTI, are determined using the specific 
identification  method  and  are  recognized  as  a  component  of 
Noninterest income in the Consolidated Statements of Income.
Securities AFS are reviewed for OTTI on a quarterly basis. 
In  determining  whether  OTTI  exists  for  securities  in  an 
unrealized loss position, the Company assesses whether it has 
the intent to sell the security or, for debt securities, the Company 
assesses the likelihood of selling the security prior to the recovery 
of its amortized cost basis. If the Company intends to sell the 
debt security or it is more-likely-than-not that the Company will 
be required to sell the debt security prior to the recovery of its 
amortized cost basis, the debt security is written down to fair 
value,  and  the  full  amount  of  any  impairment  charge  is 
recognized  as  a  component  of  Noninterest  income  in  the 
Consolidated Statements of Income. If the Company does not 
intend to sell the debt security and it is more-likely-than-not that 
the Company will not be required to sell the debt security prior 
to recovery of its amortized cost basis, only the credit component 
of any impairment of a debt security is recognized as a component 
of Noninterest income in the Consolidated Statements of Income, 
with the remaining impairment balance recorded in OCI.

The OTTI review for marketable equity securities includes 
an  analysis  of  the  facts  and  circumstances  of  each  individual 
investment and focuses on the severity of loss, the length of time 
the  fair  value  has  been  below  cost,  the  expectation  for  that 
security's  performance,  the  financial  condition  and  near-term 
prospects of the issuer, and management's intent and ability to 
hold  the  security  to  recovery. A  decline  in  value  of  an  equity 
security  that  is  considered  to  be  other-than-temporary  is 
recognized  as  a  component  of  Noninterest  income  in  the 
Consolidated Statements of Income.

Nonmarketable equity securities are accounted for under the 
cost or equity method and are included in Other assets in the 
reviews 
Consolidated  Balance  Sheets.  The  Company 
nonmarketable securities accounted for under the cost method 
on a quarterly basis, and reduces the asset value when declines 
in  value  are  considered  to  be  other-than-temporary.  Equity 
method investments are recorded at cost, adjusted to reflect the 
Company’s portion of income, loss, or dividends of the investee. 
Realized  income,  realized  losses,  and  estimated  other-than-
temporary  losses  on  cost  and  equity  method  investments  are 
the  Consolidated 
recognized 
Statements of Income.

in  Noninterest 

income 

in 

For  additional  information  on  the  Company’s  securities 
activities,  see  Note  4,  “Trading  Assets  and  Liabilities  and 
Derivatives,” and Note 5, “Securities Available for Sale.”

Loans Held for Sale
The  Company’s  LHFS  generally  includes  certain  commercial 
loans and consumer loans. Loans are initially classified as LHFS 
when  they  are  individually  identified  as  being  available  for 
immediate sale and management has committed to a formal plan 

80

to sell them. LHFS are recorded at either fair value, if elected, 
or the lower of cost or fair value. Any origination fees and costs 
for LHFS recorded at LOCOM are capitalized in the basis of the 
loan and are included in the calculation of realized gains and 
losses upon sale. Origination fees and costs are recognized in 
earnings at the time of origination for LHFS that are elected to 
be measured at fair value. Fair value is derived from observable 
current  market  prices,  when  available,  and  includes  loan 
servicing  value.  When  observable  market  prices  are  not 
available, the Company uses judgment and estimates fair value 
using  internal  models,  in  which  the  Company  uses  its  best 
estimates of assumptions it believes would be used by market 
participants  in  estimating  fair  value.  Adjustments  to  reflect 
unrealized gains and losses resulting from changes in fair value 
and realized gains and losses upon ultimate sale of the loans are 
classified as Noninterest income in the Consolidated Statements 
of Income.

The Company may transfer certain loans to LHFS measured 
at LOCOM. At the time of transfer, any credit losses subject to 
charge-off in accordance with the Company's policy are recorded 
as a reduction in the ALLL. Any subsequent losses, including 
those  related  to  interest  rate  or  liquidity  related  valuation 
adjustments, are recorded as a component of Noninterest income 
in the Consolidated Statements of Income. The Company may 
also transfer loans from LHFS to LHFI. If an LHFS for which 
fair  value  accounting  was  elected  is  transferred  to  held  for 
investment, it will continue to be accounted for at fair value in 
the LHFI portfolio. For additional information on the Company’s 
LHFS activities, see Note 6, “Loans.”

Commercial 

Loans Held for Investment
Loans that management has the intent and ability to hold for the 
foreseeable  future  or  until  maturity  or  payoff  are  considered 
LHFI. The Company’s loan balance is comprised of loans held 
in portfolio, including commercial loans and consumer loans. 
Interest income on loans, except those classified as nonaccrual, 
is accrued based upon the outstanding principal amounts using 
the effective yield method.
loans 

(C&I,  CRE,  and  commercial 
construction) are considered to be past due when payment is not 
received from the borrower by the contractually specified due 
date.  The  Company  typically  classifies  commercial  loans  as 
nonaccrual when one of the following events occurs:  (i) interest 
or principal has been past due 90 days or more, unless the loan 
is  both  well  secured  and  in  the  process  of  collection;  (ii) 
collection of contractual interest or principal is not anticipated; 
or (iii) income for the loan is recognized on a cash basis due to 
the deterioration in the financial condition of the debtor. When 
a  loan  is  placed  on  nonaccrual,  accrued  interest  is  reversed 
against  interest  income.  Interest  income  on  commercial 
nonaccrual loans, if recognized, is recognized after the principal 
has been reduced to zero. If and when commercial borrowers 
demonstrate the ability to repay a loan classified as nonaccrual 
in accordance with its contractual terms, the loan may be returned 
to accrual status upon meeting all regulatory, accounting, and 
internal policy requirements.

Consumer 

loans  secured  by  residential  real  estate 
(guaranteed 
residential  mortgages, 
residential home equity products, and residential construction 
loans) are considered to be past due when a monthly payment is 

and  nonguaranteed 

Notes to Consolidated Financial Statements, continued

due and unpaid for one month. Guaranteed residential mortgages 
continue  to  accrue  interest  regardless  of  delinquency  status 
because collection of principal and interest is reasonably assured 
by the government. Nonguaranteed residential mortgages and 
residential construction loans are generally placed on nonaccrual 
when  three  payments  are  past  due.  Residential  home  equity 
products are generally placed on nonaccrual when payments are 
90 days past due. The exceptions for nonguaranteed residential 
mortgages, residential construction loans, and residential home 
equity  products  are:  (i)  when  the  borrower  has  declared 
bankruptcy, in which case, they are moved to nonaccrual status 
once  they  become  60  days  past  due,  (ii)  loans  discharged  in 
Chapter  7  bankruptcy  that  have  not  been  reaffirmed  by  the 
borrower, in which case, they are reclassified as TDRs and moved 
to  nonaccrual  status,  and  (iii)  second  lien  loans,  which  are 
classified as nonaccrual when the first lien loan is classified as 
nonaccrual, even if the second lien loan is performing. When a 
loan is placed on nonaccrual, accrued interest is reversed against 
interest income. Interest income on nonaccrual consumer loans 
secured by residential real estate is recognized on a cash basis. 
Nonaccrual consumer loans secured by residential real estate are 
typically returned to accrual status once they no longer meet the 
delinquency threshold that resulted in them initially being moved 
to nonaccrual status, with the exception of the aforementioned 
Chapter 7 bankruptcy loans, which remain on nonaccrual until 
there is six months of payment performance following discharge 
by the bankruptcy court.

All other consumer loans (guaranteed student, other direct, 
indirect, and credit card loans) are considered to be past due when 
payment is not received from the borrower by the contractually 
specified due date. Guaranteed student loans continue to accrue 
interest regardless of delinquency status because collection of 
principal  and  interest  is  reasonably  assured.  Other  direct  and 
indirect loans are typically placed on nonaccrual when payments 
have been past due for 90 days or more, except when the borrower 
has  declared  bankruptcy,  in  which  case  they  are  moved  to 
nonaccrual status once they become 60 days past due. When a 
loan is placed on nonaccrual, accrued interest is reversed against 
interest  income.  Interest  income  on  nonaccrual  loans,  if 
recognized, is recognized on a cash basis. Nonaccrual consumer 
loans are typically returned to accrual status once they are no 
longer past due.

TDRs  are  loans  in  which  the  borrower  is  experiencing 
financial difficulty at the time of restructure and the borrower 
received an economic concession either from the Company or 
as the product of a bankruptcy court order. A restructuring that 
results in only a delay in payments that is insignificant is not 
considered  an  economic  concession.  To  date,  the  Company’s 
TDRs have been predominantly first and second lien residential 
mortgages and home equity lines of credit. Prior to granting a 
modification of a borrower’s loan terms, the Company performs 
an evaluation of the borrower’s financial condition and ability 
to service under the potential modified loan terms. The types of 
concessions generally granted are extensions of the loan maturity 
date and/or reductions in the original contractual interest rate. In 
certain situations, the Company may offer to restructure a loan 
in  a  manner  that  ultimately  results  in  the  forgiveness  of  a 
contractually specified principal balance. Typically, if a loan is 
accruing interest at the time of modification, the loan remains 
on accrual status and is subject to the Company’s charge-off and 

nonaccrual  policies.  See  the  “Allowance  for  Credit  Losses” 
section below for further information regarding these policies. 
If a loan is on nonaccrual before it is determined to be a TDR 
then the loan remains on nonaccrual. Typically, TDRs may be 
returned to accrual status if there has been at least a six month 
sustained  period  of  repayment  performance  by  the  borrower. 
Generally, once a loan becomes a TDR, the Company expects 
that  the  loan  will  continue  to  be  reported  as  a  TDR  for  its 
remaining life, even after returning to accruing status, unless the 
modified  rates  and  terms  at  the  time  of  modification  were 
available to the borrower in the market or the loan is subsequently 
restructured with no concession to the borrower and the borrower 
is no longer in financial difficulty. Interest income recognition 
on  impaired  loans  is  dependent  upon  accrual  status,  TDR 
designation, and loan type as discussed above.

For  loans  accounted  for  at  amortized  cost,  fees  and 
incremental direct costs associated with the loan origination and 
pricing process, as well as premiums and discounts, are deferred 
and amortized over the respective loan terms. Fees received for 
providing  loan  commitments  that  result  in  funded  loans  are 
recognized over the term of the loan as an adjustment of the yield. 
If a loan is never funded, the commitment fee is recognized in 
Noninterest income at the expiration of the commitment period. 
For  any  newly-originated  loans  that  are  accounted  for  at  fair 
value, the origination fees are recognized in Noninterest income 
while  the  origination  costs  are  recognized  in  Noninterest 
expense, at the time of origination. For additional information 
on the Company's loans activities, see Note 6, “Loans.”

Allowance for Credit Losses
The allowance for credit losses is composed of the ALLL and 
the reserve for unfunded commitments. The Company’s ALLL 
reflects probable current inherent losses in the LHFI portfolio 
based on management’s evaluation of the size and current risk 
characteristics of the loan portfolio. The Company employs a 
variety of modeling and estimation techniques to measure credit 
risk  and  construct  an  appropriate  and  adequate  ALLL. 
Quantitative  and  qualitative  asset  quality  measures  are 
considered in estimating the ALLL. Such evaluation considers 
a  number  of  factors  for  each  of  the  loan  portfolio  segments, 
including, but not limited to, net charge-off trends, internal risk 
ratings, changes in internal risk ratings, loss forecasts, collateral 
values, geographic location, delinquency rates, nonperforming 
and restructured loan status, origination channel, product mix, 
underwriting  practices,  industry  conditions,  and  economic 
trends. Additionally, refreshed FICO scores are considered for 
consumer  loans  and  single  name  borrower  concentration  is 
considered for commercial loans. These credit quality factors are 
incorporated into various loss estimation models and analytical 
tools  utilized  in  the  ALLL  process  and/or  are  qualitatively 
considered in evaluating the overall reasonableness of the ALLL.
Large commercial nonaccrual loans, certain consumer loans 
(nonguaranteed residential mortgages, residential home equity 
products,  residential  construction,  other  direct,  indirect,  and 
credit  card),  and  commercial  loans  whose  terms  have  been 
modified  in  a TDR  are  reviewed  to  determine  the  amount  of 
specific  allowance  required  in  accordance  with  applicable 
accounting guidance. A loan is considered impaired when, based 
on  current  information  and  events,  it  is  probable  that  the 
Company will be unable to collect all amounts due, including 

81

Notes to Consolidated Financial Statements, continued

principal and interest, according to the contractual terms of the 
agreement. If necessary, an allowance is established for these 
specifically  evaluated  impaired  loans. The  specific  allowance 
established for these loans is based on a thorough analysis of the 
most probable source of repayment, including the present value 
of the loan’s expected future cash flows, the loan’s estimated 
market  value,  or  the  estimated  fair  value  of  the  underlying 
collateral,  net  of  estimated  selling  costs. Any  change  in  the 
present value attributable to the passage of time is recognized 
through the Provision for credit losses.

General  allowances  are  established  for  loans  and  leases 
grouped  into  pools  based  on  similar  characteristics.  In  this 
process, general allowance factors are based on an analysis of 
historical charge-off experience, expected loss factors derived 
from the Company's internal risk rating process, portfolio trends, 
and  regional  and  national  economic  conditions.  Other 
adjustments may be made to the ALLL after an assessment of 
internal and external influences on credit quality that may not be 
fully  reflected  in  the  historical  loss  or  risk  rating  data. These 
influences  may  include  elements  such  as  changes  in  credit 
underwriting,  concentration  risk,  macroeconomic  conditions, 
and/or recent observable asset quality trends. 

Commercial loans are charged off when they are considered 
uncollectible. Losses on unsecured consumer loans are generally 
recognized at 120 days past due, except for losses on credit cards, 
which are recognized when the loans are 180 days past due, and 
losses on guaranteed student loans, which are recognized when 
the loans are 270 days past due and payment from the guarantor 
is  processed  by  the  servicer.  However,  if  the  borrower  is  in 
bankruptcy, the loan is charged-off in the month the loan becomes 
60  days  past  due.  Losses,  as  appropriate,  on  consumer  loans 
secured by residential real estate, are typically recognized at 120 
or 180 days past due, depending on the loan and collateral type, 
in  compliance  with  the  FFIEC  guidelines.  However,  if  the 
borrower is in bankruptcy, the secured asset is evaluated once 
the loan becomes 60 days past due. The loan value in excess of 
the secured asset value is written down or charged-off after the 
valuation occurs. Additionally, if a residential loan is discharged 
in Chapter 7 bankruptcy and not reaffirmed by the borrower, the 
Company's policy is to immediately charge-off the excess of the 
carrying amount over the fair value of the collateral.

The Company uses numerous sources of information when 
evaluating a property’s value. Estimated collateral valuations are 
based  on  appraisals,  broker  price  opinions,  recent  sales  of 
foreclosed  properties,  automated  valuation  models,  other 
property-specific information, and relevant market information, 
supplemented  by  the  Company’s  internal  property  valuation 
analysis. The value estimate is based on an orderly disposition 
of the property, inclusive of marketing costs. In limited instances, 
the  Company  adjusts  externally  provided  appraisals  for 
justifiable and well-supported reasons, such as an appraiser not 
being aware of certain property-specific factors or recent sales 
information.

For commercial loans secured by real estate, an acceptable 
third party appraisal or other form of evaluation, as permitted by 
regulation, is obtained prior to the origination of the loan and 
upon a subsequent transaction involving a material change in 
terms. In addition, updated valuations may be obtained during 
the  life  of  a  loan,  as  appropriate,  such  as  when  a  loan's 
performance  materially  deteriorates.  In  situations  where  an 

updated appraisal has not been received or a formal evaluation 
performed, the Company monitors factors that can positively or 
negatively  impact property  value,  such  as  the  date  of  the  last 
valuation, the volatility of property values in specific markets, 
changes in the value of similar properties, and changes in the 
characteristics  of  individual  properties.  Changes  in  collateral 
value affect the ALLL through the risk rating or impaired loan 
evaluation process. Charge-offs are recognized when the amount 
of the loss is quantifiable and timing is known. The charge-off 
is measured based on the difference between the loan’s carrying 
value, including deferred fees, and the estimated realizable value 
of the property, net of estimated selling costs. When valuing a 
property for the purpose of determining a charge-off, a third party 
appraisal  or  an  independently  derived  internal  evaluation  is 
generally employed.

For nonguaranteed mortgage loans secured by residential 
real estate where the Company is proceeding with a foreclosure 
action, a new valuation is obtained prior to the loan becoming 
180 days past due and, if required, the loan is written down to 
its realizable value, net of estimated selling costs. In the event 
the Company decides not to proceed with a foreclosure action, 
the full balance of the loan is charged-off. If a loan remains in 
the foreclosure process for 12 months past the original charge-
off, the Company may obtain a new valuation. Any additional 
loss based on the new valuation is charged-off. At foreclosure, 
a new valuation is obtained and the loan is transferred to OREO
at  fair  value  less  estimated  selling  costs;  any  loan  balance  in 
excess of the transfer value is charged-off. Estimated declines in 
value of the collateral between these formal evaluation events 
are captured in the ALLL based on changes in the house price 
index  in  the  applicable  metropolitan  statistical  area  or  other 
market information. 

In  addition  to  the  ALLL,  the  Company  also  estimates 
probable losses related to unfunded lending commitments, such 
as  letters  of  credit  and  binding  unfunded  loan  commitments. 
Unfunded lending commitments are analyzed and segregated by 
risk based on the Company’s internal risk rating scale. These risk 
classifications, in combination with probability of commitment 
usage,  existing  economic  conditions,  and  any  other  pertinent 
information, result in the estimation of the reserve for unfunded 
lending commitments. The Unfunded commitments reserve is 
reported in Other liabilities on the Consolidated Balance Sheets 
and  the  provision  associated  with  changes  in  the  Unfunded 
commitment  reserve  is  recognized  in  the  Provision  for  credit 
losses in the Consolidated Statements of Income. For additional 
information  on  the  Company's  allowance  for  credit  loss 
activities, see Note 7, “Allowance for Credit Losses.”

Premises and Equipment
Premises  and  equipment  are  carried  at  cost  less  accumulated 
depreciation  and  amortization.  Depreciation  is  calculated 
predominantly  using  the  straight-line  method  over  the  assets’ 
estimated useful lives. Leasehold improvements are amortized 
using  the  straight-line  method  over  the  shorter  of  the 
improvements'  estimated  useful  lives  or  the  lease  term. 
Construction and software in process includes costs related to 
in-process branch expansion, branch renovation, and software 
development  projects.  Upon  completion,  branch  and  office 
related projects are maintained in premises and equipment while 
completed software projects are reclassified to Other assets in 

82

Notes to Consolidated Financial Statements, continued

the Consolidated Balance Sheets. Maintenance and repairs are 
charged to expense, and improvements that extend the useful life 
of an asset are capitalized and depreciated over the remaining 
useful life. Premises and equipment are evaluated for impairment 
whenever events or changes in circumstances indicate that the 
carrying value of the asset may not be recoverable. For additional 
information  on  the  Company’s  premises  and  equipment 
activities, see Note 8, “Premises and Equipment.”

Goodwill and Other Intangible Assets
Goodwill represents the excess purchase price over the fair value 
of  identifiable  net  assets  of  acquired  companies.  Goodwill  is 
assigned to reporting units that are expected to benefit from the 
synergies of the business combination.

Goodwill is tested at the reporting unit level for impairment, 
at least annually as of October 1, or as events and circumstances 
change that would more-likely-than-not reduce the fair value of 
a reporting unit below its carrying amount. 

If, after considering all relevant events and circumstances, 
the Company determines it is not more-likely-than-not that the 
fair value of a reporting unit is less than its carrying amount, then 
performing an impairment test is not necessary. If the Company 
elects  to  bypass  the  qualitative  analysis,  or  concludes  via 
qualitative analysis that it is more-likely-than-not that the fair 
value of a reporting unit is less than its carrying value, a two-
step goodwill impairment test is performed. In the first step, the 
fair value of each reporting unit is compared with its carrying 
value. If the fair value is greater than the carrying value, then the 
reporting unit's goodwill is deemed not to be impaired. If the fair 
value  is  less  than  the  carrying  value,  then  the  second  step  is 
performed,  which  measures  the  amount  of  impairment  by 
comparing the carrying amount of goodwill to its implied fair 
value.  If  the  implied  fair  value  of  the  goodwill  exceeds  the 
carrying amount, there is no impairment. If the carrying amount 
exceeds the implied fair value of the goodwill, an impairment 
charge is recorded for the excess. 

The Company has identified intangible assets with finite and 
indefinite  lives.  Intangible  assets  that  have  finite  lives  are 
amortized over their useful lives and carried at amortized cost. 
Intangible assets that have indefinite lives are initially measured 
at fair value and are not amortized until the useful life is no longer 
considered indefinite. Indefinite-lived intangibles are tested for 
impairment at least annually; however, all intangible assets are 
evaluated  for  impairment  whenever  events  or  changes  in 
circumstances indicate it is more likely than not that the asset is 
impaired. For additional information on the Company’s activities 
related to goodwill and other intangibles, see Note 9, “Goodwill 
and Other Intangible Assets.”

Servicing Rights
The Company recognizes as assets the rights to service loans, 
either when the loans are sold and the associated servicing rights 
are retained or when servicing rights are purchased from a third 
party. All servicing rights are initially measured at fair value.

Fair value is determined by projecting net servicing cash 
flows, which are then discounted to estimate fair value. The fair 
value  of  servicing  rights  is  impacted  by  a  variety  of  factors, 
including prepayment assumptions, discount rates, delinquency 
rates, contractually specified servicing fees, servicing costs, and 
underlying 
underlying 

characteristics.  The 

portfolio 

assumptions  and  estimated  values  are  corroborated  by  values 
received  from  independent  third  parties  and  comparisons  to 
market transactions. 

The Company has elected to subsequently account for its 
residential MSRs under the fair value measurement method and 
actively hedges the change in fair value of its residential MSRs. 
The Company has elected to subsequently account for all other 
servicing  rights,  which  include  commercial  mortgage  and 
consumer loan servicing rights, under the amortization method. 
Commercial mortgage and consumer loan servicing rights are 
amortized in proportion to and over the period of estimated net 
servicing  income.  Servicing  rights  accounted  for  under  the 
amortization method are periodically tested for impairment by 
comparing  the  carrying  amount  of  the  servicing  rights  to  the 
estimated fair value.

Servicing rights are included in Other intangible assets on 
the  Consolidated  Balance  Sheets.  For  residential  MSRs,  both 
servicing fees, which are recognized when they are received, and 
changes  in  the  fair  value  of  MSRs  are  reported  in  Mortgage 
servicing  related  income  in  the  Consolidated  Statements  of 
Income.  For  commercial  mortgage  servicing  rights,  servicing 
fees,  amortization,  and  any  impairment  is  recognized  in 
Commercial  real  estate  related  income  in  the  Consolidated 
Statements of Income. For all other servicing rights, the related 
servicing fees, amortization, and any impairment are recognized 
in Other noninterest income in the Consolidated Statements of 
Income.

  For  additional  information  on  the  Company’s  servicing 

rights, see Note 9, “Goodwill and Other Intangible Assets.”

Other Real Estate Owned
Assets acquired through, or in lieu of, loan foreclosure are held 
for sale and are initially recorded at fair value, less estimated 
selling costs. To the extent fair value, less cost to sell, is less than 
the loan’s cost basis, the difference is charged to the ALLL at the 
date  of  transfer  into  OREO.  The  Company  estimates  market 
values  based  primarily  on  appraisals  and  other  market 
information. Pursuant to an asset transfer into OREO, the fair 
value of the asset, less cost to sell at the date of transfer, becomes 
the new cost basis of the asset. Any subsequent changes in value 
as well as gains or losses from the disposition on these assets are 
reported in Noninterest expense in the Consolidated Statements 
of  Income.  For  additional  information  on  the  Company's 
activities related to OREO, see Note 18, “Fair Value Election 
and Measurement.”

Loan Sales and Securitizations
The Company sells and at times may securitize loans and other 
financial assets. When the Company securitizes assets, it may 
hold a portion of the securities issued, including senior interests, 
subordinated  and  other  residual  interests,  interest-only  strips, 
and principal-only strips, all of which are considered retained 
interests in the transferred assets. Retained securitized interests 
are recognized and initially measured at fair value. The interests 
in securitized assets held by the Company are typically classified 
as either securities AFS or trading assets and are measured at fair 
value, which is based on independent, third party market prices, 
market  prices  for  similar  assets,  or  discounted  cash  flow 
analyses.  If  market  prices  are  not  available,  fair  value  is 
calculated  using  management’s  best  estimates  of  key 

83

Notes to Consolidated Financial Statements, continued

assumptions, including credit losses, loan repayment speeds, and 
discount rates commensurate with the risks involved.

The Company transfers first lien residential mortgage loans 
in  conjunction  with  Ginnie  Mae  and  GSE  securitization 
transactions,  whereby  the  loans  are  exchanged  for  cash  or 
securities  that  are  readily  redeemable  for  cash  and  servicing 
rights  are  retained.  Net  gains/losses  on  the  sale  of  residential 
mortgage  LHFS  are  recorded  at  inception  of  the  associated 
IRLCs and reflect the change in value of the loans resulting from 
changes in interest rates from the time the Company enters into 
IRLCs with borrowers until the loans are sold, adjusted for pull 
through  rates  and  excluding  hedge  transactions  initiated  to 
mitigate  this  market  risk.  Net  gains  related  to  the  sale  of 
residential  mortgage  loans  are  recorded  within  Mortgage 
production  related  income  in  the  Consolidated  Statements  of 
Income. 

The  Company  also  sells  commercial  mortgage  loans  to 
Fannie Mae and Freddie Mac and issues and sells Ginnie Mae 
commercial MBS backed by FHA insured loans. The loans and 
securities  are  exchanged  for  cash  and  servicing  rights  are 
retained.  Gains  and  losses  from  the  sale  of  these  commercial 
mortgage loans and securities are recorded within Commercial 
real  estate  related  income  in  the  Consolidated  Statements  of 
Income.  For  additional 
the  Company’s 
securitization  activities,  see  Note  10,  “Certain  Transfers  of 
Financial Assets and Variable Interest Entities.”

information  on 

Income Taxes
The Company's provision for income taxes is based on income 
and  expense  reported  for  financial  statement  purposes  after 
adjustments for permanent differences such as interest income 
from lending to tax-exempt entities, tax credits from community 
reinvestment  activities,  and  amortization  expense  related  to 
qualified affordable housing investment costs. In computing the 
provision for income taxes, the Company evaluates the technical 
merits of its income tax positions based on current legislative, 
judicial,  and  regulatory  guidance.  The  deferral  method  of 
accounting is used on investments that generate investment tax 
credits, such that the investment tax credits are recognized as a 
reduction to the related investment. Additionally, the Company 
recognizes all excess tax benefits and deficiencies on employee 
share-based  payments  as  a  component  of  the  Provision  for 
income taxes in the Consolidated Statements of Income. These 
tax  effects,  generally  determined  upon  the  exercise  of  stock 
options or vesting of restricted stock, are treated as discrete items 
in the period in which they occur.

DTAs and DTLs result from differences between the timing 
of the recognition of assets and liabilities for financial reporting 
purposes and for income tax purposes. These deferred assets and 
liabilities are measured using the enacted tax rates and laws that 
are expected to apply in the periods in which the DTAs or DTLs 
are expected to be realized. Subsequent changes in the tax laws 
require adjustment to these deferred assets and liabilities with 
the cumulative effect included in the Provision for income taxes 
for  the  period  in  which  the  change  is  enacted.  A  valuation 
allowance is recognized for a DTA, if based on the weight of 
available evidence, it is more likely than not that some portion 
or all of the DTA will not be realized. 

Interest and penalties related to the Company’s tax positions 
are recognized as a component of the Provision for income taxes 

84

in  the  Consolidated  Statements  of  Income.  For  additional 
information on the Company’s activities related to income taxes, 
see Note 14, “Income Taxes.”

Earnings Per Share
Basic  EPS  is  computed  by  dividing  net  income  available  to 
common  shareholders  by  the  weighted  average  number  of 
common shares outstanding during each period. Diluted EPS is 
computed  by  dividing  net  income  available  to  common 
shareholders by the weighted average number of common shares 
outstanding during each period, plus common share equivalents 
calculated  for  stock  options,  warrants,  and  restricted  stock 
outstanding using the treasury stock method. 

The  Company  has  issued  certain  restricted  stock  awards, 
which  are  unvested  share-based  payment  awards  that  contain 
non-forfeitable  rights  to  dividends  or  dividend  equivalents. 
These restricted shares are considered participating securities. 
Accordingly, the Company calculated net income available to 
common  shareholders  pursuant  to  the  two-class  method, 
whereby net income is allocated between common shareholders 
and participating securities. 

Net income available to common shareholders represents 
net income after preferred stock dividends, gains or losses from 
any repurchases of preferred stock, and dividends and allocation 
of  undistributed  earnings  to  the  participating  securities.  For 
additional information on the Company’s EPS, see Note 12, “Net 
Income Per Common Share.”

Securities Sold Under Agreements to Repurchase and 
Securities Borrowed or Purchased Under Agreements to Resell
Securities sold under agreements to repurchase and securities 
borrowed or purchased under agreements to resell are accounted 
for as collateralized financing transactions and are recorded at 
the amounts at which the securities were sold or acquired, plus 
accrued interest. The fair value of collateral pledged or received 
is continually monitored and additional collateral is obtained or 
requested to be returned to the Company as deemed appropriate. 
For additional information on the collateral pledged to secure 
repurchase  agreements,  see  Note  3,  "Federal  Funds  Sold  and 
Securities  Financing Activities,"  Note  4,  "Trading Assets  and 
Liabilities and Derivatives," and Note 5, "Securities Available 
for Sale."

Guarantees
The  Company  recognizes  a  liability  at  the  inception  of  a 
guarantee at an amount equal to the estimated fair value of the 
obligation. A guarantee is defined as a contract that contingently 
requires a company to make a payment to a guaranteed party 
based upon changes in an underlying asset, liability, or equity 
security of the guaranteed party, or upon failure of a third party 
to perform under a specified agreement. The Company considers 
the  following  arrangements  to  be  guarantees:  certain  asset 
purchase/sale agreements with recourse, standby letters of credit 
and  financial  guarantees,  certain  indemnification  agreements 
included within third party contractual arrangements, and certain 
derivative  contracts.  For  additional 
the 
Company’s guarantor obligations, see Note 16, “Guarantees.”

information  on 

Notes to Consolidated Financial Statements, continued

Derivative Instruments and Hedging Activities
The Company records derivative contracts at fair value in the 
Consolidated Balance Sheets. Accounting for changes in the fair 
value of a derivative depends upon whether or not it has been 
designated in a formal, qualifying hedging relationship. 

Changes in the fair value of derivatives not designated in a 
hedging relationship are recorded in Noninterest income. This 
includes  derivatives  that  the  Company  enters  into  in  a  dealer 
capacity to facilitate client transactions and as a risk management 
tool to economically hedge certain identified risks, along with 
certain IRLCs on residential mortgage and commercial loans that 
are a normal part of the Company’s operations. The Company 
also evaluates contracts, such as brokered deposits and debt, to 
determine whether any embedded derivatives are required to be 
bifurcated  and  separately  accounted  for  as  freestanding 
derivatives.

of  the  hedged  item.  For  discontinued  cash  flow  hedges,  the 
unrealized  gains  and  losses  recorded  in  AOCI  would  be 
reclassified  to  earnings  in  the  period  when  the  previously 
designated hedged cash flows occur unless it was determined 
that  transaction  was  probable  to  not  occur,  whereby  any 
unrealized  gains  and  losses  in AOCI  would  be  immediately 
reclassified to earnings.

It is the Company's policy to offset derivative transactions 
with a single counterparty as well as any cash collateral paid to 
and received from that counterparty for derivative contracts that 
are  subject  to  ISDA  or  other  legally  enforceable  netting 
arrangements  and  meet  accounting  guidance  for  offsetting 
treatment.  For  additional  information  on  the  Company’s 
derivative  activities,  see  Note  17,  “Derivative  Financial 
Instruments,”  and  Note  18,  “Fair  Value  Election  and 
Measurement.”

Certain  derivatives  used  as  risk  management  tools  are 
designated as accounting hedges of the Company’s exposure to 
changes  in  interest  rates  or  other  identified  market  risks. The 
Company  prepares  written  hedge  documentation  for  all 
derivatives which are designated as hedges of (1) changes in the 
fair value of a recognized asset or liability (fair value hedge) 
attributable to a specified risk or (2) a forecasted transaction, 
such as the variability of cash flows to be received or paid related 
to a recognized asset or liability (cash flow hedge). The written 
hedge  documentation  includes  identification  of,  among  other 
items,  the  risk  management  objective,  hedging  instrument, 
hedged  item  and  methodologies  for  assessing  and  measuring 
hedge effectiveness and ineffectiveness, along with support for 
management’s assertion that the hedge will be highly effective. 
Methodologies 
and 
ineffectiveness  are  consistent  between  similar  types  of  hedge 
transactions  and  include  (i)  statistical  regression  analysis  of 
changes in the cash flows of the actual derivative and a perfectly 
effective  hypothetical  derivative,  or  (ii)  statistical  regression 
analysis of changes in the fair values of the actual derivative and 
the hedged item. 

effectiveness 

related 

hedge 

to 

through 

the  matching  of  critical 

For  designated  hedging  relationships, 

the  Company 
performs  retrospective  and  prospective  effectiveness  testing 
using  quantitative  methods  and  does  not  assume  perfect 
effectiveness 
terms. 
Assessments of hedge effectiveness and measurements of hedge 
ineffectiveness are performed at least quarterly. Changes in the 
fair value of a derivative that is highly effective and that has been 
designated and qualifies as a fair value hedge are recorded in 
current period earnings, along with the changes in the fair value 
of the hedged item that are attributable to the hedged risk. The 
effective portion of the changes in the fair value of a derivative 
that is highly effective and that has been designated and qualifies 
as a cash flow hedge is initially recorded in AOCI and reclassified 
to  earnings  in  the  same  period  that  the  hedged  item  impacts 
earnings; any ineffective portion is recorded in current period 
earnings.

Hedge accounting ceases for hedging relationships that are 
no longer deemed effective, or for which the derivative has been 
terminated or de-designated. For discontinued fair value hedges 
where  the  hedged  item  remains  outstanding,  the  hedged  item 
would cease to be remeasured at fair value attributable to changes 
in the hedged risk and any existing basis adjustment would be 
recognized as an adjustment to earnings over the remaining life 

85

Stock-Based Compensation
The Company sponsors various stock-based compensation plans 
under  which  RSUs,  restricted  stock,  and  phantom  stock  units 
may be granted to certain employees. The Company measures 
the grant date fair value of the RSUs and restricted stock, which 
is expensed over the award's vesting period. For service-based 
awards, compensation expense is amortized on a straight-line 
basis  and  recognized  in  Employee  compensation  in  the 
Consolidated Statements of Income. Additionally, the Company 
estimates  the  number  of  awards  for  which  it  is  probable  that 
service  will  be  rendered  and  adjusts  compensation  cost 
accordingly. Estimated forfeitures are subsequently adjusted to 
reflect  actual  forfeitures.  For  performance-based  awards, 
compensation expense is amortized over the vesting period and 
recognized  in  Employee  compensation  in  the  Consolidated 
Statements of Income. These performance-based awards may be 
adjusted  based  on  the  estimated  outcome  of  the  award's 
associated  performance  conditions,  which  are  based  on  the 
Company's performance and/or its performance relative to its 
peers. 

The phantom stock units are subject to variable accounting 
and grant certain employees the contractual right to receive an 
amount  in  cash  equal  to  the  fair  market  value  of  a  share  of 
common  stock  on  the  specified  date  set  forth  in  the  award 
agreement, typically the vesting date. For additional information 
on the Company’s stock-based compensation plans, see Note 15, 
“Employee Benefit Plans.”

Employee Benefits
Employee benefits expense includes expenses related to (i) net 
periodic benefit costs or credits associated with the pension and 
other postretirement benefit plans, (ii) contributions under the 
defined  contribution  plans,  (iii)  the  amortization  of  restricted 
stock,  (iv)  the  issuance  of  phantom  stock  units,  (v)  historical 
stock  option  issuances,  and  (vi)  other  employee  medical  and 
benefits  costs.  For  additional  information  on  the  Company's 
employee benefit plans, see Note 15, “Employee Benefit Plans.”

Foreign Currency Transactions
Foreign denominated assets and liabilities resulting from foreign 
currency  transactions  are  valued  using  period  end  foreign 
exchange rates and the associated interest income or expense is 
determined  using  weighted  average  exchange  rates  for  the 

Notes to Consolidated Financial Statements, continued

period.  The  Company  may  enter  into  foreign  currency 
derivatives  to  mitigate  its  exposure  to  changes  in  foreign 
exchange rates. The derivative contracts are accounted for at fair 
value on a recurring basis with any resulting gains and losses 
recorded in Noninterest income in the Consolidated Statements 
of Income.

Related Party Transactions
The Company periodically enters into transactions with certain 
of its executive officers, directors, affiliates, trusts, and/or other 
related  parties  in  its  ordinary  course  of  business.  ASC  850 
requires disclosure of material related party transactions, other 
than certain compensation and other arrangements entered into 
in the normal course of business. The Company has included 
information related to its relationships with VIEs and employee 
benefit  plan  arrangements  in  its  Notes  to  the  Consolidated 
Financial Statements in this Form 10-K.

Fair Value Measurement
Fair value is defined as the price that would be received to sell 
an asset or paid to transfer a liability in an orderly transaction 
between  market  participants  at 
the  measurement  date. 
Depending on the nature of the asset or liability, the Company 

uses  various  valuation  techniques  and  assumptions  when 
estimating fair value. The Company prioritizes inputs used in 
valuation techniques based on the fair value hierarchy discussed 
in Note 18, “Fair Value Election and Measurement.”

When  measuring  assets  and  liabilities  at  fair  value,  the 
Company considers the principal or most advantageous market 
in which it would transact and considers assumptions that market 
participants would use when pricing the asset or liability. Assets 
and liabilities that are required to be measured at fair value on a 
recurring  basis  include  trading  securities,  securities AFS,  and 
derivative instruments. Assets and liabilities that the Company 
has elected to measure at fair value on a recurring basis include 
certain  MSRs,  LHFS,  LHFI,  trading  loans,  brokered  time 
deposits,  and  issuances  of  fixed  rate  debt.  Other  assets  and 
liabilities are measured at fair value on a non-recurring basis, 
such as when assets are evaluated for impairment, the basis of 
accounting is LOCOM, or for disclosure purposes. Examples of 
these  nonrecurring  fair  value  measurements  include  certain 
LHFS  and  LHFI,  OREO,  certain  cost  or  equity  method 
investments, and intangible and long-lived assets. For additional 
information on the Company’s valuation of assets and liabilities 
held  at  fair  value,  see  Note  18,  “Fair  Value  Election  and 
Measurement.”

Recently Issued Accounting Pronouncements
The following table summarizes ASUs issued by the FASB that were not yet adopted (or only partially adopted previously) as of 
December 31, 2017, that could have a material effect on the Company's financial statements:

Standard

Description

Required Date
of Adoption

Effect on the Financial Statements or Other
Significant Matters

Standard(s) Not Yet Adopted (or partially adopted previously)
ASU 2016-01,
Recognition and
Measurement of
Financial Assets
and Financial
Liabilities

The 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  most 
investments  in  equity  securities  to  be  measured  at  fair 
value  through  net  income,  unless  they  qualify  for  a 
measurement alternative, and require fair value changes 
arising from changes in instrument-specific credit risk for 
financial liabilities that are measured under the fair value 
option to be recognized in other comprehensive income. 
With  the  exception  of  disclosure  requirements  and  the 
application  of  the  measurement  alternative  for  certain 
equity investments that will be adopted prospectively, the 
ASU must be adopted on a modified retrospective basis.

January 1, 2018

Early adoption is 
permitted 
beginning January 
1, 2016 or 2017 
for the provision 
related to changes 
in instrument-
specific credit 
risk for financial 
liabilities under 
the FVO.

The Company early adopted the provision related to 
changes in instrument-specific credit risk beginning 
January  1,  2016,  which  resulted  in  an  immaterial 
cumulative effect adjustment from Retained earnings 
to  AOCI.  See  Note  1,  “Significant  Accounting 
Policies,” to the Company's 2016 Annual Report on 
Form 10-K for additional information regarding the 
early adoption of this provision. 

Effective as of January 1, 2018, an immaterial amount 
of equity securities previously classified as Securities 
AFS  were  reclassified  to  Other  assets,  as  the AFS 
classification  is  no  longer  permitted  for  equity 
securities under this ASU. The remaining provisions 
of  this ASU  did  not  have  a  material  impact  on  the 
Company's  Consolidated  Financial  Statements  and 
related disclosures upon adoption. However, for any 
investments  for  which  we  elect  the  measurement 
alternative, to the extent there is an observable price 
change  in  transactions  occurring  subsequent  to 
January 1, 2018 for identical or similar instruments of 
the same issuer, these investments will have to be re-
measured through net income based on the observed 
transaction  price,  which  may  result  in  a  material 
impact to the Company's Consolidated Statements of 
Income. 

86

 
Notes to Consolidated Financial Statements, continued

Standard

Description

Required Date
of Adoption

Effect on the Financial Statements or Other
Significant Matters

Standard(s) Not Yet Adopted (or partially adopted previously) (continued)
ASU 2016-15,
Statement of Cash
Flows (Topic 230):
Classification of
Certain Cash
Receipts and Cash
Payments

The ASU  amends ASC  Topic  230,  Statement  of  Cash 
Flows, to clarify the classification of certain cash receipts 
and  payments  within  the  Company's  Consolidated 
Statements  of  Cash  Flow.  These  items  include:  cash 
payments  for  debt  prepayment  or  debt  extinguishment 
costs;  cash  outflows  for  the  settlement  of  zero-coupon 
debt instruments or other debt instruments with coupon 
interest 
insignificant;  contingent 
consideration  payments  made  after  a  business 
combination; proceeds from the settlement of insurance 
claims; proceeds from the settlement of corporate-owned 
life  insurance  policies,  including  bank-owned  life 
insurance  policies;  distributions  received  from  equity 
method  investees;  and  beneficial  interests  acquired  in 
securitization  transactions.  The ASU  also  clarifies  that 
when  no  specific  U.S.  GAAP  guidance  exists  and  the 
source of the cash flows are not separately identifiable, 
the predominant source of cash flow should be used to 
determine the classification for the item. The ASU must 
be adopted on a retrospective basis.

that  are 

rates 

January 1, 2018

Effective as of January 1, 2018, the adoption date, the 
Company will change the presentation of certain cash 
payments  and  receipts  within  its  Consolidated 
Statements of Cash Flows. Specifically, the Company 
will  reclassify  approximately  $3  million  and  $17 
million of proceeds from the settlement of corporate-
owned life insurance policies, including bank-owned 
life  insurance  policies,  from  operating  activities  to 
investing activities for the years ended December 31, 
2017 and 2016, respectively. The Company will also 
reclassify  approximately  $127  million  and  $202 
million of cash payments related to premiums paid for 
corporate-owned  life  insurance  policies,  including 
bank-owned  life  insurance  policies,  from  operating 
activities  to  investing  activities  for  the  years  ended 
December 31, 2017 and 2016, respectively. Lastly, for 
contingent  consideration  payments  made  more  than 
three  months  after  a  business  combination,  the 
Company  will  reclassify  the  portion  of  the  cash 
payment up to the acquisition date fair value of the 
contingent consideration as a financing activity and 
any amount paid in excess of the acquisition date fair 
value  as  an  operating  activity.  For  the  year  ended 
December  31,  2016,  the  Company  will  reclassify 
approximately $13 million from investing activities to 
financing activities and will reclassify approximately 
$10  million  from  investing  activities  to  operating 
activities. For the year ended December 31, 2017, there 
were no contingent consideration payments made.

