We utilize a minimum of four forward-looking economic scenarios to calculate lifetime ECL when estimating the allowance for credit losses for in scope financial assets and the liability for off-balance sheet credit exposures. Three of the scenarios are termed the "Consensus Economic Scenarios" which include a 'most likely outcome' (the "Central scenario") and two less likely 'outer' scenarios, referred to as the "Upside scenario" and the "Downside scenario." The fourth scenario, referred to as the "Alternative Downside scenario," is designed to consider severe downside risks with more extreme economic outcomes. Each scenario is assigned a weighting deemed appropriate for the estimation of lifetime ECL, with the majority of the weighting typically placed on the Central scenario. At management's discretion, changes may be made to the weighting assigned to the four scenarios or additional scenarios may be included in order to consider current economic conditions.

Updates to Economic Scenarios and Other Changes During the Three Months Ended March 31, 2025 During the first quarter of 2025, economic uncertainty increased due to the potential impacts of new trade and other economic policies in the United States, including tariffs, along with the ongoing uncertainty associated with elevated interest rates and the effects from higher inflation. We updated our Consensus Economic Scenarios and our Alternative Downside scenario to reflect management's current view of forecasted economic conditions and utilized the four updated scenarios for estimating lifetime ECL at March 31, 2025. Each of the four scenarios were assigned weightings with the majority of the weighting placed on the Central scenario, the second most weighting placed on the Downside scenario, the third most weighting placed on the Upside scenario, and the lowest weighting placed on the Alternative Downside scenario. This weighting was deemed appropriate for the estimation of lifetime ECL under current conditions. The following discussion summarizes the Central, Upside, Downside and Alternative Downside scenarios at March 31, 2025. The economic assumptions described in this section have been formed specifically for the purpose of calculating lifetime ECL.

In the Central scenario, inflation re-accelerates in 2025 driven by escalation in tariff actions. With squeezed consumer spending and reduced trade growth, U.S. Gross Domestic Product ("GDP") growth moderates in 2025 compared with 2024, while the FRB reduces its policy rate in the second half of 2025. Amid weaker GDP growth, the unemployment rate increases slightly in the first half of 2026, but remains near historic lows, while residential housing prices grow modestly as weaker demand is offset by a limited supply of homes for sale. In the financial markets, the growth in financial asset prices stalls in 2025.

In the Upside scenario, the economy grows at a faster pace than in the Central scenario as inflation wanes and tariff actions do not escalate. As a result, the unemployment rate falls and remains lower than in the Central scenario, while both residential housing and commercial real estate prices are higher than in the Central scenario. In this scenario, the equity price index climbs with strong momentum and overall optimism fueled by easing inflation allows the FRB to normalize its policy rate slightly faster than currently anticipated, which, combined with lower inflation expectations, drive the 10-year U.S. Treasury yield lower than in the Central scenario.

In the Downside scenario, inflation re-accelerates beyond the Central scenario and the economy enters a mild recession, with the unemployment rate increasing and remaining at a higher level, while residential housing and commercial real estate prices undergo correction due to weakness in the labor market and rising inflation. In this scenario, the FRB raises its policy rate initially to tackle inflation and the equity price index goes through a substantial correction by the end of 2026 driven by an overall erosion of consumer and business sentiments, which eventually results in lower interest rates than in the Central scenario.

In the Alternative Downside scenario, geopolitical tensions and tariff actions escalate significantly, and more severe inflationary pressures accompanied by tighter monetary policy lead the U.S. economy into a deep recession in 2025, followed by a very anemic recovery starting in the second half of 2026. An extended period of economic contraction keeps the unemployment rate at an elevated level, which pressures residential housing prices to depreciate, while at the same time, contracting corporate activities and increased unemployment pushes the commercial real estate market into a downturn. In this scenario, financial markets experience a major sell-off and volatility in the financial markets remains extremely high over the next year, widening corporate credit spreads, and flight to safe-haven assets pushes the 10-year U.S. Treasury yield lower.


