Citizens Financial Group, Inc.

Good morning, everyone, and welcome to the Citizens Financial Group third quarter 2020 earnings conference call. My name is Greg, and I'll be your operator today. Currently, all participants are in a listen-only mode. Following the presentation, we will conduct a brief question and answer session. If you'd like to ask a question, please press 1 and 0. As a reminder, this event is being recorded. Now I'll turn the call over to Kristen Silberberg, Executive Vice President, Investor Relations. Kristen, you may now begin.

Thank you Greg. Good morning everyone and thank you for joining us. First this morning our Chairman and CEO Bruce Van Saan and CFO John Woods will provide an overview of third quarter results referencing our presentation which you can find on our investor relations website. After the presentation we'll be happy to take questions. Brendan Coughlin, Head of Consumer Banking and Don McCree, Head of Commercial Banking are also here to provide additional colour. Our comments today will include forward-looking statements which are subject to risks and uncertainties that may cause our results to differ materially from expectations. These are outlined for your review on page two of the presentation. We also reference non-GAAP financial measures so it's important to review our GAAP results on page three of the presentation and the reconciliation in the appendix. With that, I will hand over to Bruce.

Thank you, Kristen. Good debut for you. Good to have you on the team.

Thank you.

Okay. Good morning, everyone, and thanks for joining our call. We feel really positive about how Citizens continues to rise to the occasion and meet the unprecedented challenges of 2020. We're taking great care of customers, colleagues, and communities while posting strong results that demonstrate the diversification and resilience of our business model. We are delivering record levels of pre-provision profit, and we're managing risks and our balance sheet well in the near term, while also preserving and making the strategic investments to position us for growth and success in the long term. Financial performance in Q3 featured record revenue, fee income, and mortgage results. The low rate and flat yield curve environment puts pressure on NIM, but our well-positioned mortgage business has performed exceptionally well, capturing the refi opportunity, gaining market share, and providing a natural offset to low rates. We included a page on this business in our investor deck. In short, we believe the mortgage business has room to run, given a positive market environment, plus our own strong positioning and capabilities. In addition to mortgage, we saw a solid quarter in capital markets revenue, given strong advisory and underwriting performance, and a nice rebound in wealth fees. Consumer fees also continue to move higher off of the COVID and related lockdown lows, which should continue as the economy further reopens and consumer behavior normalizes. These factors drove non-interest income growth of 11% sequential quarter and 33% year-on-year. Combined with a modest decline in NII and broadly stable expenses, we delivered underlying positive operating leverage of 2.6% sequential quarter and 9% year-on-year. Our pre-provision net revenue grew by 22% year-on-year, and it's up 14% on a year-to-date basis. Now, this capital generation ranks near the top of peers and has allowed us to grow loans to support customers, build a prudent level of credit reserves given the uncertainty of the environment, maintain an attractive dividend payout while delivering a 9.8% set one ratio, which is within our targeted range of 975 to 10%. This capital and reserve strength gives us tremendous financial flexibility going forward from a strategic and an operational perspective. Our view on the economy continues to be cautiously optimistic. Our consumer credit book is tracking favorable expectations given past stimulus, economic reopening, and forbearance. On the commercial side, we are seeing some selective credit stress in industry segments that are most impacted by COVID-19 and the lockdowns. We took sizable charge-offs on two credits during the quarter, as loss recognition can be a little lumpy. That said, we feel we are near peak charge-offs in commercial, assuming the macro environment stays on the current trajectory. Our work on TOP and BSO continues to make solid progress. We are adding material work streams to TOP 6, largely centered on digitization, and we will provide a full expense guide on our year-end call. On BSO, we completed a student loan sale as we developed an originate-to-distribute model, and we executed an attractive sub-debt exchange that delivered both financial and regulatory capital benefits. It's been quite a remarkable year, and we feel we've handled the challenges well, and we're poised for success as the economy recovers. With that, let me turn it over to John for a thorough review of our financials. John?