These  changes  will  be  reflected  for  all  periods 
presented in the Company's Consolidated Statements 
of Cash Flows beginning with its first quarter of 2018 
Quarterly Report on Form 10-Q.

January 1, 2018

These ASUs  comprise ASC  Topic  606,  Revenue  from 
Contracts with Customers, which supersedes the revenue 
recognition  requirements  in  ASC  Topic  605,  Revenue 
Recognition,  and  most 
industry-specific  guidance 
throughout  the  Industry  Topics  of  the ASC.  The  core 
principle of these ASUs 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. These ASUs may 
be  adopted  either  retrospectively  or  on  a  modified 
retrospective  basis  to  new  contracts  and  existing 
contracts, with remaining performance obligations as of 
the effective date.

ASU 2014-09, 
Revenue from 
Contracts with 
Customers

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 Expedients

ASU 2016-20, 
Technical 
Corrections and 
Improvements to 
Topic 606, Revenue 
from Contracts with 
Customers

87

The 

Company 

conducted 

The  Company  completed  its  evaluation  of  the 
anticipated  effects  that  these ASUs  will  have  on  its 
Consolidated  Financial  Statements  and  related 
disclosures. 
a 
comprehensive  scoping  exercise  to  determine  the 
revenue streams that are in the scope of these updates. 
Results  indicate  that  certain  noninterest  income 
financial  statement  line  items,  including  service 
charges on deposit accounts, card fees, other charges 
and  fees,  investment  banking  income,  trust  and 
investment  management  income,  retail  investment 
services,  and  other  noninterest  income,  contain 
revenue  streams  that  are  within  the  scope  of  these 
updates. 

The Company adopted these ASUs on January 1, 2018 
using the modified retrospective method of adoption. 
The  adoption  resulted  in  an  immaterial  cumulative 
effect adjustment to the opening balance of retained 
earnings.  Additionally,  there  will  be  prospective 
changes to the presentation of certain types of revenue 
and  expenses,  such  as  underwriting  revenue  and 
expenses  within  investment  banking  income,  which 
will be shown on a gross basis, and to certain types of 
cash  promotions  and  card  network  expenses,  which 
will be reclassified from noninterest expense to service 
charges  on  deposit  accounts  and  card 
fees, 
respectively.  The  net  quantitative  impact  of  these 
presentation  changes  to  noninterest  income  and 
noninterest expense is immaterial and will not affect 
net  income.  The  Company  is  in  the  process  of 
completing the required  quantitative and  qualitative 
disclosures, which will be included in its first quarter 
of 2018 Quarterly Report on Form 10-Q. 

Notes to Consolidated Financial Statements, continued

Standard

Description

Standard(s) Not Yet Adopted (or partially adopted previously) (continued)
ASU 2017-09,
Stock
Compensation
(Topic 718): Scope
of Modification
Accounting

This ASU amends ASC Topic 718, Stock Compensation, 
to provide guidance about which changes to the terms or 
conditions  of  a  share-based  payment  award  require  an 
entity to apply modification accounting per ASC Topic 
718, Stock Compensation. The amendments clarify that 
modification accounting only applies to an entity if the 
fair  value,  vesting  conditions,  or  classification  of  the 
award  changes  as  a  result  of  changes  in  the  terms  or 
conditions  of  a  share-based  payment  award.  The ASU 
should be applied prospectively to awards modified on or 
after the adoption date.

ASU 2017-12,
Derivatives and
Hedging (Topic
815): Targeted
Improvements to
Accounting for
Hedging Activities

ASU 2018-02, 
Income Statement - 
Reporting 
Comprehensive 
Income (Topic 220): 
Reclassification of 
Certain Tax Effects 
from AOCI

ASU 2016-02,
Leases

The  ASU  amends  ASC  Topic  815,  Derivatives  and 
Hedging,  to  simplify  the  requirements  for  hedge 
accounting.  Key  amendments  include:  eliminating  the 
requirement  to  separately  measure  and  report  hedge 
ineffectiveness,  requiring  changes  in  the  value  of  the 
hedging instrument to be presented in the same income 
statement line as the earnings effect of the hedged item, 
and the ability to measure the hedged item based on the 
benchmark interest rate component of the total contractual 
coupon for fair value hedges. These changes expand the 
types  of  risk  management  strategies  eligible  for  hedge 
accounting. The ASU also permits entities to qualitatively 
assert that a hedging relationship was and continues to be 
highly  effective.  New  incremental  disclosures  are  also 
required for reporting periods subsequent to the date of 
adoption. All transition requirements and elections should 
be applied to hedging relationships existing on the date 
of adoption using a modified retrospective approach.

This ASU amends ASC Topic 220, Income Statement - 
Reporting  Comprehensive  Income  to  allow  for  a 
reclassification from AOCI to Retained earnings for the 
stranded tax effects resulting from the 2017 Tax Act. The 
amount  of  the  reclassification  would  be  the  difference 
between the historical federal corporate income tax rate 
and  the  newly  enacted  21  percent  federal  corporate 
income tax rate. Consequently, the amendments in this 
ASU would eliminate the stranded tax effects resulting 
from the change in the federal corporate income tax rate 
in the 2017 Tax Act. The Company may apply this ASU 
at 
the  period  of  adoption  or 
retrospectively to all periods in which the 2017 Tax Act 
is enacted.

the  beginning  of 

The  ASU  creates  ASC  Topic  842,  Leases,  which 
supersedes  ASC  Topic  840,  Leases.  ASC  Topic  842 
requires  lessees  to  recognize  right-of-use  assets  and 
associated  liabilities  that  arise  from  leases,  with  the 
exception of short-term leases. The ASU does not make 
significant changes to lessor accounting; however, there 
were  certain  improvements  made  to  align  lessor 
accounting  with  the  lessee  accounting  model  and ASC 
Topic  606,  Revenue  from  Contracts  with  Customers. 
There  are  several  new  qualitative  and  quantitative 
disclosures required. Upon transition, lessees and lessors 
are  required  to  recognize  and  measure  leases  at  the 
beginning  of  the  earliest  period  presented  using  a 
modified retrospective approach.

Required Date
of Adoption

Effect on the Financial Statements or Other
Significant Matters

January 1, 2018

The Company adopted this ASU on January 1, 2018 
and  upon  adoption,  the  ASU  did  not  impact  the 
Company's  Consolidated  Financial  Statements  and 
related disclosures.

January 1, 2019

Early adoption is 
permitted.

The  Company  early  adopted  this  ASU  beginning 
January  1,  2018  and  modified  its  measurement 
methodology  for  certain  hedged  items  designated 
under  fair  value  hedge  relationships. The  Company 
elected to perform its subsequent assessments of hedge 
effectiveness  using  a  qualitative,  rather  than  a 
quantitative,  approach.  The  adoption  resulted  in  an 
immaterial  cumulative  effect  adjustment  to  the 
opening  balance  of  Retained  earnings  and  a  basis 
adjustment to the related hedged items. The Company 
is in the process of developing the required disclosures, 
which  will  be  included  in  its  first  quarter  2018 
Quarterly Report on Form 10-Q.

January 1, 2019

Early adoption is
permitted.

The Company plans on early adopting this ASU as of 
January  1,  2018.  Upon  adoption  of  this  ASU,  the 
Company will elect to reclassify approximately $154 
million  of  stranded  tax  effects  relating  to  securities 
AFS, derivative instruments, credit risk on long-term 
debt,  and  employee  benefit  plans  from  AOCI  to 
Retained earnings. 

January 1, 2019

Early adoption is 
permitted.

The Company has formed a cross-functional team to 
oversee  the  implementation  of  this  ASU.  The 
Company's  implementation  efforts  are  ongoing, 
including the review of its lease portfolios and related 
lease  accounting  policies,  the  review  of  its  service 
contracts for embedded leases, and the deployment of 
a  new  lease  software  solution.  The  Company's 
adoption of this ASU will result in an increase in right-
of-use  assets  and  associated  lease  liabilities,  arising 
from  operating  leases  in  which  the  Company  is  the 
lessee, on its Consolidated Balance Sheets. 

The amount of the right-of-use assets and associated 
lease liabilities recorded upon adoption will be based 
primarily  on  the  present  value  of  unpaid  future 
minimum lease payments, the amount of which will 
depend on the population of leases in effect at the date 
of adoption. At December 31, 2017, the Company’s 
estimate of right-of-use assets and lease liabilities that 
would be recorded on its Consolidated Balance Sheets 
upon adoption is in excess of $1 billion. The Company 
does not expect this ASU to have a material impact on 
its Consolidated Statements of Income subsequent to 
adoption.

88

Notes to Consolidated Financial Statements, continued

Standard

Description

Standard(s) Not Yet Adopted (or partially adopted previously) (continued)
ASU 2016-13,
Measurement of
Credit Losses on
Financial
Instruments

The ASU adds ASC Topic 326, Financial Instruments-
Credit  Losses,  to  replace  the  incurred  loss  impairment 
methodology  with  a  current  expected  credit  loss 
methodology  for  financial  instruments  measured  at 
amortized cost and other commitments to extend credit. 
For this purpose, expected credit losses reflect losses over 
the remaining contractual life of an asset, considering the 
effect  of  voluntary  prepayments  and  considering 
available  information  about  the  collectability  of  cash 
flows, including information about past events, current 
conditions, and reasonable and supportable forecasts. The 
resulting allowance for credit losses is deducted from the 
amortized cost basis of the financial assets to reflect the 
net  amount  expected  to  be  collected  on  the  financial 
assets. Additional quantitative and qualitative disclosures 
are required upon adoption. The change to the allowance 
for credit losses at the time of the adoption will be made 
with a cumulative effect adjustment to Retained earnings.

ASU 2017-04,
Intangibles -
Goodwill and Other
(Topic 350):
Simplifying the Test
for Goodwill
Impairment

The current expected credit loss model does not apply to 
AFS debt securities; however, the ASU requires entities 
to record an allowance when recognizing credit losses for 
AFS securities, rather than recording a direct write-down 
of the carrying amount.

The ASU amends ASC Topic 350, Intangibles - Goodwill 
and  Other,  to  simplify  the  subsequent  measurement  of 
goodwill,  by  eliminating  Step  2  from  the  goodwill 
impairment  test.  The  amendments  require  an  entity  to 
perform its annual, or interim, goodwill impairment test 
by comparing the fair value of a reporting unit with its 
carrying amount. Entities should recognize an impairment 
charge for the amount by which a reporting unit's carrying 
amount  exceeds  its  fair  value,  but  the  loss  recognized 
should not exceed the total amount of goodwill allocated 
to  that  reporting  unit.  The ASU  must  be  applied  on  a 
prospective basis.

Required Date
of Adoption

Effect on the Financial Statements or Other
Significant Matters

January 1, 2020

Early adoption is 
permitted 
beginning January 
1, 2019.

The Company has formed a cross-functional team to 
oversee  the  implementation  of  this  ASU  and  has 
identified  the  changes  necessary  to  its  credit  loss 
estimation methodologies in order to comply with the 
new  accounting  standard  requirements.  Substantial 
progress has been made to date on implementing these 
changes,  including  the  development  of  models, 
updates to technology systems, and the documentation 
of  accounting  policy  decisions.  Additionally,  the 
Company is evaluating the impact that this ASU will 
have  on  its  Consolidated  Financial  Statements  and 
related  disclosures,  and  the  Company  currently 
anticipates that an increase to the allowance for credit 
losses will be recognized upon adoption to provide for 
the expected credit losses over the estimated life of the 
financial assets. However, since the magnitude of the 
anticipated increase in the allowance for credit losses 
will be impacted by economic conditions and trends 
in the Company’s portfolio at the time of adoption, the 
quantitative 
reasonably 
impact  cannot  yet  be 
estimated.

January 1, 2020

Early adoption is 
permitted.

Based on the Company's most recent annual goodwill 
impairment test performed as of October 1, 2017, there 
were no reporting units for which the carrying amount 
of the reporting unit exceeded its fair value; therefore, 
this ASU would not currently have an impact on the 
Company's  Consolidated  Financial  Statements  and 
related  disclosures.  However,  if  upon  adoption  the 
carrying  amount  of  a  reporting  unit  exceeds  its  fair 
value, the Company would be required to recognize 
an impairment charge for the amount that the carrying 
value exceeds the fair value.

89

Notes to Consolidated Financial Statements, continued

NOTE 2 - ACQUISITIONS/DISPOSITIONS 

During the years ended December 31, 2017, 2016, and 2015, the Company had the following notable acquisition and disposition: 

Date

(Dollars in millions)
2017
Sale of PAC
2016
Acquisition of Pillar
1 Does not include $62 million of commercial mortgage servicing rights acquired.

12/15/2016

12/1/2017

Consideration
Received/(Paid)

Goodwill

Other Intangible
Assets

Pre-tax Gain

$261

($197)

($7)

$1

$—

$13 1

$107

$—

Sale of PAC 
On December 1, 2017, the Company completed the sale of PAC, 
its commercial lines insurance premium finance subsidiary with 
$1.3  billion  in  assets  and  $1.2  billion  in  liabilities,  to  IPFS 
Corporation. As a result, the Company received consideration of 
$261 million and recognized a pre-tax gain of $107 million in 
connection with the sale, net of transaction-related expenses. 

The Company's results for the years ended December 31, 
2017, 2016, and 2015 included the following related to PAC, 
excluding the gain on sale:

(Dollars in millions)

PAC Financial Information:

2017

2016

2015

Revenue

Less:  Expenses

Income before provision for income taxes

$56

31

$25

$60

27

$33

$59

22

$37

For all periods presented, the financial results of PAC through 
the date of disposition, including the gain on sale, are reflected 
in the Company's Wholesale business segment.

Acquisition of Pillar
On December 15, 2016, the Company completed the acquisition 
of substantially all of the assets of the operating subsidiaries of 
Pillar  Financial,  LLC,  a  multi-family  agency  lending  and 
servicing  company  with  an  originate-to-distribute  focus  that 
holds licenses with Fannie Mae, Freddie Mac, and the FHA. The 
acquired assets include Pillar's multi-family lending business, 
which is comprised of multi-family affordable housing, health 
care  properties,  senior  housing,  and  manufactured  housing 
specialty  teams. Additionally,  the  transaction  includes  Cohen 
Financial's  commercial  real  estate  investor  services  business, 
which provides loan administration, advisory, and commercial 
mortgage brokerage services.

During  the  second  quarter  of  2017,  the  final  settlement 
amount  associated  with  working  capital  adjustments  was 
reached  and  the  purchase  consideration  of  $197  million  was 
finalized. 

There were no other material acquisitions or dispositions during 
the three years ended December 31, 2017.

NOTE 3 - FEDERAL FUNDS SOLD AND SECURITIES FINANCING ACTIVITIES

Federal Funds Sold and Securities Borrowed or Purchased Under Agreements to Resell

Fed Funds sold and securities borrowed or purchased under agreements to resell were as follows:

(Dollars in millions)

Fed funds sold

Securities borrowed

Securities purchased under agreements to resell

Total Fed funds sold and securities borrowed or purchased under agreements to resell

December 31, 2017

December 31, 2016

$65

298

1,175

$1,538

$58

270

979

$1,307

Securities  purchased  under  agreements  to  resell  are  primarily 
collateralized by U.S. government or agency securities and are 
carried  at  the  amounts  at  which  the  securities  will  be 
subsequently resold, plus accrued interest. Securities borrowed 
are  primarily  collateralized  by  corporate  securities.  The 
Company  borrows  securities  and  purchases  securities  under 
agreements to resell as part of its securities financing activities. 
On the acquisition date of these securities, the Company and the 

related counterparty agree on the amount of collateral required 
to secure the principal amount loaned under these arrangements. 
The  Company  monitors  collateral  values  daily  and  calls  for 
additional  collateral  to  be  provided  as  warranted  under  the 
respective agreements. At December 31, 2017 and 2016, the total 
market value of collateral held was $1.5 billion and $1.3 billion, 
of  which  $177  million  and  $246  million  was  repledged, 
respectively.

90

Notes to Consolidated Financial Statements, continued

Securities Sold Under Agreements to Repurchase
Securities sold under agreements to repurchase are accounted for as secured borrowings. The following table presents the Company’s 
related activity, by collateral type and remaining contractual maturity:

(Dollars in millions)

U.S. Treasury securities

Federal agency securities

MBS - agency

CP

Corporate and other debt securities

Total securities sold under agreements to

repurchase

December 31, 2017

December 31, 2016

Overnight
and
Continuous

Up to 30
days

30-90
days

Total

Overnight
and
Continuous

Up to 30
days

30-90
days

Total

$95

101

694

19

316

$—

15

135

—

88

$—

—

—

—

40

$95

116

829

19

444

$27

288

793

49

311

$—

24

51

—

50

$—

—

—

—

40

$27

312

844

49

401

$1,225

$238

$40

$1,503

$1,468

$125

$40

$1,633

For  these  securities  sold  under  agreements  to  repurchase,  the 
Company would be obligated to provide additional collateral in 
the event of a significant decline in fair value of the collateral 
pledged. This risk is managed by monitoring the liquidity and 
credit quality of the collateral, as well as the maturity profile of 
the transactions.

Netting of Securities - Repurchase and Resell Agreements
The  Company  has  various  financial  assets  and  financial 
liabilities  that  are  subject  to  enforceable  master  netting 
agreements or similar agreements. The Company's derivatives 
that  are  subject  to  enforceable  master  netting  agreements  or 
similar  agreements  are  discussed  in  Note  17,  "Derivative 
Financial  Instruments."  The  following  table  presents  the 
Company's securities borrowed or purchased under agreements 
to resell and securities sold under agreements to repurchase that 

are  subject  to  MRAs.  Generally,  MRAs  require  collateral  to 
exceed  the  asset  or  liability  recognized  on  the  balance  sheet. 
Transactions  subject  to  these  agreements  are  treated  as 
collateralized financings, and those with a single counterparty 
are permitted to be presented net on the Company's Consolidated 
Balance  Sheets,  provided  certain  criteria  are  met  that  permit 
balance sheet netting. At December 31, 2017 and 2016, there 
were no such transactions subject to legally enforceable MRAs 
that were eligible for balance sheet netting.

The  following  table  includes  the  amount  of  collateral 
pledged or received related to exposures subject to enforceable 
MRAs. While these agreements are typically over-collateralized, 
the amount of collateral presented in this table is limited to the 
amount  of  the  related  recognized  asset  or  liability  for  each 
counterparty.

(Dollars in millions)
December 31, 2017
Financial assets:

Gross
Amount

Amount
Offset

Net Amount
Presented in
Consolidated
Balance Sheets

Held/Pledged 
Financial
Instruments

Net
Amount

Securities borrowed or purchased under agreements to resell

$1,473

Financial liabilities:

Securities sold under agreements to repurchase

1,503

December 31, 2016
Financial assets:

Securities borrowed or purchased under agreements to resell

$1,249

Financial liabilities:

Securities sold under agreements to repurchase

1,633

$—

—

$—

—

$1,473 1

$1,462

1,503

1,503

$1,249 1

$1,241

1,633

1,633

$11

—

$8

—

1 Excludes $65 million and $58 million of Fed Funds sold, which are not subject to a master netting agreement at December 31, 2017 and 2016, respectively.

91

Notes to Consolidated Financial Statements, continued

NOTE 4 - TRADING ASSETS AND LIABILITIES AND DERIVATIVE INSTRUMENTS 

The fair values of the components of trading assets and liabilities and derivative instruments are presented in the following table:

(Dollars in millions)
Trading Assets and Derivative Instruments:

U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency
CLO securities
Corporate and other debt securities
CP
Equity securities
Derivative instruments 1
Trading loans 2

Total trading assets and derivative instruments

Trading Liabilities and Derivative Instruments:

U.S. Treasury securities
MBS - agency
Corporate and other debt securities
Equity securities
Derivative instruments 1

Total trading liabilities and derivative instruments

December 31, 2017

December 31, 2016

$157
395
61
700
—
655
118
56
802
2,149
$5,093

$577
—
289
9
408
$1,283

$539
480
134
567
1
656
140
49
984
2,517
$6,067

$697
1
255
—
398
$1,351

1 Amounts include the impact of offsetting cash collateral received from and paid to the same derivative counterparties, and the impact of netting derivative assets 
and derivative liabilities when a legally enforceable master netting agreement or similar agreement exists.
2 Includes loans related to TRS.

Various trading and derivative instruments are used as part of 
the Company’s overall balance sheet management strategies and 
to support client requirements executed through the Bank and/
or  STRH,  a  broker/dealer  subsidiary  of  the  Company.  The 
Company  manages  the  potential  market  volatility  associated 
with trading instruments by using appropriate risk management 
strategies. The size, volume, and nature of the trading products 
and  derivative  instruments  can  vary  based  on  economic 
conditions as well as client-specific and Company-specific asset 
or liability positions. 

Product  offerings  to  clients  include  debt  securities,  loans 
traded  in  the  secondary  market,  equity  securities,  derivative 
contracts, and other similar financial instruments. Other trading-

related activities include acting as a market maker for certain 
debt  and  equity  security  transactions,  derivative  instrument 
transactions, and foreign exchange transactions. The Company 
also uses derivatives to manage its interest rate and market risk 
from  non-trading  activities.  The  Company  has  policies  and 
procedures to manage market risk associated with client trading 
and  non-trading  activities,  and  assumes  a  limited  degree  of 
market risk by managing the size and nature of its exposure. For 
valuation assumptions and additional information related to the 
Company's trading products and derivative instruments, see Note 
17, “Derivative Financial Instruments,” and the “Trading Assets 
and Derivative Instruments and Securities Available for Sale” 
section of Note 18, “Fair Value Election and Measurement.”

Pledged trading assets are presented in the following table:

(Dollars in millions)
Pledged trading assets to secure repurchase agreements 1
Pledged trading assets to secure certain derivative agreements

Pledged trading assets to secure other arrangements

December 31, 2017

December 31, 2016

$1,016

72

41

$968

471

40

1 Repurchase agreements secured by collateral totaled $975 million and $928 million at December 31, 2017 and 2016, respectively.

92

Notes to Consolidated Financial Statements, continued

NOTE 5 – SECURITIES AVAILABLE FOR SALE 

Securities Portfolio Composition

(Dollars in millions)
U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency residential
MBS - non-agency commercial
ABS
Corporate and other debt securities
Other equity securities 1
Total securities AFS

(Dollars in millions)
U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency residential
MBS - non-agency commercial
ABS
Corporate and other debt securities
Other equity securities 1
Total securities AFS

December 31, 2017

Amortized
Cost

Unrealized
Gains

Unrealized
Losses

Fair
Value

$4,361
257
618
22,616
2,121
55
862
6
17

472

$2
3
7
222
3
4
7
2
—

—

$32
1
8
134
38
—
3
—
—

3

$4,331
259
617
22,704
2,086
59
866
8
17

469

$31,385

$250

$219

$31,416

December 31, 2016

Amortized
Cost

Unrealized
Gains

Unrealized
Losses

Fair
Value

$5,486
310
279
22,379
1,263
71
257
8
34

642

$5
5
5
311
2
3
—
2
1

1

$86
2
5
254
39
—
5
—
—

1

$5,405
313
279
22,436
1,226
74
252
10
35

642

$30,729

$335

$392

$30,672

1 At December 31, 2017, the fair value of other equity securities was comprised of the following:  $15 million of FHLB of Atlanta stock, $403 million of Federal 
Reserve Bank of Atlanta stock, $49 million of mutual fund investments, and $2 million of other.
At December 31, 2016, the fair value of other equity securities was comprised of the following:  $132 million of FHLB of Atlanta stock, $402 million of Federal 
Reserve Bank of Atlanta stock, $102 million of mutual fund investments, and $6 million of other.

The following table presents interest and dividends on securities AFS:

(Dollars in millions)
Taxable interest
Tax-exempt interest
Dividends

Total interest and dividends on securities AFS

Year Ended December 31
2016

2017

2015

$743
13
18

$774

$630
6
15

$651

$552
6
35

$593

93

 
 
 
Notes to Consolidated Financial Statements, continued

Securities AFS  pledged  to  secure  public  deposits,  repurchase 
agreements,  trusts,  certain  derivative  agreements,  and  other 
funds had a fair value of $4.3 billion and $2.0 billion at December 
31, 2017 and 2016, respectively.

The following table presents the amortized cost, fair value, 
and weighted average yield of investments in debt securities AFS 

at December 31, 2017, by remaining contractual maturity, with 
the exception of MBS and ABS, which are based on estimated 
average life. Receipt of cash flows may differ from contractual 
maturities because borrowers may have the right to call or prepay 
obligations with or without penalties. 

(Dollars in millions)

Amortized Cost:

U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency residential
MBS - non-agency commercial
ABS
Corporate and other debt securities

Distribution of Remaining Maturities

Due in 1 Year
or Less

Due After 1
Year through 5
Years

Due After 5
Years through
10 Years

Due After 10
Years

Total

$—
121
6
2,686
—
—
—
—
7

$2,322
46
49
7,937
315
55
12
6
10

$2,039
4
149
11,781
1,547
—
813
—
—

$—
86
414
212
259
—
37
—
—

$4,361
257
618
22,616
2,121
55
862
6
17

Total debt securities AFS

$2,820

$10,752

$16,333

$1,008

$30,913

Fair Value:

U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency residential
MBS - non-agency commercial
ABS
Corporate and other debt securities

$—
123
6
2,748
—
—
—
—
7

$2,305
47
52
7,980
308
59
12
8
10

$2,026
4
153
11,763
1,525
—
816
—
—

$—
85
406
213
253
—
38
—
—

$4,331
259
617
22,704
2,086
59
866
8
17

Total debt securities AFS

$2,884

$10,781

$16,287

 Weighted average yield 1

3.36%

2.34%

2.81%

$995

3.23%

$30,947

2.71%

1 Weighted average yields are based on amortized cost and presented on an FTE basis.

94

Notes to Consolidated Financial Statements, continued

Securities AFS in an Unrealized Loss Position
The  Company  held  certain  investment  securities AFS  where 
amortized cost exceeded fair value, resulting in unrealized loss 
positions.  Market  changes  in  interest  rates  and  credit  spreads 
may result in temporary unrealized losses as the market prices 
of securities fluctuate. At December 31, 2017, the Company did 

not intend to sell these securities nor was it more-likely-than-not 
that the Company would be required to sell these securities before 
their anticipated recovery or maturity. The Company reviewed 
its portfolio for OTTI in accordance with the accounting policies 
described in Note 1, "Significant Accounting Policies." 

Securities AFS in an unrealized loss position at period end are presented in the following tables:

(Dollars in millions)
Temporarily impaired securities AFS:

U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency commercial
ABS
Corporate and other debt securities
Other equity securities

Total temporarily impaired securities AFS

OTTI securities AFS 1:

ABS

Total OTTI securities AFS
Total impaired securities AFS

Less than twelve months

Fair
Value

Unrealized
 Losses 2

December 31, 2017
Twelve months or longer
Unrealized
 Losses 2

Fair
Value

Total

Fair
Value

Unrealized
 Losses 2

$1,993
23
267
8,095
887
134
—
10
—
11,409

—
—
$11,409

$12
—
3
38
9
1
—
—
—
63

—
—
$63

$841
60
114
4,708
915
93
4
—
2
6,737

1
1
$6,738

$20
1
5
96
29
2
—
—
3
156

—
—
$156

$2,834
83
381
12,803
1,802
227
4
10
2
18,146

1
1
$18,147

$32
1
8
134
38
3
—
—
3
219

—
—
$219

1 OTTI securities AFS are impaired securities for which OTTI credit losses have been previously recognized in earnings.
2 Unrealized losses less than $0.5 million are presented as zero within the table.

(Dollars in millions)

Temporarily impaired securities AFS:

U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency commercial
ABS
Corporate and other debt securities
Other equity securities

Total temporarily impaired securities AFS

OTTI securities AFS 1:

MBS - non-agency residential
ABS

Total OTTI securities AFS
Total impaired securities AFS

Less than twelve months

December 31, 2016
Twelve months or longer

Total

Fair
Value

Unrealized
 Losses 2

Fair
Value

Unrealized
 Losses 2 

Fair
Value

Unrealized
 Losses 2

$4,380
96
149
13,505
1,117
184
—
12
—
19,443

16
—
16
$19,459

$86
2
5
247
38
5
—
—
—
383

—
—
—
$383

$—
3
—
436
15
—
5
—
4
463

—
1
1
$464

$—
—
—
7
1
—
—
—
1
9

—
—
—
$9

$4,380
99
149
13,941
1,132
184
5
12
4
19,906

16
1
17
$19,923

$86
2
5
254
39
5
—
—
1
392

—
—
—
$392

1 OTTI securities AFS are impaired securities for which OTTI credit losses have been previously recognized in earnings.
2 Unrealized losses less than $0.5 million are presented as zero within the table.

At December 31, 2017, temporarily impaired securities AFS that 
have been in an unrealized loss position for twelve months or 
longer included residential and commercial agency MBS, U.S. 
Treasury  securities,  municipal  securities,  commercial  non-
agency MBS, federal agency securities, one ABS collateralized 

by  2004  vintage  home  equity  loans,  and  one  equity  security. 
Unrealized losses on temporarily impaired securities were due 
to market interest rates being higher than the securities' stated 
coupon rates. Unrealized losses on securities AFS that relate to 
factors other than credit are recorded in AOCI, net of tax.

95

 
 
 
Notes to Consolidated Financial Statements, continued

Realized  Gains  and  Losses  and  Other-Than-Temporarily 
Impaired Securities AFS

result  in  unrealized  gains  relating  to  factors  other  than  credit 
recorded in AOCI, net of tax.

During the years ended December 31, 2017, 2016, and 2015, 
credit impairment losses recognized on securities AFS held at 
the end of each period were immaterial. The accumulated balance 
of OTTI credit losses recognized in earnings on securities AFS 
held at period end was $23 million, $23 million, and $25 million
at December 31, 2017, 2016, and 2015, respectively. Subsequent 
credit  losses  may  be  recorded  on  securities  without  a 
corresponding further decline in fair value when there has been 
a decline in expected cash flows.

The following table presents a summary of the significant 
inputs  used  in  determining  the  measurement  of  OTTI  credit 
losses recognized in earnings for non-agency MBS for the years 
ended December 31:

Default rate

Prepayment rate

2017 1

3%

19%

2016 2

N/A

N/A

2015 1

9%

13%

41%

Loss severity
1 OTTI credit losses recognized in earnings relate to one non-agency MBS with 
a fair value of $12 million and $20 million at December 31, 2017 and 2015, 
respectively. 
2 "N/A"  -  Not  applicable  as  there  were  no  OTTI  credit  losses  recognized  in 
earnings for the year ended December 31, 2016.

56%

N/A

Significant inputs represent lifetime average estimates of each 
security  for  which  credit  losses  were  recognized  in  earnings. 
Inputs may vary from period to period as the securities for which 
credit losses are recognized vary. Additionally, severity may vary 
widely when losses are few and large.

(Dollars in millions)

Gross realized gains

Gross realized losses

OTTI credit losses recognized in

earnings
Net securities (losses)/gains

Year Ended December 31

2017

2016

2015

$3

(110)

(1)

($108)

$4

—

—

$4

$25

(3)

(1)

$21

Securities  AFS  in  an  unrealized  loss  position  are  evaluated 
quarterly for other-than-temporary credit impairment, which is 
determined  using  cash  flow  analyses  that  take  into  account 
security  specific  collateral  and  transaction  structure.  Future 
expected credit losses are determined using various assumptions, 
the most significant of which include default rates, prepayment 
rates, and loss severities. If, based on this analysis, a security is 
in an unrealized loss position and the Company does not expect 
to  recover  the  entire  amortized  cost  basis  of  the  security,  the 
expected cash flows are then discounted at the security’s initial 
effective interest rate to arrive at a present value amount. Credit 
losses on the OTTI security are recognized in earnings and reflect 
the difference between the present value of cash flows expected 
to be collected and the amortized cost basis of the security. See 
Note  1,  "Significant  Accounting  Policies,"  for  additional 
information regarding the Company's policy on securities AFS 
and related impairments. 

The Company seeks to reduce existing exposure on OTTI 
securities primarily through paydowns. In certain instances, the 
amount of credit losses recognized in earnings on a debt security 
exceeds the total unrealized losses on the security, which may 

96

 
Notes to Consolidated Financial Statements, continued

NOTE 6 - LOANS

Composition of Loan Portfolio

(Dollars in millions)
Commercial loans:

C&I 1
CRE
Commercial construction

Total commercial loans

Consumer loans:

Residential mortgages -

guaranteed

Residential mortgages - 

nonguaranteed 2

Residential home equity

products

Residential construction
Guaranteed student
Other direct
Indirect
Credit cards

Total consumer loans

December 31,
2017

December 31,
2016

$66,356
5,317
3,804
75,477

560

27,136

10,626
298
6,633
8,729
12,140
1,582
67,704

$69,213
4,996
4,015
78,224

537

26,137

11,912
404
6,167
7,771
10,736
1,410
65,074

$2,290

$143,298

$143,181

LHFI
LHFS 3
1 Includes $3.7 billion of lease financing at both December 31, 2017 and 2016, 
and $778 million and $729 million of installment loans at December 31, 2017 
and 2016, respectively.
2  Includes  $196  million  and  $222  million  of  LHFI  measured  at  fair  value  at 
December 31, 2017 and 2016, respectively.
3  Includes  $1.6  billion  and  $3.5  billion  of  LHFS  measured  at  fair  value  at 
December 31, 2017 and 2016, respectively.

$4,169

During  the  years  ended  December  31,  2017  and  2016,  the 
Company transferred $288 million and $360 million of LHFI to 
LHFS, and transferred $19 million and $30 million of LHFS to 
LHFI,  respectively.  In  addition  to  sales  of  residential  and 
commercial mortgage LHFS in the normal course of business, 
the Company sold $705 million and $1.6 billion of loans and 
leases for an immaterial net gain and a net gain of $6 million 
during  the  years  ended  December  31,  2017  and  2016, 
respectively.

During the year ended December 31, 2017, the Company 
purchased  $1.7  billion  of  guaranteed  student  loans  and  $233 
million of consumer indirect loans, and during the year ended 
December  31,  2016,  the  Company  purchased  $2.2  billion  of 
guaranteed student loans.

At December 31, 2017 and 2016, the Company had $24.3 
billion and $22.6 billion of net eligible loan collateral pledged 
to the Federal Reserve discount window to support $18.2 billion 
and  $17.0  billion  of  available,  unused  borrowing  capacity, 
respectively.

At December 31, 2017 and 2016, the Company had $38.0 
billion and $36.9 billion of net eligible loan collateral pledged 
to the FHLB of Atlanta to support $30.5 billion and $31.9 billion 
of  available  borrowing  capacity,  respectively.  The  available 
FHLB borrowing capacity at December 31, 2017 was used to 
support $4 million of long-term debt and $6.7 billion of letters 
of credit issued on the Company's behalf. At December 31, 2016, 
the available FHLB borrowing capacity was used to support $2.8 

billion of long-term debt and $7.3 billion of letters of credit issued 
on the Company's behalf.

Credit Quality Evaluation
The Company evaluates the credit quality of its loan portfolio 
by employing a dual internal risk rating system, which assigns 
both PD and LGD ratings to derive expected losses. Assignment 
of these ratings are predicated upon numerous factors, including 
consumer  credit  risk  scores,  rating  agency  information, 
borrower/guarantor  financial  capacity,  LTV  ratios,  collateral 
type, debt service coverage ratios, collection experience, other 
internal metrics/analyses, and/or qualitative assessments.

For the commercial portfolio, the Company believes that 
the  most  appropriate  credit  quality  indicator  is  an  individual 
loan’s  risk  assessment  expressed  according  to  the  broad 
regulatory  agency  classifications  of  Pass  or  Criticized.  The 
Company conforms to the following regulatory classifications 
for  Criticized  assets:    Other Assets  Especially  Mentioned  (or 
Special  Mention), Adversely  Classified,  Doubtful,  and  Loss. 
However, for the purposes of disclosure, management believes 
the most meaningful distinction within the Criticized categories 
is between Criticized accruing (which includes Special Mention 
and  a  portion  of  Adversely  Classified)  and  Criticized 
nonaccruing (which includes a portion of Adversely Classified 
and  Doubtful  and  Loss).  This  distinction  identifies  those 
relatively higher risk loans for which there is a basis to believe 
that the Company will not collect all amounts due under those 
loan  agreements.  The  Company's  risk  rating  system  is  more 
granular, with multiple risk ratings in both the Pass and Criticized 
categories.  Pass  ratings  reflect  relatively  low  PDs,  whereas, 
Criticized assets have higher PDs. The granularity in Pass ratings 
assists  in  establishing  pricing,  loan  structures,  approval 
requirements,  reserves,  and  ongoing  credit  management 
requirements.  Commercial  risk  ratings  are  refreshed  at  least 
annually,  or  more  frequently  as  appropriate,  based  upon 
considerations 
conditions,  borrower 
as  market 
characteristics, and portfolio trends. Additionally, management 
routinely 
trends,  and 
concentrations  to  support  risk  identification  and  mitigation 
activities.

reviews  portfolio 

ratings, 

such 

risk 

For consumer loans, the Company monitors credit risk based 
on  indicators  such  as  delinquencies  and  FICO  scores.  The 
Company believes that consumer credit risk, as assessed by the 
industry-wide FICO scoring method, is a relevant credit quality 
indicator.  Borrower-specific  FICO  scores  are  obtained  at 
origination  as  part  of  the  Company’s  formal  underwriting 
process, and refreshed FICO scores are obtained by the Company 
at least quarterly. 

For  guaranteed  loans,  the  Company  monitors  the  credit 
quality based primarily on delinquency status, as it is a more 
relevant  indicator  of  credit  quality  due  to  the  government 
guarantee. At  December  31,  2017  and  2016,  28%  and  29%, 
respectively, of guaranteed residential mortgages were current 
with respect to payments. At both December 31, 2017 and 2016, 
75% of guaranteed student loans were current with respect to 
payments.  The  Company's  loss  exposure  on  guaranteed 
residential  mortgages  and  student  loans  is  mitigated  by  the 
government guarantee.

97

Notes to Consolidated Financial Statements, continued

LHFI by credit quality indicator are presented in the following tables:

(Dollars in millions)
Risk rating:

Pass

Criticized accruing

Criticized nonaccruing

Total

C&I

Commercial Loans
CRE

Commercial Construction

December 31,
2017

December 31,
2016

December 31,
2017

December 31,
2016

December 31,
2017

December 31,
2016

$64,546

$66,961

$5,126

$4,574

$3,770

$3,914

1,595

215

1,862

390

167

24

415

7

33

1

84

17

$66,356

$69,213

$5,317

$4,996

$3,804

$4,015

Residential Mortgages -
Nonguaranteed

 Consumer Loans 1
Residential
Home Equity Products

Residential Construction

December 31,
2017

December 31,
2016

December 31,
2017

December 31,
2016

December 31,
2017

December 31,
2016

$23,602

$22,194

2,721

813

3,042

901

$27,136

$26,137

$8,946

1,242

438

$10,626

$9,826

1,540

546

$11,912

$240

50

8

$298

$292

96

16

$404

Other Direct

Indirect

Credit Cards

December 31,
2017

December 31,
2016

December 31,
2017

December 31,
2016

December 31,
2017

December 31,
2016

$7,929

$7,008

757

43

$8,729

703

60

$7,771

$9,094

2,344

702

$12,140

$7,642

2,381

713

$10,736

$1,088

395

99

$1,582

$974

351

85

$1,410

(Dollars in millions)

Current FICO score range:

700 and above

620 - 699
Below 620 2

Total

(Dollars in millions)

Current FICO score range:

700 and above

620 - 699
Below 620 2

Total

1 Excludes $6.6 billion and $6.2 billion of guaranteed student loans and $560 million and $537 million of guaranteed residential mortgages at December 31, 2017 
and 2016, respectively, for which there was nominal risk of principal loss due to the government guarantee. 
2 For substantially all loans with refreshed FICO scores below 620, the borrower’s FICO score at the time of origination exceeded 620 but has since deteriorated as 
the loan has seasoned.

98

 
 
 
Notes to Consolidated Financial Statements, continued

The LHFI portfolio by payment status is presented in the following tables:

(Dollars in millions)
Commercial loans:

C&I
CRE
Commercial construction
Total commercial loans

Consumer loans:

Accruing
30-89 Days
Past Due

December 31, 2017
Accruing
90+ Days
Past Due

 Nonaccruing 2

Total

$42
—
—
42

$7
—
—
7

$215
24
1
240

$66,356
5,317
3,804
75,477

Accruing
Current

$66,092
5,293
3,803
75,188

Residential mortgages - guaranteed
Residential mortgages - nonguaranteed 1
Residential home equity products
Residential construction
Guaranteed student
Other direct
Indirect
Credit cards

55
148
75
7
659
36
111
13
1,104
$1,146
Total LHFI
1 Includes $196 million of loans measured at fair value, the majority of which were accruing current.
2 Nonaccruing loans past due 90 days or more totaled $357 million. Nonaccruing loans past due fewer than 90 days include nonaccrual loans modified in TDRs, 
performing second lien loans where the first lien loan is nonperforming, and certain energy-related commercial loans. 

560
27,136
10,626
298
6,633
8,729
12,140
1,582
67,704
$143,181

159
26,778
10,348
280
4,946
8,679
12,022
1,556
64,768
$139,956

346
4
—
—
1,028
7
—
13
1,398
$1,405

—
206
203
11
—
7
7
—
434
$674

Total consumer loans

(Dollars in millions)
Commercial loans:

C&I
CRE
Commercial construction
Total commercial loans

Consumer loans:

Accruing
Current

$68,776
4,988
3,998
77,762

Accruing
30-89 Days
Past Due

December 31, 2016
Accruing
90+ Days
Past Due

 Nonaccruing 2

Total

$35
1
—
36

$12
—
—
12

$390
7
17
414

$69,213
4,996
4,015
78,224

Residential mortgages - guaranteed
Residential mortgages - nonguaranteed 1
Residential home equity products
Residential construction
Guaranteed student
Other direct
Indirect
Credit cards

55
84
81
3
603
35
126
12
999
Total LHFI
$1,035
1 Includes $222 million of loans measured at fair value, the majority of which were accruing current.
2 Nonaccruing loans past due 90 days or more totaled $360 million. Nonaccruing loans past due fewer than 90 days include nonaccrual loans modified in TDRs, 
performing second lien loans where the first lien loan is nonperforming, and certain energy-related commercial loans.

537
26,137
11,912
404
6,167
7,771
10,736
1,410
65,074
$143,298

155
25,869
11,596
389
4,637
7,726
10,608
1,388
62,368
$140,130

327
7
—
—
927
4
1
10
1,276
$1,288

—
177
235
12
—
6
1
—
431
$845

Total consumer loans

99

 
 
Notes to Consolidated Financial Statements, continued

Impaired Loans
A  loan  is  considered  impaired  when  it  is  probable  that  the 
Company will be unable to collect all amounts due, including 
principal and interest, according to the contractual terms of the 
agreement. Commercial nonaccrual loans greater than $3 million 
and certain commercial and consumer loans whose terms have 
been  modified  in  a  TDR  are  individually  evaluated  for 

impairment.  Smaller-balance  homogeneous  loans  that  are 
collectively evaluated for impairment and loans measured at fair 
value are not included in the following tables. Additionally, the 
following 
loans  and 
tables  exclude  guaranteed  student 
guaranteed residential mortgages for which there was nominal 
risk of principal loss due to the government guarantee.