	For the Quarter Ended
	June 30, 2025		December 31, 2025		June 30, 2026		December 31, 2026
Unemployment rate (quarterly average):
Forecast at March 31, 2025	4.2	%	4.4	%	4.5	%	4.4	%

Forecast at December 31, 2024	4.4		4.4		4.3		4.3
GDP growth rate (year-over-year):
Forecast at March 31, 2025	1.9		1.4		1.9		2.3

Forecast at December 31, 2024	2.0		1.8		1.6		1.6

In addition to the updates to the economic scenarios, during the three months ended March 31, 2025, we increased our commercial allowance for credit losses associated with individually assessed loans due primarily to the downgrade of a large commercial real estate loan. During the three months ended March 31, 2025, we also increased the management judgement allowance on our commercial loan portfolio for risk factors associated with higher risk exposures reflecting uncertainty in the forward economic outlook that are not fully captured in the models.

While we believe that the assumptions used in our credit loss models are reasonable and within the parameters for which the models have been built and calibrated to operate, inflation, elevated interest rates, and new trade and other economic policies in the United States, including tariffs, may adversely impact certain clients, which may not be fully captured by the models. As a result, adjustments to model outputs to reflect consideration of management judgment are used with stringent governance in place to ensure an appropriate lifetime ECL estimate.

The impacts of the new trade and other economic policies in the United States, including tariffs, are evolving and, along with the ongoing impacts of elevated interest rates and the effects from higher inflation, will continue to impact our business and our allowance for credit losses in future periods, the extent of which remains uncertain. We will continue to monitor these situations closely and will continue to adapt our approach as necessary to reflect management's current view of forecasted economic conditions.


	March 31, 2025		December 31, 2024
	(in millions)
Allowance for credit losses:
Loans	$	634	$	537
Securities held-to-maturity(1)	—		—
Other financial assets measured at amortized cost(2)	—		—
Securities available-for-sale(1)	—		—
Total allowance for credit losses	$	634	$	537

Liability for off-balance sheet credit exposures	$	145	$	139


	Commercial Loans						Consumer Loans
	Real Estate, including Construction		Business and Corporate Banking(1)		Other Comm'l		Residential Mortgages		Home Equity Mortgages		Credit Cards		Other Consumer		Total Loans
	(in millions)


















Three Months Ended March 31, 2025
Allowance for credit losses – beginning of period	$	144	$	381	$	1	$	(12)	$	6	$	13	$	4	$	537


Provision charged (credited) to income	66		46		—		—		(1)		1		—		112
Charge-offs	—		(15)		—		—		—		(2)		—		(17)
Recoveries	—		—		—		1		—		1		—		2
Net (charge-offs) recoveries	—		(15)		—		1		—		(1)		—		(15)

Allowance for credit losses – end of period	$	210	$	412	$	1	$	(11)	$	5	$	13	$	4	$	634

Three Months Ended March 31, 2024
Allowance for credit losses – beginning of period	$	144	$	429	$	1	$	(9)	$	7	$	16	$	3	$	591


Provision charged (credited) to income	(10)		(1)		—		1		1		—		(1)		(10)
Charge-offs	—		(1)		—		—		—		(2)		—		(3)
Recoveries	—		1		—		1		—		1		—		3
Net (charge-offs) recoveries	—		—		—		1		—		(1)		—		—

Allowance for credit losses – end of period	$	134	$	428	$	1	$	(7)	$	8	$	15	$	2	$	581

(1)In connection with changes to our business segments as discussed further in Note 13, "Business Segments," during the first quarter of 2025, we changed our presentation for what was previously reported as global banking to include such activity within business and corporate banking. As a result, we have reclassified prior year amounts to conform to the current year presentation.

Accrued Interest Receivables The following table summarizes accrued interest receivables associated with financial assets carried at amortized cost and securities available-for-sale along with the related allowance for credit losses, which are reported net in other assets on the consolidated balance sheet. These accrued interest receivables are excluded from the amortized cost basis disclosures presented elsewhere in these financial statements, including Note 3, "Securities," and Note 4, "Loans."


	March 31, 2025		December 31, 2024
	(in millions)
Accrued interest receivables:
Loans	$	244	$	249
Securities held-to-maturity	71		67
Other financial assets measured at amortized cost	47		25
Securities available-for-sale	130		117
Total accrued interest receivables	492		458
Allowance for credit losses	—		—
Accrued interest receivables, net	$	492	$	458