(Dollars in millions)
Impaired LHFI with no ALLL recorded:

Commercial loans:

C&I

Total commercial loans with no ALLL recorded

Consumer loans:

Residential mortgages - nonguaranteed
Residential construction

Total consumer loans with no ALLL recorded

Impaired LHFI with an ALLL recorded:

Commercial loans:

C&I
CRE

Total commercial loans with an ALLL recorded

Consumer loans:

Residential mortgages - nonguaranteed
Residential home equity products
Residential construction
Other direct
Indirect
Credit cards

Total consumer loans with an ALLL recorded

December 31, 2017

December 31, 2016

Unpaid
Principal
Balance

Carrying
   Value 1

Related
ALLL

Unpaid
Principal
Balance

Carrying
   Value 1

Related
ALLL

$38
38

458
15
473

127
21
148

1,133
953
93
59
123
26
2,387

$35
35

363
9
372

117
21
138

1,103
895
90
59
122
7
2,276

$—
—

—
—
—

19
2
21

113
54
7
1
7
1
183

$266
266

466
16
482

225
26
251

1,277
863
109
59
103
24
2,435

2

$214
214

360
8
368

151
17
168

1,248
795
107
59
103
6
2,318

2

$—
—

—
—
—

31
2
33

150
54
11
1
5
1
222

Total impaired LHFI

$3,046

$2,821

$204

$3,434

$3,068

$255

1 Carrying value reflects charge-offs that have been recognized plus other amounts that have been applied to adjust the net book balance.
2 Includes $41 million of TDRs that were modified prior to 2016 and reclassified as TDRs in the fourth quarter of 2016.

Included in the impaired LHFI carrying values above at December 31, 2017 and 2016 were $2.4 billion and $2.5 billion of accruing 
TDRs, of which 96% and 97% were current, respectively. See Note 1, “Significant Accounting Policies,” for further information 
regarding the Company’s loan impairment policy.

100

 
Notes to Consolidated Financial Statements, continued

(Dollars in millions)

Impaired LHFI with no ALLL recorded:

Commercial loans:

C&I

CRE

Total commercial loans with no ALLL recorded

Consumer loans:

Residential mortgages - nonguaranteed

Residential construction

Total consumer loans with no ALLL recorded

Impaired LHFI with an ALLL recorded:

Commercial loans:

C&I

CRE

Total commercial loans with an ALLL recorded

Consumer loans:

Residential mortgages - nonguaranteed

Residential home equity products

Residential construction

Other direct

Indirect

Credit cards

Total consumer loans with an ALLL recorded

Total impaired LHFI

Year Ended December 31

2017

2016

2015

Average
Carrying
Value

Interest
Income
Recognized1

Average
Carrying
Value

Interest
Income
Recognized1

Average
Carrying
Value

Interest
Income
Recognized 1

$34

—

34

357

8

365

112

22

134

1,123

914

94

60

136

6

2,333

$2,866

$1

—

1

15

—

15

2

1

3

58

32

5

4

6

1

106

$125

$169

—

169

370

8

378

170

25

195

1,251

812

110

10

114

6

2,303

$3,045

$3

—

3

16

—

16

1

1

2

64

29

6

1

6

1

107

$128

$58

10

68

390

11

401

147

—

147

1,349

682

125

12

125

7

2,300

$2,916

$2

—

2

17

—

17

5

—

5

65

28

8

—

6

1

108

$132

1 Of the interest income recognized during the years ended December 31, 2017, 2016, and 2015, cash basis interest income was $4 million, $4 million, and $7 million, 
respectively.

101

Notes to Consolidated Financial Statements, continued

NPAs are presented in the following table:

(Dollars in millions)

Nonaccrual loans/NPLs:

Commercial loans:

C&I

CRE

Commercial construction

Consumer loans:

Residential mortgages - nonguaranteed

Residential home equity products

Residential construction

Other direct

Indirect

Total nonaccrual loans/NPLs 1

OREO 2
Other repossessed assets

Total NPAs

December 31, 2017

December 31, 2016

$215

24

1

206

203

11

7

7

674

57

10

$741

$390

7

17

177

235

12

6

1

845

60

14

$919

1 Nonaccruing restructured loans are included in total nonaccrual loans/NPLs.
2 Does not include foreclosed real estate related to loans insured by the FHA or guaranteed by the VA. Proceeds due from the FHA and the VA are recorded as a 
receivable in Other assets in the Consolidated Balance Sheets until the property is conveyed and the funds are received. The receivable related to proceeds due from 
the FHA and the VA totaled $45 million and $50 million at December 31, 2017 and 2016, respectively.

The  Company's  recorded  investment  of  nonaccruing  loans 
secured  by  residential  real  estate  properties  for  which  formal 
foreclosure proceedings were in process at December 31, 2017 
and  2016  was  $73  million  and  $85  million,  respectively. The 
Company's recorded investment of accruing loans secured by 
residential  real  estate  properties  for  which  formal  foreclosure 
proceedings were in process at December 31, 2017 and 2016 was 
$101 million and $122 million, of which $97 million and $114 
million  were  insured  by  the  FHA  or  guaranteed  by  the  VA, 
respectively.

At  December 31,  2017,  OREO  included  $51  million  of 
foreclosed  residential  real  estate  properties  and  $4  million  of 
foreclosed commercial real estate properties, with the remaining 
$2 million related to land.

At  December 31,  2016,  OREO  included  $50  million  of 
foreclosed  residential  real  estate  properties  and  $7  million  of 
foreclosed commercial real estate properties, with the remaining 
$3 million related to land.

102

Notes to Consolidated Financial Statements, continued

Restructured Loans
A TDR is a loan for which the Company has granted an economic 
concession  to  a  borrower  in  response  to  certain  instances  of 
financial  difficulty  experienced  by  the  borrower,  which  the 
Company would not have considered otherwise. When a loan is 
modified under the terms of a TDR, the Company typically offers 
the  borrower  an  extension  of  the  loan  maturity  date  and/or  a 
reduction  in  the  original  contractual  interest  rate.  In  limited 
situations,  the  Company  may  offer  to  restructure  a  loan  in  a 

(Dollars in millions)
Commercial loans:

C&I

Consumer loans:

Residential mortgages - nonguaranteed
Residential home equity products
Other direct 
Indirect
Credit cards

Total TDR additions

manner  that  ultimately  results  in  the  forgiveness  of  a 
contractually specified principal balance.

At  December  31,  2017  and  2016,  the  Company  had  $2 
million and $29 million, respectively, of commitments to lend 
additional funds to debtors whose terms have been modified in 
a TDR. The number and carrying value of loans modified under 
the terms of a TDR, by type of modification, are presented in the 
following tables:

Number of
Loans
Modified

Year Ended December 31, 2017 1
Term Extension
and/or Other
Concessions

Rate
Modification

Total

178

150
2,488
661
2,740
919
7,136

$3

22
45
—
—
4
$74

$43

10
176
9
61
—
$299

$46

32
221
9
61
4
$373

1 Includes loans modified under the terms of a TDR that were charged-off during the period.

(Dollars in millions)
Commercial loans:

C&I
Commercial construction

Consumer loans:

Residential mortgages - nonguaranteed
Residential home equity products
Residential construction
Other direct 2
Indirect
Credit cards

Total TDR additions

Number of
Loans
Modified

Year Ended December 31, 2016 1
Term Extension
and/or Other
Concessions

Rate
Modification

Total

84
1

397
2,611
1
3,925
1,539
720
9,278

$2
—

79
9
—
—
—
3
$93

$68
—

12
227
—
50
32
—
$389

$70
—

91
236
—
50
32
3
$482

1 Includes loans modified under the terms of a TDR that were charged-off during the period.
2 Includes 3,321 loans with a carrying value of $41 million that were modified prior to 2016 and reclassified as TDRs in the fourth quarter of 2016.

103

Notes to Consolidated Financial Statements, continued

(Dollars in millions)
Commercial loans:

C&I
CRE
Commercial construction

Consumer loans:

Residential mortgages - nonguaranteed
Residential home equity products
Residential construction
Other direct
Indirect
Credit cards

Total TDR additions

Number of
Loans
Modified

 Year Ended December 31, 2015 1
Term Extension
and/or Other
Concessions

Rate
 Modification

Total

57
2
1

737
1,888
4
54
2,299
557
5,599

$1
—
—

125
24
5
—
—
2
$157

$3
—
—

34
108
—
1
47
—
$193

$4
—
—

159
132
5
1
47
2
$350

1 Includes loans modified under the terms of a TDR that were charged-off during the period.

mortgage  commitments  outstanding,  respectively.  At  both 
December 31,  2017  and  December 31,  2016,  1%  of  the 
Company's residential real estate secured LHFI were insured by 
the FHA or guaranteed by the VA, respectively.

The following table presents residential mortgage LHFI that 
included a high original LTV ratio (in excess of 80%), an interest 
only feature, and/or a second lien position that may increase the 
Company's exposure to credit risk and/or result in a concentration 
of  credit  risk. At  December  31,  2017  and  2016,  the  current 
weighted  average  FICO  score  for  the  borrowers  of  these 
residential mortgage LHFI was 756 and 751, respectively.

(Dollars in millions)

December 31,
2017

December 31,
2016

Interest only mortgages with MI or with 

combined original LTV 

 80% 1

Interest only mortgages with no MI and 
with combined original LTV > 80% 1
Total interest only mortgages 1

Amortizing mortgages with combined 
original LTV > 80% and/or second liens 2

Total mortgages with potential
concentration of credit risk

$569

77

646

10,197

$845

279

1,124

9,198

$10,843

$10,322

1 Comprised of first and/or second liens, primarily with an initial 10 year interest 
only period.
2 Comprised of loans with no MI.

TDRs that defaulted during the years ended December 31, 2017, 
2016, and 2015, which were first modified within the previous 
12  months,  were  immaterial. The  majority  of  loans  that  were 
modified under the terms of a TDR and subsequently became 90 
days  or  more  delinquent  have  remained  on  nonaccrual  status 
since the time of delinquency.

Concentrations of Credit Risk
The Company does not have a significant concentration of credit 
risk to any individual client except for the U.S. government and 
its agencies. However, a geographic concentration arises because 
the  Company  operates  primarily  within  Florida,  Georgia, 
Virginia, Maryland, and North Carolina. The Company engages 
in limited international banking activities. The Company’s total 
cross-border outstanding loans were $1.4 billion and $2.2 billion 
at December 31, 2017 and 2016, respectively.

With  respect  to  collateral  concentration,  the  Company's 
recorded  investment  in  residential  real  estate  secured  LHFI 
totaled $38.6 billion at December 31, 2017 and represented 27% 
of total LHFI. At December 31, 2016, the Company's recorded 
investment in residential real estate secured LHFI totaled $39.0 
billion  and  represented  27%  of  total  LHFI.  Additionally,  at 
December 31, 2017 and 2016, the Company had $10.1 billion 
and  $10.3  billion  in  commitments  to  extend  credit  on  home 
equity  lines  and  $3.0  billion  and  $4.2  billion  in  residential 

104

Notes to Consolidated Financial Statements, continued

NOTE 7 - ALLOWANCE FOR CREDIT LOSSES 

The allowance for credit losses consists of the ALLL and the unfunded commitments reserve. Activity in the allowance for credit 
losses is summarized in the following table:

(Dollars in millions)
Balance, beginning of period
Provision for loan losses
Provision for unfunded commitments
Loan charge-offs
Loan recoveries
Other 1

Balance, end of period

Components:
ALLL
Unfunded commitments reserve 2

Allowance for credit losses

Year Ended December 31
2016

2017

2015

$1,776
397
12
(491)
124
(4)
$1,814

$1,735
79
$1,814

$1,815
440
4
(591)
108
—
$1,776

$1,709
67
$1,776

$1,991
156
9
(470)
129
—
$1,815

$1,752
63
$1,815

1 Related to loans disposed in connection with the sale of PAC. For additional information regarding the sale of PAC, see Note 2, "Acquisitions/Dispositions."
2 The unfunded commitments reserve is recorded in Other liabilities in the Consolidated Balance Sheets.

Activity in the ALLL by loan segment is presented in the following tables:

(Dollars in millions)
Balance, beginning of period

Provision for loan losses

Loan charge-offs

Loan recoveries
Other 1

Balance, end of period

(Dollars in millions)

Balance, beginning of period

Provision for loan losses

Loan charge-offs

Loan recoveries

Balance, end of period

Year Ended December 31, 2017

Commercial
Loans

Consumer
Loans

$1,124

108

(167)

40

(4)

$1,101

$585

289

(324)

84

—

$634

Total

$1,709

397

(491)

124

(4)

$1,735

Year Ended December 31, 2016

Commercial
Loans

Consumer
Loans

Total

$1,047

329

(287)

35

$1,124

$705

111

(304)

73

$585

$1,752

440

(591)

108

$1,709

1 Related to loans disposed in connection with the sale of PAC. For additional information regarding the sale of PAC, see Note 2, "Acquisitions/Dispositions."

As discussed in Note 1, “Significant Accounting Policies,” the 
ALLL  is  composed  of  both  specific  allowances  for  certain 
nonaccrual loans and TDRs, and general allowances for groups 
of  loans  with  similar  risk  characteristics.  No  allowance  is 

required  for  loans  measured  at  fair  value.  Additionally,  the 
Company records an immaterial allowance for loan products that 
are insured by federal agencies or guaranteed by GSEs, as there 
is nominal risk of principal loss. 

105

 
 
Notes to Consolidated Financial Statements, continued

The Company’s LHFI portfolio and related ALLL is presented in the following tables:

(Dollars in millions)

LHFI evaluated for impairment:

Individually evaluated

Collectively evaluated

Total evaluated

LHFI measured at fair value

Total LHFI

(Dollars in millions)
LHFI evaluated for impairment:

Individually evaluated

Collectively evaluated

Total evaluated

LHFI measured at fair value

Total LHFI

Commercial Loans

December 31, 2017
Consumer Loans

Total

Carrying
Value

Related
ALLL

Carrying
Value

Related
ALLL

Carrying
Value

Related
ALLL

$173

75,304

75,477

—

$21

1,080

1,101

—

$2,648

64,860

67,508

196

$183

451

634

—

$2,821

140,164

142,985

196

$204

1,531

1,735

—

$75,477

$1,101

$67,704

$634

$143,181

$1,735

December 31, 2016

Commercial Loans

Consumer Loans

Total

Carrying
Value

Related
ALLL

Carrying
Value

Related
ALLL

Carrying
Value

Related
ALLL

$382

77,842

78,224

—

$33

1,091

1,124

—

$2,686

62,166

64,852

222

$222

363

585

—

$3,068

140,008

143,076

222

$255

1,454

1,709

—

$78,224

$1,124

$65,074

$585

$143,298

$1,709

NOTE 8 - PREMISES AND EQUIPMENT 

Premises  and  equipment  at  December  31  consisted  of  the 
following:

(Dollars in millions)

Land

Buildings and improvements

Leasehold improvements

Furniture and equipment

Construction in progress

Total premises and equipment

Useful Life 
(in years)
Indefinite

1 - 40

1 - 30

1 - 20

Less:  Accumulated depreciation and amortization

2017

2016

$321

1,047

691

1,430

488

3,977

2,243

$320

1,028

645

1,492

357

3,842

2,286

Premises and equipment, net

$1,734

$1,556

in 

indebtedness  (included 

None of the Company's premises and equipment was subject to 
long-term  debt)  at 
mortgage 
December 31,  2017  and  2016.  Capital  leases  included  in  net 
premises and equipment was immaterial at both December 31, 
2017 and 2016. Aggregate rent expense (principally for offices), 
including  any  contingent  rent  expense  and  sublease  income, 
totaled $201 million, $202 million, and $200 million for the years 
ended  December  31,  2017,  2016,  and  2015,  respectively. 
Depreciation  and  amortization  expense  on  premises  and 
equipment for the years ended December 31, 2017, 2016, and 
2015  totaled  $175  million,  $179  million,  and  $175  million, 
respectively.

The  Company  previously  completed  sale-leaseback 
transactions  consisting  of  branch  properties  and  various 
individual  office  buildings.  Upon  completion  of 
these 
transactions, the Company recognized a portion of the resulting 

106

gains and deferred the remainder to be recognized ratably over 
the expected term of the lease, predominantly 10 years, as an 
offset to net occupancy expense. To the extent that terms on these 
leases  are  extended,  the  remaining  deferred  gain  would  be 
amortized  over  the  new  lease  term. Amortization  of  deferred 
gains  on  sale-leaseback  transactions  was  $17  million,  $43 
million, and $54 million for the years ended December 31, 2017, 
2016, and 2015, respectively. At December 31, 2017 and 2016, 
the  remaining  deferred  gain  associated  with  sale-leaseback 
transactions was $49 million and $67 million, respectively.

The Company has various obligations under capital leases 
and noncancelable operating leases for premises and equipment. 
The leases predominantly expire over the next 21 years, with the 
longest lease term having an expiration date in 2081. Many of 
these  leases  include  a  renewal  option  and  some  provide  for 
periodic  adjustment  of  rentals  based  on  changes  in  various 
economic indicators. 

The  following  table  presents  future  minimum  payments 
under noncancelable operating leases, net of sublease rentals, 
with initial terms in excess of one year at December 31, 2017.

(Dollars in millions)

2018
2019
2020
2021
2022
Thereafter

Total minimum lease payments

Operating
Leases

$205
199
179
167
151
657
$1,558

 
 
 
 
Notes to Consolidated Financial Statements, continued

NOTE 9 – GOODWILL AND OTHER INTANGIBLE ASSETS

Goodwill
As  discussed  in  Note  20,  "Business  Segment  Reporting,"  the 
Company  realigned  its  business  segment  structure  from  three 
segments to two segments in the second quarter of 2017. As a 
result, the Company reassessed the composition of its goodwill 
reporting units and combined the Consumer Banking and Private 
Wealth  Management  reporting  unit  and  Mortgage  Banking 
reporting unit into a single Consumer goodwill reporting unit. 
The Mortgage Banking reporting unit did not have any associated 
goodwill prior to this change. The composition of the Wholesale 
Banking reporting unit was not impacted by the business segment 
structure realignment. 

The Company conducts a goodwill impairment test at the 
reporting unit level at least annually, or more frequently as events 
occur or circumstances change that would more-likely-than-not 
reduce  the  fair  value  of  a  reporting  unit  below  its  carrying 
amount.  See  Note  1,  "Significant  Accounting  Policies,"  for 
additional  information  regarding  the  Company's  goodwill 
accounting policy.

The Company performed goodwill impairment analyses for 
its Wholesale  and  Consumer  reporting  units  as  of  October  1, 
2017, 2016, and 2015. Based on the results of the impairment 
analyses,  the  Company  concluded  that  the  fair  values  of  the 
reporting units exceed their respective carrying values; therefore, 
there  was  no  goodwill  impairment.  The  Company  monitored 
events and circumstances during the fourth quarter of 2017 and 
did  not  observe  any  factors  that  would  more-likely-than-not 
reduce  the  fair  value  of  a  reporting  unit  below  its  respective 
carrying value. 

Changes in the carrying amount of goodwill by reportable 
segment for the year ended December 31, 2017 are presented in 
the  following  table.  There  were  no  material  changes  in  the 
carrying amount of goodwill by reportable segment for the year 
ended December 31, 2016.

(Dollars in millions)

Balance, January 1, 2017

Measurement period adjustment related to the acquisition of Pillar

Sale of PAC

Balance, December 31, 2017

Consumer

Wholesale

Total

$4,262

$2,075

$6,337

—

—

1

(7)

1

(7)

$4,262

$2,069

$6,331

107

Notes to Consolidated Financial Statements, continued

Other Intangible Assets
Changes in the carrying amounts of other intangible assets for the years ended December 31 are presented in the following table:

(Dollars in millions)

Balance, January 1, 2017
Amortization 1
Servicing rights originated

Changes in fair value:

Due to changes in inputs and assumptions 2
Other changes in fair value 3

Servicing rights sold
Other 4
Balance, December 31, 2017

Balance, January 1, 2016
Amortization 1
Servicing rights originated

Servicing rights purchased

Servicing rights acquired in Pillar acquisition
Other intangible assets acquired in Pillar acquisition 5
Changes in fair value:

Due to changes in inputs and assumptions 2
Other changes in fair value 3

Servicing rights sold

Balance, December 31, 2016

Residential
MSRs -
Fair Value

Commercial
Mortgage
Servicing Rights
and Other

Total

$1,572

—

394

(22)

(226)

(8)

—

$1,710

$1,307

—

312

200

—

—

(13)

(232)

(2)

$1,572

$85

(20)

17

—

—

—

(1)

$81

$18

(9)

—

—

62

14

—

—

—

$85

$1,657

(20)

411

(22)

(226)

(8)

(1)

$1,791

$1,325

(9)

312

200

62

14

(13)

(232)

(2)

$1,657

1 Does not include expense associated with non-qualified community development investments. See Note 10, "Certain Transfers of Financial Assets and Variable 
Interest Entities," for additional information.
2 Primarily reflects changes in option adjusted spreads and prepayment speed assumptions, due to changes in interest rates.
3 Represents changes due to the collection of expected cash flows, net of accretion due to the passage of time.
4 Represents the first quarter of 2017 measurement period adjustment on other intangible assets acquired previously in the Pillar acquisition.
5 The majority of other intangible assets acquired from Pillar relate to indefinite-lived agency licenses.

The gross carrying amount and accumulated amortization of other intangible assets are presented in the following table:

(Dollars in millions)
Amortized other intangible assets 1:

Commercial mortgage servicing rights

Other (definite-lived)

Unamortized other intangible assets:

Residential MSRs (carried at fair value)

Other (indefinite-lived)

Total other intangible assets

1 Excludes fully amortized other intangible assets.

December 31, 2017

December 31, 2016

Gross
Carrying
Value

Accumulated
Amortization

Net
Carrying
Value

Gross
Carrying
Value

Accumulated
Amortization

Net
Carrying
Value

$79

32

1,710

12

$1,833

($14)

(28)

—

—

$65

4

1,710

12

($42)

$1,791

$62

35

1,572

10

$1,679

$—

(22)

—

—

$62

13

1,572

10

($22)

$1,657

108

Notes to Consolidated Financial Statements, continued

The  Company's  estimated  future  amortization  of  intangible 
assets at December 31, 2017 is presented in the following table:

(Dollars in millions)
2018
2019
2020
2021
2022
Thereafter
Total 1

$13
10
9
8
6
23

$69

1 Does not include indefinite-lived intangible assets of $12 million.

Servicing Rights
The  Company  acquires  servicing  rights  and  retains  servicing 
rights  for  certain  of  its  sales  or  securitizations  of  residential 
mortgages  and  commercial 
loans.  MSRs  on  residential 
mortgages and servicing rights on commercial mortgages are the 
only material servicing assets capitalized by the Company and 
are  classified  as  Other  intangible  assets  on  the  Company's 
Consolidated Balance Sheets.

Residential Mortgage Servicing Rights
Income  earned  by  the  Company  on  its  residential  MSRs  is 
derived  primarily  from  contractually  specified  mortgage 
servicing fees and late fees, net of curtailment costs. Such income 
earned for the years ended December 31, 2017, 2016, and 2015 
totaled  $403  million,  $366  million,  and  $347  million, 
respectively. These amounts are reported in Mortgage servicing 
related income in the Consolidated Statements of Income.

At December 31, 2017 and 2016, the total UPB of residential 
mortgage loans serviced was $165.5 billion and $160.2 billion, 
respectively. Included in these amounts at December 31, 2017 
and 2016 were $136.1 billion and $129.6 billion, respectively, 
of  loans  serviced  for  third  parties.  The  Company  purchased 
MSRs on residential loans with a UPB of $19.7 billion during 
the year ended December 31, 2016. No MSRs on residential loans 
were  purchased  during  the  year  ended  December  31,  2017. 
During  the  years  ended  December  31,  2017  and  2016,  the 
Company  sold  MSRs  on  residential  loans,  at  a  price 
approximating their fair value, with a UPB of $1.1 billion and 
$575 million, respectively.

The  Company  measures  the  fair  value  of  its  residential 
MSRs using a valuation model that calculates the present value 
of  estimated  future  net  servicing  income  using  prepayment 
projections,  spreads,  and  other  assumptions.  The  Consumer 
Valuation  Committee  reviews  and  approves  all  significant 
assumption changes at least quarterly, evaluating these inputs 
compared to various market and empirical data sources. Changes 
to valuation model inputs are reflected in the periods' results. See 
Note  18,  “Fair Value  Election  and  Measurement,”  for  further 
information regarding the Company's residential MSR valuation 
methodology.

A summary of the key inputs used to estimate the fair value 
of the Company’s residential MSRs at December 31, 2017 and 
2016, and the sensitivity of the fair values to immediate 10% and 
20%  adverse  changes  in  those  inputs,  are  presented  in  the 
following table.

109

(Dollars in millions)

Fair value of residential MSRs
Prepayment rate assumption (annual)
Decline in fair value from 10%

adverse change

Decline in fair value from 20%

adverse change

Option adjusted spread (annual)

Decline in fair value from 10%

adverse change

Decline in fair value from 20%

adverse change

Weighted-average life (in years)
Weighted-average coupon

December 31,
2017

December 31,
2016

$1,710

13%

$85

160

4%

$47

90
5.4
3.9%

$1,572

9%

$50

97

8%

$63

122

7.0
4.0%

These residential MSR sensitivities are hypothetical and should 
be used with caution. Changes in fair value based on variations 
in assumptions generally cannot be extrapolated because (i) the 
relationship of the change in an assumption to the change in fair 
value may not be linear and (ii) changes in one assumption may 
result in changes in another, which might magnify or counteract 
the  sensitivities.  The  sensitivities  do  not  reflect  the  effect  of 
hedging activity undertaken by the Company to offset changes 
in the fair value of MSRs. See Note 17, “Derivative Financial 
Instruments,” for further information regarding these hedging 
activities.

Commercial Mortgage Servicing Rights 
In December 2016, the Company completed the acquisition of 
substantially  all  of  the  assets  of  the  operating  subsidiaries  of 
Pillar, and as a result, the Company recognized a $62 million
servicing asset.

Income earned by the Company on its commercial mortgage 
servicing rights is derived primarily from contractually specified 
servicing fees and other ancillary fees. Such income earned for 
the year ended December 31, 2017 totaled $22 million and is 
reported  in  Commercial  real  estate  related  income  in  the 
Consolidated  Statements  of  Income.  Income  earned  on 
commercial  mortgage  servicing  rights  for  the  year  ended 
December  31,  2016  was  immaterial  and  there  was  no  such 
income earned for the year ended December 31, 2015.

The Company also earns income from subservicing certain 
third party commercial mortgages for which the Company does 
not  record  servicing  rights.  Such  income  earned  for  the  year 
ended December 31, 2017 totaled $14 million and is reported in 
Commercial  real  estate  related  income  in  the  Consolidated 
Statements of Income. Income earned from such subservicing 
arrangements  for  the  year  ended  December  31,  2016  was 
immaterial and there was no such income earned for the year 
ended December 31, 2015.

At  December  31,  2017  and  2016,  the  total  UPB  of 
commercial mortgage loans serviced for third parties was $30.1 
billion and $27.7 billion, respectively. Included in these amounts 
at  December  31,  2017  and  2016  were  $5.8  billion  and  $4.8 
billion, respectively, of loans serviced for third parties for which 
the  Company  records  servicing  rights,  and  $24.3  billion  and 
$22.9 billion, respectively, of loans subserviced for third parties 
for  which  the  Company  does  not  record  servicing  rights.  No 
commercial mortgage servicing rights were purchased or sold 

Notes to Consolidated Financial Statements, continued

during the years ended December 31, 2017 and 2016 (other than 
those that were acquired as part of the Pillar acquisition).

Commercial mortgage servicing rights are accounted for at 
amortized cost and are monitored for impairment on an ongoing 
basis.  The  Company  calculates  the  fair  value  of  commercial 
servicing rights based on the present value of estimated future 
net servicing income, considering prepayment projections and 
other assumptions. Impairment, if any, is recognized when the 
carrying value of the servicing asset exceeds the fair value at the 
measurement  date.  The  amortized  cost  of  the  Company's 
commercial mortgage servicing rights were $65 million and $62 
million  at  December 31,  2017  and  December 31,  2016, 
respectively.

A summary of the key inputs used to estimate the fair value 
of  the  Company’s  commercial  mortgage  servicing  rights  are 
presented in the following table.

(Dollars in millions)

Fair value of commercial mortgage

servicing rights

Discount rate (annual)

Prepayment rate assumption (annual)

Float earnings rate (annual)

Weighted-average life (in years)

December 31,
2017

December 31,
2016

$75

12%

7

1.1

7.0

$62

12%

6

0.5

7.0

NOTE 10 - CERTAIN TRANSFERS OF FINANCIAL ASSETS AND VARIABLE INTEREST ENTITIES

The  Company  has  transferred  loans  and  securities  in  sale  or 
securitization transactions for which the Company retains certain 
beneficial  interests,  servicing  rights,  and/or  recourse.  These 
transfers of financial assets include certain residential mortgage 
loans, guaranteed student loans, and commercial and corporate 
loans,  as  discussed  in  the  following  section,  "Transfers  of 
Financial  Assets."  Cash  receipts  on  beneficial  interests  held 
related to these transfers were $11 million, $12 million and $19 
million for the years ended December 31, 2017, 2016, and 2015, 
respectively. The servicing fees related to these asset transfers 
(excluding  servicing  fees  for  residential  and  commercial 
mortgage loan transfers to GSEs, which are discussed in Note 9, 
“Goodwill and Other Intangible Assets”) were immaterial for 
each of the years ended December 31, 2017, 2016, and 2015.

When a transfer or other transaction occurs with a VIE, the 
Company first determines whether it has a VI in the VIE. A VI 
is  typically  in  the  form  of  securities  representing  retained 
interests in transferred assets and, at times, servicing rights, and 
for commercial mortgage loans sold to Fannie Mae, the loss share 
guarantee. When determining whether to consolidate the VIE, 
the Company evaluates whether it is a primary beneficiary which 
has  both  (i) the  power  to  direct  the  activities  that  most 
significantly impact the economic performance of the VIE, and 
(ii) the obligation to absorb losses, or the right to receive benefits, 
that could potentially be significant to the VIE.

To determine whether a transfer should be accounted for as 
a sale or a secured borrowing, the Company evaluates whether: 
(i) the transferred assets are legally isolated, (ii) the transferee 
has the right to pledge or exchange the transferred assets, and 
(iii)  the  Company  has  relinquished  effective  control  of  the 
transferred assets. If all three conditions are met, then the transfer 
is accounted for as a sale.

Except  as  specifically  noted  herein,  the  Company  is  not 
required  to  provide  additional  financial  support  to  any  of  the 
entities to which the Company has transferred financial assets, 
nor has the Company provided any support it was not otherwise 
obligated to provide. No events occurred during the year ended 
December  31,  2017  that  changed  the  Company’s  previous 
conclusions regarding whether it is the primary beneficiary of 
the  VIEs  described  herein.  Furthermore,  no  events  occurred 
during  the  year  ended  December  31,  2017  that  changed  the 
to  previously 
Company’s  sale  conclusion  with  regards 

110

transferred residential mortgage loans, guaranteed student loans, 
or commercial and corporate loans.

Transfers of Financial Assets

The  following  discussion  summarizes  transfers  of  financial 
assets to entities for which the Company has retained some level 
of continuing involvement.

Consumer Loans
Residential Mortgage Loans
The Company typically transfers first lien residential mortgage 
loans in conjunction with Ginnie Mae, Fannie Mae, and Freddie 
Mac  securitization 
loans  are 
exchanged for cash or securities that are readily redeemable for 
cash, and servicing rights are retained.

transactions,  whereby 

the 

The  Company  sold  residential  mortgage  loans  to  Ginnie 
Mae, Fannie Mae, and Freddie Mac, which resulted in pre-tax 
net gains of $213 million, $331 million, and $232 million for the 
years ended December 31, 2017, 2016, and 2015, respectively. 
Net gains/losses on the sale of residential mortgage LHFS are 
recorded  at  inception  of  the  associated  IRLCs  and  reflect  the 
change in value of the loans resulting from changes in interest 
rates from the time the Company enters into the related IRLCs 
with borrowers until the loans are sold, but do not include the 
results of hedging activities initiated by the Company to mitigate 
this  market  risk.  See  Note  17,  "Derivative  Financial 
Instruments," for further discussion of the Company's hedging 
activities. The Company has made certain representations and 
warranties with respect to the transfer of these loans. See Note 
16,  “Guarantees,” 
regarding 
representations and warranties.

for  additional 

information 

In  a  limited  number  of  securitizations,  the  Company  has 
received  securities  in  addition  to  cash  in  exchange  for  the 
transferred  loans,  while  also  retaining  servicing  rights.  The 
securities received are measured at fair value and classified as 
securities AFS. At December 31, 2017 and 2016, the fair value 
of  securities  received  totaled  $22  million  and  $30  million, 
respectively.

The Company evaluates securitization entities in which it 
has a VI for potential consolidation under the VIE consolidation 
model.  Notwithstanding  the  Company's  role  as  servicer,  the 

Notes to Consolidated Financial Statements, continued

Company typically does not have power over the securitization 
entities as a result of rights held by the master servicer. In certain 
transactions, the Company does have power as the servicer, but 
does not have an obligation to absorb losses, or the right to receive 
benefits, that could potentially be significant. In all such cases, 
the Company does not consolidate the securitization entity. Total 
assets of the unconsolidated entities in which the Company has 
a VI were $147 million and $203 million at December 31, 2017 
and 2016, respectively. 

The Company’s maximum exposure to loss related to these 
unconsolidated  residential  mortgage  loan  securitizations  is 
comprised of the loss of value of any interests it retains, which 
was $22 million and $30 million at December 31, 2017 and 2016, 
respectively, and any repurchase obligations or other losses it 
incurs  as  a  result  of  any  guarantees  related  to  these 
securitizations,  which  is  discussed  further  in  Note  16, 
“Guarantees.”

Guaranteed Student Loans
The Company has securitized government-guaranteed student 
loans through a transfer of loans to a securitization entity and 
retained  the  residual  interest  in  the  entity.  The  Company 
concluded  that  this  entity  should  be  consolidated  because  the 
Company  has  (i)  the  power  to  direct  the  activities  that  most 
significantly impact the economic performance of the VIE and 
(ii)  the  obligation  to  absorb  losses,  and  the  right  to  receive 
benefits, that could potentially be significant. At December 31, 
2017  and  2016,  the  Company’s  Consolidated  Balance  Sheets 
reflected $192 million and $225 million of assets held by the 
securitization entity and $189 million and $222 million of debt 
issued by the entity, respectively, inclusive of related accrued 
interest.

To the extent that the securitization entity incurs losses on 
its assets, the securitization entity has recourse to the guarantor 
of the underlying loan, which is backed by the Department of 

Education up to a maximum guarantee of 98%, or in the event 
of  death,  disability,  or  bankruptcy,  100%.  When  not  fully 
guaranteed, losses reduce the amount of available cash payable 
to the Company as the owner of the residual interest. To the extent 
that losses result from a breach of servicing responsibilities, the 
Company,  which  functions  as  the  master  servicer,  may  be 
required to repurchase the defaulted loan(s) at par value. If the 
breach was caused by the subservicer, the Company would seek 
reimbursement  from  the  subservicer  up  to  the  guaranteed 
amount. The Company’s maximum exposure to loss related to 
the securitization entity would arise from a breach of its servicing 
responsibilities. To date, loss claims filed with the guarantor that 
have been denied due to servicing errors have either been, or are 
in  the  process  of,  being  cured,  or  reimbursement  has  been 
provided to the Company by the subservicer, or in limited cases, 
absorbed by the Company.

Commercial and Corporate Loans
In connection with the Pillar acquisition completed in December 
2016, the Company acquired licenses and approvals to originate 
and sell certain commercial mortgage loans to Fannie Mae and 
Freddie Mac, to originate FHA insured loans, and to issue and 
sell Ginnie Mae commercial MBS secured by FHA insured loans. 
The Company transferred commercial loans to these Agencies 
and GSEs, which resulted in pre-tax net gains of $37 million for 
the year ended December 31, 2017. No associated gains or losses 
were  recognized  for  the  year  ended  December  31,  2016. The 
loans  are  exchanged  for  cash  or  securities  that  are  readily 
redeemable  for  cash,  with  servicing  rights  retained. The 
Company has made certain representations and warranties with 
respect to the transfer of these loans and has entered into a loss 
share  guarantee  related  to  certain  loans  transferred  to  Fannie 
Mae. See  Note  16,  “Guarantees,”  for  additional  information 
regarding the commercial mortgage loan loss share guarantee.

The Company's total managed loans, including the LHFI portfolio and other transferred loans (securitized and unsecuritized), are 
presented in the following table by portfolio balance and delinquency status (accruing loans 90 days or more past due and all nonaccrual 
loans) at December 31, 2017 and 2016, as well as the related net charge-offs for the years ended December 31, 2017 and 2016.

(Dollars in millions)

LHFI portfolio:

Commercial

Consumer

Total LHFI portfolio

Managed securitized loans 1:

Commercial 2
Consumer

Total managed securitized loans

Managed unsecuritized loans 4

Portfolio Balance

Past Due and Nonaccrual

Net Charge-offs

December 31,
2017

December 31,
2016

December 31,
2017

December 31,
2016

Year Ended December 31

2017

2016

$75,477

67,704

143,181

5,760

134,160

139,920

2,200

$78,224

65,074

143,298

4,761

127,153

131,914

2,985

$247

1,832

2,079

—

171

171

340

$426

1,707

2,133

—

115

115

438

$127

240

367

—
8 3
8

—

$252

231

483

—
11 3
11

—

Total managed loans

$285,301

$278,197

$2,590

$2,686

$375

$494

1 Excludes loans that have completed the foreclosure or short sale process (i.e., involuntary prepayments).
2 Comprised of commercial mortgages sold through Fannie Mae, Freddie Mac, and Ginnie Mae securitizations, whereby servicing has been retained by the Company.
3 Amounts associated with $602 million and $922 million of managed securitized loans at December 31, 2017 and 2016, respectively. Net charge-off data is not 
reported to the Company for the remaining balance of $133.6 billion and $126.2 billion of managed securitized loans at December 31, 2017 and 2016, respectively.
4 Comprised of unsecuritized loans the Company originated and sold to private investors with servicing rights retained. Net charge-offs on these loans are not presented 
in the table as the data is not reported to the Company by the private investors that own these related loans.

111

 
Notes to Consolidated Financial Statements, continued

Other Variable Interest Entities
In addition to exposure to VIEs arising from transfers of financial 
assets, the Company also has involvement with VIEs from other 
business activities.

Total Return Swaps
The  Company  facilitates  matched  book  TRS  transactions  on 
behalf  of  clients,  whereby  a  VIE  purchases  reference  assets 
identified by a client and the Company enters into a TRS with 
the VIE, with a mirror-image TRS facing the client. The TRS 
contract  between  the  VIE  and  the  Company  hedges  the 
Company's  exposure  to  the  TRS  contract  with  its  third  party 
client. The Company provides senior financing to the VIE, in the 
form of demand notes to fund the purchase of the reference assets. 
The TRS contracts pass through interest and other cash flows on 
the reference assets to the third party clients, along with exposing 
those clients to decreases in value on the assets and providing 
them with the rights to appreciation on the assets. The terms of 
the TRS contracts require the third parties to post initial margin 
collateral, in addition to ongoing margin as the fair values of the 
underlying reference assets change.

The Company evaluated the related VIEs for consolidation, 
noting that the Company and its third party clients are VI holders. 
The Company evaluated the nature of all VIs and other interests 
and involvement with the VIEs, in addition to the purpose and 
design of the VIEs, relative to the risks they were designed to 
create. The VIEs were designed for the benefit of the third parties 
and would not exist if the Company did not enter into the TRS 
contracts on their behalf. The activities of the VIEs are restricted 
to buying and selling the reference assets and the risks/benefits 
of any such assets owned by the VIEs are passed to the third 
party clients via the TRS contracts. The Company determined 
that it is not the primary beneficiary of the VIEs, as the design 
of its matched book TRS business results in the Company having 
no substantive power to direct the significant activities of the 
VIEs, and therefore, the VIEs are not consolidated.

At December 31, 2017 and 2016, the outstanding notional 
amounts of the Company's VIE-facing TRS contracts were $1.7 
billion and $2.1 billion, and related senior financing outstanding 
to VIEs were $1.7 billion and $2.1 billion, respectively. These 
financings  were  measured  at  fair  value  and  classified  within 
Trading assets and derivative instruments on the Consolidated 
Balance Sheets. The Company entered into client-facing TRS 
contracts of the same outstanding notional amounts. The notional 
amounts  of  the  TRS  contracts  with  VIEs  represent  the 
Company’s maximum exposure to loss, although this exposure 
has been mitigated via the TRS contracts with third party clients. 
For additional information on the Company’s TRS contracts and 
its  involvement  with  these  VIEs,  see  Note  17,  “Derivative 
Financial Instruments.”

Community Development Investments
As part of its community reinvestment initiatives, the Company 
invests  in  multi-family  affordable  housing  developments  and 
other community development entities as a limited partner and/

or  a  debt  provider. The  Company  receives  tax  credits  for  its 
limited partner investments. The Company has determined that 
the majority of the related partnerships are VIEs.

The  Company  has  concluded  that  it  is  not  the  primary 
beneficiary of affordable housing partnerships when it invests 
as a limited partner and there is a third party general partner. The 
investments are accounted for in accordance with the accounting 
guidance  for  investments  in  affordable  housing  projects.  The 
general  partner,  or  an  affiliate  of  the  general  partner,  often 
provides guarantees to the limited partner, which protects the 
Company from construction and operating losses and tax credit 
allocation deficits. Assets of $2.3 billion and $1.7 billion in these 
and  other  community  development  partnerships  were  not 
included in the Consolidated Balance Sheets at December 31, 
2017  and  2016,  respectively.  The  Company's  limited  partner 
interests had carrying values of $1.1 billion and $780 million at 
December 31, 2017 and 2016, respectively, and are recorded in 
Other  assets on  the Company’s  Consolidated Balance Sheets. 
The Company’s maximum exposure to loss for these investments 
totaled $1.4 billion and $1.1 billion at December 31, 2017 and 
2016, respectively. The Company’s maximum exposure to loss 
would result from the loss of its limited partner investments, net 
of liabilities, along with $350 million and $306 million of loans, 
interest-rate swap fair value exposures, or letters of credit issued 
by the Company to the entities at December 31, 2017 and 2016, 
respectively.  The  remaining  exposure  to  loss  is  primarily 
attributable to unfunded equity commitments that the Company 
is required to fund if certain conditions are met.

The Company also owns noncontrolling interests in funds 
whose  purpose  is  to  invest  in  community  developments. At 
December 31, 2017 and 2016, the Company's investment in these 
funds totaled $278 million and $200 million, respectively. The 
Company's maximum exposure to loss on its investment in these 
funds is comprised of its equity investments in the funds, loans 
issued, and any additional unfunded equity commitments, which 
totaled $643 million and $562 million at December 31, 2017 and 
2016, respectively.

During the years ended December 31, 2017, 2016, and 2015, 
the  Company  recognized  $108  million,  $92  million,  and  68 
million of tax credits for qualified affordable housing projects, 
and $109 million, $87 million, and $66 million of amortization 
on  these  qualified  affordable  housing  projects,  respectively. 
These tax credits and amortization, net of the related tax benefits, 
are recorded in the Provision for income taxes.

Certain  of 

the  Company's  community  development 
investments  do  not  qualify  as  affordable  housing  projects  for 
accounting purposes. The Company recognized tax credits for 
these investments of $90 million, $64 million, and $53 million
during  the  years  ended  December  31,  2017,  2016,  and  2015, 
respectively,  in  the  Provision  for  income  taxes. Amortization 
recognized  on  these  investments  totaled  $70  million,  $46 
million, and $35 million during the years ended December 31, 
2017, 2016, and 2015, respectively, recorded in Amortization in 
the Company's Consolidated Statements of Income.

112

Notes to Consolidated Financial Statements, continued

NOTE 11 - BORROWINGS AND CONTRACTUAL COMMITMENTS

Short-term Borrowings

Short-term borrowings at December 31 consisted of the following:

(Dollars in millions)
Funds purchased

Securities sold under agreements to repurchase
Other short-term borrowings

Total short-term borrowings

2017

2016

Balance

Interest Rate

Balance

Interest Rate

$2,561

1,503
717

$4,781

1.33%

1.39
1.00

$2,116

1,633
1,015

$4,764

0.55%

0.55
0.56

Long-term Debt

Long-term debt at December 31 consisted of the following:

(Dollars in millions)
Parent Company Only:

Senior, fixed rate
Senior, variable rate
Subordinated, fixed rate
Junior subordinated, variable rate

Total

Less:  Debt issuance costs

Total Parent Company debt

Subsidiaries 1:

Senior, fixed rate 2
Senior, variable rate
Subordinated, fixed rate

Total

Less:  Debt issuance costs
Total subsidiaries debt

Total long-term debt 3

Maturity Date(s)

Interest Rate(s)

Balance

2017

2016

Balance

2018 - 2028
2018 - 2019
2026
2027 - 2028

2.35% - 6.00%
0.25 - 1.53
6.00
2.09 - 2.32

2018 - 2057
2020 - 2043
2018 - 2026

0.80 - 9.10
1.04 - 1.84
3.30 - 7.25

$3,379
267
200
628
4,474
8
4,466

3,609
512
1,206
5,327
8
5,319

$3,818
314
200
627
4,959
9
4,950

2,539
2,613
1,651
6,803
5
6,798

$9,785

$11,748

1 77% and 88% of total subsidiary debt was issued by the Bank as of December 31, 2017 and 2016, respectively.
2 Includes leases and other obligations that do not have a stated interest rate.
3 Includes $530 million and $963 million of long-term debt measured at fair value at December 31, 2017 and 2016, respectively.

The Company had no foreign denominated debt outstanding at 
December 31,  2017  or  2016.  Maturities  of  long-term  debt  at 
December 31, 2017 were as follows:

(Dollars in millions)
2018
2019
2020
2021
2022
Thereafter

Total maturities

Less:  Debt issuance costs
Total long-term debt

Parent
Company

$874
792
—
965
990
853
4,474
8
$4,466

Subsidiaries
$361
27
1,508
4
1,022
2,405
5,327
8
$5,319

113

During 2017, the Bank (i) issued $1.0 billion of 3-year fixed rate 
senior notes, (ii) issued $300 million of 3-year floating rate senior 
notes, and (iii) issued $1.0 billion of 5-year fixed rate senior notes 
under its Global Bank Note program. Additionally, $2.8 billion
of the Company's long-term FHLB advances were terminated or 
matured during the year. Furthermore, $1.5 billion of senior notes 
and $188 million of subordinated notes matured during 2017. 
The Company had no additional material issuances, advances, 
repurchases, terminations, or extinguishments of long-term debt 
during the year.

Restrictive provisions of several long-term debt agreements 
prevent the Company from creating liens on, disposing of, or 
issuing (except to related parties) voting stock of subsidiaries. 
Furthermore, there are restrictions on mergers, consolidations, 
certain leases, sales or transfers of assets, minimum shareholders’ 
equity,  and  maximum  borrowings  by  the  Company.  At 

Notes to Consolidated Financial Statements, continued

December 31, 2017, the Company was in compliance with all 
covenants and provisions of long-term debt agreements. 

As currently defined by federal bank regulators, long-term 
debt of $1.6 billion and $1.7 billion qualified as Tier 2 capital at 
December  31,  2017  and  2016,  respectively.  See  Note  13, 
"Capital," for additional information regarding regulatory capital 
adequacy requirements for the Company and the Bank.

The Company does not consolidate certain wholly-owned 
trusts which were formed for the sole purpose of issuing trust 
preferred  securities.  The  proceeds  from  the  trust  preferred 
securities  issuances  were  invested  in  junior  subordinated 
debentures  of  the  Parent  Company.  The  obligations  of  these 
debentures constitute a full and unconditional guarantee by the 
Parent Company of the trust preferred securities.

Contractual Commitments
In the normal course of business, the Company enters into certain 
contractual  commitments.  These  commitments 
include 
obligations  to  make  future  payments  on  the  Company's 
borrowings, partnership investments, and lease arrangements, as 
well  as  commitments  to  lend  to  clients  and  to  fund  capital 
expenditures and service contracts. 

The  following  table  presents  the  Company's  significant 
contractual  commitments  at  December 31,  2017,  except  for 
long-term debt and short-term borrowings, operating leases, and 
pension and other postretirement benefit plans. Information on 
those obligations is included above, in Note 8, "Premises and 
Equipment," and in Note 15, "Employee Benefit Plans." Capital 
lease obligations were immaterial at December 31, 2017 and are 
not presented in the table.

(Dollars in millions)

2018

2019

2020

2021

2022

Thereafter

Total

Payments Due by Period

76

278

260

4,720

$9,648

$15,879

$13,380

$13,773

$25,265

Unfunded lending commitments
Purchase obligations 1
Consumer and other time deposits 2, 3
Brokered time deposits 3
Commitments to fund partnership investments 4
1 For legally binding purchase obligations of $5 million or more, amounts include either termination fees under the associated contracts when early termination 
provisions exist, or the total potential obligation over the full contractual term for noncancelable purchase obligations. Payments made towards the purchase of 
goods or services under these contracts totaled $395 million, $236 million, and $243 million in 2017, 2016, and 2015, respectively.
2 The aggregate amount of time deposit accounts in denominations of $250,000 or more was $3.2 billion and $1.7 billion at December 31, 2017 and 2016, respectively.
3 Amounts do not include interest.
4 Commitments to fund investments in affordable housing and other partnerships do not have defined funding dates as certain criteria must be met before the Company 
is obligated to fund. Accordingly, these commitments are considered to be due on demand for presentation purposes. See Note 10, "Certain Transfers of Financial 
Assets and Variable Interest Entities," in this Form 10-K for additional information.

$90,011

$12,066

12,076

2,015

1,331

2,559

247

690

194

105

181

985

959

834

690

617

251

178

—

48

—

—

76

—

50

—

114

Notes to Consolidated Financial Statements, continued

NOTE 12 – NET INCOME PER COMMON SHARE 

Equivalent shares of 1 million and 14 million related to common 
stock  options  and  common  stock  warrants  outstanding  at 
December 31, 2016 and 2015, respectively, were excluded from 
the  computations  of  diluted  net  income  per  average  common 
share because they would have been anti-dilutive.

Reconciliations  of  net  income  to  net  income  available  to 
common shareholders and the difference between average basic 
common shares outstanding and average diluted common shares 
outstanding are presented in the following table.

(Dollars and shares in millions, except per share data)

Net income

Less:

Preferred stock dividends

Dividends and undistributed earnings allocated to unvested common share awards

Net income available to common shareholders

Average common shares outstanding - basic

Add dilutive securities:

RSUs

Common stock warrants and restricted stock

Stock options

Average common shares outstanding - diluted

Net income per average common share - diluted

Net income per average common share - basic

Year Ended December 31

2017

2016

2015

$2,273

$1,878

$1,933

(94)

—

(66)

(1)

(64)

(6)

$2,179

$1,811

$1,863

481.3

3.0

1.8

0.9

487.0

$4.47

4.53

498.6

2.9

0.6

1.4

503.5

$3.60

3.63

514.8

2.6

1.7

1.5

520.6

$3.58

3.62

NOTE 13 – CAPITAL

During 2017, pursuant to the Federal Reserve's non-objection to 
the Company's capital plan in conjunction with the 2017 CCAR, 
the  Company  increased  its  quarterly  common  stock  dividend 
from $0.26 to $0.40 per share beginning in the third quarter of 
2017, maintained dividend payments on its preferred stock, and 
repurchased $660 million of its outstanding common stock at 
market value (approximately 11.1 million shares) under the 2017 
capital  plan.  During  the  first  half  of  2017,  the  Company 
repurchased  $480  million  of  its  outstanding  common  stock, 
which completed its authorized repurchase of common equity 
under the 2016 CCAR capital plan, which effectively expired on 
June  30,  2017.  At  December 31,  2017,  the  Company  had 
remaining capacity under its 2017 capital plan to repurchase an 
additional $660 million of its outstanding common stock through 
June 30, 2018.

During the years ended December 31, 2017, 2016, and 2015, 
the  Company  declared  and  paid  common  dividends  of  $634 
million, or $1.32 per common share, $498 million, or $1.00 per 
common share, and $475 million, or $0.92 per common share, 
respectively.  The  Company  also  recognized  dividends  on 
perpetual preferred stock of $94 million, $66 million, and $64 
million during the years ended December 31, 2017, 2016, and 
2015, respectively. During 2017, both the Series A and Series B 
Perpetual Preferred Stock dividend was $4,056 per share, the 
Series  E  Perpetual  Preferred  Stock  dividend  was  $5,875  per 
share,  the  Series  F  Perpetual  Preferred  Stock  dividend  was 
$5,625 per share, the Series G Perpetual Preferred Stock dividend 

115

was $3,128 per share, and the Series H Perpetual Preferred Stock 
dividend was $669 per share.

The Company remains subject to certain restrictions on its 
ability to increase the dividend on common shares as a result of 
participating  in  the  U.S.  Treasury’s  CPP.  If  the  Company 
increases its dividend above $0.54 per share per quarter prior to 
the tenth anniversary of its participation in the CPP (in the fourth 
quarter  of  2018),  then  the  anti-dilution  provision  within  the 
warrants issued in connection with the Company’s participation 
in the CPP will require the exercise price and number of shares 
to be issued upon exercise to be proportionately adjusted. The 
amount  of  such  adjustment  is  determined  by  a  formula  and 
depends in part on the extent to which the Company raises its 
dividend. The formulas are contained in the warrant agreements 
which were filed as exhibits to Registration Statements on Form 
8-A filed on September 23, 2011.

Substantially  all  of  the  Company’s  retained  earnings  are 
undistributed  earnings  of  the  Bank,  which  are  restricted  by 
various  regulations  administered  by  federal  and  state  bank 
regulatory  authorities. At  both  December 31,  2017  and  2016, 
retained  earnings  of  the  Bank  available  for  payment  of  cash 
dividends to the Parent Company under these regulations totaled 
approximately  $2.5  billion. Additionally,  the  Federal  Reserve 
requires 
reserves.  At 
December 31, 2017 and 2016, these reserve requirements totaled 
$1.2 billion and $1.3 billion, respectively, and were fulfilled with 
a  combination  of  cash  on  hand  and  deposits  at  the  Federal 
Reserve.

to  maintain  cash 

the  Company 

Notes to Consolidated Financial Statements, continued

is  subject 

Regulatory Capital
to  various  regulatory  capital 
The  Company 
requirements 
the 
Company’s  assets.  The  following  table  presents  regulatory 
capital metrics for SunTrust and the Bank at December 31:

involve  quantitative  measures  of 

that 

(Dollars in millions)
SunTrust Banks, Inc.

CET1
Tier 1 capital
Total capital
Leverage

SunTrust Bank

CET1
Tier 1 capital
Total capital
Leverage

2017

2016

Amount

Ratio

Amount

Ratio

$17,141
19,622
23,028

$19,474
19,496
22,132

9.74% $16,953
11.15
18,186
13.09
21,685
9.80

11.29% $18,535
11.31
18,573
12.83
21,276
9.97

9.59%
10.28
12.26
9.22

10.71%
10.73
12.29
9.63

In 2013, the Federal Reserve published final rules in the Federal 
Register  implementing  Basel  III.  These  rules,  which  became 
effective  for  the  Company  and  the  Bank  on  January  1,  2015, 
include  the  following  minimum  capital  requirements:    CET1 
ratio of 4.5%; Tier 1 capital ratio of 6%; Total capital ratio of 
8%; Leverage ratio of 4%; and a capital conservation buffer of 
2.5%.  The  capital  conservation  buffer  became  applicable  on 
January 1, 2016 and is being phased-in through December 31, 
2018.

Preferred Stock
Preferred stock at December 31 consisted of the following:

(Dollars in millions)

Series A (1,725 shares outstanding)
Series B (1,025 shares outstanding) 
Series E (4,500 shares outstanding)

Series F (5,000 shares outstanding)

Series G (7,500 shares outstanding)

Series H (5,000 shares outstanding)

2017

2016

2015

$172

$172

$172

103

450

500

750

500

103

450

500

—

—

103

450

500

—

—

Total preferred stock

$2,475

$1,225

$1,225

In  September  2006,  the  Company  authorized  and  issued 
depositary  shares  representing  ownership  interests  in  5,000 
shares of Perpetual Preferred Stock, Series A, no par value and 
$100,000  liquidation  preference  per  share  (the  "Series  A 
Preferred Stock"). The Series A Preferred Stock has no stated 
maturity  and  will  not  be  subject  to  any  sinking  fund  or  other 
obligation of the Company. Dividends on the Series A Preferred 
Stock, if declared, will accrue and be payable quarterly at a rate 
per  annum  equal  to  the  greater  of  three-month  LIBOR  plus 
0.53%, or 4.00%. Dividends on the shares are noncumulative. 
Shares  of  the  Series A  Preferred  Stock  have  priority  over  the 
Company’s  common  stock  with  regard  to  the  payment  of 
dividends and, as such, the Company may not pay dividends on 
or repurchase, redeem, or otherwise acquire for consideration 
shares of  its common stock unless dividends for  the Series A 
Preferred Stock have been declared for that period and sufficient 

116

funds have been set aside to make payment. During 2009, the 
Company  repurchased  3,275  shares  of  the  Series A  Preferred 
Stock. In September 2011, the Series A Preferred Stock became 
redeemable at the Company’s option at a redemption price equal 
to $100,000 per share, plus any declared and unpaid dividends. 
Except in certain limited circumstances, the Series A Preferred 
Stock does not have any voting rights. 

In October 2006, the Company authorized 5,010 shares of 
Perpetual Preferred Stock, Series B, and in December 2011, the 
Company  issued  1,025  shares  of  Perpetual  Preferred  Stock, 
Series B, no par value and $100,000 liquidation preference per 
share (the "Series B Preferred Stock"). The Series B Preferred 
Stock has no stated maturity and will not be subject to any sinking 
fund or other obligation of the Company. Dividends on the shares 
are noncumulative and, if declared, will accrue and be payable 
quarterly at a rate per annum equal to the greater of three-month 
LIBOR plus 0.645%, or 4.00%. Shares of the Series B Preferred 
Stock  have  priority  over  the  Company's  common  stock  with 
regard to the payment of dividends and, as such, the Company 
may not pay dividends on or repurchase, redeem, or otherwise 
acquire  for  consideration  shares  of  its  common  stock  unless 
dividends for the Series B Preferred Stock have been declared 
for that period and sufficient funds have been set aside to make 
payment.  The  Series  B  Preferred  Stock  was  immediately 
redeemable  upon  issuance  at  the  Company's  option  at  a 
redemption price equal to $100,000 per share, plus any declared 
and unpaid dividends. Except in certain limited circumstances, 
the Series B Preferred Stock does not have any voting rights.

In  December  2012,  the  Company  authorized  and  issued 
depositary  shares  representing  ownership  interests  in  5,000
shares  and  4,500  shares,  respectively,  of  Perpetual  Preferred 
Stock, Series E, no par value and $100,000 liquidation preference 
per share (the "Series E Preferred Stock"). The Series E Preferred 
Stock has no stated maturity and will not be subject to any sinking 
fund or other obligation of the Company to redeem, repurchase, 
or retire the shares. Dividends on the shares are noncumulative 
and, if declared, will accrue and be payable quarterly at a rate 
per annum of 5.875%. Shares of the Series E Preferred Stock 
have priority over the Company's common stock with regard to 
the payment of dividends and rank equally with the Company's 
outstanding  Perpetual  Preferred  Stock,  Series A  and  Series  B 
and,  as  such,  the  Company  may  not  pay  dividends  on  or 
repurchase,  redeem,  or  otherwise  acquire  for  consideration 
shares of its common stock unless dividends for the Series E 
Preferred Stock have been declared for that period and sufficient 
funds  have  been  set  aside  to  make  payment.  The  Series  E 
Preferred Stock is redeemable, at the option of the Company, on 
any dividend payment date occurring on or after March 15, 2018 
or at any time within 90 days following a regulatory capital event, 
at  a  redemption  price  equal  to  $100,000  per  share,  plus  any 
declared and unpaid dividends, without regard to any undeclared 
dividends. Except in certain limited circumstances, the Series E 
Preferred Stock does not have any voting rights.

In  November  2014,  the  Company  authorized  and  issued 
depositary shares representing ownership interest in 5,000 shares 
of  Perpetual Preferred  Stock,  Series  F,  with  no  par value  and 
$100,000  liquidation  preference  per  share  (the  "Series  F 
Preferred Stock"). The Series F Preferred Stock has no stated 
maturity  and  will  not  be  subject  to  any  sinking  fund  or  other 

 
 
Notes to Consolidated Financial Statements, continued

obligation of the Company to redeem, repurchase, or retire the 
shares.  Dividends  for  the  shares  are  noncumulative  and,  if 
declared, will be payable semi-annually beginning on June 15, 
2015 through December 15, 2019 at a rate per annum of 5.625%, 
and payable quarterly beginning on March 15, 2020 at a rate per 
annum equal to the three-month LIBOR plus 3.86%. By its terms, 
the Company may redeem the Series F Preferred Stock on any 
dividend payment date occurring on or after December 15, 2019 
or at any time within 90 days following a regulatory capital event, 
at a redemption price of $100,000 per share plus any declared 
and unpaid dividends. Except in certain limited circumstances, 
the Series F Preferred Stock does not have any voting rights.

In May 2017, the Company authorized and issued depositary 
shares  representing  ownership  interest  in  7,500  shares  of 
Perpetual  Preferred  Stock,  Series  G,  with  no  par  value  and 
$100,000  liquidation  preference  per  share  (the  "Series  G 
Preferred Stock"). The Series G Preferred Stock has no stated 
maturity  and  will  not  be  subject  to  any  sinking  fund  or  other 
obligation of the Company to redeem, repurchase, or retire the 
shares.  Dividends  for  the  shares  are  noncumulative  and,  if 
declared, will be payable semi-annually beginning on December 
15, 2017 through June 15, 2022 at a rate per annum of 5.05%, 
and payable quarterly beginning on September 15, 2022 at a rate 
per annum equal to the three-month LIBOR plus 3.102%. By its 
terms, the Company may redeem the Series G Preferred Stock 
on  any  dividend  payment  date  occurring  on  or  after  June  15, 
2022 or at any time within 90 days following a regulatory capital 
event,  at  a  redemption  price  of  $100,000  per  share  plus  any 
declared  and  unpaid  dividends.  Except  in  certain  limited 
circumstances, the Series G Preferred Stock does not have any 
voting rights.

In  November  2017,  the  Company  authorized  and  issued 
depositary shares representing ownership interest in 5,000 shares 
of Perpetual Preferred Stock, Series H, with no par value and 
$100,000  liquidation  preference  per  share  (the  "Series  H 
Preferred Stock"). The Series H Preferred Stock has no stated 
maturity  and  will  not  be  subject  to  any  sinking  fund  or  other 
obligation of the Company to redeem, repurchase, or retire the 
shares.  Dividends  for  the  shares  are  noncumulative  and,  if 

declared, will be payable semi-annually beginning on June 15, 
2018 through December 15, 2027 at a rate per annum of 5.125%, 
and payable quarterly beginning on March 15, 2028 at a rate per 
annum  equal  to  the  three-month  LIBOR  plus  2.786%.  By  its 
terms, the Company may redeem the Series H Preferred Stock 
on any dividend payment date occurring on or after December 
15, 2027 or at any time within 90 days following a regulatory 
capital event, at a redemption price of $100,000 per share plus 
any  declared  and  unpaid  dividends.  Except  in  certain  limited 
circumstances, the Series H Preferred Stock does not have any 
voting rights.

In 2008, the Company issued to the U.S. Treasury as part of 
the CPP, 35,000 and 13,500 shares of Series C and D Fixed Rate 
Cumulative Perpetual Preferred Stock, respectively, and Series 
A and B warrants to purchase a total of 17.9 million shares of 
the Company's common stock. The Series A warrants entitle the 
holder to purchase 6 million shares of the Company's common 
stock at an exercise price of $33.70 per share, while the Series 
B warrants entitle the holder to purchase 11.9 million shares of 
the Company's common stock at an exercise price of $44.15 per 
share. 

In March 2011, the Company repurchased its Series C and 
D  Preferred  Stock  from  the  U.S. Treasury,  and  in  September 
2011, the U.S. Treasury held a public auction to sell the Series 
A and B common stock purchase warrants. In conjunction with 
the U.S. Treasury's auction, the Company acquired 4 million of 
the common stock purchase warrants, Series A, for $11 million, 
which were then retired. In January and February of 2016, the 
Company acquired an additional 1.1 million of Series A common 
stock  warrants  and  5.4  million  of  Series  B  common  stock 
warrants as part of its 2015 CCAR capital plan for a total of $24 
million. 

At December 31, 2017, 7.1 million warrants to purchase the 
Company's  common  stock  remained  outstanding  and  the 
Company had authority from its Board to repurchase all of these 
outstanding  stock  purchase  warrants.  The  Series  A  and  B 
warrants have expiration dates of December 2018 and November 
2018, respectively.

117

Notes to Consolidated Financial Statements, continued

NOTE 14 - INCOME TAXES

The components of the Provision for income taxes included in the Consolidated Statements of Income for the years ended December 
31 are presented in the following table:

(Dollars in millions)

Current income tax provision:

Federal

State

Total

Deferred income tax provision/(benefit):

Federal

State

Total

Total provision for income taxes

2017

2016

2015

$129

59

188

275

69

344

$532

$667

27

694

59

52

111

$805

$707

36

743

27

(6)

21

$764

The 2017 Tax Act, enacted on December 22, 2017, reduced the 
U.S. federal corporate income tax rate from 35% to 21% effective 
January 1, 2018. At December 31, 2017, the Company recorded 
a net income tax benefit for the estimated effects of the 2017 Tax 
Act as a component of the provision for income taxes, which 
was  due  primarily  to  a  $333  million  tax  benefit  for  the 
remeasurement of the Company's estimated DTAs and DTLs to 
reflect  the  new  federal  income  tax  rate  of  21%.  However,  as 
additional  information  becomes  available  and  additional 
analysis is completed, the estimate of the DTAs and DTLs may 
change, which could impact the remeasurement of these deferred 
tax  balances.  Any  adjustment  to  the  remeasurement  amount 
would be recorded as an adjustment to the provision for income 

taxes in 2018 in the period the amounts are determined. 

The  provision  for  income  taxes  does  not  reflect  the  tax 
effects  of  unrealized  gains  and  losses  and  other  income  and 
expenses  recorded  in  AOCI,  with  the  exception  of  the 
remeasurement  of  the  related  DTAs  and  DTLs  due  to  the 
enactment  of  the  2017  Tax  Act.  For  additional  information 
see  Note  21,  “Accumulated  Other 
regarding  AOCI, 
Comprehensive Loss.” 

A  reconciliation  of  the  income  tax  provision,  using  the 
statutory federal income tax rate of 35%, to the Company’s actual 
provision for income taxes and the effective tax rate during the 
years ended December 31 are presented in the following table:

(Dollars in millions)

2017

2016

2015

Amount

% of
Pre-Tax 
Income

Amount

% of
Pre-Tax 
Income

Amount

% of
Pre-Tax
Income

Income tax provision at federal statutory rate

$982

35.0%

$939

35.0%

$944

35.0%

Increase/(decrease) resulting from:

State income taxes, net
Tax-exempt interest
Changes in UTBs (including interest), net
Income tax credits, net of amortization 1
Estimated impact of the remeasurement of DTAs and DTLs

and other tax reform-related items 2

66
(90)
26
(117)

2.4
(3.2)
0.9
(4.2)

53
(86)
6
(86)

(303)
(32)
$532

(10.8)
(1.1)
19.0%

—
(21)
$805

2.0
(3.2)
0.2
(3.2)

—

0.9
(3.3)
(1.1)
(2.6)

—

25
(88)
(31)
(69)

—
(17)
$764

Other 3

(0.6)
28.3%
Total provision for income taxes and effective tax rate
1 Excludes income tax benefits of $43 million, $2 million, and $6 million for the years ended December 31, 2017, 2016, and 2015, respectively, related to tax credits, 
which were recognized as a reduction to the related investment asset.
2 Includes reasonable estimates as of December 31, 2017, which could be adjusted as additional analysis is completed in 2018.
3 Includes excess tax benefits of $25 million and $15 million for the years ended December 31, 2017 and 2016, respectively, related to the Company's adoption of 
ASU 2016-09.

(0.8)
30.0%

Deferred income tax assets and liabilities result from differences 
between the timing of the recognition of assets and liabilities for 
financial reporting purposes and for income tax purposes. These 
assets and liabilities are measured using the enacted federal and 
state tax rates expected to apply in the periods in which the DTAs 
or DTLs are expected to be realized. The net deferred income 
tax liability is recorded in Other liabilities in the Consolidated 
Balance Sheets.

118

At December 31, 2017, the Company remeasured its DTAs 
and DTLs using the newly enacted federal income tax rate of 
21%, which is the rate that is expected to apply in the periods in 
which these assets and liabilities are expected to be realized in 
the future. 

 
Notes to Consolidated Financial Statements, continued

The significant DTAs and DTLs at December 31, net of the federal impact for state taxes, are presented in the following table:

(Dollars in millions)
DTAs:

ALLL

Net unrealized losses in AOCI

State NOLs and other carryforwards

Accruals and reserves

Other

Total gross DTAs

Valuation allowance

Total DTAs

DTLs:

Leasing
Servicing rights
Employee compensation and benefits
Deferred income
Goodwill and other intangible assets
Fixed assets
Loans
Other

Total DTLs

Net DTL

  2017 1

  2016 2

$412

302

227

180

17

1,138

(143)

995

459
290
210
193
155
111
104
41
1,563

$639

472

170

343

19

1,643

(80)

1,563

659
370
179
22
233
113
176
43
1,795

($568)

($232)

1 The Company's DTAs and DTLs for December 31, 2017 were calculated using the enacted federal income rate of 21%.
2 The Company's DTAs and DTLs for December 31, 2016 were calculated using the enacted federal income rate of 35%.

The DTAs include state NOLs and other state carryforwards that 
will expire, if not utilized, in varying amounts from 2018 to 2037. 
At December 31, 2017 and 2016, the Company had a valuation 
allowance recorded against its state carryforwards and certain 
state DTAs of $143 million and $80 million, respectively. The 
increase  in  the  valuation  allowance  was  due  primarily  to  an 
increase  in  the  valuation  allowance  recorded  for  STM's  state 
NOLs as well as the reduction in the federal benefit of the state 
valuation allowance due to the reduction in the federal income 
tax rate. A valuation allowance is not required for the federal and 
the remaining state DTAs because the Company believes it is 
more-likely-than-not that these assets will be realized. 

The following table provides a rollforward of the Company's 
gross federal and state UTBs, excluding interest and penalties, 
during the years ended December 31:

(Dollars in millions)

Balance at January 1

2017

2016

$111

$100

Increases in UTBs related to prior years

Decreases in UTBs related to prior years

Increases in UTBs related to the current year

Decreases in UTBs related to settlements

Balance at December 31

22

(5)

13

—

$141

18

(4)

13

(16)

$111

The amount of UTBs that would favorably affect the Company's 
effective  tax  rate,  if  recognized,  was  $112  million  at 
December 31, 2017.

Interest and penalties related to UTBs are recorded in the 
Provision for income taxes in the Consolidated Statements of 
Income. The Company had a gross liability of $17 million and 
$8  million  for  interest  and  penalties  related  to  its  UTBs  at 
December  31,  2017  and  2016,  respectively.  During  the  years 
ended December 31, 2017 and 2016, the Company recognized 
a gross expense of $10 million and a gross benefit of less than 
$1 million, respectively, related to interest and penalties on the 
UTBs. 

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. 
With limited exceptions, the Company is no longer subject to 
examination by state and local taxing authorities for taxable years 
prior to 2012. It is reasonably possible that the liability for UTBs 
could decrease by as much as $30 million during the next 12 
months due to completion of tax authority examinations and the 
expiration of statutes of limitations. It is uncertain how much, if 
any,  of  this  potential  decrease  will  impact  the  Company’s 
effective tax rate.

119

Notes to Consolidated Financial Statements, continued

NOTE 15 - EMPLOYEE BENEFIT PLANS 

The  Company  sponsors  various  compensation  and  benefit 
programs  to  attract  and  retain  talent. Aligned  with  a  pay  for 
performance culture, the Company's plans and programs include 
short-term incentives, AIP, and various LTI plans. All incentive 
awards  are  subject  to  clawback  provisions.  Compensation 
expense  for AIP  and  LTI  plans  with  cash  payouts  was  $319 
million,  $291  million,  and  $245  million  for  the  years  ended 
December  31,  2017,  2016,  and  2015, 
respectively. 
Compensation expense for short-term incentive plans with cash 
payouts was $476 million, $469 million, and $448 million for 
the  years  ended  December  31,  2017,  2016,  and  2015, 
respectively.

Stock-Based Compensation
The Company provides stock-based awards through the 2009 
Stock Plan and various other deferred compensation plans under 
which the Compensation Committee of the Board of Directors 
has the authority to grant stock options, stock appreciation rights, 
restricted  stock,  phantom  stock  units,  and  RSUs  to  key 
employees of the Company. Award vesting may be conditional 
based  upon  individual,  business  unit,  Company,  and/or 
performance relative to peer group metrics.

Effective  January  1,  2014,  following  approval  by  the 
Compensation Committee of the Board, shareholders approved 
an amendment to the 2009 Stock Plan to remove the sub-limit 
on shares available for grant that may be issued as restricted stock 
or  RSUs.  Accordingly,  all  17  million  remaining  authorized 
shares  previously  under  the  Stock  Plan  became  available  for 

grant as stock options, stock appreciation rights, restricted stock, 
or RSUs. Prior to the amendment, only a portion of such shares 
were available to be granted as either restricted stock or RSUs. 
At December 31, 2017, approximately 16 million shares were 
available for grant. All stock option grants are exercisable for 10 
years after the grant date.

Shares  or  units  of  restricted  stock  may  be  granted  to 
employees and directors. Generally, grants to employees either 
cliff vest after three years or vest pro-rata annually over three 
years. Restricted stock and RSU grants may be subject to one or 
more  criteria,  including  employment,  performance,  or  other 
conditions as established by the Compensation Committee at the 
time of grant. Any shares of restricted stock that are forfeited 
will again become available for issuance under the Stock Plan. 
An  employee  or  director  has  the  right  to  vote  the  shares  of 
restricted stock after grant until they are forfeited. Compensation 
cost for restricted stock and RSUs is generally equal to the fair 
market value of the shares on the grant date of the award and is 
amortized  over  the  vesting  period.  Dividends  are  paid  on 
awarded, unvested restricted stock. The Company accrues and 
reinvests dividends in equivalent shares of SunTrust common 
stock for unvested RSU awards, which are paid out when the 
underlying  RSU  award  vests.  RSU  awards  are  generally 
classified as equity.

Consistent with the Company's 2014 decision to discontinue 
the  issuance  of  stock  options,  no  stock  options  were  granted 
during the years ended December 31, 2017, 2016, and 2015. 

The following table presents a summary of stock options, restricted stock, and RSU activity for the year ended December 31, 2017:

Stock Options

Restricted Stock

RSUs

(Dollars in millions, except per share
data)

Shares

Price
Range

Weighted
Average
Exercise
Price

Balance, January 1, 2017

3,253,793

$9.06 - 85.34

$42.54

Granted

—

—

Exercised/distributed

(830,383)

9.06 - 64.58

Cancelled/expired/forfeited

(764,105)

56.34 - 85.34

Balance, December 31, 2017

1,659,305

$9.06 - 64.58

Exercisable, December 31, 2017

1,659,305

—

25.38

81.77

$35.33

$35.33

Deferred
Compensation

Weighted
Average
Grant
Price

Weighted
Average
Grant
Price

Shares

$—

$42.44

4,175,809

$36.27

1

—

—

$1

57.19

42.44

—

1,901,144

(1,703,795)

(219,439)

59.95

36.62

44.32

$57.19

4,153,719

$44.68

Shares

11,312

8,744

(11,312)

—

8,744

120

Notes to Consolidated Financial Statements, continued

The following table presents stock option information at December 31, 2017:

Options Outstanding

Options Exercisable

(Dollars in millions,
except per share
data)

Number
Outstanding 
at 
December 31, 
2017

Weighted
Average
Exercise
Price

Weighted
Average
Remaining
Contractual
Life (Years)

Total
Aggregate
Intrinsic
Value

Number
Exercisable 
at
December 31, 
2017

Weighted
Average
Exercise
Price

Weighted
Average
Remaining
Contractual
Life (Years)

Total
Aggregate
Intrinsic
Value

Range of Exercise Prices:

$9.06 to 49.46

$64.58

$9.06 to 64.58

1,170,605

488,700

1,659,305

$23.12

64.58

$35.33

3.42

0.12

2.45

$48,545

5

$48,550

1,170,605

488,700

1,659,305

$23.12

64.58

$35.33

3.42

0.12

2.45

$48,545

5

$48,550

Stock-based 

in 
Employee  compensation  in  the  Consolidated  Statements  of 
Income consisted of the following:

compensation 

recognized 

expense 

(Dollars in millions)

RSUs
Phantom stock units 1
Restricted stock

Years Ended December 31

2017

2016

2015

$83

$56

$46

77

—

—

67

2

—

32

16

1

Total stock-based compensation

expense

$160

$125

$95

Stock-based compensation tax 

benefit 2

$61

$48

$36

1 Phantom stock units are settled in cash. The Company paid $80 million, $28 
million, and $16 million during the years ended December 31, 2017, 2016, and 
2015, respectively, related to these share-based liabilities.
2 Does not include excess tax benefits or deficiencies recognized in the Provision 
for income taxes in the Consolidated Statements of Income.

Retirement Plans

frozen, 

various 

Noncontributory Pension Plans
funded, 
The  Company  maintains 
noncontributory qualified retirement plans ("Retirement Plans") 
covering employees meeting certain service requirements. The 
Retirement Plans provide benefits based on salary and years of 
service. The SunTrust Retirement Plan includes a cash balance 
formula where the PPAs continue to be credited with interest 
each year. The interest crediting rate applied to each PPA was 
3.11% for 2017. The Company monitors the funded status of the 
Retirement Plans closely and, due to the current funded status, 
the Company did not make a contribution to them for the 2017
plan year. 

The aggregate intrinsic value in the preceding table represents 
the  total  pre-tax  intrinsic  value  (the  difference  between  the 
Company’s closing stock price on the last trading day of 2017 
and the exercise price, multiplied by the number of in-the-money 
stock  options)  that  would  have  been  received  by  the  option 
holders  had  all  option  holders  exercised  their  options  on 
December 31,  2017.  Additional  option  and  stock-based 
compensation information at December 31 is presented in the 
following table:

(Dollars in millions)
Intrinsic value of options exercised 1
Fair value of vested restricted shares 1
Fair value of vested RSUs 1
1 Measured as of the grant date.

2017

2016

2015

Stock options

$28

—

62

$43

41

74

$15

35

23

respectively, 

At December 31, 2017 and 2016, there was $75 million and $65 
million, 
stock-based 
compensation expense related to stock options, restricted stock, 
and RSUs. The unrecognized stock compensation expense for 
December 31, 2017 is expected to be recognized over a weighted 
average period of 2.0 years.

unrecognized 

of 

Additionally,  the  Company  allows  for  the  granting  of 
phantom stock units, whereby certain employees are granted the 
contractual right to receive an amount in cash equal to the fair 
market value of a share of common stock on the vesting date. 
These  shares  vest  pro-rata  annually  over  three  years  on  the 
anniversary  of  the  grant  date  and  are  subject  to  variable 
accounting. The employees are entitled to dividend-equivalent 
rights on the granted shares. The Company granted less than 1 
million, 2 million, and 1 million phantom stock units during the 
years ended December 31, 2017, 2016, and 2015, respectively. 
The  unrecognized  compensation  expense  related  to  these 
phantom stock units as of December 31, 2017 was $56 million 
based on the Company's stock price as of that date. 

121

Notes to Consolidated Financial Statements, continued

The  Company  also  maintains  various  frozen,  unfunded, 
noncontributory  nonqualified  supplemental  defined  benefit 
pension plans that cover key executives of the Company (the 
"SERP", the "ERISA Excess Plan", and the "Restoration Plan"). 
These plans provide defined benefits based on years of service 
and salary.

Other Postretirement Benefits
The  Company  provides  certain  health  care  and  life  insurance 
benefits (“Other Postretirement Benefits”) to retired employees. 
At  the  option  of  the  Company,  retirees  may  continue  certain 
health and life insurance benefits if they meet specific age and 
service requirements at the time of retirement. The health care 
plans  are  contributory  with  participant  contributions  adjusted 
annually,  and  the  life  insurance  plans  are  noncontributory. 

Certain  retiree  health  benefits  are  funded  in  a  Retiree  Health 
Trust. Additionally,  certain  retiree  life  insurance  benefits  are 
funded  in  a  VEBA.  Effective  April  1,  2014,  the  Company 
amended the plan, which now requires retirees age 65 and older 
to enroll in individual Medicare supplemental plans. In addition, 
the Company will fund a tax-advantaged HRA to assist some 
retirees with medical expenses.

Changes in Benefit Obligations and Plan Assets

The following table presents the change in benefit obligations, 
change in fair value of plan assets, funded status, accumulated 
benefit obligation, and the weighted average discount rate related 
to the Company's pension and other postretirement benefits plans 
for the years ended December 31:

(Dollars in millions)
Benefit obligation, beginning of year

Service cost
Interest cost
Plan participants’ contributions
Actuarial loss/(gain)
Benefits paid
Administrative expenses paid from pension trust
Plan amendments
Special termination benefits
Benefit obligation, end of year 2

Change in plan assets:

Fair value of plan assets, beginning of year
Actual return on plan assets
Employer contributions 3
Plan participants’ contributions
Benefits paid
Administrative expenses paid from pension trust

Fair value of plan assets, end of year 4

Funded status at end of year 5, 6
Funded status at end of year (%)

Pension Benefits 1

Other Postretirement Benefits

2017

2016

2017

2016

$2,747
5
95
—
225
(156)
(6)
—
—

$2,910

$3,016
425
9
—
(156)
(6)
$3,288

$2,716
5
97
—
76
(142)
(5)
—
—

$2,747

$2,879
279
5
—
(142)
(5)
$3,016

$378
113%

$269
110%

$58
—
1
4
(1)
(8)
—
(5)
9

$58

$157
11
—
4
(8)
—
$164

$106

$65
—
2
4
(4)
(9)
—
—
—

$58

$156
5
—
5
(9)
—
$157

$99

Accumulated benefit obligation

$2,910

$2,747

3.62%

Discount rate
3.70%
1 Employer contributions represent the benefits that were paid to nonqualified plan participants. Unfunded nonqualified supplemental pension plans are not funded 
through plan assets.
2 Includes $78 million and $80 million of benefit obligations for the unfunded nonqualified supplemental pension plans at December 31, 2017 and 2016, respectively.
3 The Company contributed less than $1 million to the other postretirement benefits plans during both 2017 and 2016.
4 Includes $1 million and $2 million of the Company's common stock acquired by the asset manager and held as part of the equity portfolio for pension benefits at 
December 31, 2017 and 2016, respectively. During both 2017 and 2016, there was no SunTrust common stock held in the other postretirement benefit plans.
5 Pension benefits recorded in the Consolidated Balance Sheets included other assets of $456 million and $349 million, and other liabilities of $78 million and $80 
million, at December 31, 2017 and 2016, respectively.
6 Other postretirement benefits recorded in the Consolidated Balance Sheets included other assets of $106 million and $99 million at December 31, 2017 and 2016, 
respectively.

4.18%

3.29%

122

Notes to Consolidated Financial Statements, continued

Net Periodic Benefit
Components of net periodic benefit related to the Company's pension and other postretirement benefits plans for the years ended 
December 31 are presented in the following table and are recognized in Employee benefits in the Consolidated Statements of Income: 

(Dollars in millions)
Service cost
Interest cost
Expected return on plan assets
Amortization of prior service credit
Amortization of actuarial loss
Other

Net periodic benefit

Pension Benefits 1
2016
$5
97
(186)
—
25
—
($59)

2017
$5
95
(195)
—
25
—
($70)

2015
$5
116
(206)
—
21
—
($64)

Other Postretirement Benefits

2017
$—
1
(5)
(6)
—
9
($1)

2016
$—
2
(5)
(6)
—
—
($9)

2015
$—
2
(5)
(6)
—
—
($9)

Weighted average assumptions used to determine net periodic benefit:

Discount rate
Expected return on plan assets

4.18%
6.66

4.44%
6.68

4.09%
6.91

3.70%
3.12

3.95%
3.13

3.60%
3.50

1 Administrative fees are recognized in service cost for each of the periods presented.

In the second quarter of 2017, the Company amended its NCF 
Retirement Plan in accordance with its decision to terminate the 
pension plan effective as of July 31, 2017. The NCF pension plan 
termination is expected to be completed by the end of 2018 and 
the  Company  is  in  process  of  evaluating  the  impact  of  the 
termination  and  expected  future  settlement  accounting  on  its 
Consolidated Financial Statements and related disclosures. 

Amounts Recognized in AOCI
Components  of  the  benefit  obligations  AOCI  balance  at 
December 31 were as follows:

Pension Benefits

Other 
Postretirement
Benefits    

(Dollars in millions)

2017

2016

2017

2016

Prior service credit

Net actuarial loss/(gain)
Total AOCI, pre-tax

$—

1,001

$—

1,031

$1,001

$1,031

($58)

(22)

($80)

($59)

(15)

($74)

Other changes in plan assets and benefit obligations recognized 
in AOCI during 2017 were as follows:

(Dollars in millions)

Current year prior service credit

Current year actuarial gain

Amortization of prior service credit

Amortization of actuarial loss

Total recognized in AOCI, pre-tax
Total recognized in net periodic
benefit and AOCI, pre-tax

Pension
Benefits
$—
(5)

—

(25)

($30)

($100)

Other
Postretirement
Benefits

($5)
(7)

6

—

($6)

($7)

For  pension  plans,  the  estimated  actuarial  loss  that  will  be 
amortized from AOCI into net periodic benefit in 2018 is $23 
million.  For  other  postretirement  benefit  plans,  the  estimated 
prior service credit and actuarial gain to be amortized from AOCI 
into net periodic benefit in 2018 is $7 million. The amortization 

for net gains and losses reflects a corridor based on 10% of the 
greater of the projected benefit obligation or the market-related 
value of assets. The amount of net gains and losses that exceeds 
the corridor is amortized over a fixed period based on the average 
remaining lifetime.

Plan Assumptions
Each year, the SBFC, which includes several members of senior 
management, reviews and approves the assumptions used in the 
year-end measurement calculations for each plan. The discount 
rate for each plan, used to determine the present value of future 
benefit obligations, is determined by matching the expected cash 
flows  of  each  plan  to  a  yield  curve  based  on  long-term,  high 
quality  fixed  income  debt  instruments  available  as  of  the 
measurement date. A series of benefit payments projected to be 
paid by the plan is developed based on the most recent census 
data, plan provisions, and assumptions. The benefit payments at 
each future maturity date are discounted by the year-appropriate 
spot interest rates. The model then solves for the discount rate 
that  produces  the  same  present  value  of  the  projected  benefit 
payments as generated by discounting each year’s payments by 
the spot interest rate.

The Company utilizes a full yield curve approach to estimate 
the service and interest cost components of net periodic benefit 
expense for pension and other postretirement benefit plans by 
applying  specific  spot  rates  along  the  yield  curve  used  in  the 
determination of the benefit obligation to the relevant projected 
cash flows.

Actuarial  gains  and  losses  are  created  when  actual 
experience  deviates  from  assumptions.  The  actuarial  gains 
during 2017 and 2016 for the pension plans resulted primarily 
from  asset  experience,  partially  offset  by  losses  due  to  the 
decrease in discount rates. 

The SBFC establishes investment policies and strategies and 
formally  monitors 
investments 
the  performance  of 
throughout the year. The Company’s investment strategy with 
respect to pension assets is to invest the assets in accordance with 
ERISA and related fiduciary standards. The long-term primary 
investment  objectives  for  the  pension  plans  are  to  provide  a 

the 

123

 
Notes to Consolidated Financial Statements, continued

commensurate  amount  of  long-term  growth  of  principal  and 
income in order to satisfy the pension plan obligations without 
undue exposure to risk in any single asset class or investment 
category. The objectives are accomplished through investments 
in equities, fixed income, and cash equivalents using a mix that 
is conducive to participation in a rising market while allowing 
for protection in a declining market. The portfolio is viewed as 
long-term in its entirety, avoiding decisions regarding short-term 
concerns and any single investment. Asset allocation, as a percent 
of the total market value of the total portfolio, is set with the 
target percentages and ranges presented in the investment policy 
statement. Rebalancing occurs on a periodic basis to maintain 
the target allocation, but normal market activity may result in 
deviations.

The basis for determining the overall expected long-term 
rate of return on plan assets considers past experience, current 
market conditions, and expectations on future trends. A building 

block approach is used that considers long-term inflation, real 
returns, equity risk premiums, target asset allocations, market 
corrections, and expenses. Capital market simulations, survey 
data, economic forecasts, and actuarial judgment are all used in 
this process. The expected long-term rate of return for pension 
obligations is 5.90% for 2018.

The investment strategy for the other postretirement benefit 
plans is maintained separately from the strategy for the pension 
plans. The Company’s investment strategy is to create a series 
of  investment  returns  sufficient  to  provide  a  commensurate 
amount of long-term principal and income growth in order to 
satisfy the other postretirement benefit plan's obligations. Assets 
are diversified among equity funds and fixed income investments 
according  to  the  mix  approved  by  the  SBFC.  Due  to  other 
postretirement benefits having a shorter time horizon, a lower 
equity  profile  is  appropriate.  The  expected  long-term  rate  of 
return for other postretirement benefits is 3.10% for 2018.

Plan Assets Measured at Fair Value
The following tables present combined pension and other postretirement benefit plan assets measured at fair value. See Note 18, 
"Fair Value Election and Measurement" for level definitions within the fair value hierarchy.

(Dollars in millions)
Money market funds 2
Equity securities
Mutual funds 3:

Equity index fund
Tax exempt municipal bond funds
Taxable fixed income index funds

Futures contracts
Fixed income securities
Other assets

Total plan assets

Total

Fair Value Measurements at December 31, 2017 1
Level 3
Level 2
Level 1

$138
936

56
85
12
(5)
2,201
9
$3,432

$138
936

56
85
12
(5)
512
9
$1,743

$—
—

—
—
—
—
1,689
—
$1,689

1 Fair value measurements do not include pension benefits accrued income amounting to less than 0.7% of total plan assets.
2 Includes $11 million for other postretirement benefit plans.
3 Relates exclusively to other postretirement benefit plans.

(Dollars in millions)
Money market funds 2
Equity securities
Mutual funds 3:

Equity index fund
Tax exempt municipal bond funds
Taxable fixed income index funds

Futures contracts
Fixed income securities
Other assets

Total plan assets

Total

Fair Value Measurements at December 31, 2016 1
Level 3
Level 2
Level 1

$112
1,415

47
82
13
(5)
1,486
6
$3,156

$112
1,415

47
82
13
—
—
6
$1,675

$—
—

—
—
—
(5)
1,486
—
$1,481

1 Fair value measurements do not include pension benefits accrued income amounting to less than 0.6% of total plan assets.
2 Includes $16 million for other postretirement benefit plans.
3 Relates exclusively to other postretirement benefit plans.

$—
—

—
—
—
—
—
—
$—

$—
—

—
—
—
—
—
—
$—

124

Notes to Consolidated Financial Statements, continued

Target allocations for pension and other postretirement benefits at December 31, by asset category, are presented below:

Cash equivalents
Equity securities
Debt securities

Total

Pension Benefits

Other Postretirement Benefits

2017 Target
Allocation

% of plan assets
2017
2016

2017 Target
Allocation

% of plan assets
2017
2016

0-10 %
0-40
40-100

4%
29
67
100%

3%
47
50
100%

5-15 %
20-40
50-70

7%
34
59
100%

10%
30
60
100%

The Company sets pension asset values equal to their market 
value,  reflecting  gains  and  losses  immediately  rather  than 
deferring over a period of years, which provides a more realistic 
economic measure of the plan’s funded status and cost. Assumed 
healthcare  cost  trend  rates  have  a  significant  effect  on  the 
amounts reported for the other postretirement benefit plans. At 
December 31, 2017, the Company assumed that pre-65 retiree 
healthcare costs will increase at an initial rate of 8.25% per year. 
The Company expects this annual cost increase to decrease over 
an 8-year period to 4.50% per year. The effect of a 1% increase/

decrease in the healthcare cost trend rate for other postretirement 
benefit obligations, service cost, and interest cost are less than 
$1 million, respectively. Assumed discount rates and expected 
returns on plan assets affect the amounts of net periodic benefit. 
A  25  basis  point  increase/decrease  in  the  expected  long-term 
return on plan assets would increase/decrease the net periodic 
benefit  by  $8  million  for  pension  and  other  postretirement 
benefits plans. A 25 basis point increase/decrease in the discount 
rate  would  change  the  net  periodic  benefit  by  $1  million  for 
pension and other postretirement benefits plans.

Expected Cash Flows
Expected cash flows for the pension and other postretirement benefit plans are presented in the following table:

(Dollars in millions)
Employer Contributions:
2018 (expected) to plan trusts
2018 (expected) to plan participants 3

Pension Benefits 1

Other Postretirement Benefits 
(excluding Medicare Subsidy) 2

$—
9

Expected Benefit Payments:
2018
2019
2020
2021
2022
2023 - 2027
1 Based on the funding status and ERISA limitations, the Company anticipates contributions to the Retirement Plan will not be required during 2018.
2 Expected payments under other postretirement benefit plans are shown net of participant contributions.
3 The expected benefit payments for the SERP will be paid directly from the Company's corporate assets.

210
172
172
170
167
824

$—
—

7
6
6
6
5
18

Defined Contribution Plans
SunTrust's  employee  benefit  program  includes  a  qualified 
defined contribution plan. For years ended December 31, 2017, 
2016,  and  2015,  the  401(k)  plan  provided  a  dollar-for-dollar 
match on the first 6% of eligible pay that a participant, including 
executive participants, elected to defer. 

SunTrust also maintains the SunTrust Banks, Inc. Deferred 
Compensation Plan in which key executives of the Company are 
eligible. Matching contributions for the deferred compensation 
plan  are  the  same  percentage  as  provided  in  the  401(k)  plan, 
subject  to  limitations  imposed  by  the  plans'  provisions  and 

applicable laws and regulations. Matching contributions for both 
the Company's 401(k) plan and the deferred compensation plan 
fully vest upon two years of completed service. Furthermore, 
both  plans  permit  an  additional  discretionary  Company 
contribution equal to a fixed percentage of eligible pay. 

The Company's 401(k) expense, including any discretionary 
contributions, was $130 million, $105 million, and $121 million
for  the  years  ended  December  31,  2017,  2016,  and  2015, 
respectively.

125

Notes to Consolidated Financial Statements, continued

NOTE 16 – GUARANTEES

The Company has undertaken certain guarantee obligations in 
the  ordinary  course  of  business.  The  issuance  of  a  guarantee 
imposes an obligation for the Company to stand ready to perform 
and make future payments should certain triggering events occur. 
Payments may be in the form of cash, financial instruments, other 
assets, shares of stock, or through provision of the Company’s 
services. The following is a discussion of the guarantees that the 
Company has issued at December 31, 2017. The Company has 
also entered into certain contracts that are similar to guarantees, 
but that are accounted for as derivative instruments as discussed 
in Note 17, “Derivative Financial Instruments.”

Letters of Credit
Letters  of  credit  are  conditional  commitments  issued  by  the 
Company, generally to guarantee the performance of a client to 
a  third  party  in  borrowing  arrangements,  such  as  CP,  bond 
financing,  or  similar  transactions. The  credit  risk  involved  in 
issuing letters of credit is essentially the same as that involved 
in  extending  loan  facilities  to  clients  but  may  be  reduced  by 
selling participations to third parties. The Company issues letters 
of  credit  that  are  classified  as  financial  standby,  performance 
standby, or commercial letters of credit; however, commercial 
letters of credit are considered guarantees of funding and are not 
subject to the disclosure requirements of guarantee obligations.
At December 31, 2017 and 2016, the maximum potential 
exposure to loss related to the Company's issued letters of credit 
was $2.6 billion and $2.9 billion, respectively. The Company’s 
outstanding letters of credit generally have a term of more than 
one year. Some standby letters of credit are designed to be drawn 
upon in the normal course of business and others are drawn upon 
only  in  circumstances  of  dispute  or  default  in  the  underlying 
transaction to which the Company is not a party. In all cases, the 
Company is entitled to reimbursement from the client. If a letter 
of credit is drawn upon and reimbursement is not provided by 
the client, the Company may take possession of the collateral 
securing the letter of credit, where applicable.

The Company monitors its credit exposure under standby 
letters  of  credit  in  the  same  manner  as  it  monitors  other 
extensions  of  credit  in  accordance  with  its  credit  policies. 
Consistent  with  the  methodologies  used  for  all  commercial 
borrowers, an internal assessment of the PD and loss severity in 
the event of default is performed. The management of credit risk 
for  letters  of  credit  leverages  the  risk  rating  process  to  focus 
greater visibility on higher risk and higher dollar letters of credit. 
The allowance associated with letters of credit is a component 
of  the  unfunded  commitments  reserve  recorded  in  Other 
liabilities on the Consolidated Balance Sheets and is included in 
the allowance for credit losses as disclosed in Note 7, “Allowance 
for Credit Losses.” Additionally, unearned fees relating to letters 
of credit are recorded in Other liabilities on the Consolidated 
Balance Sheets. The net carrying amount of unearned fees was 
immaterial at both December 31, 2017 and 2016.

Loan Sales and Servicing
STM, a consolidated subsidiary of the Company, originates and 
purchases residential mortgage loans, a portion of which are sold 
to outside investors in the normal course of business through a 
combination of whole loan sales to GSEs, Ginnie Mae, and non-

126

agency investors. The Company also originates and sells certain 
commercial mortgage loans to Fannie Mae and Freddie Mac, 
originates FHA insured loans, and issues and sells Ginnie Mae
commercial MBS secured by FHA insured loans.

When  loans  are  sold,  representations  and  warranties 
regarding certain attributes of the loans are made to third party 
purchasers. Subsequent to the sale, if a material underwriting 
deficiency or documentation defect is discovered, the Company 
may  be  obligated  to  repurchase  the  loan  or  to  reimburse  an 
investor  for  losses  incurred  (make  whole  requests),  if  such 
deficiency or defect cannot be cured by the Company within the 
specified period following discovery. These representations and 
warranties may extend through the life of the loan. In addition 
to  representations  and  warranties  related  to  loan  sales,  the 
Company  makes  representations  and  warranties  that  it  will 
service  the  loans  in  accordance  with  investor  servicing 
guidelines and standards, which may include (i) collection and 
remittance of principal and interest, (ii) administration of escrow 
for taxes and insurance, (iii) advancing principal, interest, taxes, 
insurance, and collection expenses on delinquent accounts, and 
(iv) loss mitigation strategies, including loan modifications and 
foreclosures. 

The  following  table  summarizes  the  changes  in  the 
Company’s reserve for residential mortgage loan repurchases for 
the years ended December 31:

(Dollars in millions)

2017

2016

2015

Balance, beginning of period

Repurchase provision/(benefit)

Charge-offs, net of recoveries

Balance, end of period

$40

—

(1)

$39

$57

(17)

—

$40

$85

(12)

(16)

$57

A significant degree of judgment is used to estimate the mortgage 
repurchase  liability  as  the  estimation  process  is  inherently 
uncertain and subject to imprecision. The Company believes that 
its reserve appropriately estimates incurred losses based on its 
current  analysis  and  assumptions.  While 
the  mortgage 
repurchase reserve includes the estimated cost of settling claims 
related to required repurchases, the Company's estimate of losses 
its  assumptions  regarding  GSE  and  other 
depends  on 
counterparty behavior, loan performance, home prices, and other 
factors.  The  liability  is  recorded  in  Other  liabilities  on  the 
Consolidated  Balance  Sheets,  and  the  related  repurchase 
provision/(benefit) is recognized in Mortgage production related 
income in the Consolidated Statements of Income. See Note 19, 
"Contingencies,"  for  additional  information  on  current  legal 
matters related to loan sales.

The following table summarizes the carrying value of the 
Company's outstanding repurchased residential mortgage loans 
at December 31:

(Dollars in millions)

2017

2016

Outstanding repurchased residential mortgage loans:

Performing LHFI

Nonperforming LHFI

Total carrying value of outstanding

repurchased residential mortgages

$203

16

$219

$230

12

$242

Notes to Consolidated Financial Statements, continued

Residential mortgage loans sold to Ginnie Mae are insured by 
the FHA or are guaranteed by the VA. As servicer, the Company 
may  elect  to  repurchase  delinquent  loans  in  accordance  with 
Ginnie  Mae  guidelines;  however,  the  loans  continue  to  be 
insured. The Company may also indemnify the FHA and VA for 
losses related to loans not originated in accordance with their 
guidelines.

Commercial Mortgage Loan Loss Share Guarantee
In connection with the December 2016 acquisition of Pillar, the 
Company assumed a loss share obligation associated with the 
terms of a master loss sharing agreement with Fannie Mae for 
multi-family commercial mortgage loans that were sold by Pillar 
to Fannie Mae under Fannie Mae’s delegated underwriting and 
servicing program. Upon the acquisition of Pillar, the Company 
entered into a lender contract amendment with Fannie Mae for 
multi-family  commercial  mortgage  loans  that  Pillar  sold  to 
Fannie Mae prior to acquisition and that the Company sold to 
Fannie Mae subsequent to acquisition, whereby the Company 
bears  a  risk  of  loss  of  up  to  one-third  of  the  incurred  losses 
resulting  from  borrower  defaults.  The  breach  of  any 
representation or warranty related to a loan sold to Fannie Mae 
could increase the Company's level of risk-sharing associated 
with the loan. The outstanding UPB of loans sold subject to the 
loss  share  guarantee  was  $3.4  billion  and  $2.9  billion  at 
December  31,  2017  and  2016,  respectively.  The  maximum 
potential exposure to loss was $962 million and $787 million at 
December 31, 2017 and 2016, respectively. Using probability of 
default and severity of loss estimates, the Company's loss share 
liability was $11 million and $6 million at December 31, 2017 
and 2016, respectively, and is recorded in Other liabilities on the 
Consolidated Balance Sheets.

Visa
The  Company  executes  credit  and  debit  transactions  through 
Visa and MasterCard. The Company is a defendant, along with 
Visa  and  MasterCard  (the  “Card  Associations”),  as  well  as 
several  other  banks,  in  one  of  several  antitrust  lawsuits 
challenging  the  practices  of  the  Card  Associations  (the 
“Litigation”).  The  Company  entered  into  judgment  and  loss 
sharing agreements with Visa and certain other banks in order 
to apportion financial responsibilities arising from any potential 
adverse  judgment  or  negotiated  settlements  related  to  the 
Litigation. Additionally, in connection with Visa's restructuring 
in 2007, shares of Visa common stock were issued to its financial 
institution members and the Company received its proportionate 
number  of  shares  of  Visa  Inc.  common  stock,  which  were 
subsequently  converted  to  Class  B  shares  of  Visa  Inc.  upon 
completion of Visa’s IPO in 2008. A provision of the original 
Visa  By-Laws,  which  was  restated  in  Visa's  certificate  of 
incorporation,  contains  a  general  indemnification  provision 
between a Visa member and Visa that explicitly provides that 
each  member's  indemnification  obligation  is  limited  to  losses 
arising  from  its  own  conduct  and  the  specifically  defined 
Litigation.  While  the  district  court  approved  a  class  action 
settlement of the Litigation in 2012, the U.S. Court of Appeals 
for the Second Circuit reversed the district court's approval of 
the settlement on June 30, 2016. The U.S. Supreme Court denied 
plaintiffs' petition for certiorari on March 27, 2017, and the case 
returned to the district court for further action. 

Agreements associated with Visa's IPO have provisions that 
Visa will fund a litigation escrow account, established for the 
purpose  of  funding  judgments  in,  or  settlements  of,  the 
Litigation. If  the  escrow  account  is  insufficient  to  cover  the 
Litigation losses, then Visa will issue additional Class A shares
(“loss shares”). The proceeds from the sale of the loss shares 
would then be deposited in the escrow account. The issuance of 
the loss shares will cause a dilution of Visa's Class B shares as 
a result of an adjustment to lower the conversion factor of the 
Class  B  shares  to  Class A  shares. Visa  U.S.A.'s  members  are 
responsible  for  any  portion  of  the  settlement  or  loss  on  the 
Litigation after the escrow account is depleted and the value of 
the Class B shares is fully diluted.

the  derivative, 

In  May  2009,  the  Company  sold  its  3.2  million  Class  B 
shares to the Visa Counterparty and entered into a derivative with 
the  Visa  Counterparty.  Under 
the  Visa 
Counterparty is compensated by the Company for any decline 
in  the  conversion  factor  as  a  result  of  the  outcome  of  the 
Litigation. Conversely, the Company is compensated by the Visa 
Counterparty  for  any  increase  in  the  conversion  factor.  The 
amount of payments made or received under the derivative is a 
function of the 3.2 million shares sold to the Visa Counterparty, 
the change in conversion rate, and Visa’s share price. The Visa 
Counterparty, as a result of its ownership of the Class B shares, 
is impacted by dilutive adjustments to the conversion factor of 
the Class B shares caused by the Litigation losses. Additionally, 
the Company will make periodic payments based on the notional 
of  the  derivative  and  a  fixed  rate  until  the  date  on  which  the 
Litigation is settled. The fair value of the derivative is estimated 
based  on  unobservable  inputs  consisting  of  management's 
estimate of the probability of certain litigation scenarios and the 
timing of the resolution of the Litigation due in large part to the 
aforementioned decision by the U.S. Court of Appeals for the 
Second Circuit. The fair value of the derivative liability was $15 
million at both December 31, 2017 and 2016. The fair value of 
the derivative is estimated based on the Company's expectations 
regarding the resolution of the Litigation. The ultimate impact 
to  the  Company  could  be  significantly  different  based  on  the 
Litigation outcome.

Public Deposits
The Company holds public deposits from various states in which 
it  does  business.  Individual  state  laws  require  banks  to 
collateralize public deposits, typically as a percentage of their 
public deposit balance in excess of FDIC insurance and may also 
require  a  cross-guarantee  among  all  banks  holding  public 
deposits of the individual state. The amount of collateral required 
varies  by  state  and  may  also  vary  by  bank  within  each  state, 
depending  on  the  individual  state's  risk  assessment  of  each 
participating bank. Certain of the states in which the Company 
holds public deposits use a pooled collateral method, whereby 
in  the  event  of  default  of  a  bank  holding  public  deposits,  the 
collateral  of  the  defaulting  bank  is  liquidated  to  the  extent 
necessary to recover the loss of public deposits of the defaulting 
bank. To the extent the collateral is insufficient, the remaining 
public  deposit  balances  of  the  defaulting  bank  are  recovered 
through an assessment of the other banks holding public deposits 
in that state. The maximum potential amount of future payments 
the Company could be required to make is dependent on a variety 
of factors, including the amount of public funds held by banks 

127

Notes to Consolidated Financial Statements, continued

in the states in which the Company also holds public deposits 
and  the  amount  of  collateral  coverage  associated  with  any 
defaulting bank. Individual states appear to be monitoring this 
risk  and  evaluating  collateral  requirements;  therefore,  the 
likelihood that the Company would have to perform under this 
guarantee  is  dependent  on  whether  any  banks  holding  public 
funds default as well as the adequacy of collateral coverage.

and 

provides 

agreements 

Other
In  the  normal  course  of  business,  the  Company  enters  into 
indemnification 
standard 
representations  and  warranties  in  connection  with  numerous 
transactions.  These  transactions  include  those  arising  from 
securitization activities, underwriting agreements, merger and 
acquisition agreements, swap clearing agreements, loan sales, 
contractual  commitments,  payment  processing,  sponsorship 
transactions  or 
agreements,  and  various  other  business 
arrangements. The extent of the Company's obligations under 
these indemnification agreements depends upon the occurrence 

of  future  events;  therefore,  the  Company's  potential  future 
liability under these arrangements is not determinable. STIS and 
STRH, broker-dealer affiliates of the Company, use a common 
third party clearing broker to clear and execute their customers' 
securities  transactions  and  to  hold  customer  accounts.  Under 
their respective agreements, STIS and STRH agree to indemnify 
the clearing broker for losses that result from a customer's failure 
to  fulfill  its  contractual  obligations. As  the  clearing  broker's 
rights to charge STIS and STRH have no maximum amount, the 
Company believes that the maximum potential obligation cannot 
be estimated. However, to mitigate exposure, the affiliate may 
seek recourse from the customer through cash or securities held 
in  the  defaulting  customer's  account.  For  the  years  ended 
December  31,  2017,  2016,  and  2015,  STIS  and  STRH
experienced minimal net losses as a result of the indemnity. The 
clearing  agreements  expire  in  May  2020  for  both  STIS  and 
STRH.

NOTE 17 - DERIVATIVE FINANCIAL INSTRUMENTS

The  Company  enters 
into  various  derivative  financial 
instruments,  both  in  a  dealer  capacity  to  facilitate  client 
transactions and as an end user as a risk management tool. The 
Company  generally  manages  the  risk  associated  with  these 
derivatives  within  the  established  MRM  and  credit  risk 
management  frameworks.  Derivatives  may  be  used  by  the 
Company to hedge various economic or client-related exposures. 
In such instances, derivative positions are typically monitored 
using  a  VAR  methodology,  with  exposures  reviewed  daily. 
Derivatives are also used as a risk management tool to hedge the 
Company’s balance sheet exposure to changes in identified cash 
flow and fair value risks, either economically or in accordance 
with  hedge  accounting  provisions. The  Company’s  Corporate 
Treasury function is responsible for employing the various hedge 
strategies to manage these objectives. The Company enters into 
IRLCs on residential and commercial mortgage loans that are 
accounted for as freestanding derivatives. Additionally, certain 
contracts containing embedded derivatives are measured, in their 
entirety, at fair value. All derivatives, including both freestanding 
as well as any embedded derivatives that the Company bifurcates 
from  the  host  contracts,  are  measured  at  fair  value  in  the 
Consolidated Balance Sheets in Trading assets and derivative 
instruments and Trading liabilities and derivative instruments. 
The associated gains and losses are either recognized in AOCI, 
net  of  tax,  or  within  the  Consolidated  Statements  of  Income, 
depending upon the use and designation of the derivatives.

Credit and Market Risk Associated with Derivative Instruments
Derivatives expose the Company to risk that the counterparty to 
the  derivative  contract  does  not  perform  as  expected.  The 
Company  manages  its  exposure  to  counterparty  credit  risk 
associated  with  derivatives  by  entering  into  transactions  with 
counterparties with defined exposure limits based on their credit 
quality  and  in  accordance  with  established  policies  and 
procedures. All counterparties are reviewed regularly as part of 
the Company’s credit risk management practices and appropriate 
action  is  taken  to  adjust  the  exposure  limits  to  certain 

128

counterparties  as  necessary.  The  Company’s  derivative 
transactions are generally governed by ISDA agreements or other 
legally enforceable industry standard master netting agreements. 
In certain cases and depending on the nature of the underlying 
derivative transactions, bilateral collateral agreements are also 
utilized.  Furthermore,  the  Company  and  its  subsidiaries  are 
subject to OTC derivative clearing requirements, which require 
certain derivatives to be cleared through central clearing houses, 
such as LCH and the CME. These clearing houses require the 
Company to post initial and variation margin to mitigate the risk 
of  non-payment,  the  latter  of  which  is  received  or  paid  daily 
based  on  the  net  asset  or  liability  position  of  the  contracts. 
Effective  January  3,  2017,  the  CME  amended  its  rulebook  to 
legally characterize variation margin cash payments for cleared 
OTC  derivatives  as  settlement  rather  than  as  collateral. As  a 
result, in the first quarter of 2017, the Company began reducing 
the  corresponding  derivative  asset  and  liability  balances  for 
CME-cleared OTC derivatives to reflect the settlement of those 
positions via the exchange of variation margin. Variation margin 
cash payments for LCH-cleared OTC derivatives continue to be 
subject  to  collateral  accounting  and  characterized  by  the 
Company as collateral through December 31, 2017. However, 
effective January 16, 2018, LCH amended its rulebook to legally 
characterize variation margin cash payments for cleared OTC
derivatives as settlement rather than as collateral, consistent with 
the CME's amended requirements. Accordingly, beginning in the 
first  quarter  of  2018,  the  Company  will  begin  reducing  the 
corresponding derivative asset and liability balances for LCH-
cleared  OTC  derivatives  to  reflect  the  settlement  of  those 
positions via the exchange of variation margin.

When  the  Company  has  more  than  one  outstanding 
derivative transaction with a single counterparty, and there exists 
a  legal  right  of  offset  with  that  counterparty,  the  Company 
considers its exposure to the counterparty to be the net fair value 
of its derivative positions with that counterparty. If the net fair 
value is positive, then the corresponding asset value also reflects 
cash  collateral  held.  At  December 31,  2017,  the  economic 

Notes to Consolidated Financial Statements, continued

would have the right to apply any collateral posted by the Bank 
against any net amount owed by the Bank. Additionally, certain 
of  the  Company’s  derivative  liability  positions,  totaling  $1.1 
billion in fair value at both December 31, 2017 and 2016, contain 
provisions  conditioned  on  downgrades  of  the  Bank’s  credit 
rating. These provisions, if triggered, would either give rise to 
an ATE that permits the counterparties to close-out net and apply 
collateral or, where a CSA is present, require the Bank to post 
additional collateral. 

At December 31, 2017, the Bank held senior long-term debt 
credit  ratings  of  Baal/A-/A-  from  Moody’s,  S&P,  and  Fitch, 
respectively. At December 31, 2017, ATEs have been triggered 
for less than $1 million in fair value liabilities. The maximum 
additional  liability  that  could  be  triggered  from  ATEs  was 
approximately  $17  million  at  December 31,  2017.  At 
December 31,  2017,  $1.1  billion  in  fair  value  of  derivative 
liabilities  were  subject  to  CSAs,  against  which  the  Bank  has 
posted $1.0 billion in collateral, primarily in the form of cash. If 
requested by the counterparty pursuant to the terms of the CSA, 
the  Bank  would  be  required  to  post  additional  collateral  of 
approximately $2 million against these contracts if the Bank were 
downgraded  to  Baa3/BBB.  Further  downgrades  to  Ba1/BBB- 
would  require  the  Bank  to  post  an  additional  $2  million  of 
collateral. Any  further  downgrades  below  Ba1/BBB-  do  not 
contain predetermined collateral posting levels.

Notional and Fair Value of Derivative Positions 
The following tables present the Company’s derivative positions 
at December 31, 2017 and 2016. The notional amounts in the 
tables are presented on a gross basis and have been classified 
within  derivative  assets  or  derivative  liabilities  based  on  the 
estimated fair value of the individual contract at December 31, 
2017  and  2016.  Gross  positive  and  gross  negative  fair  value 
amounts  associated  with  respective  notional  amounts  are 
presented  without  consideration  of  any  netting  agreements, 
including  collateral  arrangements.  Net  fair  value  derivative 
amounts are adjusted on an aggregate basis, where applicable, 
to  take  into  consideration  the  effects  of  legally  enforceable 
master  netting  agreements,  including  any  cash  collateral 
received  or  paid,  and  are  recognized  in  Trading  assets  and 
derivative  instruments  or  Trading  liabilities  and  derivative 
instruments on the Consolidated Balance Sheets. For contracts 
constituting  a  combination  of  options  that  contain  a  written 
option and a purchased option (such as a collar), the notional 
amount of each option is presented separately, with the purchased 
notional amount generally being presented as a derivative asset 
and the written notional amount being presented as a derivative 
liability.  For  other  contracts  that  contain  a  combination  of 
options, the fair value is generally presented as a single value 
with the purchased notional amount if the combined fair value 
is positive, and with the written notional amount if the combined 
fair value is negative.

exposure of these net derivative asset positions was $541 million, 
reflecting $940 million of net derivative gains, adjusted for cash 
and other collateral of $399 million that the Company held in 
relation to these positions. At December 31, 2016, the economic 
exposure  of  net  derivative  asset  positions  was  $774  million, 
reflecting $1.1 billion of net derivative gains, adjusted for cash 
and other collateral held of $339 million.

Derivatives also expose the Company to market risk arising 
from the adverse effects that changes in market factors, such as 
interest rates, currency rates, equity prices, commodity prices, 
or implied volatility, may have on the value of a derivative. The 
Company  manages  this  risk  by  establishing  and  monitoring 
limits on the types and degree of risk that may be undertaken. 
The Company measures its market risk exposure using a VAR 
methodology for derivatives designated as trading instruments. 
Other tools and risk measures are also used to actively manage 
risk associated with derivatives including scenario analysis and 
stress testing.

take 

Derivative instruments are priced using observable market 
inputs  at  a  mid-market  valuation  point  and 
into 
consideration appropriate valuation adjustments for collateral, 
market liquidity, and counterparty credit risk. For purposes of 
determining  fair  value  adjustments  to  its  OTC  derivative 
positions, the Company takes into consideration the credit profile 
and likelihood of default by counterparties and itself, as well as 
its  net  exposure,  which  considers  legally  enforceable  master 
netting  agreements  and  collateral  along  with  remaining 
maturities. The expected loss of each counterparty is estimated 
using market-based views of counterparty default probabilities 
observed in the single-name CDS market, when available and of 
sufficient liquidity. When single-name CDS market data is not 
available or not of sufficient liquidity, the probability of default 
is estimated using a combination of the Company's internal risk 
rating system and sector/rating based CDS data.

For purposes of estimating the Company’s own credit risk 
on  derivative  liability  positions,  the  DVA,  the  Company  uses 
probabilities  of  default  from  observable,  sector/rating  based 
CDS  data.  The  Company  adjusted  the  net  fair  value  of  its 
derivative contracts for estimates of both counterparty credit risk 
and  its  own  credit  risk  by  approximately  $5  million  and  $6 
million  at  December  31,  2017  and  2016,  respectively.  For 
fair  value 
additional 
measurements,  see  Note  18,  "Fair  Value  Election  and 
Measurement."

information  on 

the  Company's 

Currently,  the  majority  of  the  Company’s  derivatives 
contain contingencies that relate to the creditworthiness of the 
Bank.  These  contingencies,  which  are  contained  in  industry 
standard master netting agreements, may be considered events 
of  default.  Should  the  Bank  be  in  default  under  any  of  these 
provisions, the Bank’s counterparties would be permitted to close 
out transactions with the Bank on a net basis, at amounts that 
would approximate the fair values of the derivatives, resulting 
in a single sum due by one party to the other. The counterparties 

129

Notes to Consolidated Financial Statements, continued

(Dollars in millions)
Derivative instruments designated in cash flow hedging relationships 1

Interest rate contracts hedging floating rate LHFI

Derivative instruments designated in fair value hedging relationships 2

Interest rate contracts hedging fixed rate debt

Interest rate contracts hedging brokered CDs

Total

Derivative instruments not designated as hedging instruments 3

Interest rate contracts hedging:

Residential MSRs 4
LHFS, IRLCs 5
LHFI
Trading activity 6

Foreign exchange rate contracts hedging loans and trading activity

Credit contracts hedging:

LHFI
Trading activity 7

Equity contracts hedging trading activity 6
Other contracts:

IRLCs and other 8
Commodity derivatives

Total

Total derivative instruments

Total gross derivative instruments, before netting

Less:  Legally enforceable master netting agreements

Less:  Cash collateral received/paid

Total derivative instruments, after netting

December 31, 2017

Asset Derivatives

Liability Derivatives

Notional
Amounts

Fair
Value

Notional
Amounts

Fair
Value

$8,350

$252

$5,850

1,250

30

1,280

31,895

4,550

90

78,223

3,409

—

1,721

13,837

1,671

712

$2

1

—

1

119

9

2

1,066

110

—

15

2,499

18

63

4,670

30

4,700

10,126

3,040

85

48,143

3,649

515

1,733

25,070

346

710

136,108

3,901

93,417

$143,238

$3,904

$106,467

$3,904

(2,731)

(371)

$802

58

—

58

119

6

2

946

102

11

12

2,857

16

61

4,132

$4,442

$4,442

(2,731)

(1,303)

$408

1 See “Cash Flow Hedges” in this Note for further discussion.
2 See “Fair Value Hedges” in this Note for further discussion.
3 See “Economic Hedging and Trading Activities” in this Note for further discussion.
4 Amount includes $16.6 billion of notional amounts related to interest rate futures. These futures contracts settle in cash daily, one day in arrears. The derivative 
asset or liability associated with the one day lag is included in the fair value column of this table.
5 Amount includes $190 million of notional amounts related to interest rate futures. These futures contracts settle in cash daily, one day in arrears. The derivative 
asset or liability associated with the one day lag is included in the fair value column of this table.
6 Amounts include $9.8 billion of notional amounts related to interest rate futures and $1.2 billion of notional amounts related to equity futures. These futures contracts 
settle in cash daily, one day in arrears. The derivative asset or liability associated with the one day lag is included in the fair value column of this table. Amounts 
also include notional amounts related to interest rate swaps hedging fixed rate debt.
7 Asset and liability amounts include $4 million and $11 million, respectively, of notional amounts from purchased and written credit risk participation agreements, 
whose notional is calculated as the notional of the derivative participated adjusted by the relevant RWA conversion factor.
8 Includes $49 million notional amount that is based on the 3.2 million of Visa Class B shares, the conversion ratio from Class B shares to Class A shares, and the 
Class A share price at the derivative inception date of May 28, 2009. This derivative was established upon the sale of Class B shares in the second quarter of 2009. 
See Note 16, “Guarantees” for additional information.

130

 
 
Notes to Consolidated Financial Statements, continued

(Dollars in millions)
Derivative instruments designated in cash flow hedging relationships 1

December 31, 2016

Asset Derivatives

Liability Derivatives

Notional
Amounts

Fair
Value

Notional
Amounts

Fair
Value

Interest rate contracts hedging floating rate LHFI

$6,400

$34

$11,050

$265

Derivative instruments designated in fair value hedging relationships 2

Interest rate contracts hedging fixed rate debt

Interest rate contracts hedging brokered CDs

Total

Derivative instruments not designated as hedging instruments 3

Interest rate contracts hedging:

Residential MSRs 4
LHFS, IRLCs 5
LHFI
Trading activity 6

Foreign exchange rate contracts hedging loans and trading activity

Credit contracts hedging:

LHFI
Trading activity 7

Equity contracts hedging trading activity 6
Other contracts:

IRLCs and other 8
Commodity derivatives

Total

Total derivative instruments

Total gross derivative instruments, before netting

Less:  Legally enforceable master netting agreements

Less:  Cash collateral received/paid

Total derivative instruments, after netting

600

60

660

12,165

11,774

100

70,599

3,231

15

2,128

17,225

2,412

747

2

—

2

413

134

2

1,536

161

—

34

2,095

28

75

4,510

30

4,540

18,774

8,306

36

67,477

3,360

620

2,271

28,658

668

746

120,396

4,478

130,916

$127,456

$4,514

$146,506

$4,514

(3,239)

(291)

$984

81

—

81

335

58

1

1,401

148

8

33

2,477

22

73

4,556

$4,902

$4,902

(3,239)

(1,265)

$398

1 See “Cash Flow Hedges” in this Note for further discussion. 
2 See “Fair Value Hedges” in this Note for further discussion.
3 See “Economic Hedging and Trading Activities” in this Note for further discussion.
4 Amount includes $6.7 billion of notional amounts related to interest rate futures. These futures contracts settle in cash daily, one day in arrears. The derivative asset 
or liability associated with the one day lag is included in the fair value column of this table.
5 Amount includes $720 million of notional amounts related to interest rate futures. These futures contracts settle in cash daily, one day in arrears. The derivative 
asset or liability associated with the one day lag is included in the fair value column of this table.
6 Amounts include $12.3 billion of notional amounts related to interest rate futures and $629 million of notional amounts related to equity futures. These futures 
contracts settle in cash daily, one day in arrears. The derivative asset or liability associated with the one day lag is included in the fair value column of this table. 
Amounts also include notional amounts related to interest rate swaps hedging fixed rate debt.
7 Asset and liability amounts include $5 million and $13 million, respectively, of notional amounts from purchased and written credit risk participation agreements, 
whose notional is calculated as the notional of the derivative participated adjusted by the relevant RWA conversion factor.
8 Includes $49 million notional amount that is based on the 3.2 million of Visa Class B shares, the conversion ratio from Class B shares to Class A shares, and the 
Class A share price at the derivative inception date of May 28, 2009. This derivative was established upon the sale of Class B shares in the second quarter of 2009. 
See Note 16, “Guarantees” for additional information.

131

 
 
Notes to Consolidated Financial Statements, continued

Impact of Derivative Instruments on the Consolidated Statements of Income and Shareholders’ Equity 

The  impacts  of  derivative  instruments  on  the  Consolidated 
Statements  of  Income  and  the  Consolidated  Statements  of 
Shareholders’ Equity for the years ended December 31, 2017, 
2016, and 2015 are presented in the following tables. The impacts 
are segregated between derivatives that are designated in hedge 
accounting relationships and those that are used for economic 

hedging or trading purposes, with further identification of the 
underlying risks in the derivatives and the hedged items, where 
appropriate. The tables do not disclose the financial impact of 
the activities that these derivative instruments are intended to 
hedge.

(Dollars in millions)

Derivative instruments in cash flow hedging relationships:

Year Ended December 31, 2017

Amount of Pre-tax Loss
Recognized in OCI on 
Derivatives 
(Effective Portion)

Amount of Pre-tax Gain
Reclassified from AOCI
into Income
(Effective Portion)

Classification of Pre-tax
Gain Reclassified
from AOCI into Income
(Effective Portion)

Interest rate contracts hedging floating rate LHFI 1

($54)

Interest and fees on loans 
held for investment

$38

1 During the year ended December 31, 2017, the Company also reclassified $51 million of pre-tax gains from AOCI into Net interest income relating to hedging 
relationships that have been terminated and are reclassified into earnings consistent with the pattern of net cash flows expected to be recognized.

(Dollars in millions)

Derivative instruments in fair value hedging relationships:

Interest rate contracts hedging fixed rate debt 1
Interest rate contracts hedging brokered CDs 1

Total

Year Ended December 31, 2017

Amount of Loss on
Derivatives
Recognized in Income

Amount of Gain
on Related Hedged Items
Recognized in Income

Amount of Gain
Recognized in Income
on Hedges
(Ineffective Portion)

($38)

—

($38)

$40

—

$40

$2

—

$2

1 Amounts are recognized in Trading income in the Consolidated Statements of Income.

Classification of Gain/(Loss)
Recognized in Income on Derivatives

Amount of Gain/(Loss) Recognized in 
Income on Derivatives During the 
Year Ended December 31, 2017

(Dollars in millions)

Derivative instruments not designated as hedging instruments:

Interest rate contracts hedging:

Residential MSRs

LHFS, IRLCs

Trading activity

Mortgage servicing related income

Mortgage production related income

Trading income

Foreign exchange rate contracts hedging loans and trading activity Trading income

Credit contracts hedging:

LHFI

Trading activity

Other contracts:

IRLCs and other

Commodity derivatives

Total

Other noninterest income

Trading income

Mortgage production related income,
Commercial real estate related income

Trading income

132

$42

(54)

42

(37)

(4)

26

185

1

$201

 
 
 
Notes to Consolidated Financial Statements, continued

(Dollars in millions)

Derivative instruments in cash flow hedging relationships:

Year Ended December 31, 2016

Amount of Pre-tax Loss 
Recognized in OCI on 
Derivatives 
(Effective Portion)

Amount of Pre-tax Gain
Reclassified from AOCI
into Income
(Effective Portion)

Classification of Pre-tax
Gain Reclassified
from AOCI into Income
(Effective Portion)

Interest rate contracts hedging floating rate LHFI 1

($145)

Interest and fees on loans 
held for investment

$147

1 During the year ended December 31, 2016, the Company also reclassified $97 million of pre-tax gains from AOCI into Net interest income relating to hedging 
relationships that have been terminated and are reclassified into earnings consistent with the pattern of net cash flows expected to be recognized.

(Dollars in millions)

Derivative instruments in fair value hedging relationships:

Interest rate contracts hedging fixed rate debt 1
Interest rate contracts hedging brokered CDs 1

Total

Year Ended December 31, 2016

Amount of Loss on
Derivatives
Recognized in Income

Amount of Gain 
on Related Hedged Items
Recognized in Income

Amount of Gain
Recognized in Income
on Hedges
(Ineffective Portion)

($87)

—

($87)

$89

—

$89

$2

—

$2

1 Amounts are recognized in Trading income in the Consolidated Statements of Income.

(Dollars in millions)

Derivative instruments not designated as hedging instruments:

Interest rate contracts hedging:

Classification of Gain/(Loss)
Recognized in Income on Derivatives

Amount of Gain/(Loss) Recognized in 
Income on Derivatives During the 
Year Ended December 31, 2016

Residential MSRs

LHFS, IRLCs

LHFI

Trading activity

Mortgage servicing related income

Mortgage production related income

Other noninterest income

Trading income

Foreign exchange rate contracts hedging loans and trading activity

Trading income

Credit contracts hedging:

LHFI

Trading activity

Equity contracts hedging trading activity

Other contracts:

IRLCs

Commodity derivatives

Total

Other noninterest income

Trading income

Trading income

Mortgage production related income

Trading income

$62

(6)

(1)

51

101

(3)

19

4

210

3

$440

133

 
 
Notes to Consolidated Financial Statements, continued

(Dollars in millions)

Derivative instruments in cash flow hedging relationships:

Year Ended December 31, 2015

Amount of Pre-tax Gain
Recognized in OCI on
Derivatives
(Effective Portion)

Amount of Pre-tax Gain 
Reclassified from AOCI 
into Income 
(Effective Portion)

Classification of Pre-tax
Gain Reclassified
from AOCI into Income
(Effective Portion)

Interest rate contracts hedging floating rate LHFI 1

$246

$169

Interest and fees on loans
held for investment

1 During  the  year  ended  December 31,  2015,  the  Company  also  reclassified  $92  million  pre-tax  gains  from AOCI  into  Net  interest  income  relating  to  hedging 
relationships that have been terminated and are reclassified into earnings consistent with the pattern of net cash flows expected to be recognized.

(Dollars in millions)

Derivative instruments in fair value hedging relationships:

Interest rate contracts hedging fixed rate debt 1
Interest rate contracts hedging brokered CDs 1

Total

Year Ended December 31, 2015

Amount of Loss on 
Derivatives 
Recognized in Income

Amount of Gain on 
Related Hedged Items
Recognized in Income

Amount of Loss
Recognized in Income
on Hedges
(Ineffective Portion)

($2)

—

($2)

$1

—

$1

($1)

—

($1)

1 Amounts are recognized in Trading income in the Consolidated Statements of Income.

(Dollars in millions)

Derivative instruments not designated as hedging instruments:

Interest rate contracts hedging:

Classification of Gain/(Loss)
Recognized in Income on Derivatives

Amount of Gain/(Loss) Recognized in 
Income on Derivatives During the 
Year Ended December 31, 2015

Residential MSRs

LHFS, IRLCs

LHFI

Trading activity

Mortgage servicing related income

Mortgage production related income

Other noninterest income

Trading income

Foreign exchange rate contracts hedging loans and trading activity

Trading income

Credit contracts hedging:

LHFI

Trading activity

Equity contracts hedging trading activity

Other contracts:

IRLCs

Commodities

Total

Other noninterest income

Trading income

Trading income

Mortgage production related income

Trading income

$19

(45)

(1)

61

93

(1)

23

4

156

2

$311

134

 
 
Notes to Consolidated Financial Statements, continued

Netting of Derivative Instruments
The  Company  has  various  financial  assets  and  financial 
liabilities  that  are  subject  to  enforceable  master  netting 
agreements  or  similar  agreements.  The  Company's  securities 
borrowed or purchased under agreements to resell, and securities 
sold  under  agreements  to  repurchase,  that  are  subject  to 
enforceable  master  netting  agreements  or  similar  agreements, 
are  discussed  in  Note  3,  "Federal  Funds  Sold  and  Securities 
Financing Activities." The Company enters into ISDA or other 
legally enforceable industry standard master netting agreements 
with  derivative  counterparties.  Under  the  terms  of  the  master 
netting agreements, all transactions between the Company and 
the counterparty constitute a single business relationship such 
that in the event of default, the nondefaulting party is entitled to 
set off claims and apply property held by that party in respect of 
any  transaction  against  obligations  owed.  Any  payments, 
deliveries, or other transfers may be applied against each other 
and netted.

tables  present 

The  following 

total  gross  derivative 
instrument assets and liabilities at December 31, 2017 and 2016, 
which are adjusted to reflect the effects of legally enforceable 
master netting agreements and cash collateral received or paid 
when calculating the net amount reported in the Consolidated 
Balance  Sheets.  Also  included  in  the  tables  are  financial 
instrument collateral related to legally enforceable master netting 
agreements  that  represents  securities  collateral  received  or 
pledged  and  customer  cash  collateral  held  at  third  party 
custodians. These amounts are not offset on the Consolidated 
Balance Sheets but are shown as a reduction to total derivative 
instrument assets and liabilities to derive net derivative assets 
and liabilities. These amounts are limited to the derivative asset/
liability  balance,  and  accordingly,  do  not  include  excess 
collateral received/pledged.

(Dollars in millions)
December 31, 2017
Derivative instrument assets:

Derivatives subject to master netting arrangement or similar

arrangement

Derivatives not subject to master netting arrangement or similar

arrangement

Exchange traded derivatives

Total derivative instrument assets

Derivative instrument liabilities:

Derivatives subject to master netting arrangement or similar

arrangement

Derivatives not subject to master netting arrangement or similar

arrangement

Exchange traded derivatives

Total derivative instrument liabilities

December 31, 2016

Derivative instrument assets:

Derivatives subject to master netting arrangement or similar

arrangement

Derivatives not subject to master netting arrangement or similar

arrangement

Exchange traded derivatives

Total derivative instrument assets

Derivative instrument liabilities:

Derivatives subject to master netting arrangement or similar

arrangement

Derivatives not subject to master netting arrangement or similar

arrangement

Exchange traded derivatives

Total derivative instrument liabilities

Gross
Amount

Amount
Offset

Net Amount
Presented in
Consolidated
Balance Sheets

Held/Pledged
Financial
Instruments

Net
Amount

$3,491

$2,923

18

395

—

179

$3,904

$3,102

$4,128

$3,855

130

184

—

179

$4,442

$4,034

$4,193

$3,384

27

294

—

146

$4,514

$3,530

$4,649

$4,358

105

148

—

146

$4,902

$4,504

$568

18

216

1

$802

$273

130

5

2

$408

$809

27

148

$984

1

$291

105

2

2

$398

$28

—

—

$28

$27

—

—

$27

$48

—

—

$48

$33

—

—

$33

$540

18

216

$774

$246

130

5

$381

$761

27

148

$936

$258

105

2

$365

1 At December 31, 2017, $802 million, net of $371 million offsetting cash collateral, is recognized in Trading assets and derivative instruments within the Company's 
Consolidated Balance Sheets. At December 31, 2016, $984 million, net of $291 million offsetting cash collateral, is recognized in Trading assets and derivative 
instruments within the Company's Consolidated Balance Sheets.
2 At December 31, 2017, $408 million, net of $1.3 billion offsetting cash collateral, is recognized in Trading liabilities and derivative instruments within the Company's 
Consolidated Balance Sheets. At December 31, 2016, $398 million, net of $1.3 billion offsetting cash collateral, is recognized in Trading liabilities and derivative 
instruments within the Company's Consolidated Balance Sheets.

135

Notes to Consolidated Financial Statements, continued

Credit Derivative Instruments
As part of the Company's trading businesses, the Company enters 
into contracts that are, in form or substance, written guarantees; 
specifically, CDS, risk participations, and TRS. The Company 
accounts  for  these  contracts  as  derivatives,  and  accordingly, 
records these contracts at fair value, with changes in fair value 
recognized in Trading income in the Consolidated Statements of 
Income.

At December 31, 2017 and 2016, the gross notional amount 
of purchased CDS contracts designated as trading instruments 
was $5 million and $135 million, respectively. The fair value of 
purchased CDS was immaterial at December 31, 2017 and $3 
million at December 31, 2016.

The Company has also entered into TRS contracts on loans. 
The Company’s TRS business consists of matched trades, such 
that when the Company pays depreciation on one TRS, it receives 
the same amount on the matched TRS. To mitigate its credit risk, 
the Company typically receives initial cash collateral from the 
counterparty  upon  entering  into  the  TRS  and  is  entitled  to 
additional collateral if the fair value of the underlying reference 
assets deteriorates. There were $1.7 billion and $2.1 billion of 
outstanding TRS notional balances at December 31, 2017 and 
2016,  respectively.  The  fair  values  of  these  TRS  assets  and 
liabilities  at  December 31,  2017  were  $15  million  and  $13 
million,  respectively,  and  related  cash  collateral  held  at 
December 31, 2017 was $368 million. The fair values of the TRS 
assets and liabilities at December 31, 2016 were $34 million and 
$31  million,  respectively,  and  related  cash  collateral  held  at 
December 31,  2016  was  $450  million.  For  additional 
information  on  the  Company's  TRS  contracts,  see  Note  10, 
"Certain  Transfers  of  Financial  Assets  and  Variable  Interest 
Entities,"  as  well  as  Note  18,  "Fair  Value  Election  and 
Measurement."

The Company writes risk participations, which are credit 
derivatives, whereby the Company has guaranteed payment to 
a dealer counterparty in the event the counterparty experiences 
a loss on a derivative, such as an interest rate swap, due to a 
failure to pay by the counterparty’s customer (the “obligor”) on 
that derivative. The Company manages its payment risk on its 
risk  participations  by  monitoring  the  creditworthiness  of  the 
obligors, which are all corporations or partnerships, through the 
normal  credit  review  process  that  the  Company  would  have 
performed  had  it  entered  into  a  derivative  directly  with  the 
obligors. To date, no material losses have been incurred related 
to the Company’s written risk participations. At December 31, 
2017, the remaining terms on these risk participations generally 
ranged from less than one year to nine years, with a weighted 
average term on the maximum estimated exposure of 5.5 years. 
At  December 31,  2016,  the  remaining  terms  on  these  risk 
participations generally ranged from less than one year to thirty-
one  years,  with  a  weighted  average  term  on  the  maximum 
estimated  exposure  of  8.5  years.  The  Company’s  maximum 
estimated exposure to written risk participations, as measured 
by  projecting  a  maximum  value  of  the  guaranteed  derivative 
instruments  based  on  interest  rate  curve  simulations  and 
assuming 100% default by all obligors on the maximum values, 
was approximately $55 million and $95 million at December 31, 
2017 and 2016, respectively. The fair values of the written risk 
participations were immaterial at both December 31, 2017 and 
2016.

136

Cash Flow Hedging Instruments
The  Company  utilizes  a  comprehensive  risk  management 
strategy  to  monitor  sensitivity  of  earnings  to  movements  in 
interest rates. Specific types of funding and principal amounts 
hedged are determined based on prevailing market conditions 
and the shape of the yield curve. In conjunction with this strategy, 
the Company may employ various interest rate derivatives as 
risk management tools to hedge interest rate risk from recognized 
assets and liabilities or from forecasted transactions. The terms 
and  notional  amounts  of  derivatives  are  determined  based  on 
management’s assessment of future interest rates, as well as other 
factors.

Interest  rate  swaps  have  been  designated  as  hedging  the 
exposure  to  the  benchmark  interest  rate  risk  associated  with 
floating  rate  loans. At  December 31,  2017,  the  maturities  for 
hedges of floating rate loans ranged from less than one year to 
five  years,  with  the  weighted  average  being  3.6  years.  At 
December 31, 2016, the maturities for hedges of floating rate 
loans  ranged  from  less  than  one  year  to  six  years,  with  the 
weighted  average  being  4.1  years.  These  hedges  have  been 
highly effective in offsetting the designated risks, yielding an 
immaterial  amount  of  ineffectiveness  for  the  years  ended 
December  31,  2017  and  2016.  At  December 31,  2017,  $21 
million of deferred net pre-tax losses on derivative instruments 
designated as cash flow hedges on floating rate loans recognized 
in AOCI are expected to be reclassified into net interest income 
during the next twelve months. The amount to be reclassified 
into  income  incorporates  the  impact  from  both  active  and 
terminated cash flow hedges, including the net interest income 
earned on the active hedges, assuming no changes in LIBOR. 
The Company may choose to terminate or de-designate a hedging 
relationship due to a change in the risk management objective 
for that specific hedge item, which may arise in conjunction with 
an overall balance sheet management strategy.

Fair Value Hedging Instruments
The Company enters into interest rate swap agreements as part 
of the Company’s risk management objectives for hedging its 
exposure to changes in fair value due to changes in interest rates. 
These hedging arrangements convert certain fixed rate long-term 
debt and CDs to floating rates. Consistent with this objective, 
the  Company  reflects  the  accrued  contractual  interest  on  the 
hedged  item  and  the  related  swaps  as  part  of  current  period 
interest expense. There were no components of derivative gains 
or  losses  excluded  in  the  Company’s  assessment  of  hedge 
effectiveness related to the fair value hedges.

Economic Hedging Instruments and Trading Activities
In  addition  to  designated  hedge  accounting  relationships,  the 
Company  also  enters  into  derivatives  as  an  end  user  to 
economically hedge risks associated with certain non-derivative 
and derivative instruments, along with entering into derivatives 
in a trading capacity with its clients.

The primary risks that the Company economically hedges 
are interest rate risk, foreign exchange risk, and credit risk. The 
Company  mitigates  these  risks  by  entering  into  offsetting 
derivatives  either  on  an  individual  basis  or  collectively  on  a 
macro basis.

Notes to Consolidated Financial Statements, continued

The Company utilizes interest rate derivatives as economic 

hedges related to:

•  Residential MSRs. The Company hedges these instruments 
with a combination of interest rate derivatives, including 
forward  and  option  contracts,  futures,  and  forward  rate 
agreements.

•  Residential  mortgage  IRLCs  and  LHFS.  The  Company 
hedges  these  instruments  using  forward  and  option 
contracts, futures, and forward rate agreements.

The Company is exposed to volatility and changes in foreign 
exchange  rates  associated  with  certain  commercial  loans.  To 
hedge against this foreign exchange rate risk, the Company enters 
into foreign exchange rate contracts that provide for the future 

receipt and delivery of foreign currency at previously agreed-
upon terms.

The  Company  enters  into  CDS  to  hedge  credit  risk 
associated with certain loans held within its Wholesale segment. 
The Company accounts for these contracts as derivatives, and 
accordingly,  recognizes  these  contracts  at  fair  value,  with 
changes in fair value recognized in Other noninterest income in 
the Consolidated Statements of Income.

Trading  activity  primarily  includes  interest  rate  swaps, 
equity derivatives, CDS, futures, options, foreign exchange rate 
contracts,  and  commodity  derivatives.  These  derivatives  are 
entered into in a dealer capacity to facilitate client transactions, 
or are utilized as a risk management tool by the Company as an 
end user (predominantly in certain macro-hedging strategies).

137

Notes to Consolidated Financial Statements, continued

NOTE 18 - FAIR VALUE ELECTION AND MEASUREMENT

The Company measures certain assets and liabilities at fair value, 
which  are  classified  as  level  1,  2,  or  3  within  the  fair  value 
hierarchy,  as  shown  below,  on  the  basis  of  whether  the 
measurement  employs  observable  or  unobservable  inputs. 
Observable inputs reflect market data obtained from independent 
sources, while unobservable inputs reflect the Company’s own 
assumptions,  taking  into  account  information  about  market 
participant assumptions that is readily available.

•  Level 1: Quoted prices for identical instruments in active 

markets 

•  Level 2: Quoted prices for similar instruments in active 
markets; quoted prices for identical or similar instruments 
in  markets  that  are  not  active;  and  model-derived 
valuations in which all significant inputs and significant 
value drivers are observable in active markets 

•  Level 3: Valuations derived from valuation techniques in 
which one or more significant inputs or significant value 
drivers are unobservable 

Fair value is defined as the price that would be received to 
sell an asset, or paid to transfer a liability, in an orderly transaction 
between  market  participants  at  the  measurement  date.  The 
Company’s  recurring  fair  value  measurements  are  based  on 
either a requirement to measure such assets and liabilities at fair 
value or on the Company’s election to measure certain financial 
assets and liabilities at fair value. Assets and liabilities that are 
required to be measured at fair value on a recurring basis include 
trading  securities,  securities  AFS,  and  derivative  financial 
instruments. Assets and liabilities that the Company has elected 
to measure at fair value on a recurring basis include its residential 
MSRs, trading loans, and certain LHFS, LHFI, brokered time 
deposits, and fixed rate debt issuances.

The Company elects to measure certain assets and liabilities 
at fair value to better align its financial performance with the 
economic value of actively traded or hedged assets or liabilities. 
The use of fair value also enables the Company to mitigate non-
economic earnings volatility caused from financial assets and 
liabilities being measured using different bases of accounting, 
as well as to more accurately portray the active and dynamic 
management of the Company’s balance sheet.

The  Company  uses  various  valuation  techniques  and 
assumptions in estimating fair value. The assumptions used to 
estimate  the  value  of  an  instrument  have  varying  degrees  of 
impact to the overall fair value of an asset or liability. This process 
involves  gathering  multiple  sources  of  information,  including 
broker  quotes,  values  provided  by  pricing  services,  trading 
activity in other identical or similar securities, market indices, 
and  pricing  matrices.  When  observable  market  prices  for  the 
asset or liability are not available, the Company employs various 

modeling techniques, such as discounted cash flow analyses, to 
estimate fair value. Models used to produce material financial 
reporting information are validated prior to use and following 
any  material  change  in  methodology.  Their  performance  is 
monitored at least quarterly, and any material deterioration in 
model performance is escalated. This review is performed by 
different internal groups depending on the type of fair value asset 
or liability.

The Company has formal processes and controls in place to 
support the appropriateness of its fair value estimates. For fair 
values obtained from a third party, or those that include certain 
trader  estimates  of  fair  value,  there  is  an  independent  price 
validation function that provides oversight for these estimates. 
For  level  2  instruments  and  certain  level  3  instruments,  the 
validation generally involves evaluating pricing received from 
two or more third party pricing sources that are widely used by 
market  participants.  The  Company  evaluates  this  pricing 
information from both a qualitative and quantitative perspective 
and  determines  whether  any  pricing  differences  exceed 
acceptable thresholds. If thresholds are exceeded, the Company 
assesses differences in valuation approaches used, which may 
include contacting a pricing service to gain further insight into 
the  valuation  of  a  particular  security  or  class  of  securities  to 
resolve the pricing variance, which could include an adjustment 
to the price used for financial reporting purposes.

The Company classifies instruments within level 2 in the 
fair  value  hierarchy  when  it  determines  that  external  pricing 
sources estimated fair value using prices for similar instruments 
trading in active markets. A wide range of quoted values from 
pricing sources may imply a reduced level of market activity and 
indicate  that  significant  adjustments  to  price  indications  have 
been made. In such cases, the Company evaluates whether the 
asset or liability should be classified as level 3.

Determining whether to classify an instrument as level 3 
involves judgment and is based on a variety of subjective factors, 
including whether a market is inactive. A market is considered 
inactive  if  significant  decreases  in  the  volume  and  level  of 
activity for the asset or liability have been observed. In making 
this determination the Company evaluates the number of recent 
transactions in either the primary or secondary market, whether 
or  not  price  quotations  are  current,  the  nature  of  market 
participants, the variability of price quotations, the breadth of 
bid/ask spreads, declines in, or the absence of, new issuances, 
and  the  availability  of  public  information.  When  a  market  is 
determined to be inactive, significant adjustments may be made 
to price indications when estimating fair value. In making these 
adjustments the Company seeks to employ assumptions a market 
participant would use to value the asset or liability, including 
consideration of illiquidity in the referenced market.

138

Notes to Consolidated Financial Statements, continued

Recurring Fair Value Measurements
The following tables present certain information regarding assets and liabilities measured at fair value on a recurring basis and the 
changes in fair value for those specific financial instruments for which fair value has been elected.

(Dollars in millions)
Assets
Trading assets and derivative instruments:

U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency
Corporate and other debt securities
CP
Equity securities
Derivative instruments
Trading loans

Total trading assets and derivative instruments

Securities AFS:

U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency residential
MBS - non-agency commercial
ABS
Corporate and other debt securities
Other equity securities 2

Total securities AFS

LHFS
LHFI
Residential MSRs

Liabilities
Trading liabilities and derivative instruments:

U.S. Treasury securities
Corporate and other debt securities
Equity securities
Derivative instruments

Total trading liabilities and derivative instruments

Brokered time deposits
Long-term debt

Fair Value Measurements

December 31, 2017

Level 1

Level 2

Level 3

Netting
 Adjustments 1

Assets/Liabilities
at Fair Value

$157
—
—
—
—
—
56
395
—
608

4,331
—
—
—
—
—
—
—
—
51
4,382

—
—
—

577
—
9
183
769

—
—

$—
395
61
700
655
118
—
3,493
2,149
7,571

—
259
617
22,704
2,086
—
866
—
12
—
26,544

1,577
—
—

—
289
—
4,243
4,532

236
530

$—
—
—
—
—
—
—
16
—
16

—
—
—
—
—
59
—
8
5
418
490

—
196
1,710

—
—
—
16
16

—
—

$—
—
—
—
—
—
—
(3,102)
—
(3,102)

—
—
—
—
—
—
—
—
—
—
—

—
—
—

—
—
—
(4,034)
(4,034)

—
—

$157
395
61
700
655
118
56
802
2,149
5,093

4,331
259
617
22,704
2,086
59
866
8
17
469
31,416

1,577
196
1,710

577
289
9
408
1,283

236
530

1 Amounts represent offsetting cash collateral received from, and paid to, the same derivative counterparties, and the impact of netting derivative assets and derivative 
liabilities when a legally enforceable master netting agreement or similar agreement exists. See Note 17, "Derivative Financial Instruments," for additional information.
2 Includes $49 million of mutual fund investments, $15 million of FHLB of Atlanta stock, $403 million of Federal Reserve Bank of Atlanta stock, and $2 million of 
other. 

139

 
 
 
Notes to Consolidated Financial Statements, continued

(Dollars in millions)
Assets
Trading assets and derivative instruments:

U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency
CLO securities
Corporate and other debt securities
CP
Equity securities
Derivative instruments
Trading loans

Total trading assets and derivative instruments

Securities AFS:

U.S. Treasury securities
Federal agency securities
U.S. states and political subdivisions
MBS - agency residential
MBS - agency commercial
MBS - non-agency residential
MBS - non-agency commercial
ABS
Corporate and other debt securities
Other equity securities 2

Total securities AFS

LHFS
LHFI
Residential MSRs

Liabilities
Trading liabilities and derivative instruments:

U.S. Treasury securities
MBS - agency
Corporate and other debt securities
Derivative instruments

Total trading liabilities and derivative instruments

Brokered time deposits
Long-term debt

Fair Value Measurements

December 31, 2016

Level 1

Level 2

Level 3

Netting
 Adjustments 1

Assets/Liabilities
at Fair Value

$539
—
—
—
—
—
—
49
293
—
881

5,405
—
—
—
—
—
—
—
—
102
5,507

—
—
—

697
—
—
149
846

—
—

$—
480
134
567
1
656
140
—
4,193
2,517
8,688

—
313
275
22,436
1,226
—
252
—
30
—
24,532

3,528
—
—

—
1
255
4,731
4,987

78
963

$—
—
—
—
—
—
—
—
28
—
28

—
—
4
—
—
74
—
10
5
540
633

12
222
1,572

—
—
—
22
22

—
—

$—
—
—
—
—
—
—
—
(3,530)
—
(3,530)

—
—
—
—
—
—
—
—
—
—
—

—
—
—

—
—
—
(4,504)
(4,504)

—
—

$539
480
134
567
1
656
140
49
984
2,517
6,067

5,405
313
279
22,436
1,226
74
252
10
35
642
30,672

3,540
222
1,572

697
1
255
398
1,351

78
963

1 Amounts represent offsetting cash collateral received from, and paid to, the same derivative counterparties, and the impact of netting derivative assets and derivative 
liabilities when a legally enforceable master netting agreement or similar agreement exists. See Note 17, "Derivative Financial Instruments," for additional information.
2 Includes $102 million of mutual fund investments, $132 million of FHLB of Atlanta stock, $402 million of Federal Reserve Bank of Atlanta stock, and $6 million
of other.

140

 
 
 
Notes to Consolidated Financial Statements, continued

The following tables present the difference between fair value and the aggregate UPB for which the FVO has been elected for certain 
trading loans, LHFS, LHFI, brokered time deposits, and long-term debt instruments.

(Dollars in millions)

Assets:

Trading loans
LHFS:

Accruing

Past due 90 days or more

LHFI:

Accruing

Nonaccrual

Liabilities:

Brokered time deposits

Long-term debt

(Dollars in millions)

Assets:

Trading loans

LHFS:

Accruing

LHFI:

Accruing

Nonaccrual

Liabilities:

Brokered time deposits

Long-term debt

Fair Value at
December 31, 2017

Aggregate UPB at
December 31, 2017

Fair Value
Over/(Under)
Unpaid Principal

$2,149

1,576

1

192

4

236

530

$2,111

1,533

1

198

6

233

517

Fair Value at
December 31, 2016

Aggregate UPB at
December 31, 2016

Fair Value
Over/(Under)
Unpaid Principal

$2,517

3,540

219

3

78

963

$2,488

3,516

225

4

80

924

$38

43

—

(6)

(2)

3

13

$29

24

(6)

(1)

(2)

39

141

Notes to Consolidated Financial Statements, continued

The following tables present the change in fair value during the 
years ended December 31, 2017, 2016, and 2015 of financial 
instruments for which the FVO has been elected, as well as for 
residential MSRs. The tables do not reflect the change in fair 
value attributable to related economic hedges that the Company 
uses to mitigate market-related risks associated with the financial 
instruments. Generally, changes in the fair value of economic 

hedges are recognized in Trading income, Mortgage production 
related income, Mortgage servicing related income, Commercial 
real  estate  related  income,  or  Other  noninterest  income  as 
appropriate, and are designed to partially offset the change in 
fair value of the financial instruments referenced in the tables 
below.  The  Company’s  economic  hedging  activities  are 
deployed at both the instrument and portfolio level.

(Dollars in millions)

Assets:

Trading loans

LHFS

Residential MSRs

Liabilities:

Long-term debt

Fair Value Gain/(Loss) for the Year Ended 
December 31, 2017 for Items Measured at Fair Value
Pursuant to Election of the FVO

Mortgage 
Production 
Related 
Income 1

Mortgage 
Servicing 
Related 
Income

Other 
Noninterest 
Income

Trading 
Income

Total 
Changes in 
Fair Values 
Included in 
Earnings 2

$21

—

—

21

$—

61

5

—

$—

—

(248)

—

$—

—

—

—

$21

61

(243)

21

1 Income related to LHFS does not include income from IRLCs. For the year ended December 31, 2017, income related to residential MSRs includes income recognized upon 
the sale of loans reported at LOCOM.
2 Changes in fair value for the year ended December 31, 2017 exclude accrued interest for the period then ended. Interest income or interest expense on trading loans, LHFS, 
and long-term debt that have been elected to be measured at fair value are recognized in Interest income or Interest expense in the Consolidated Statements of Income.

(Dollars in millions)

Assets:

Trading loans

LHFS

Residential MSRs

Liabilities:

Brokered time deposits

Long-term debt

Fair Value Gain/(Loss) for the Year Ended
December 31, 2016 for Items Measured at Fair Value
Pursuant to Election of the FVO

Mortgage 
Production 
Related 
Income 1

Mortgage
Servicing
Related
Income

Other
Noninterest
Income

Trading
Income

Total 
Changes in 
Fair Values 
Included in 
Earnings 2

$15

—

—

4

27

$—

75

3

—

—

$—

—

(245)

—

—

$—

—

—

—

—

$15

75

(242)

4

27

1 Income related to LHFS does not include income from IRLCs. For the year ended December 31, 2016, income related to residential MSRs includes income recognized upon 
the sale of loans reported at LOCOM.
2 Changes in fair value for the year ended December 31, 2016 exclude accrued interest for the period then ended. Interest income or interest expense on trading loans, LHFS, 
brokered time deposits, and long-term debt that have been elected to be measured at fair value are recognized in Interest income or Interest expense in the Consolidated 
Statements of Income.

142

Notes to Consolidated Financial Statements, continued

Fair Value (Loss)/Gain for the Year Ended
December 31, 2015 for Items Measured at Fair Value
Pursuant to Election of the FVO

Mortgage 
Production 
Related 
Income 1

Mortgage
Servicing
Related
Income

Other
Noninterest
Income

Trading
Income

Total 
Changes in 
Fair Values 
Included in 
Earnings 2

($1)

$—

—

—

—

41

44

—

2

—

$—

—

—

(242)

—

$—

—

5

—

—

($1)
44

5
(240)

41

(Dollars in millions)

Assets:

Trading loans

LHFS

LHFI

Residential MSRs

Liabilities:

Long-term debt

1 Income related to LHFS does not include income from IRLCs. For the year ended December 31, 2015, income related to residential MSRs includes income recognized upon 
the sale of loans reported at LOCOM.
2 Changes in fair value for the year ended December 31, 2015 exclude accrued interest for the period then ended. Interest income or interest expense on trading loans, LHFS, 
LHFI, and long-term debt that have been elected to be measured at fair value are recognized in Interest income or Interest expense in the Consolidated Statements of Income.

The following is a discussion of the valuation techniques and inputs used in estimating fair value for assets and liabilities measured 
at fair value on a recurring basis and classified as level 1, 2, and/or 3.

Trading  Assets  and  Derivative  Instruments  and  Securities 
Available for Sale 
Unless  otherwise  indicated,  trading  assets  are  priced  by  the 
trading desk and securities AFS are valued by an independent 
third party pricing service. The third party pricing service gathers 
relevant market data and observable inputs, such as new issue 
data,  benchmark  curves,  reported  trades,  credit  spreads,  and 
dealer bids and offers, and integrates relevant credit information, 
perceived market movements, and sector news into its matrix 
pricing and other market-based modeling techniques.

U.S. Treasury Securities
The  Company  estimates  the  fair  value  of  its  U.S.  Treasury 
securities based on quoted prices observed in active markets; as 
such, these investments are classified as level 1.

Federal Agency Securities
The Company includes in this classification securities issued by 
federal  agencies  and  GSEs. Agency  securities  consist  of  debt 
obligations  issued  by  HUD,  FHLB,  and  other  agencies  or 
collateralized by loans that are guaranteed by the SBA and are, 
therefore,  backed  by  the  full  faith  and  credit  of  the  U.S. 
government. For SBA instruments, the Company estimates fair 
value  based  on  pricing  from  observable  trading  activity  for 
similar  securities  or  from  a  third  party  pricing  service. 
Accordingly, the Company classified these instruments as level 
2.

U.S. States and Political Subdivisions
The  Company’s  investments  in  U.S.  states  and  political 
subdivisions (collectively “municipals”) include obligations of 
county and municipal authorities and agency bonds, which are 
general  obligations  of  the  municipality  or  are  supported  by  a 
specified 
revenue  source.  Holdings  are  geographically 
dispersed, with no significant concentrations in any one state or 
municipality.  Additionally,  all  AFS  municipal  obligations 
classified  as  level  2  are  highly  rated  or  are  otherwise 

collateralized by securities backed by the full faith and credit of 
the federal government.

At  December 31,  2016,  the  Company  had  an  immaterial 
amount of bonds classified as level 3 AFS municipal securities. 
These level 3 AFS municipal securities were redeemable with 
the issuer at par and could not be traded in the market. As such, 
no significant observable market data for these instruments was 
available;  therefore,  these  securities  were  priced  at  par.  At 
December 31, 2017, the Company had no level 3 AFS municipal 
securities as these instruments matured during the second quarter 
of 2017.

MBS – Agency
Agency MBS includes pass-through securities and collateralized 
mortgage  obligations  issued  by  GSEs  and  U.S.  government 
agencies, such as Fannie Mae, Freddie Mac, and Ginnie Mae. 
Each security contains a guarantee by the issuing GSE or agency. 
For agency MBS, the Company estimates fair value based on 
pricing from observable trading activity for similar securities or 
from a third party pricing service; accordingly, the Company has 
classified these instruments as level 2.

MBS – Non-agency
Non-agency  residential  MBS  includes  purchased  interests  in 
third  party  securitizations,  as  well  as  retained  interests  in 
Company-sponsored securitizations of 2006 and 2007 vintage 
residential  mortgages  (including  both  prime  jumbo  fixed  rate 
collateral and floating rate collateral). At the time of purchase or 
origination, these securities had high investment grade ratings; 
however,  through  the  most  recent  financial  crisis,  they 
experienced deterioration in credit quality leading to downgrades 
to non-investment grade levels. The Company obtains pricing 
for  these  securities  from  an  independent  pricing  service. The 
Company  evaluates  third  party  pricing  to  determine  the 
reasonableness of the information relative to changes in market 
data, such as any recent trades, information received from market 
participants  and  analysts,  and/or  changes  in  the  underlying 

143

Notes to Consolidated Financial Statements, continued

collateral performance. The Company continued to classify non-
agency residential MBS as level 3, as the Company believes that 
available third party pricing relies on significant unobservable 
assumptions, as evidenced by a persistently wide bid-ask price 
range  and  variability  in  pricing  from  the  pricing  services, 
particularly for the vintage and exposures held by the Company.
Non-agency  commercial  MBS  consists  of  purchased 
interests in third party securitizations. These interests have high 
investment grade ratings, and the Company obtains pricing for 
these  securities  from  an  independent  pricing  service.  The 
Company has classified these non-agency commercial MBS as 
level 2, as the third party pricing service relies on observable 
data for similar securities in active markets.

CLO Securities
CLO preference share exposure was estimated at fair value based 
on pricing from observable trading activity for similar securities. 
Accordingly, the Company classified these instruments as level 
2 at December 31, 2016.

Asset-Backed Securities
ABS classified as securities AFS includes purchased interests in 
third party securitizations collateralized by home equity loans 
and  are  valued  based  on  third  party  pricing  with  significant 
unobservable assumptions; as such, they are classified as level 
3.

Corporate and Other Debt Securities
Corporate debt securities are comprised predominantly of senior 
and subordinate debt obligations of domestic corporations and 
are classified as level 2. Other debt securities classified as AFS 
in level 3 at December 31, 2017 and 2016 include bonds that are 
redeemable with the issuer at par and cannot be traded in the 
market. As such, observable market data for these instruments 
is not available.

Commercial Paper
The Company acquires CP that is generally short-term in nature 
(maturity of less than 30 days) and highly rated. The Company 
estimates the fair value of this CP based on observable pricing 
from  executed  trades  of  similar  instruments;  as  such,  CP  is 
classified as level 2.

Equity Securities
The  Company  estimates  the  fair  value  of  its  equity  securities 
classified as trading assets based on quoted prices observed in 
active markets; accordingly, these investments are classified as 
level 1.

Other equity securities classified as securities AFS include 
primarily FHLB of Atlanta stock and Federal Reserve Bank of 
Atlanta stock, which are redeemable with the issuer at cost and 
cannot be traded in the market; as such, these instruments are 
classified as level 3. The Company accounts for the stock based 
on industry guidance that requires these investments be carried 
at  cost  and  evaluated  for  impairment  based  on  the  ultimate 
recovery of cost. The Company estimates the fair value of its 
mutual  fund  investments  and  certain  other  equity  securities 
classified as securities AFS based on quoted prices observed in 
active  markets;  therefore,  these  investments  are  classified  as 
level 1. 

Derivative Instruments
The Company holds derivative instruments for both trading and 
risk  management  purposes.  Level  1  derivative  instruments 
generally include exchange-traded futures or option contracts for 
which  pricing  is  readily  available.  The  Company’s  level  2 
instruments  are  predominantly  OTC  swaps,  options,  and 
forwards,  measured  using  observable  market  assumptions  for 
interest rates, foreign exchange, equity, and credit. Because fair 
values for OTC contracts are not readily available, the Company 
estimates  fair  values  using  internal,  but  standard,  valuation 
models. The selection of valuation models is driven by the type 
of  contract:  for  option-based  products,  the  Company  uses  an 
appropriate  option  pricing  model  such  as  Black-Scholes.  For 
forward-based products, the Company’s valuation methodology 
is generally a discounted cash flow approach.

The Company's derivative instruments classified as level 2 
are primarily transacted in the institutional dealer market and 
priced  with  observable  market  assumptions  at  a  mid-market 
valuation  point,  with  appropriate  valuation  adjustments  for 
liquidity  and  credit  risk.  See  Note  17,  “Derivative  Financial 
Instruments,”  for  additional  information  on  the  Company's 
derivative instruments.

The Company's derivative instruments classified as level 3 
include IRLCs that satisfy the criteria to be treated as derivative 
financial instruments. The fair value of IRLCs on LHFS, while 
based  on  interest  rates  observable  in  the  market,  is  highly 
dependent  on  the  ultimate  closing  of  the  loans.  These  “pull-
through” rates are based on the Company’s historical data and 
reflect  the  Company’s  best  estimate  of  the  likelihood  that  a 
commitment will result in a closed loan. As pull-through rates 
increase, the fair value of IRLCs also increases. Servicing value 
is  included  in  the  fair  value  of  IRLCs,  and  the  fair  value  of 
servicing is determined by projecting cash flows, which are then 
discounted to estimate an expected fair value. The fair value of 
servicing  is  impacted  by  a  variety  of  factors,  including 
prepayment  assumptions,  discount  rates,  delinquency  rates, 
contractually  specified  servicing  fees,  servicing  costs,  and 
underlying portfolio characteristics. Because these inputs are not 
transparent in market trades, IRLCs are considered to be level 3 
assets. During the years ended December 31, 2017 and 2016, the 
Company 
transferred  $191  million  and  $211  million, 
respectively, of net IRLCs out of level 3 as the associated loans 
were closed.

Trading Loans
The Company engages in certain businesses whereby electing 
to measure loans at fair value for financial reporting aligns with 
the  underlying  business  purpose.  Specifically,  loans  included 
within this classification include trading loans that are (i) made 
or acquired in connection with the Company’s TRS business, 
(ii) part  of  the  loan  sales  and  trading  business  within  the 
Company’s Wholesale segment, or (iii) backed by the SBA. See 
Note  10,  "Certain  Transfers  of  Financial Assets  and  Variable 
Interest  Entities,"  and  Note  17,  “Derivative  Financial 
Instruments,” for further discussion of this business. All of these 
loans are classified as level 2 due to the nature of market data 
that the Company uses to estimate fair value.

The  loans  made  in  connection  with  the  Company’s  TRS
business  are  short-term,  senior  demand  loans  supported  by  a 
pledge agreement granting first priority security interest to the 

144

 
Notes to Consolidated Financial Statements, continued

Bank in all the assets held by the borrower, a VIE with assets 
comprised primarily of corporate loans. While these TRS-related 
loans do not trade in the market, the Company believes that the 
par  amount  of  the  loans  approximates  fair  value  and  no 
unobservable  assumptions  are  used  by  the  Company  to  value 
these loans. At December 31, 2017 and 2016, the Company had 
$1.7  billion  and  $2.1  billion  of  these  short-term  loans 
outstanding, measured at fair value, respectively.

The loans from the Company’s sales and trading business 
are  commercial  and  corporate  leveraged  loans  that  are  either 
traded  in  the  market  or  for  which  similar  loans  trade.  The 
Company elected to measure these loans at fair value since they 
are actively traded. For each of the years ended December 31, 
2017, 2016, and 2015, the Company recognized an immaterial 
amount  of  gains/(losses)  in  the  Consolidated  Statements  of 
Income due to changes in fair value attributable to instrument-
specific credit risk. The Company is able to obtain fair value 
estimates for substantially all of these loans through a third party 
valuation  service  that  is  broadly  used  by  market  participants. 
While most of the loans are traded in the market, the Company 
does not believe that trading activity qualifies the loans as level 
1  instruments,  as  the  volume  and  level  of  trading  activity  is 
subject to variability and the loans are not exchange-traded. At 
December  31,  2017  and  2016,  $48  million  and  $46  million, 
respectively, of loans related to the Company’s trading business 
were held in inventory.

SBA loans are similar to SBA securities discussed herein 
under “Federal agency securities,” except for their legal form. 
In  both  cases,  the  Company  trades  instruments  that  are  fully 
guaranteed by the U.S. government as to contractual principal 
and interest and there is sufficient observable trading activity 
upon which to base the estimate of fair value. As these SBA loans 
are fully guaranteed, the changes in fair value are attributable to 
factors other than instrument-specific credit risk. At December 
31, 2017 and 2016, the Company held $368 million and $310 
million of SBA loans in inventory, respectively.

Loans Held for Sale and Loans Held for Investment
Residential Mortgage LHFS
The  Company  values  certain  newly-originated  residential 
mortgage LHFS at fair value based upon defined product criteria. 
The Company chooses to fair value these residential mortgage 
LHFS to eliminate the complexities and inherent difficulties of 
achieving hedge accounting and to better align reported results 
with the underlying economic changes in value of the loans and 
related hedge instruments. Any origination fees are recognized 
within Mortgage production related income in the Consolidated 
Statements of Income when earned at the time of closing. The 
servicing value is included in the fair value of the loan and is 
initially recognized at the time the Company enters into IRLCs 
with borrowers. The Company employs derivative instruments 
to economically hedge changes in interest rates and the related 
impact on servicing value in the fair value of the loan. The mark-
to-market  adjustments  related  to  LHFS  and  the  associated 
economic hedges are captured in Mortgage production related 
income.

LHFS classified as level 2 are primarily agency loans which 
trade in active secondary markets and are priced using current 
market  pricing  for  similar  securities,  adjusted  for  servicing, 
interest  rate  risk,  and  credit  risk.  Non-agency  residential 

mortgage  LHFS  are  also  included  in  level  2.  The  Company 
transferred certain residential mortgage LHFS into level 3 during 
the years ended December 31, 2017 and 2016. These transfers 
were  largely  due  to  borrower  defaults  or  the  identification  of 
other loan defects impacting the marketability of the loans. At 
December 31, 2017, the Company had no residential mortgage 
LHFS  classified  as  level  3 AFS  as  these  loans  were  sold  or 
transferred out of level 3 during 2017.

For residential mortgages that the Company has elected to 
measure at fair value, the Company recognized an immaterial 
amount  of  gains/(losses)  in  the  Consolidated  Statements  of 
Income due to changes in fair value attributable to borrower-
specific credit risk for each of the years ended December 31, 
2017, 2016, and 2015. In addition to borrower-specific credit 
risk, there are other more significant variables that drive changes 
in the fair values of the loans, including interest rates and general 
market conditions.

Commercial Mortgage LHFS
The Company values certain commercial mortgage LHFS at fair 
value based upon observable current market prices for similar 
loans. These loans are generally transferred to agencies within 
90 days of origination. The Company had commitments from 
agencies to purchase these loans at December 31, 2017 and 2016; 
therefore,  they  are  classified  as  level  2.  Origination  fees  are 
recognized within commercial real estate related income in the 
Consolidated Statements of Income when earned at the time of 
closing. To mitigate the effect of interest rate risk inherent in 
entering into IRLCs with borrowers, the Company enters into 
forward contracts with investors at the same time that it enters 
into  IRLCs  with  borrowers.  The  mark-to-market  adjustments 
related  to  commercial  mortgage  LHFS,  IRLCs,  and  forward 
contracts  are  recognized  in  Commercial  real  estate  related 
income.  For  commercial  mortgages  that  the  Company  has 
elected  to  measure  at  fair  value,  the  Company  recognized  no 
gains/(losses) in the Consolidated Statements of Income due to 
changes in fair value attributable to borrower-specific credit risk 
for each the years ended December 31, 2017, 2016, and 2015.

LHFI
LHFI  classified  as  level  3  includes  predominantly  mortgage 
loans that are not marketable, largely due to the identification of 
loan defects. The Company chooses to measure these mortgage 
LHFI  at  fair  value  to  better  align  reported  results  with  the 
underlying  economic  changes  in  value  of  the  loans  and  any 
related hedging instruments. The Company values these loans 
using a discounted cash flow approach based on assumptions 
that  are  generally  not  observable  in  current  markets,  such  as 
prepayment  speeds,  default  rates,  loss  severity  rates,  and 
discount rates. Level 3 LHFI also includes mortgage loans that 
are  valued  using  collateral  based  pricing.  Changes  in  the 
applicable  housing  price  index  since  the  time  of  the  loan 
origination  are  considered  and  applied  to  the  loan's  collateral 
value. An additional discount representing the return that a buyer 
would require is also considered in the overall fair value.

Residential Mortgage Servicing Rights
The Company records residential MSR assets at fair value using 
a discounted cash flow approach. The fair values of residential 
MSRs are impacted by a variety of factors, including prepayment 

145

Notes to Consolidated Financial Statements, continued

assumptions,  discount  rates,  delinquency  rates,  contractually 
specified  servicing  fees,  servicing  costs,  and  underlying 
portfolio  characteristics.  The  underlying  assumptions  and 
estimated  values  are  corroborated  by  values  received  from 
independent third parties based on their review of the servicing 
portfolio, and comparisons to market transactions. Because these 
inputs are not transparent in market trades, residential MSRs are 
classified as level 3 assets. For additional information see Note 
9, "Goodwill and Other Intangible Assets."

Liabilities
Trading Liabilities and Derivative Instruments
Trading  liabilities  are  comprised  primarily  of  derivative 
contracts, including IRLCs that satisfy the criteria to be treated 
as derivative financial instruments, as well as various contracts 
(primarily  U.S.  Treasury  securities,  corporate  and  other  debt 
securities)  that  the  Company  uses  in  certain  of  its  trading 
businesses. The Company's valuation methodologies for these 
derivative  contracts  and  securities  are  consistent  with  those 
discussed  within  the  corresponding  sections  herein  under 
“Trading  Assets  and  Derivative  Instruments  and  Securities 
Available for Sale.”

During the second quarter of 2009, in connection with its 
sale of Visa Class B shares, the Company entered into a derivative 
contract whereby the ultimate cash payments received or paid, 
if any, under the contract are based on the ultimate resolution of 
the Litigation involving Visa. The fair value of the derivative is 
estimated based on the Company’s expectations regarding the 
ultimate 
that  Litigation.  The  significant 
unobservable inputs used in the fair value measurement of the 
derivative involve a high degree of judgment and subjectivity; 
accordingly, the derivative liability is classified as level 3. See 
Note  16,  "Guarantees,"  for  a  discussion  of  the  valuation 
assumptions.

resolution  of 

Brokered Time Deposits
The Company has elected to measure certain CDs that contain 
embedded derivatives at fair value. This fair value election better 
aligns  the  economics  of  the  CDs  with  the  Company’s  risk 
management  strategies.  The  Company  evaluated,  on  an 
instrument by instrument basis, whether a new issuance would 
be measured at fair value.

The Company has classified CDs measured at fair value as 
level 2 instruments due to the Company's ability to reasonably 
measure  all  significant  inputs  based  on  observable  market 
variables.  The  Company  employs  a  discounted  cash  flow 
approach based on observable market interest rates for the term 
of  the  CD  and  an  estimate  of  the  Bank's  credit  risk.  For  any 
embedded  derivative  features,  the  Company  uses  the  same 
valuation methodologies as if the derivative were a standalone 
derivative, as discussed herein under "Derivative instruments."

Long-term Debt
The Company has elected to measure at fair value certain fixed 
rate issuances of public debt that are valued by obtaining price 
indications from a third party pricing service and utilizing broker 
quotes  to  corroborate  the  reasonableness  of  those  marks. 
Additionally, information from market data of recent observable 
trades and indications from buy side investors, if available, are 
taken into consideration as additional support for the value. Due 
to the availability of this information, the Company determined 
that the appropriate classification for these debt issuances is level 
2.  The  Company  utilizes  derivative  instruments  to  convert 
interest rates on its fixed rate debt to floating rates. The Company 
elected to measure certain fixed rate debt issuances at fair value 
to  align  the  accounting  for  the  debt  with  the  accounting  for 
offsetting derivative positions, without having to apply complex 
hedge accounting.

146

Notes to Consolidated Financial Statements, continued

The valuation technique and range, including weighted average, of the unobservable inputs associated with the Company's level 3 
assets and liabilities are as follows:

(Dollars in millions)
Assets
Trading assets and derivative instruments:

Fair value 
December 31, 
2017

 Level 3 Significant Unobservable Input Assumptions

Valuation Technique

Unobservable Input 1

Range 
(weighted average)

Derivative instruments, net 2

$— Internal model

Pull through rate
MSR value

41-100% (81%)
41-190 bps (113 bps)

Securities AFS:

MBS - non-agency residential
ABS
Corporate and other debt securities
Other equity securities

LHFI

Residential MSRs

Third party pricing
59
Third party pricing
8
Cost
5
418
Cost
192 Monte Carlo/

Discounted cash
flow

N/A
N/A
N/A
N/A
Option adjusted spread
Conditional prepayment 

rate

62-784 bps (215 bps)

2-34 CPR (11 CPR)

4

Collateral based

pricing

1,710 Monte Carlo/

Discounted cash
flow

Conditional default rate
Appraised value

0-5 CDR (0.7 CDR)
NM 3

Conditional prepayment 

rate

6-30 CPR (13 CPR)

Option adjusted spread

1-125% (4%)

1 For certain assets and liabilities where the Company utilizes third party pricing, the unobservable inputs and their ranges are not reasonably available, and therefore, 
have been noted as not applicable ("N/A").
2 Amount represents the net of IRLC assets and liabilities and includes the derivative liability associated with the Company's sale of Visa shares. Refer to the "Trading 
Liabilities and Derivative Instruments" section herein for a discussion of valuation assumptions related to the Visa derivative liability.
3 Not meaningful. 

(Dollars in millions)
Assets
Trading assets and derivative instruments:

Fair value
December 31,
2016

 Level 3 Significant Unobservable Input Assumptions

Valuation Technique

Unobservable Input 1

Range 
(weighted average)

Derivative instruments, net 2

$6

Internal model

Pull through rate
MSR value

40-100% (81%)
22-170 bps (106 bps)

Securities AFS:

U.S. states and political subdivisions
MBS - non-agency residential
ABS
Corporate and other debt securities
Other equity securities

Residential LHFS

LHFI

Residential MSRs

Cost
4
Third party pricing
74
Third party pricing
10
Cost
5
540
Cost
12 Monte Carlo/

Discounted cash
flow

219 Monte Carlo/

Discounted cash
flow

3

Collateral based

pricing

1,572 Monte Carlo/

Discounted cash 
flow

N/A
N/A
N/A
N/A
N/A
Option adjusted spread
Conditional prepayment rate
Conditional default rate
Option adjusted spread
Conditional prepayment rate
Conditional default rate
Appraised value

104-125 bps (124 bps)
2-28 CPR (7 CPR)
0-3 CDR (0.4 CDR)
62-784 bps (184 bps)
3-36 CPR (13 CPR)
0-5 CDR (2.1 CDR)
NM 3

Conditional prepayment rate

1-25 CPR (9 CPR)

Option adjusted spread

0-122% (8%)

1 For certain assets and liabilities where the Company utilizes third party pricing, the unobservable inputs and their ranges are not reasonably available, and therefore, 
have been noted as not applicable ("N/A").
2 Amount represents the net of IRLC assets and liabilities and includes the derivative liability associated with the Company's sale of Visa shares. Refer to the "Trading 
Liabilities and Derivative Instruments" section herein for a discussion of valuation assumptions related to the Visa derivative liability.
3 Not meaningful.

147

Notes to Consolidated Financial Statements, continued

The following tables present a reconciliation of the beginning 
and ending balances for assets and liabilities measured at fair 
value on a recurring basis using significant unobservable inputs 
(other  than  servicing  rights  which  are  disclosed  in  Note  9, 
“Goodwill and Other Intangible Assets”). Transfers into and out 
of the fair value hierarchy levels are assumed to occur at the end 

of the period in which the transfer occurred. None of the transfers 
into or out of level 3 have been the result of using alternative 
valuation  approaches  to  estimate  fair  values.  There  were  no 
transfers between level 1 and 2 during the years ended December 
31, 2017 and 2016.

Fair Value Measurements
Using Significant Unobservable Inputs

Beginning
Balance
January 1,
2017

Included
in
Earnings

OCI

Purchases

Sales

Settlements

Transfers
to/from
Other
Balance
Sheet
Line Items

Transfers
into
Level 3

Transfers
out of
Level 3

Fair Value 
December 31,
2017

Included in 
Earnings 
(held at 
December 31, 
2017 1)

$6

4

74

10

5

540

633

12

222

$185 2

$—

$—

$—

$—

($191)

$—

$—

$—

$12 2

—

(1)

—

—

1

—

—

—

—

1 3
1 3

—

(1) 3
1 3

—

—

—

—

—

—

75

75

—

—

—

—

—

—

(1)

(1)

(25)

—

(4)

(15)

(3)

—

(191)

(213)

(1)

(34)

—

—

—

—

—

—

(4)

3

—

—

—

—

—

—

26

5

—

—

—

—

(5)

(5)

(8)

—

—

59

8

5

418

490

—

196

—

(1)

—

—

—

(1)

—
(1) 4

(Dollars in millions)

Assets

Trading assets:

Derivative

instruments, net

Securities AFS:

U.S. states and
political
subdivisions

MBS - non-agency
residential

ABS

Corporate and other
debt securities

Other equity
securities

Total securities AFS

Residential LHFS

LHFI

1 Change in unrealized gains/(losses) included in earnings during the period related to financial assets still held at December 31, 2017.
2 Includes issuances, fair value changes, and expirations. Amount related to residential IRLCs is recognized in Mortgage production related income, amount related 
to commercial IRLCs is recognized in Commercial real estate related income, and amount related to Visa derivative liability is recognized in Other noninterest 
expense.
3 Amounts recognized in OCI are included in change in net unrealized gains on securities AFS, net of tax.
4 Amounts are generally included in Mortgage production related income; however, the mark on certain fair value loans is included in Other noninterest income.

148

 
Notes to Consolidated Financial Statements, continued

Fair Value Measurements
Using Significant Unobservable Inputs

Beginning
Balance
January 1,
2016

Included
in
Earnings

OCI

Purchases

Sales

Settlements

Transfers to/
from Other
Balance
Sheet
Line Items

Transfers
into
Level 3

Transfers
out of
Level 3

Fair Value 
December 31, 
2016

Included in 
Earnings 
(held at 
December 31,
2016 1)

$89

15

104

5

94

12

5

440

556

5

257

23

($1) 2

$—

$— ($88)

$—

198 3

197

—

—

—

—

—

—

(1) 5
(2) 5

—

—

—

—

1 4
1 4

—

—
2 4

—

—

—

2

2

—

—

—

—

308

308

—

—

—

—

(88)

—

—

—

—

—

—

(35)

—

—

2

2

(1)

(21)

(3)

—

(208)

(233)

—

(44)

(23)

$—

(211)

(211)

—

—

—

—

—

—

(5)

1

—

$—

—

—

—

—

—

—

—

—

52

10

—

$—

—

—

—

—

—

—

—

—

(4)

—

—

$—

6

6

4

74

10

5

540

633

12

222

—

$—

7 3

7

—

—

—

—

—

—

(1) 5
(2) 5

—

(Dollars in millions)

Assets

Trading assets:

Corporate and other
debt securities

Derivative

instruments, net

Total trading assets

Securities AFS:

U.S. states and
political
subdivisions

MBS - non-agency
residential

ABS

Corporate and other
debt securities

Other equity
securities

Total securities AFS

Residential LHFS

LHFI

Liabilities

Other liabilities

1 Change in unrealized gains/(losses) included in earnings during the period related to financial assets/liabilities still held at December 31, 2016.
2 Amounts included in earnings are recognized in Trading income.
3 Includes issuances, fair value changes, and expirations. Amount related to residential IRLCs is recognized in Mortgage production related income and amount 
related to Visa derivative liability is recognized in Other noninterest expense.
4 Amounts recognized in OCI are included in change in net unrealized gains/(losses) on securities AFS, net of tax.
5 Amounts are generally included in Mortgage production related income; however, the mark on certain fair value loans is included in Other noninterest income.

149

 
Notes to Consolidated Financial Statements, continued

Non-recurring Fair Value Measurements
The  following  tables  present  losses  recognized  on  assets  still 
held at period end, and measured at fair value on a non-recurring 
basis, for the year ended December 31, 2017 and the year ended 
December 31, 2016. Adjustments to fair value generally result 

(Dollars in millions)
LHFS
LHFI
OREO
Other assets

(Dollars in millions)
LHFI
OREO
Other assets

December 31, 2017
$13
49
24
53

December 31, 2016
$75
17
112

from  the  application  of  LOCOM  or  through  write-downs  of 
individual assets. The tables do not reflect changes in fair value 
attributable to economic hedges the Company may have used to 
mitigate interest rate risk associated with LHFS.

Fair Value Measurements

Level 1

Level 2

Level 3

Losses for the
Year Ended
December 31, 2017

$—
—
—
—

$13
—
1
4

$—
49
23
49

$—
—
(4)
(43)

Fair Value Measurements

Level 1

Level 2

Level 3

Losses for the
Year Ended
December 31, 2016

$—
—
—

$—
—
58

$75
17
54

$—
(2)
(36)

Discussed below are the valuation techniques and inputs used in estimating fair values for assets measured at fair value on a non-
recurring basis and classified as level 2 and/or 3.

Loans Held for Sale
At December 31, 2017, LHFS classified as level 2 consisted of 
commercial  loans  that  were  valued  using  market  prices  and 
measured  at  LOCOM.  During  the  year  ended  December  31, 
2017,  the  Company  transferred  $31  million  of  C&I  NPLs  to 
LHFS as the Company elected to actively market these loans for 
sale. As  a  result  of  transferring  the  C&I  NPLs  to  LHFS,  the 
Company recognized a $5 million charge-off to reflect the loans' 
estimated market value. These transferred C&I NPLs were sold 
during the fourth quarter of 2017 at a price approximating their 
carrying  values.  There  were  no  gains/(losses)  recognized  in 
earnings during the year ended December 31, 2017 as the charge-
offs related to these loans are a component of the ALLL.

Loans Held for Investment
At December 31, 2017 and 2016, LHFI consisted primarily of 
consumer loans discharged in Chapter 7 bankruptcy that had not 
been reaffirmed by the borrower, as well as nonperforming CRE 
loans  for  which  specific  reserves  had  been  recognized.  Cash 
proceeds from the sale of the underlying collateral is the expected 
source of repayment for a majority of these loans. Accordingly, 
the fair value of these loans is derived from the estimated fair 
value of the underlying collateral, incorporating market data if 
available. There were no gains/(losses) recognized during the 
year  ended  December  31,  2017  or  during  the  year  ended 
December 31, 2016, as the charge-offs related to these loans are 
a component of the ALLL. Due to the lack of market data for 
similar assets, all of these loans are classified as level 3.

OREO
OREO is measured at the lower of cost or fair value less costs 
to sell. Level 2 OREO consists primarily of residential homes, 
commercial  properties,  and  vacant  lots  and  land  for  which 
binding  purchase  agreements  exist.  Level  3  OREO  consists 
primarily  of  residential  homes,  commercial  properties,  and 
vacant lots and land for which initial valuations are based on 

property-specific appraisals, broker pricing opinions, or other 
limited,  highly  subjective  market  information.  Updated  value 
estimates are received regularly for level 3 OREO.

Other Assets
Other  assets  consists  of  cost  and  equity  method  investments, 
other repossessed assets, assets under operating leases where the 
Company is the lessor, branch properties, land held for sale, and 
software.

Investments  in  cost  and  equity  method  investments  are 
evaluated  for  potential  impairment  based  on  the  expected 
remaining cash flows to be received from these assets discounted 
at a market rate that is commensurate with the expected risk, 
considering  relevant  Company-specific  valuation  multiples, 
where  applicable.  Based  on  the  valuation  methodology  and 
associated unobservable inputs, these investments are classified 
as  level  3.  During  the  year  ended  December  31,  2017,  the 
Company  recognized  an  immaterial  amount  of  impairment 
charges  on  is  equity  investments.  During  the  year  ended 
December 31,  2016,  the  Company  recognized  impairment 
charges of $8 million on its equity investments. 

Other  repossessed  assets  comprises  repossessed  personal 
property that is measured at fair value less cost to sell. These 
assets are classified as level 3 as their fair value is determined 
based  on  a  variety  of  subjective,  unobservable  factors. There 
were no losses recognized in earnings by the Company on other 
repossessed assets during the year ended December 31, 2017 or 
during the year ended December 31, 2016, as the impairment 
charges on repossessed personal property were a component of 
the ALLL. 

The  Company  monitors  the  fair  value  of  assets  under 
operating leases where the Company is the lessor and recognizes 
impairment on the leased asset to the extent the carrying value 
is not recoverable and is greater than its fair value. Fair value is 
determined  using  collateral  specific  pricing  digests,  external 
appraisals,  broker  opinions,  recent  sales  data  from  industry 

150

Notes to Consolidated Financial Statements, continued

equipment dealers, and the discounted cash flows derived from 
the underlying lease agreement. As market data for similar assets 
and lease arrangements is available and used in the valuation, 
these assets are considered level 2. The Company recognized an 
immaterial amount of impairment charges during the year ended 
December 31, 2017 attributable to changes in the fair value of 
various personal property under operating leases. During the year 
ended December 31, 2016, the Company recognized impairment 
charges of $12 million attributable to changes in the fair value 
of various personal property under operating leases.

Branch properties are classified as level 3, as their fair value 
is based on market comparables and broker opinions. During the 
year  ended  December  31,  2017  and  2016,  the  Company 
recognized impairment charges of $10 million and $12 million 
on branch properties, respectively.

Land held for sale is recorded at the lesser of carrying value 
or fair value less cost to sell, and is considered level 3 as its fair 
value is determined based on market comparables and broker 
opinions. The  Company  recognized  an  immaterial  amount  of 
impairment charges on land held for sale for each of the years 
ended December 31, 2017 and 2016.

Software consisted primarily of external software licenses 
and internally developed software classified as level 3, as their 
fair  value  is  based  on  unobservable  vendor  pricing  and 
capitalized  software  development  costs.  The  Company 
recognized impairment charges of $28 million during the year 
ended December 31, 2017. During the year ended December 31, 
2016,  the  Company  recognized  no  impairment  charges  on 
software.

Fair Value of Financial Instruments
The carrying amounts and fair values of the Company’s financial instruments are as follows:

(Dollars in millions)

Financial assets:

Cash and cash equivalents

Trading assets and derivative instruments

Securities AFS

LHFS

LHFI, net

Financial liabilities:

Deposits

Short-term borrowings

Long-term debt

Trading liabilities and derivative instruments

(Dollars in millions)

Financial assets:

Cash and cash equivalents

Trading assets and derivative instruments

Securities AFS
LHFS

LHFI, net

Financial liabilities:

Deposits

Short-term borrowings

Long-term debt

Trading liabilities and derivative instruments

December 31, 2017

Carrying
Amount

Fair
Value

Fair Value Measurements

Level 1

Level 2

Level 3

$6,912

5,093

31,416

2,290

$6,912

5,093

31,416

2,293

141,446

141,575

160,780

160,586

4,781

9,785

1,283

4,781

9,892

1,283

$6,912

608

4,382

—

—

—

—

—

769

$—

4,469

26,544

2,239

—

160,586

4,781

8,834

498

$— (a) 
16 (b) 
490 (b) 

54 (c) 

141,575 (d)

— (e) 
— (f) 
1,058 (f) 
16 (b) 

December 31, 2016

Carrying
Amount

Fair
Value

Fair Value Measurements

Level 1

Level 2

Level 3

$6,423

6,067

30,672
4,169

$6,423

6,067

30,672
4,178

141,589

140,516

160,398

4,764

11,748

1,351

160,280

4,764

11,779

1,351

$6,423

881

5,507
—

—

—

—

—

846

$—

5,158

24,532
4,161

282

160,280

4,764

11,051

483

$— (a) 

28 (b) 

633 (b) 
17 (c) 

140,234 (d)

— (e) 

— (f) 

728 (f) 

22 (b) 

The following methods and assumptions were used by the Company in estimating the fair value of financial instruments:

(a)  Cash  and  cash  equivalents  are  valued  at  their  carrying 
amounts, which are reasonable estimates of fair value due 
to the relatively short period to maturity of the instruments.
(b)  Trading assets and derivative instruments, securities AFS, 
and  trading  liabilities  and  derivative  instruments  that  are 
classified  as  level  1  are  valued  based  on  quoted  prices 
observed in active markets. For those instruments classified 

as level 2 or 3, refer to the respective valuation discussions 
within this footnote.

(c)  LHFS  are  generally  valued  based  on  observable  current 
market prices or, if quoted market prices are not available, 
quoted market prices of similar instruments. Refer to the 
LHFS  section  within  this  footnote  for  further  discussion. 
When valuation assumptions are not readily observable in 

151

 
 
 
 
 
 
Notes to Consolidated Financial Statements, continued

the  market,  instruments  are  valued  based  on  the  best 
available data to approximate fair value. This data may be 
internally  developed  and  considers  risk  premiums  that  a 
market participant would require under then-current market 
conditions.

(d)  LHFI  fair  values  are  based  on  a  hypothetical  exit  price, 
which does not represent the estimated intrinsic value of the 
loan  if  held  for  investment.  The  assumptions  used  are 
expected  to  approximate  those  that  a  market  participant 
purchasing the loans would use to value the loans, including 
a market risk premium and liquidity discount. Estimating 
the  fair  value  of  the  loan  portfolio  when  loan  sales  and 
trading  markets  are  illiquid  or  nonexistent  requires 
significant judgment.

Generally, the Company measures fair value for LHFI 
based  on  estimated  future  discounted  cash  flows  using 
current origination rates for loans with similar terms and 
credit quality, which derived an estimated value of 101% on 
the loan portfolio’s net carrying value at both December 31, 
2017 and 2016. The value derived from origination rates 
likely  does  not  represent  an  exit  price;  therefore,  an 
incremental market risk and liquidity discount was applied 
when estimating the fair value of these loans. The discounted 
value is a function of a market participant’s required yield 
in  the  current  environment  and  is  not  a  reflection  of  the 
expected cumulative losses on the loans.

(e)  Deposit liabilities with no defined maturity such as DDAs, 
NOW/money market accounts, and savings accounts have 
a fair value equal to the amount payable on demand at the 
reporting date (i.e., their carrying amounts). Fair values for 
CDs are estimated using a discounted cash flow approach 
that applies current interest rates to a schedule of aggregated 
expected maturities. The assumptions used in the discounted 

cash flow analysis are expected to approximate those that 
market participants would use in valuing deposits. The value 
of long-term relationships with depositors is not taken into 
account  in  estimating  fair  values.  Refer  to  the  respective 
valuation  section  within  this  footnote  for  valuation 
information  related  to  brokered  time  deposits  that  the 
Company measures at fair value as well as those that are 
carried at amortized cost.

(f)  Fair values for short-term borrowings and certain long-term 
debt  are  based  on  quoted  market  prices  for  similar 
instruments or estimated discounted cash flows utilizing the 
Company’s current incremental borrowing rate for similar 
types  of  instruments.  Refer  to  the  respective  valuation 
section within this footnote for valuation information related 
to long-term debt that the Company measures at fair value. 
For level 3 debt, the terms are unique in nature or there are 
no  similar  instruments  that  can  be  used  to  value  the 
instrument  without  using 
significant  unobservable 
assumptions.

Unfunded  loan  commitments  and  letters  of  credit  are  not 
included in the table above. At December 31, 2017 and 2016, 
the Company had $66.4 billion and $67.2 billion, respectively, 
of unfunded commercial loan commitments and letters of credit. 
A reasonable estimate of the fair value of these instruments is 
the  carrying  value  of  deferred  fees  plus  the  related  unfunded 
commitments reserve, which was a combined $84 million and 
$71 million at December 31, 2017 and 2016, respectively. No 
active  trading  market  exists  for  these  instruments,  and  the 
estimated fair value does not include value associated with the 
borrower relationship. The Company does not estimate the fair 
values of consumer unfunded lending commitments which can 
generally be canceled by providing notice to the borrower.

152

Notes to Consolidated Financial Statements, continued

NOTE 19 – CONTINGENCIES

Litigation and Regulatory Matters

In  the  ordinary  course  of  business,  the  Company  and  its 
subsidiaries are parties to numerous civil claims and lawsuits 
and  subject  to  regulatory  examinations,  investigations,  and 
requests for information. Some of these matters involve claims 
for substantial amounts. The Company’s experience has shown 
that  the  damages  alleged  by  plaintiffs  or  claimants  are  often 
overstated, based on unsubstantiated legal theories, unsupported 
by facts, and/or bear no relation to the ultimate award that a court 
might  grant.  Additionally,  the  outcome  of  litigation  and 
regulatory  matters  and  the  timing  of  ultimate  resolution  are 
inherently difficult to predict. These factors make it difficult for 
the Company to provide a meaningful estimate of the range of 
reasonably possible outcomes of claims in the aggregate or by 
individual claim. However, on a case-by-case basis, reserves are 
established for those legal claims in which it is probable that a 
loss  will  be  incurred  and  the  amount  of  such  loss  can  be 
reasonably  estimated.  The  Company's  financial  statements  at 
December 31, 2017 reflect the Company's current best estimate 
of probable losses associated with these matters, including costs 
to comply with various settlement agreements, where applicable. 
The actual costs of resolving these claims may be substantially 
higher or lower than the amounts reserved.

these 

to  range  from  $0 

For a limited number of legal matters in which the Company 
is involved, the Company is able to estimate a range of reasonably 
possible losses in excess of related reserves, if any. Management 
to 
losses 
currently  estimates 
approximately $160 million. This estimated range of reasonably 
possible losses represents the estimated possible losses over the 
life  of  such  legal  matters,  which  may  span  a  currently 
indeterminable  number  of  years,  and  is  based  on  information 
available  at  December 31,  2017.  The  matters  underlying  the 
estimated range will change from time to time, and actual results 
may  vary  significantly  from  this  estimate.  Those  matters  for 
which an estimate is not possible are not included within this 
estimated  range;  therefore,  this  estimated  range  does  not 
represent  the  Company’s  maximum  loss  exposure.  Based  on 
current  knowledge,  it  is  the  opinion  of  management  that 
liabilities  arising  from  legal  claims  in  excess  of  the  amounts 
currently reserved, if any, will not have a material impact on the 
Company’s  financial  condition,  results  of  operations,  or  cash 
flows. However, in light of the significant uncertainties involved 
in these matters and the large or indeterminate damages sought 
in some of these matters, an adverse outcome in one or more of 
these  matters  could  be  material  to  the  Company’s  financial 
condition,  results  of  operations,  or  cash  flows  for  any  given 
reporting period.

The following is a description of certain litigation and regulatory 
matters:

Card Association Antitrust Litigation
The Company is a defendant, along with Visa and MasterCard, 
as  well  as  several  other  banks,  in  several  antitrust  lawsuits 
challenging  their  practices.  For  a  discussion  regarding  the 
Company’s involvement in this litigation matter, see Note 16, 
“Guarantees.”

153

Bickerstaff v. SunTrust Bank
This case was filed in the Fulton County State Court on July 12, 
2010, and an amended complaint was filed on August 9, 2010. 
Plaintiff  asserts  that  all  overdraft  fees  charged  to  his  account 
which related to  debit card and ATM  transactions are actually 
interest charges and therefore subject to the usury laws of Georgia. 
Plaintiff has brought claims for violations of civil and criminal 
usury  laws,  conversion,  and  money  had  and  received,  and 
purports to bring the action on behalf of all Georgia citizens who 
incurred  such  overdraft  fees  within  the  four  years  before  the 
complaint was filed where the overdraft fee resulted in an interest 
rate being charged in excess of the usury rate. On April 8, 2013, 
the plaintiff filed a motion for class certification and that motion 
was denied but the ruling was later reversed and remanded by the 
Georgia  Supreme  Court.  On  October  6,  2017,  the  trial  court 
granted plaintiff's motion for class certification and the Bank filed 
an appeal of the decision on November 3, 2017. 

ERISA Class Actions
Company Stock Class Action
Beginning  in  July  2008,  the  Company  and  certain  officers, 
directors, and employees of the Company were named in a class 
action alleging that they breached their fiduciary duties under 
ERISA  by  offering  the  Company's  common  stock  as  an 
investment option in the SunTrust Banks, Inc. 401(k) Plan (the 
“Plan”). The plaintiffs sought to represent all current and former 
Plan  participants  who  held  the  Company  stock  in  their  Plan 
accounts  from  May  15,  2007  to  March  30,  2011  and  seek  to 
recover alleged losses these participants supposedly incurred as 
a result of their investment in Company stock.

This case was originally filed in the U.S. District Court for 
the Southern District of Florida but was transferred to the U.S. 
District  Court  for  the  Northern  District  of  Georgia,  Atlanta 
Division (the “District Court”), in November 2008. Since the 
filing  of  the  case,  various  amended  pleadings,  motions,  and 
appeals were made by the parties that ultimately resulted in the 
District  Court  granting  a  motion  for  summary  judgment  for 
certain  non-fiduciary  defendants  and  granting  certain  of  the 
plaintiffs' motion for class certification. The class is defined as 
"All  persons,  other  than  Defendants  and  members  of  their 
immediate families, who were participants in or beneficiaries of 
the SunTrust Banks, Inc. 401(k) Savings Plan (the "Plan") at any 
time between May 15, 2007 and March 30, 2011, inclusive (the 
"Class  Period")  and  whose  accounts  included  investments  in 
SunTrust  common  stock  ("SunTrust  Stock")  during  that  time 
period and who sustained a loss to their account as a result of 
the investment in SunTrust Stock." Discovery has closed in the 
matter.  On  February  22,  2018,  the  Company  informed  the 
District Court that it had reached an agreement in principle with 
class counsel to settle this class action, subject to court approval.

Mutual Funds Class Actions
On March 11, 2011, the Company and certain officers, directors, 
and employees of the Company were named in a putative class 
action alleging that they breached their fiduciary duties under 
ERISA  by  offering  certain  STI  Classic  Mutual  Funds  as 
investment options in the Plan. The plaintiffs purport to represent 
all current and former Plan participants who held the STI Classic 
Mutual Funds in their Plan accounts from April 2002 through 

Notes to Consolidated Financial Statements, continued

December 2010 and seek to recover alleged losses these Plan 
participants supposedly incurred as a result of their investment 
in the STI Classic Mutual Funds. This action is pending in the 
U.S. District Court for the Northern District of Georgia, Atlanta 
Division (the “District Court”). Subsequently, plaintiffs' counsel 
initiated  a  substantially  similar  lawsuit  against  the  Company 
naming two new plaintiffs. On June 27, 2014, Brown, et al. v. 
SunTrust Banks, Inc., et al., another putative class action alleging 
breach of fiduciary duties associated with the inclusion of STI 
Classic  Mutual  Funds  as  investment  options  in  the  Plan,  was 
filed in the U.S. District Court for the District of Columbia but 
then was transferred to the District Court.

After  various  appeals,  the  cases  were  remanded  to  the 
District  Court.  On  March  25,  2016,  a  consolidated  amended 
complaint was filed, consolidating all of these pending actions 
into one case. The Company filed an answer to the consolidated 
amended complaint on June 6, 2016. Subsequent to the closing 
of  fact  discovery,  plaintiffs  filed  their  second  amended 
consolidated  complaint  on  December  19,  2017  which  among 
other things named five new defendants. On January 2, 2018, 
the  second  amended 
defendants  filed 
consolidated complaint.

their  answer 

to 

Intellectual Ventures II v. SunTrust Banks, Inc. and 
SunTrust Bank
This action was filed in the U.S. District Court for the Northern 
District  of  Georgia  on  July  24,  2013.  Plaintiff  alleged  that 
SunTrust violates five patents held by plaintiff in connection with 
SunTrust’s  provision  of  online  banking  services  and  other 
systems and services. Plaintiff seeks damages for alleged patent 
infringement of an unspecified amount, as well as attorney’s fees 
and expenses. The matter was stayed on October 7, 2014 pending 
inter partes reviews of a number of the claims asserted against 
SunTrust. After completion of those reviews, plaintiff dismissed 
its claims regarding four of the five patents on August 1, 2017.

Consent Order with the Federal Reserve
On April 13, 2011, SunTrust, SunTrust Bank, and STM entered 
into a Consent Order with the FRB in which SunTrust, SunTrust 
Bank, and STM agreed to strengthen oversight of, and improve 
risk  management,  internal  audit,  and  compliance  programs 
concerning  the  residential  mortgage  loan  servicing,  loss 
mitigation, and foreclosure activities of STM. On January 12, 
2018, the FRB terminated the Consent Order without penalty, 
finding 
the  Company  has  demonstrated  sustained 
improvements  in  oversight  and  mortgage  loan  servicing  and 
foreclosure practice.

that 

United States Mortgage Servicing Settlement
In the second quarter of 2014, STM and the U.S., through the 
DOJ, HUD, and Attorneys General for several states, reached a 
final  settlement  agreement  related  to  the  National  Mortgage 
Servicing  Settlement.  The  settlement  agreement  became 
effective  on  September  30,  2014  when  the  court  entered  the 
Consent Judgment. Pursuant to the settlements, STM made $50 
million in cash payments, provided $500 million of consumer 
relief, and implemented certain mortgage servicing standards. 
In an August 10, 2017 report, the independent Office of Mortgage 
Settlement  Oversight  ("OMSO"),  appointed  to  review  and 
certify  compliance  with  the  provisions  of  the  settlement, 

154

confirmed  that  the  Company  fulfilled  its  consumer  relief 
commitments of the settlement. STM's compliance with certain 
mortgage servicing standards continues to be monitored, tested, 
and reported quarterly by an internal review group and semi-
annually  by  the  OMSO. The  Company  does  not  expect  costs 
associated with remaining servicing standard obligations to have 
a material impact on the Company's financial results.

United States Attorney’s Office for the Southern District of 
New York Foreclosure Expense Investigation
In April 2013, STM began cooperating with the United States 
Attorney's  Office  for  the  Southern  District  of  New York  (the 
"Southern  District")  in  a  broad-based  industry  investigation 
regarding  claims  for  foreclosure-related  expenses  charged  by 
law firms in connection with the foreclosure of loans guaranteed 
or  insured  by  Fannie  Mae,  Freddie  Mac,  or  FHA. The 
investigation relates to a private litigant qui tam lawsuit filed 
under seal and remains in early stages. The Southern District has 
not  yet  advised  STM  how  it  will  proceed  in  this  matter. The 
Southern  District  and  STM  engaged  in  dialogue  regarding 
potential  resolution  of  this  matter  as  part  of  the  National 
Mortgage  Servicing  Settlement,  but  were  unable  to  reach 
agreement.

LR Trust v. SunTrust Banks, Inc., et al. 
In  November  2016,  the  Company  and  certain  officers  and 
directors were named as defendants in a shareholder derivative 
action alleging that defendants failed to take action related to 
activities at issue in the National Mortgage Servicing, HAMP, 
and  FHA  Originations  settlements,  and  certain  other  legal 
matters  or  to  ensure  that  the  alleged  activities  in  each  were 
remedied  and  otherwise  appropriately  addressed.  Plaintiff 
sought  an  award  in  favor  of  the  Company  for  the  amount  of 
damages  sustained  by  the  Company,  disgorgement  of  alleged 
benefits obtained by defendants, and enhancements to corporate 
governance and internal controls. On September 18, 2017, the 
court dismissed this matter and on October 16, 2017, Plaintiff 
filed an appeal.

Millennium Lender Claim Trust v. STRH and SunTrust 
Bank, et al.
In August 2017, the Trustee of the Millennium Lender Claim 
Trust filed a suit in the New York State Court against STRH, 
SunTrust Bank, and other lenders of the $1.775 B Millennium 
Health LLC f/k/a Millennium Laboratories LLC (“Millennium”) 
syndicated loan. The Trustee alleges that the loan was actually 
a security and that defendants misrepresented or omitted to state 
material  facts  in  the  offering  materials  and  communications 
provided  concerning  the  legality  of  Millennium's  sales, 
marketing, and billing practices and the known risks posed by a 
pending  government  investigation  into  the  illegality  of  such 
practices.  The  Trustee  brings  claims  for  violation  of  the 
California Corporate Securities Law, the Massachusetts Uniform 
Securities  Act,  the  Colorado  Securities  Act,  and  the  Illinois 
Securities Law, as well as negligent misrepresentation and seeks 
rescission of sales of securities as well as unspecified rescissory 
damages,  compensatory  damages,  punitive  damages,  interest, 
and attorneys' fees and costs. The defendants have removed the 
case to the U.S. District Court for the Southern District of New 
York.

Notes to Consolidated Financial Statements, continued

NOTE 20 - BUSINESS SEGMENT REPORTING

The Company operates and measures business activity across 
two  segments:  Consumer  and  Wholesale,  with  functional 
activities included in Corporate Other. In the second quarter of 
2017, the Company realigned its business segment structure from 
three segments to two segments based on, among other things, 
the  manner  in  which  financial  information  is  evaluated  by 
in  conjunction  with  Company-wide 
management  and 
organizational  changes  that  were  announced  during  the  first 
quarter of 2017. Specifically, the Company retained the previous 
composition of the Wholesale Banking segment and changed the 
basis  of  presentation  of  the  Consumer  Banking  and  Private 
Wealth Management segment and Mortgage Banking segment 
such that those segments were combined into a single Consumer 
segment. 

The  following  is  a  description  of  the  segments  and  their 

primary businesses at December 31, 2017.

The Consumer segment is made up of four primary businesses: 

•  Consumer  Banking  provides  services 

to 

individual 
consumers  and  branch-managed  small  business  clients 
through  an  extensive  network  of  traditional  and  in-store 
branches, ATMs, the internet (www.suntrust.com), mobile 
banking, and by telephone (1-800-SUNTRUST). Financial 
products  and  services  offered  to  consumers  and  small 
business clients include deposits and payments, loans, and 
various fee-based services. Consumer Banking also serves 
as an entry point for clients and provides services for other 
businesses.

the 

•  Consumer Lending offers an array of lending products to 
individual  consumers  and  small  business  clients  via  the 
Company's  Consumer  Banking  and  PWM  businesses, 
through 
and 
www.lightstream.com), as well as through various national 
offices  and  partnerships. Products  offered  include  home 
equity  lines,  personal  credit  lines  and  loans,  direct  auto, 
indirect auto, student lending, credit cards, and other lending 
products.

(www.suntrust.com 

internet 

• 

PWM provides a full array of wealth management products 
and  professional  services  to  individual  consumers  and 
institutional  clients,  including  loans,  deposits,  brokerage, 
professional  investment  advisory,  and  trust  services  to 
clients  seeking  active  management  of  their  financial 
resources. Institutional clients are served by the Institutional 
Investment  Solutions  business.  Discount/online  and  full-
service brokerage products are offered to individual clients 
through STIS. Investment advisory products and services 
are offered to clients by STAS, an SEC registered investment 
advisor. PWM also includes GFO, which provides family 
office solutions to ultra-high net worth individuals and their 
families.  Utilizing  teams  of  multi-disciplinary  specialists 
with  expertise  in  investments,  tax,  accounting,  estate 
planning, and other wealth management disciplines, GFO 
helps  clients  manage  and  sustain  wealth  across  multiple 
generations.

•  Mortgage  Banking  offers  residential  mortgage  products 
nationally through its retail and correspondent channels, the 
internet  (www.suntrust.com),  and  by  telephone  (1-800-

155

SUNTRUST).  These  products  are  either  sold  in  the 
secondary market, primarily with servicing rights retained, 
or held in the Company’s loan portfolio. Mortgage Banking 
also services loans for other investors, in addition to loans 
held in the Company’s loan portfolio.

The Wholesale segment is made up of three primary businesses 
and the Treasury & Payment Solutions product group: 

•  CIB  delivers  comprehensive  capital  markets  solutions, 
including  advisory,  capital  raising,  and  financial  risk 
management,  with  the  goal  of  serving  the  needs  of  both 
public and private companies in the Wholesale segment and 
PWM  business.  Investment  Banking  and  Corporate 
Banking teams within CIB serve clients across the nation, 
offering a full suite of traditional banking and investment 
banking  products  and  services  to  companies  with  annual 
revenues  typically  greater  than  $150  million.  Investment 
Banking  serves  select 
including 
consumer and retail, energy, technology, financial services, 
healthcare,  industrials,  and  media  and  communications. 
Corporate Banking serves clients across diversified industry 
sectors based on size, complexity, and frequency of capital 
markets  issuance.  Also  managed  within  CIB  is  the 
Equipment Finance Group, which provides lease financing 
solutions  (through  SunTrust  Equipment  Finance  & 
Leasing).

industry  segments 

•  Commercial  &  Business  Banking  offers  an  array  of 
traditional  banking  products,  including  lending,  cash 
management and investment banking solutions via STRH
to  commercial  clients  (generally  clients  with  revenues 
between  $1  million  and  $250  million),  not-for-profit 
organizations,  and  governmental  entities,  as  well  as  auto 
dealer financing (floor plan inventory financing). 

  On December 1, 2017, the Company completed the 
sale of PAC, its commercial lines insurance premium 
finance  subsidiary.  For  all  periods  presented,  the 
financial results of PAC, including the gain on the 
sale,  are  reflected  in  the  Wholesale  segment.  See 
Note  2,  "Acquisitions/Dispositions,"  for  additional 
information related to the sale of PAC.

•  Commercial Real Estate provides a full range of financial 
solutions for commercial real estate developers, owners, and 
including  construction,  mini-perm,  and 
operators, 
permanent real estate financing, as well as tailored financing 
and  equity  investment  solutions  via  STRH.  Commercial 
Real Estate also provides multi-family agency lending and 
servicing,  as  well  as  loan  administration,  advisory,  and 
commercial  mortgage  brokerage  services  via  Pillar.  The 
Institutional Property Group business targets relationships 
with  REITs,  pension  fund  advisors,  private  funds, 
homebuilders, and insurance companies and the Regional 
business  focuses  on  private  real  estate  owners  and 
developers 
structure. 
Commercial Real Estate also offers tailored financing and 
equity  investment  solutions  for  community  development 
and  affordable  housing  projects  through  STCC,  with 

regional  delivery 

through  a 

Notes to Consolidated Financial Statements, continued

•  Noninterest income – includes federal and state tax credits 
that  are  grossed-up  on  a  pre-tax  equivalent  basis,  related 
primarily to certain community development investments.

•  Provision for income taxes-FTE – is calculated using a 
blended  income  tax  rate  for  each  segment  and  includes 
reversals of the tax adjustments and credits described above. 
The difference between the calculated Provision for income 
taxes at the segment level and the consolidated Provision 
for income taxes is reported as reconciling items.

The  segment’s  financial  performance  is  comprised  of  direct 
financial results and allocations for various corporate functions 
that  provide  management  an  enhanced  view  of  the  segment’s 
financial  performance. 
the 
following:

Internal  allocations 

include 

•  Operational  costs  –  expenses  are  charged  to  segments 
based on a methodical activity-based costing process, which 
also allocates residual expenses to the segments. Generally, 
recoveries of these costs are reported in Corporate Other.

• 

Support  and  overhead  costs  –  expenses  not  directly 
attributable  to  a  specific  segment  are  allocated  based  on 
various drivers (number of equivalent employees, number 
of  PCs/laptops,  net  revenue,  etc.).  Recoveries  for  these 
allocations are reported in Corporate Other.

The  application  and  development  of  management  reporting 
methodologies  is  an  active  process  and  undergoes  periodic 
enhancements. The  implementation  of  these  enhancements  to 
the internal management reporting methodology may materially 
affect the results disclosed for each segment, with no impact on 
consolidated  results.  If  significant  changes  to  management 
reporting methodologies take place, the impact of these changes 
is  quantified  and  prior  period  information  is  revised,  when 
practicable.

In  the  second  quarter  of  2017,  in  conjunction  with  the 
aforementioned  business  segment  structure  realignment,  the 
Company made certain adjustments to its internal funds transfer 
pricing methodology. Prior period information was revised to 
conform to the new business segment structure and the updated 
internal funds transfer pricing methodology.

particular expertise in Low Income Housing Tax Credits and 
New Market Tax Credits.

•  Treasury & Payment Solutions provides Wholesale clients 
with  services  required  to  manage  their  payments  and 
receipts, combined with the ability to manage and optimize 
their deposits across all aspects of their business. Treasury 
&  Payment  Solutions  operates  all  electronic  and  paper 
payment types, including card, wire transfer, ACH, check, 
and cash. It also provides clients the means to manage their 
accounts  electronically  online,  both  domestically  and 
internationally.

instruments,  short-term 

Corporate  Other  includes  management  of  the  Company’s 
investment  securities  portfolio,  long-term  debt,  end  user 
derivative 
liquidity  and  funding 
activities, balance sheet risk management, and most real estate 
assets. Additionally,  Corporate  Other  includes  the  Company's 
functional activities such as marketing, SunTrust online, human 
resources, finance, ER, legal and compliance, communications, 
procurement,  enterprise  information  services,  corporate  real 
estate, and executive management.

Because  business  segment  results  are  presented  based  on 
management  accounting  practices, 
the 
consolidated results prepared under U.S. GAAP creates certain 
differences, which are reflected in Reconciling Items. Business 
segment reporting conventions are described below:

transition 

the 

to 

•  Net interest income-FTE – is reconciled from Net interest 
income and is grossed-up on an FTE basis to make income 
from  tax-exempt  assets  comparable  to  other  taxable 
products. Segment results reflect matched maturity funds 
transfer pricing, which ascribes credits or charges based on 
the economic value or cost created by assets and liabilities 
of  each  segment.  Differences  between  these  credits  and 
charges are captured as reconciling items. The change in this 
variance is generally attributable to corporate balance sheet 
management strategies.

•  Provision for credit losses – represents net charge-offs by 
segment combined with an allocation to the segments for 
the provision attributable to each segment's quarterly change 
in the ALLL and Unfunded commitments reserve balances.

156

Notes to Consolidated Financial Statements, continued

(Dollars in millions)

Balance Sheets:

Average LHFI

Average consumer and commercial deposits

Average total assets

Average total liabilities

Average total equity
Statements of Income:

Net interest income

FTE adjustment
Net interest income-FTE 1
Provision for credit losses 2

Net interest income after provision for credit losses-FTE

Total noninterest income

Total noninterest expense

Income before provision for income taxes-FTE
Provision for income taxes-FTE 3, 4

Net income including income attributable to noncontrolling interest

Less: Net income attributable to noncontrolling interest

Net income

Year Ended December 31, 2017
Corporate
Other

Reconciling
Items

Wholesale

Consolidated

$71,521

56,618

85,227

62,291

—

$76

175

34,567

14,610

—

($3)

(64)

2,630

(28)

24,301

$144,216

159,549

204,931

180,630

24,301

Consumer

$72,622

102,820

82,507

103,757

—

$3,698

$2,247

($44)

($268)

$5,633

—

3,698

368

3,330

1,874

3,842

1,362

491

871

—

$871

142

2,389

41

2,348

1,710

1,869

2,189

816

1,373

—

$1,373

3

(41)

—

(41)

(33)

73

(147)

(355)

208

9

$199

—

(268)

—

(268)

(197)

(20)

(445)

(275)

(170)

—

145

5,778

409

5,369

3,354

5,764

2,959

677

2,282

9

($170)

$2,273

1 Presented on a matched maturity funds transfer price basis for the segments.
2 Provision for credit losses represents net charge-offs by segment combined with an allocation to the segments for the provision attributable to quarterly changes in 
the ALLL and Unfunded commitment reserve balances.
3 Includes regular Provision for income taxes as well as FTE income and tax credit adjustment reversals.
4 Tax effects resulting from the 2017 Tax Act are included in Corporate Other.

(Dollars in millions)

Balance Sheets:

Average LHFI

Average consumer and commercial deposits

Average total assets

Average total liabilities

Average total equity
Statements of Income:

Net interest income

FTE adjustment
Net interest income-FTE 2
Provision for credit losses 3

Net interest income after provision for credit losses-FTE

Total noninterest income

Total noninterest expense

Income before provision for income taxes-FTE
Provision for income taxes-FTE 4

Net income including income attributable to noncontrolling interest

Less: Net income attributable to noncontrolling interest

Net income

Year Ended December 31, 2016 1
Corporate
Other

Reconciling
Items

Wholesale

Consolidated

$71,600

54,713

85,494

60,438

—

$66

124

31,952

14,148

—

($3)

(72)

2,440

(73)

24,068

$141,118

154,189

199,004

174,936

24,068

Consumer

$69,455

99,424

79,118

100,423

—

$3,465

$2,018

$101

($363)

$5,221

—

3,465

172

3,293

2,036

3,796

1,533

568

965

—

$965

136

2,154

272

1,882

1,356

1,676

1,562

583

979

—

$979

2

103

—

103

138

13

228

59

169

9

—

(363)

—

(363)

(147)

(17)

(493)

(267)

(226)

—

138

5,359

444

4,915

3,383

5,468

2,830

943

1,887

9

$160

($226)

$1,878

1 Beginning in the second quarter of 2017, the Company realigned its business segment structure from three segments to two segments. Specifically, the Company 
retained the previous composition of the Wholesale Banking segment and changed the basis of presentation of the Consumer Banking and Private Wealth Management 
segment and Mortgage Banking segment such that those segments were combined into a single Consumer segment. Accordingly, business segment information 
presented for the year ended December 31, 2016 has been revised to conform to the new business segment structure and updated internal funds transfer pricing 
methodology for consistent presentation.
2 Presented on a matched maturity funds transfer price basis for the segments.
3 Provision for credit losses represents net charge-offs by segment combined with an allocation to the segments for the provision attributable to quarterly changes in 
the ALLL and Unfunded commitment reserve balances.
4 Includes regular Provision for income taxes as well as FTE income and tax credit adjustment reversals.

157

 
 
Notes to Consolidated Financial Statements, continued

(Dollars in millions)

Balance Sheets:

Average LHFI

Average consumer and commercial deposits

Average total assets

Average total liabilities

Average total equity
Statements of Income:

Net interest income

Consumer

Year Ended December 31, 2015 1
Corporate
Other

Reconciling
Items

Wholesale

$65,637

$67,872

93,789

75,204

94,801

—

50,373

80,903

56,044

—

$60

101

29,668

14,771

—

$3,324

$1,918

$152

FTE adjustment
Net interest income-FTE 2
Provision for credit losses 3
Net interest income after provision for credit losses-FTE

Total noninterest income

Total noninterest expense

Income before provision for income taxes-FTE
Provision for income taxes-FTE 4
Net income including income attributable to noncontrolling interest

Less: Net income attributable to noncontrolling interest

Net income

1

3,325

27

3,298

1,967

3,631

1,634

553

1,081

—
$1,081

138

2,056

137

1,919

1,285

1,523

1,681

628

1,053

—
$1,053

3

155

—

155

137

17

275

81

194

10
$184

Consolidated

$133,558

144,203

188,892

165,546

23,346

$4,764

142

4,906

165

4,741

3,268

5,160

2,849

906

1,943

10
$1,933

($11)

(60)

3,117

(70)

23,346

($630)

—

(630)

1

(631)

(121)

(11)

(741)

(356)

(385)

—
($385)

1 Beginning in the second quarter of 2017, the Company realigned its business segment structure from three segments to two segments. Specifically, the Company 
retained the previous composition of the Wholesale Banking segment and changed the basis of presentation of the Consumer Banking and Private Wealth Management 
segment and Mortgage Banking segment such that those segments were combined into a single Consumer segment. Accordingly, business segment information 
presented for the year ended December 31, 2015 has been revised to conform to the new business segment structure and updated internal funds transfer pricing 
methodology for consistent presentation.
2 Presented on a matched maturity funds transfer price basis for the segments.
3 Provision for credit losses represents net charge-offs by segment combined with an allocation to the segments for the provision attributable to quarterly changes in 
the ALLL and Unfunded commitment reserve balances.
4 Includes regular Provision for income taxes as well as FTE income and tax credit adjustment reversals.

158

 
Notes to Consolidated Financial Statements, continued

NOTE 21 - ACCUMULATED OTHER COMPREHENSIVE LOSS

Changes in the components of AOCI, net of tax, are presented in the following table:

(Dollars in millions)

Year Ended December 31, 2017

Balance, beginning of period

Net unrealized (losses)/gains arising during the period

Amounts reclassified to net income

Other comprehensive income/(loss), net of tax

Balance, end of period

Year Ended December 31, 2016

Balance, beginning of period
Cumulative credit risk adjustment 1

Net unrealized (losses)/gains arising during the period

Amounts reclassified to net income

Other comprehensive (loss)/income, net of tax

Balance, end of period

Year Ended December 31, 2015

Balance, beginning of period

Net unrealized (losses)/gains arising during the period

Amounts reclassified to net income

Other comprehensive loss, net of tax

Balance, end of period

Securities
AFS

Derivative
Instruments

Brokered
Time
Deposits

Long-Term
Debt

Employee
Benefit
Plans

Total

($62)

($157)

(7)

68

61

($1)

$135

—

(194)

(3)

(197)

($62)

$298

(150)

(13)

(163)

$135

(31)

(56)

(87)

($244)

$87

—

(91)

(153)

(244)

($157)

$97

154

(164)

(10)

$87

($1)

—

—

—

($1)

$—

—

(1)

—

(1)

($1)

$—

—

—

—

$—

($7)

($594)

3

—

3

11

13

24

($821)

(24)

25

1

($4)

($570)

($820)

$—

(5)

(2)

—

(2)

($7)

$—

—

—

—

$—

($682)

($460)

—

76

12

88

(5)

(212)

(144)

(356)

($594)

($821)

($517)

(174)

9

(165)

($682)

($122)

(170)

(168)

(338)

($460)

1 Related to the Company's early adoption of the ASU 2016-01 provision related to changes in instrument-specific credit risk. See Note 1, "Significant Accounting 
Policies," for additional information.

Reclassifications from AOCI to Net income, and the related tax effects, are presented in the following table:

(Dollars in millions)

Year Ended December 31

Details About AOCI Components

2017

2016

2015

Impacted Line Item in the
Consolidated Statements of
Income

Securities AFS:

Realized losses/(gains) on securities AFS

Tax effect

Derivative Instruments:

Employee Benefit Plans:

Realized gains on cash flow hedges

Tax effect

Amortization of prior service credit

Amortization of actuarial loss

Tax effect

$108

(40)

68

(89)

33

(56)

(6)

25

19

(6)

13

($4)

1

(3)

(244)

91

(153)

(6)

25

19

(7)

12

($21) Net securities (losses)/gains

8 Provision for income taxes

(13)

(261)

Interest and fees on loans
held for investment

97 Provision for income taxes

(164)

(6) Employee benefits

21 Employee benefits

15

(6) Provision for income taxes

9

Total reclassifications from AOCI to net income

$25

($144)

($168)

159

Notes to Consolidated Financial Statements, continued

NOTE 22 - PARENT COMPANY FINANCIAL INFORMATION

Statements of Income - Parent Company Only

(Dollars in millions)

Income

Dividends 1
Interest from loans to subsidiaries

Interest from deposits at banks

Other income

Total income

Expense

Interest on short-term borrowings

Interest on long-term debt
Employee compensation and benefits 2
Service fees to subsidiaries

Other expense

Total expense

Income before income tax benefit and equity in undistributed income of subsidiaries

Income tax benefit

Income before equity in undistributed income of subsidiaries

Equity in undistributed income of subsidiaries

Net income

Total other comprehensive income/(loss), net of tax

Total comprehensive income

1 Substantially all dividend income is from subsidiaries (primarily the Bank).
2 Includes incentive compensation allocations between the Parent Company and subsidiaries.

Year Ended December 31

2017

2016

2015

$1,414

$1,300

$1,159

25

22

5

15

12

2

8

5

9

1,466

1,329

1,181

4

137

103

12

33

289

1,177

72

1,249

1,024

$2,273

1

$2,274

2

140

57

12

24

235

1,094

59

1,153

725

$1,878

(356)

$1,522

1

128

69

6

21

225

956

61

1,017

916

$1,933

(338)

$1,595

160

Notes to Consolidated Financial Statements, continued

Balance Sheets - Parent Company Only

(Dollars in millions)

Assets

Cash held at SunTrust Bank

Interest-bearing deposits held at SunTrust Bank

Interest-bearing deposits held at other banks

Cash and cash equivalents

Securities available for sale

Loans to subsidiaries
Investment in capital stock of subsidiaries stated on the basis of the Company’s equity in

subsidiaries’ capital accounts:
Banking subsidiaries

Nonbanking subsidiaries

Goodwill

Other assets

Total assets

Liabilities

Short-term borrowings:

Subsidiaries

Non-affiliated companies

Long-term debt:

Non-affiliated companies

Other liabilities

Total liabilities

Shareholders’ Equity

Preferred stock

Common stock

Additional paid-in capital

Retained earnings

Treasury stock, at cost, and other

Accumulated other comprehensive loss, net of tax

Total shareholders’ equity

Total liabilities and shareholders’ equity

December 31

2017

2016

$701

2,144

24

2,869

123

1,218

24,590

1,423

211

547

$30,981

$205

350

4,466

909

5,930

2,475

550

9,000

17,540

(3,694)

(820)

25,051

$30,981

$535

1,126

23

1,684

147

2,516

23,617

1,359

211

528

$30,062

$283

483

4,950

831

6,547

1,225

550

9,010

16,000

(2,449)

(821)

23,515

$30,062

161

 
Notes to Consolidated Financial Statements, continued

Statements of Cash Flows - Parent Company Only

(Dollars in millions)
Cash Flows from Operating Activities:

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

Year Ended December 31
2016

2017

2015

$2,273

$1,878

$1,933

Equity in undistributed income of subsidiaries
Depreciation, amortization, and accretion
Deferred income tax expense/(benefit)
Stock-based compensation
Net securities (gains)/losses

Net increase in other assets
Net increase/(decrease) in other liabilities

Net cash provided by operating activities

Cash Flows from Investing Activities:

Proceeds from maturities, calls, and paydowns of securities available for sale
Proceeds from sales of securities available for sale
Purchases of securities available for sale
Net decrease/(increase) in loans to subsidiaries
Other, net

Net cash provided by/(used in) investing activities

Cash Flows from Financing Activities:

Net (decrease)/increase in short-term borrowings
Proceeds from long-term debt
Repayment of long-term debt
Proceeds from the issuance of preferred stock
Repurchase of common stock
Repurchase of common stock warrants
Common and preferred dividends paid
Taxes paid related to net share settlement of equity awards
Proceeds from the exercise of stock options
Net cash used in financing activities
Net increase/(decrease) in cash and cash equivalents
Cash and cash equivalents at beginning of period
Cash and cash equivalents at end of period

Supplemental Disclosures:
Income taxes paid to subsidiaries
Income taxes received by Parent Company

Net income taxes paid by Parent Company

Interest paid

(1,024)
5
5
—
(1)
(15)
122
1,365

38
1
(17)
1,298
—
1,320

(211)
9
(482)
1,239
(1,314)
—
(723)
(39)
21
(1,500)
1,185
1,684
$2,869

($489)
414
($75)
$140

(725)
3
11
3
—
(129)
62
1,103

49
4
(4)
(889)
(3)
(843)

5
2,005
(1,784)
—
(806)
(24)
(564)
(48)
25
(1,191)
(931)
2,615
$1,684

($886)
812
($74)
$135

(916)
6
(4)
11
—
(72)
(28)
930

66
—
(15)
1,042
(2)
1,091

(763)
—
(29)
—
(679)
—
(539)
(36)
17
(2,029)
(8)
2,623
$2,615

($499)
481
($18)
$130

162

 
CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND
FINANCIAL DISCLOSURE

Item 9.

None.

Rule  13a-15(f)  of  the  Exchange Act)  for  the  Company.  The 
Company’s internal control over financial reporting is a process 
designed under the supervision of the Company’s CEO and CFO 
to  provide  reasonable  assurance  regarding  the  reliability  of 
financial  reporting  and  the  preparation  of  the  Company’s 
financial  statements  for  external  purposes  in  accordance  with 
U.S. GAAP.

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.
Management has made a comprehensive review, evaluation, 
and assessment of the Company’s internal control over financial 
reporting  at  December 31,  2017.  In  making  its  assessment  of 
internal control over financial reporting, management utilized 
the framework issued in 2013 by the Committee of Sponsoring 
Organizations  of  the  Treadway  Commission  ("COSO")  in 
Internal  Control—Integrated  Framework.  Based  on  that 
assessment, management concluded that, at December 31, 2017, 
the  Company’s  internal  control  over  financial  reporting  is 
effective.

Ernst  &  Young  LLP,  the  independent  registered  public 
accounting  firm  that  audited  our  consolidated  financial 
statements at, and for, the year ended December 31, 2017, has 
issued  an  audit  report  on  the  effectiveness  of  the  Company’s 
internal control over financial reporting at December 31, 2017. 
This audit report issued by Ernst & Young LLP is included in 
Item 8 of this Annual Report on Form 10-K.

Item 9A.

CONTROLS AND PROCEDURES

Evaluation of Disclosure Controls and Procedures

The Company's management conducted an evaluation, under the 
supervision and with the participation of its CEO and CFO, of 
the effectiveness of the design and operation of the Company’s 
disclosure controls and procedures (as defined in Rule 13a-15(e) 
of  the  Exchange Act)  at  December 31,  2017. The  Company’s 
disclosure controls and procedures are designed to ensure that 
information  required  to  be  disclosed  by  the  Company  in  the 
reports that it files or submits under the Exchange Act is recorded, 
processed,  summarized,  and  reported  within  the  time  periods 
specified  in  the  rules  and  forms  of  the  SEC,  and  that  such 
information 
the 
Company’s  management,  including  its  CEO  and  CFO,  as 
appropriate,  to  allow  timely  decisions  regarding  required 
disclosure.  Based  upon  the  evaluation,  the  CEO  and  CFO 
concluded 
the  Company’s  disclosure  controls  and 
procedures were effective at December 31, 2017.

is  accumulated  and  communicated 

that 

to 

Changes in Internal Control over Financial Reporting

There have been no changes to the Company’s internal control 
over  financial  reporting  during  the  year  ended  December  31, 
2017 that have materially affected, or are reasonably likely to 
materially affect, the Company’s internal control over financial 
reporting.

Management’s Report on Internal Control over Financial 
Reporting

Management  is  responsible  for  establishing  and  maintaining 
adequate internal control over financial reporting (as defined in 

Item 9B. 

OTHER INFORMATION

None.

163

SECURITY OWNERSHIP OF CERTAIN
BENEFICIAL OWNERS AND
MANAGEMENT AND RELATED
STOCKHOLDER MATTERS

The information at the captions “Equity Compensation Plans,” 
and “Stock Ownership of Directors, Management, and Principal 
Shareholders” in the registrant’s definitive Proxy Statement for 
its 2018 Annual Meeting of Shareholders to be held on April 24, 
2018 and to be filed with the SEC is incorporated by reference 
into this Item 12.

Item 13.

CERTAIN RELATIONSHIPS AND
RELATED TRANSACTIONS, AND
DIRECTOR INDEPENDENCE

The  information  at  the  captions  “Policies  and  Procedures  for 
Approval  of  Related  Party  Transactions,”  “Transactions  with 
Related Persons, Promoters, and Certain Control Persons,” and 
“Corporate  Governance  and  Director  Independence”  in  the 
registrant’s  definitive  Proxy  Statement  for  its  2018  Annual 
Meeting of Shareholders to be held on April 24, 2018 and to be 
filed with the SEC is incorporated by reference into this Item 13.

Item 14.

PRINCIPAL ACCOUNTANT FEES AND
SERVICES

The  information  at  the  captions  “Audit  Fees  and  Related 
Matters,” “Audit and Non-Audit Fees,” and “Audit Committee 
Policy for Pre-Approval of Independent Auditor Services” in 
the registrant’s definitive Proxy Statement for its 2018 Annual 
Meeting of Shareholders to be held on April 24, 2018 and to be 
filed with the SEC is incorporated by reference into this Item 14.

PART III

Item 10.

DIRECTORS, EXECUTIVE OFFICERS
AND CORPORATE GOVERNANCE

Item 12.

The information at the captions “Nominees for Directorship,” 
“Executive  Officers,”  “Section  16(a)  Beneficial  Ownership 
Reporting Compliance,” “Corporate Governance and Director 
Independence,” 
and 
Nominations for Election to the Board,” and “Board Committees 
and Attendance” in the registrant’s definitive Proxy Statement 
for  its  2018 Annual  Meeting  of  Shareholders  to  be  held  on 
April 24, 2018 and to be filed with the SEC is incorporated by 
reference into this Item 10.

Recommendations 

“Shareholder 

Item 11.

EXECUTIVE COMPENSATION

Risk 

Management,” 

The  information  at  the  captions  “Compensation  Policies  that 
Affect 
“Executive 
Compensation”  (“Compensation  Discussion  and  Analysis,” 
“Compensation  Committee  Report,” 
“2017  Summary 
Compensation  Table,”  “2017  Grants  of  Plan-Based Awards,” 
“Outstanding  Equity  Awards  at  December 31,  2017,”  “2017 
Pension  Benefits  Table,”  “2017  Nonqualified  Deferred 
Compensation  Table,”  “2017  Potential  Payments  Upon 
Termination or Change in Control,” and “Option Exercises and 
Stock  Vested  in  2017”),  “2017  Director  Compensation,”  and 
“Compensation Committee Interlocks and Insider Participation” 
in the registrant’s definitive Proxy Statement for its 2018 Annual 
Meeting of Shareholders to be held on April 24, 2018 and to be 
filed with the SEC is incorporated by reference into this Item 11.

164

PART IV

Item 15.

EXHIBITS, FINANCIAL STATEMENT SCHEDULES

(a)(1) Financial Statements of SunTrust Banks, Inc. included in this report:

Consolidated Statements of Income for the years ended December 31, 2017, 2016, and 2015;
Consolidated Statements of Comprehensive Income for the years ended December 31, 2017, 2016, and 2015;
Consolidated Balance Sheets at December 31, 2017 and 2016;
Consolidated Statements of Shareholders’ Equity for the years ended December 31, 2017, 2016, and 2015; and
Consolidated Statements of Cash Flows for the years ended December 31, 2017, 2016, and 2015.

(a)(2) Financial Statement Schedules

All  financial  statement  schedules  for  the  Company  have  been  included  in  the  Consolidated  Financial  Statements  or  the 
accompanying Notes, or are either inapplicable or not required.

(a)(3) Exhibits

The following documents are filed as part of this report:

Exhibit
Number
3.1

 Description
Amended and Restated Articles of Incorporation, restated effective January 20, 2009, incorporated by reference 
to Exhibit 4.1 to the registrant's Current Report on Form 8-K filed January 22, 2009, as further amended by (i) 
Articles of Amendment dated December 13, 2012, incorporated by reference to Exhibit 3.1 to the registrant's Current 
Report on Form 8-K filed December 20, 2012, (ii) the Articles of Amendment dated November 6, 2014, incorporated 
by reference to Exhibit 3.1 to the registrant's Current Report on Form 8-K filed November 7, 2014, (iii) the Articles 
of Amendment dated May 1, 2017, incorporated by reference to Exhibit 3.1 to the registrant's Current Report on 
Form  8-K  filed  May  2,  2017,  and  (iv)  the Articles  of Amendment  dated  November  13,  2017,  incorporated  by 
reference to Exhibit 3.1 to the registrant's Current Report on Form 8-K filed November 14, 2017.

Location
*

3.2

4.1

4.2

4.3

4.4

4.5

4.6

4.7

4.8

Bylaws of the Registrant, as amended and restated on August 11, 2015, incorporated by reference to Exhibit 3.2 
to the registrant's Current Report on Form 8-K filed August 13, 2015.

Indenture between registrant and The First National Bank of Chicago, as Trustee, dated May 1, 1993, incorporated 
by reference to Exhibit 4(b) to Registration Statement No. 33-62162.

Indenture between registrant and PNC, N.A., as Trustee, dated May 1, 1993, incorporated by reference to Exhibit 
4(a) to Registration Statement No. 33-62162.

Indenture between National Commerce Financial Corporation and The Bank of New York, as Trustee, dated as of 
March 27, 1997, incorporated by reference to Exhibit 4.1 to the Registration Statement on Form S-4 of National 
Commerce Bancorporation (File No. 333-29251).

Form of Indenture between registrant and The First National Bank of Chicago, as Trustee, to be used in connection 
with the issuance of Subordinated Debt Securities, incorporated by reference to Exhibit 4.4 to Registration Statement 
No. 333-25381 filed May 6, 1997.

First Supplemental Indenture between National Commerce Financial Corporation and the Bank of New York, 
as Trustee, dated as of March 27, 1997, incorporated by reference to Exhibit 4.2 to the Registration Statement on 
Form S-4 of National Commerce Bancorporation (File No. 333-29251).

Form of Indenture between registrant and The First National Bank of Chicago, as Trustee, to be used in connection 
with the issuance of Subordinated Debt Securities, incorporated by reference to Exhibit 4.4 to Registration Statement 
No. 333-46123 filed February 11, 1998.

Indenture, dated as of October 25, 2006, between SunTrust Banks, Inc. and U.S. Bank National Association, as 
Trustee, incorporated by reference to Exhibit 4.3 to the registrant's Registration Statement on Form 8-A filed on 
December 5, 2006.

Form of First Supplemental Indenture (to Indenture dated as of October 25, 2006) between SunTrust Banks, Inc. 
and  U.S.  Bank  National Association,  as  Trustee,  incorporated  by  reference  to  Exhibit  4.5  to  the  registrant's 
Registration Statement on Form 8-A filed on October 24, 2006.

*

*

*

*

*

*

*

*

*

165

Exhibit
Number
4.9

 Description
Form of Second Supplemental Indenture (to Indenture dated as of October 25, 2006) between SunTrust Banks, 
Inc. and U.S. Bank National Association, as Trustee, incorporated by reference to Exhibit 4.4 to the registrant's 
Registration Statement on Form 8-A filed on December 5, 2006.

Location
*

4.10

4.11

4.12

4.13

4.14

4.15

4.16

4.17

4.18

4.19

10.1

Senior Indenture, dated as of September 10, 2007 by and between SunTrust Banks, Inc. and U.S. Bank National 
Association, as Trustee, incorporated by reference to Exhibit 4.1 to the registrant's Current Report on Form 8-K 
filed on September 10, 2007.

Form of Third Supplemental Indenture to the Junior Subordinated Notes Indenture between SunTrust Banks, 
Inc. and U.S. Bank National Association, as Trustee, incorporated by reference to Exhibit 4.4 to the registrant's 
Registration Statement on Form 8-A filed on March 3, 2008.

Warrant  Agreement  for  6,008,902  Warrants,  dated  September  22,  2011,  among  SunTrust  Banks,  Inc., 
Computershare  Inc.  and  Computershare Trust  Company,  N.A.,  incorporated  by  reference  to  Exhibit  4.1  to  the 
registrant's Form 8-A for the Series A Warrants filed September 23, 2011. 

Warrant  Agreement  for  11,891,280  Warrants,  dated  September  22,  2011,  among  SunTrust  Banks,  Inc., 
Computershare  Inc.  and  Computershare Trust  Company,  N.A.,  incorporated  by  reference  to  Exhibit  4.1  to  the 
registrant's Form 8-A for the Series B Warrants filed September 23, 2011. 

Form of Series A Preferred Stock Certificate, incorporated by reference to Exhibit 4.2 to registrant's Current 
Report on Form 8-K filed September 12, 2006.

Form  of  Stock  Certificate  Representing  the  5.853%  Fixed-to-Floating  Rate  Normal  Preferred  Purchase 
Securities of SunTrust Preferred Capital I, incorporated by reference to Exhibit 4.3.2 to registrant's Post-Effective 
Amendment No. 1 to Form S-3 filed on October 18, 2006.

Form of Series E Preferred Stock Certificate, incorporated by reference to Exhibit 4.2 to registrant's Current 
Report on Form 8-K filed December 20, 2012.

Form of Series F Preferred Stock Certificate, incorporated by reference to Exhibit 4.2 to registrant's Current 
Report on Form 8-K filed November 7, 2014.

Form of Series G Preferred Stock Certificate, incorporated by reference to Exhibit 4.1 to registrant's Current 
Report on Form 8-K filed May 2, 2017.

Form of Series H Preferred Stock Certificate, incorporated by reference to Exhibit 4.1 to registrant's Current 
Report on Form 8-K filed November 14, 2017.

SunTrust  Banks,  Inc. Annual  Incentive  Plan,  amended  and  restated  as  of  January  1,  2014,  incorporated  by 
reference to Appendix B to the registrant’s Proxy Statement filed March 10, 2014.

*

*

*

*

*

*

*

*

*

*

*

166

Exhibit
Number
10.2

10.3

10.4

 Description
SunTrust Banks, Inc. 2009 Stock Plan, as amended and restated as of August 11, 2015, incorporated by reference 
to Exhibit 10.1 to Current Report on Form 8-K filed August 13, 2015, together with (i) Form of Nonqualified Stock 
Option Agreement; (ii) Form of Performance-Vested Stock Option Agreement; (iii) Form of Pro-Rata Nonqualified 
Stock  Option Award Agreement;  (iv)  Form  of  Restricted  Stock Agreement  (3-year  cliff  vesting);  (v)  Form  of 
Restricted Stock Agreement (3-year ratable vesting); (vi) Form of Performance Stock Agreement; (vii) Form of 
CCP Long Term Restricted Stock Award Agreement; (viii) Form of Performance Stock Unit Agreement; (ix) Form 
of TSR Performance-Vested Restricted Stock Unit Award Agreement; (x) Form of Tier 1 Capital Performance-
Vested Restricted Stock Unit Award Agreement; (xi) Form of (2010) Salary Share Stock Unit Award Agreement; 
(xii)  Form  of  (2011)  SunTrust  Banks,  Inc.  Salary  Share  Stock  Unit Agreement;  (xiii)  Form  of  Non-Employee 
Director Restricted Stock Award Agreement; (xiv) Form of Non-Employee Director Restricted Stock Unit Award 
Agreement; (xv) Form of Co-investment Restricted Stock Unit Award Agreement with clawback under the SunTrust 
Banks, Inc. 2009 Stock Plan; (xvi) Form of Performance Vested (ROA) Restricted Stock Unit Award Agreement 
with clawback under the SunTrust Banks, Inc. 2009 Stock Plan; (xvii) Form of Performance Vested (TSR) Restricted 
Stock Unit Award Agreement with clawback under the SunTrust Banks, Inc. 2009 Stock Plan; (xviii) Form of 
Nonqualified Stock Option Award Agreement with clawback under the SunTrust Banks, Inc. 2009 Stock Plan; (xix) 
Form of Time Vested Restricted Stock Award Agreement with clawback under the SunTrust Banks, Inc. 2009 Stock 
Plan; (xx) Form of 2012 Non-Qualified Stock Option Award Agreement (2-year cliff vested) under the SunTrust 
Banks, Inc. 2009 Stock Plan; (xxi) Form of Restricted Stock Unit Award Agreement, 2013 RORWA; (xxii) Form 
of Restricted Stock Unit Award Agreement, 2013 TSR; (xxiii) Form of Restricted Stock Unit Agreement, 2014 
TSR/Return on Tangible Common Equity (corrected); (xxiv) Form of Time-Vested Restricted Stock Unit Agreement, 
2014 Type I; (xxv) Form of Time-Vested Restricted Stock Unit Agreement, 2014 Type II; (xxvi) Form of Restricted 
Stock Unit Agreement, 2014 Return on Tangible Common Equity (corrected); (xxvii) Form of Restricted Stock 
Unit Agreement, 2015 Return on Tangible Common Equity; (xxviii) Form of Restricted Stock Unit Agreement, 
2015 Type I, three-year cliff; (xxix) Form of Restricted Stock Unit Agreement, 2016 Return on Tangible Common 
Equity; (xxx) Form of Restricted Stock Unit Agreement, 2016 Retention I; (xxxi) Form of Restricted Stock Unit 
Agreement, 2016 Retention II; (xxxii) Form of Restricted Stock Unit Award Agreement, 2016 ROTCE/TSR; and 
(xxxiii) Form of Performance Vested Restricted Stock Unit Award Agreement, 2017, (ROTCE/TSR), Form of Time 
Vested Restricted Stock Unit Award Agreement, 2017, Type I (VIR), and Form of Time Vested Restricted Stock 
Unit Award Agreement, 2017, Type II, incorporated by reference to:

(i) Exhibit 10.1.1 to the Company's Registration Statement No. 333-158866 on Form S-8 filed April 28, 2009; (ii) 
Exhibit 10.1.2 to the Company's Registration Statement No. 333-158866 on Form S-8 filed April 28, 2009; (iii) 
Exhibit 10.3 of the Company's Current Report on Form 8-K filed April 4, 2011; (iv) Exhibit 10.1.4 to the Company's 
Registration Statement No. 333-158866 on Form S-8 filed April 28, 2009; (v) Exhibit 10.1.3 to the Company's 
Registration Statement No. 333-158866 on Form S-8 filed April 28, 2009; (vi) Exhibit 10.1.6 to the Company's 
Registration Statement No. 333-158866 on Form S-8 filed April 28, 2009; (vii) Exhibit 10.1 of the Company's 
Quarterly  Report  on  Form  10-Q  filed  November  5,  2010;  (viii)  Exhibit  10.1.7  to  the  Company's  Registration 
Statement No. 333-158866 on Form S-8 filed April 28, 2009; (ix) Exhibit 10.1 of the Company's Current Report 
on Form 8-K/A filed April 27, 2011; (x) Exhibit 10.2 of the Company's Current Report on Form 8-K filed April 4, 
2011; (xi) Exhibit 10.2 of the Company's Current Report on Form 8-K/A filed January 13, 2010; (xii) Exhibit 10.5 
of the Company's Current Report on Form 8-K filed January 6, 2011; (xiii) Exhibit 10.1 of the Company's Current 
Report on Form 8-K filed April 27, 2011; (xiv) Exhibit 10.2 of the Company's Current Report on Form 8-K filed 
April 27, 2011; (xv) to (xix) Exhibits 10.26, Exhibits 10.27, Exhibits 10.28, Exhibits 10.29, and Exhibit 10.30 of 
the Company's Annual Report on Form 10-K filed February 24, 2012; (xx) Exhibit 10.1 of the Company's Quarterly 
Report on Form 10-Q filed August 1, 2012; (xxi) Exhibit 10.23 of the Company's Annual Report on Form 10-K 
filed February 27, 2013; (xxii) Exhibit 10.24 of the Company's Annual Report on Form 10-K filed February 27, 
2013; (xxiii) Exhibit 10.17 of the Company's Annual Report on Form 10-K filed February 24, 2014; (xxiv) Exhibit 
10.18 of the Company's Annual Report on Form 10-K filed February 24, 2014; (xxv) Exhibit 10.19 of the Company's 
Annual Report on Form 10-K filed February 24, 2014; (xxvi) Exhibit 10.17 of the Company's Annual Report on 
Form 10-K filed February 24, 2015; (xxvii) Exhibit 10.18 of the Company's Annual Report on Form 10-K filed 
February 24, 2015; (xxviii) Exhibit 10.1 of the Company's Quarterly Report on Form 10-Q filed August 5, 2015; 
(xxix) Exhibit 10.7 of the Company's Annual Report on Form 10-K filed February 23, 2016; (xxx) Exhibit 10.1 of 
the Company's Current Report on Form 8-K filed February 12, 2016; (xxxi) Exhibit 10.2 of the Company's Current 
Report on Form 8-K filed February 12, 2016; (xxxii) Exhibit 10.3 of the Company's Quarterly Report on Form 10-
Q filed May 4, 2016; and (xxxiii) Exhibit 10.19, Exhibit 10.20, and Exhibit 10.21 of the Company's Annual Report 
on Form 10-K filed February 24, 2017.

SunTrust Banks, Inc. 2004 Stock Plan, effective April 20, 2004, as amended and restated February 12, 2008, 
incorporated by reference to Exhibit 10.1 to the registrant's Current Report on Form 8-K filed February 15, 2008, 
as further amended effective January 1, 2009, incorporated by reference to Exhibit 10.14 to the registrant's Current 
Report on Form 8-K filed January 7, 2009, together with (i) Form of Non-Qualified Stock Option Agreement, (ii) 
Form of Restricted Stock Agreement, (iii) Form of Director Restricted Stock Agreement, and (iv) Form of Director 
Restricted Stock Unit Agreement, incorporated by reference to (i) Exhibit 10.70 of the registrant's Quarterly Report 
on Form 10-Q filed May 8, 2006, (ii) Exhibit 10.71 of the registrant's Quarterly Report on Form 10-Q filed May 
8, 2006, (iii) Exhibit 10.72 of the registrant's Quarterly Report on Form 10-Q filed May 8, 2006, and (iv) Exhibit 
10.74 of the registrant's Quarterly Report on Form 10-Q filed May 8, 2006.

SunTrust Banks, Inc. 2000 Stock Plan, effective February 8, 2000, and amendments effective January 1, 2005, 
November 14, 2006, and January 1, 2009, incorporated by reference to Exhibit A to registrant's 2000 Proxy Statement 
on Form 14A (File No. 001-08918), to Exhibits 10.1 and 10.2 to the registrant's Current Report on Form 8-K filed 
February 16, 2007, and to Exhibit 10.12 to the registrant's Current Report on Form 8-K filed January 7, 2009.

Location
*

*

*

167

Exhibit
Number
10.5

 Description
GB&T Bancshares, Inc. Stock Option Plan of 1997, incorporated by reference to Exhibit 10.6 to the annual report 
on Form 10-K of GB&T Bancshares Inc. filed March 31, 2003 (File No. 005-82430).

Location
*

10.6

10.7

10.8

10.9

10.10

10.11

10.12

10.13

10.14

10.15

10.16

10.17

GB&T Bancshares, Inc. 2007 Omnibus Long-Term Incentive Plan, incorporated by reference to Appendix A 
to the definitive proxy statement of GB&T Bancshares Inc. filed April 18, 2007 (File No. 005-82430).

SunTrust Banks, Inc. Supplemental Executive Retirement Plan, amended and restated as of January 1, 2011, 
incorporated by reference to Exhibit 10.7 to the registrant's Quarterly Report on Form 10-Q filed August 9, 2011, 
as further amended by Amendment Number One, effective as of January 1, 2012, incorporated by reference to 
Exhibit 10.10 to the registrant's Annual Report on Form 10-K filed February 24, 2012.

SunTrust Banks, Inc. ERISA Excess Retirement Plan, amended and restated effective as of January 1, 2011, 
incorporated by reference to Exhibit 10.8 to the registrant's Quarterly Report on Form 10-Q filed August 9, 2011, 
as further amended by Amendment Number One, effective as of January 1, 2012, incorporated by reference to 
Exhibit 10.1 to the registrant's Annual Report on Form 10-K filed February 24, 2012.

SunTrust Restoration Plan, amended and restated effective May 31, 2011, incorporated by reference to Exhibit 
10.9 to the registrant's Quarterly Report on Form 10-Q filed August 9, 2011, as further amended by Amendment 
Number One, effective as of January 1, 2012, incorporated by reference to Exhibit 10.11 to the registrant's Annual 
Report on Form 10-K filed February 24, 2012.

Forms of Change in Control Agreements between registrant and (i) William H. Rogers, Jr., (ii) Aleem Gillani, 
(iii) Thomas E. Freeman, (iv) Mark A. Chancy, and (v) Anil Cheriyan, incorporated by reference to: (i) - (iii), Exhibit 
10.13 to the registrant's Annual Report on Form 10-K filed February 23, 2010; (iv), Exhibit 10.12 to the registrant's 
Annual Report on Form 10-K filed February 23, 2010; and (v) Exhibit 10.16 to the registrant's Annual Report on 
Form 10-K filed February 24, 2012.

Executive Severance Plan, amended and restated July 24, 2014, incorporated by reference to Exhibit 10.5 to the 
Company's Quarterly Report on Form 10-Q filed August 6, 2014.

SunTrust  Banks,  Inc.  Deferred  Compensation  Plan,  amended  and  restated  effective  as  of  January  1,  2015, 
incorporated by reference to Exhibit 10.10 to the registrant's Annual Report on Form 10-K filed February 24, 2015.

SunTrust Banks, Inc. 401(k) Plan, amended and restated effective as of January 1, 2016, incorporated by reference 
to Exhibit 10.13 to the registrant's Annual Report on Form 10-K filed February 24, 2017. 

SunTrust Banks, Inc. 401(k) Plan Trust Agreement, amended and restated as of July 1, 2011, incorporated by 
reference to Exhibit 10.23 to the registrant's Annual Report on Form 10-K filed February 24, 2012.

Consent Judgment between SunTrust Mortgage, Inc. (“SunTrust Mortgage”) on the one hand and the United States 
Department of Justice, the United States Department of Housing and Urban Development, certain other federal 
agencies, and the Attorneys General for forty-nine states and the District of Columbia dated as of June 17, 2014, 
incorporated by reference to Exhibit 10.3 to the Registrant's Quarterly Report on Form 10-Q filed August 6, 2014.

Restitution and Remediation Agreement, dated as of July 3, 2014 between SunTrust Mortgage, Inc. and the 
United States of America, incorporated by reference to Exhibit 10.1 to the registrant's Current Report on Form 8-
K filed July 3, 2014.

Master Agency Agreement, dated as of September 13, 2010 among SunTrust and SunTrust Robinson Humphrey, 
Inc. (incorporated by reference to Exhibit 1.1 to the registrant's Form 8-K filed on September 14, 2010), as amended 
by Amendment No. 1 to Master Agency Agreement, dated October 3, 2012, incorporated by reference to Exhibit 
10.1 to the registrant's Current Report on Form 8-K filed October 3, 2012.

10.18

Form of Performance Vested Restricted Stock Unit Award Agreement, 2018, Type I.

10.19

Form of Performance Vested Restricted Stock Unit Award Agreement, 2018, Type II.

10.20

Form of Time Vested Restricted Stock Unit Award Agreement, 2018, Type I.

*

*

*

*

*

*

*

*

*

*

*

*

**

**

**

168

Exhibit
Number
10.21

Form of Time Vested Restricted Stock Unit Award Agreement, 2018, Type II.

 Description

Location
**

10.22

Form of Time Vested Restricted Stock Unit Award Agreement, 2018, Type III.

10.23

Form of Time Vested Restricted Stock Unit Award Agreement, 2018, Type IV.

12.1

21.1

23.1

31.1

31.2

32.1

32.2

99.1

Ratio of Earnings to Fixed Charges and Preferred Stock Dividends.

Registrant's Subsidiaries.

Consent of Independent Registered Public Accounting Firm.

Certification of Chairman and Chief Executive Officer pursuant to 18 U.S.C. Section 1350, as adopted pursuant 
to Section 302 of the Sarbanes-Oxley Act of 2002.

Certification of Corporate Executive Vice President and Chief Financial Officer pursuant to 18 U.S.C. Section 
1350, as adopted pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.

Certification of Chairman and Chief Executive Officer pursuant to 18 U.S.C. Section 1350, as adopted pursuant 
to Section 906 of the Sarbanes-Oxley Act of 2002.

Certification of Corporate Executive Vice President and Chief Financial Officer pursuant to 18 U.S.C. Section 
1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002.

Recoupment Policy, incorporated by reference to Exhibit 99.1 to the registrant's Annual Report on Form 10-K 
filed February 23, 2016.

101.1

Interactive Data File.

**

**

**

**

**

**

**

**

**

*

**

Certain instruments defining rights of holders of long-term debt of the registrant and its subsidiaries are not filed herewith pursuant 
to Item 601(b)(4)(iii) of Regulation S-K. At the Commission’s request, the registrant agrees to give the Commission a copy of any 
instrument with respect to long-term debt of the registrant and its consolidated subsidiaries and any of its unconsolidated subsidiaries 
for which financial statements are required to be filed under which the total amount of debt securities authorized does not exceed 
ten percent of the total assets of the registrant and its subsidiaries on a consolidated basis.

*

**

incorporated by reference

filed herewith

169

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this Annual 
Report on Form 10-K to be signed on its behalf by the undersigned, thereunto duly authorized, on the 23rd day of February 2018.

SIGNATURES

SUNTRUST BANKS, INC.

(Registrant)

By:  /s/ William H. Rogers, Jr.
William H. Rogers, Jr.,
Chairman of the Board and Chief Executive Officer

POWER OF ATTORNEY

KNOW ALL PERSONS BY THESE PRESENTS, that each person whose signature appears below hereby constitutes and appoints 
Ellen M. Fitzsimmons and Aleem Gillani and each of them acting individually, as his or her attorneys-in-fact, each with full power 
of substitution, for him or her in any and all capacities, to sign any and all amendments to this Annual Report on Form 10-K, and to 
file the same, with exhibits thereto and other documents in connection therewith, with the Securities and Exchange Commission, 
hereby ratifying and confirming our signatures as they may be signed by our said attorney to any and all amendments to said Annual 
Report on Form 10-K.

170

 
Pursuant to the requirements of the Securities Exchange Act of 1934, this Annual Report on Form 10-K has been signed below 

by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

Signatures

Date

Title

Principal Executive Officer:
/s/ William H. Rogers, Jr.
William H. Rogers, Jr.

Principal Financial Officer:
/s/ Aleem Gillani
Aleem Gillani

Principal Accounting Officer:
/s/ R. Ryan Richards
R. Ryan Richards

Directors:
/s/ Dallas S. Clement
Dallas S. Clement

/s/ Paul R. Garcia
Paul R. Garcia

/s/ M. Douglas Ivester
M. Douglas Ivester

/s/ Kyle Prechtl Legg
Kyle Prechtl Legg

/s/ Donna S. Morea
Donna S. Morea

/s/ David M. Ratcliffe
David M. Ratcliffe

/s/ Agnes Bundy Scanlan
Agnes Bundy Scanlan

/s/ Frank P. Scruggs, Jr.
Frank P. Scruggs, Jr.

/s/ Bruce L. Tanner
Bruce L. Tanner

/s/ Steven C. Voorhees
Steven C. Voorhees

/s/ Thomas R. Watjen
Thomas R. Watjen

_________________
Dr. Phail Wynn, Jr.

February 13, 2018

Chairman of the Board and
Chief Executive Officer

February 14, 2018

Corporate Executive Vice President and

Chief Financial Officer

February 14, 2018

Senior Vice President, Controller

February 13, 2018

Director

February 13, 2018

Director

February 13, 2018

Director

February 13, 2018

Director

February 13, 2018

Director

February 13, 2018

Director

February 13, 2018

Director

February 13, 2018

Director

February 13, 2018

Director

February 13, 2018

Director

February 13, 2018

Director

_______________

Director

171

SunTrust Banks, Inc.
303 Peachtree Street NE
Atlanta, GA 30308

©2018 SunTrust Banks, Inc. SUNTRUST, LIGHTING THE WAY TO FINANCIAL WELL-BEING, CONFIDENCE STARTS HERE, THE 
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