Thanks, Bruce, and good morning, everyone. Let's start with a brief overview of our headlines for the quarter, starting on page five. This was an outstanding quarter for citizens, despite the ongoing challenges in the operating environment. We have generated record revenue in PPNR in the last two quarters, with an excellent balance sheet position at September 30th. For the third quarter, we reported underlying net income of $338 million, EPS of $0.73, and record revenue of $1.8 billion. Our underlying ROTC was 9%. PP&R increased 6% linked quarter to another record level and was up 22% year over year. We posted record fee income for the quarter, faced by record mortgage fees and strong results in capital markets and wealth. Also, we delivered positive operating leverage of 2.6% linked quarter and 9% year-over-year as we continued our strong expense discipline. Net interest income was down 2% linked quarter due to a 3% decline in loans given line draw paydowns and a five basis point reduction in NIM due to rates and elevated cash. This was mitigated by excellent results in interest-bearing deposit costs, which fell 13 basis points linked quarter to 35 basis points. I should note that on a normalized basis, which adjusts for PPP loans, commercial line repayments and the education loan sale completed in the quarter, average loans were up slightly linked quarter. We increased our allowance for credit losses to $2.7 billion, which translates to a prudent ACL coverage ratio of 2.29%, excluding PPP loans, up from 2.09% last quarter. Note that the reserve bill during the quarter of $209 million impacted EPS by 40 cents and ROCI by 5 percentage points. We believe charge-offs should be stable in Q4, and barring a deterioration in economic outlook, we should start to see reserve releases beginning in the fourth quarter. Even with a significant reserve bill, we demonstrated excellent balance sheet strength. ending the quarter with a set one ratio of 9.8%, up 20 basis points linked quarter, and back within our pre-COVID operating level of approximately 9.75% to 10%. Our liquidity ratios also improved as we ended the quarter with an LDR of 87%, and we remain in compliance with the LCR. Our tangible book value per share is $32.24 at quarter end, up 2% compared with a year ago. On page six, I'll cover net interest income. Net interest income was down 2% linked quarter, given the impact of lower rates and a 3% decrease in loans as line draws were repaid, partly offset by lower interest-bearing deposit costs and improved deposit mix. Despite the challenging rate environment, net interest margin held up well, down five basis points this quarter. Rates drove a seven basis point decrease through lower asset yields, and higher cash balances were a two basis point impact. These were partially offset by lower interest-bearing deposit costs and outsized growth in DDA. Moving to page 7, we delivered record results again this quarter in fees, reflecting our ongoing efforts to invest in and diversify our revenue streams. Underlying non-interest income was up 11% linked quarter and 33% year-over-year as our fee-income ratio improved to 37%. Mortgage banking delivered record results again this quarter on continued strength and originations, more than offsetting the modest decline in margins compared to last quarter's all-time high. The mortgage business continues to provide an excellent natural hedge, as intended, against low rate pressure on NII. The wealth business rebounded nicely in the quarter, with revenues rebounding to record levels. This was driven by a strong increase in transaction volume and a solid increase in AUM. Service charges and card fees continued to trend back to pre-COVID levels. Key consumer drivers were increases in credit card purchase volume and debit card transaction volume, each of which is nearing pre-COVID activity levels. Capital market fees were down one quarter, driven primarily by a recovery in trading values in the prior quarter. Excluding this, capital market fees were up 11%, driven by accelerating activity in loan syndications and M&A advisories. Turning to page eight, let's take a closer look at the mortgage business. The strong performance of the mortgage business again this quarter has really boosted our overall performance, providing diversification in this low-rate environment. The business continues to demonstrate the benefits of the scale and diversity of our origination channels off the back of our 2018 acquisition of Franklin America. We have made significant investments in the business over the last few years, upgrading our customer-facing technology with our focus on innovating the customer experience. Over 60% of retail applications are now completed through our digital app. The strength of our multichannel distribution capabilities has enabled us to meet the extraordinary increase in demand in the market, with 2020 the largest year for mortgage originations in U.S. history. We expect volumes to remain elevated through 2021 at today's rates. And we expect to make market share gains even as rates rise as we transition to a more purchase-driven market, given our strength and execution consistency and leveraging our scale and channel diversification across our retail, correspondent, and wholesale channels. Turning to page nine on expenses. Underlying non-interest expense was down slightly late quarter, reflecting continued strong expense discipline that generated robust positive operating leverage in the quarter. This continued expense discipline has contributed to the year-over-year and linked quarter improvement in the efficiency ratio, now at 53%. Salaries and employee benefits were relatively stable linked quarter and up 3% year-over-year due to expenses connected to strong mortgage banking production volumes. Next, on page 10, average core loans were down 3% linked quarter and up slightly after normalizing for the impact of PPP loans, commercial line repayments, and loan sales. We saw growth in consumer lending in both mortgage and student. Moving to page 11. Average deposits were broadly stable in quarter and up 14% year over year, as consumers and small businesses benefited from government stimulus and clients built liquidity. We were especially pleased with our progress on deposit costs, which declined 29% or 10 basis points to 25 basis points during the quarter. Interest-bearing deposit costs were down 13 basis points to 35 basis points. We executed our deposit playbook to manage down deposit costs across all channels while improving our overall funding mix. We brought interest-bearing deposit costs down significantly by leveraging data and analytics to personalize offers and optimize pricing for our affluent and mass affluent customers. We continued to see a shift towards lower-cost categories with average DDA growth of 8% on the linked quarter basis and 40% year-over-year. This continues the peer-leading momentum we have demonstrated in growing low-cost deposits over the last three years. Turning to page 12 to discuss our CECL methodology and reserves. We have summarized the key aspects of our macroeconomic scenario, which is a foundational element of the CECL reserve estimate. This scenario has improved slightly on that used in Q2. Nonetheless, we used management overlays and qualitative factors to build reserves, focusing on expected performance trends in specific commercial sector portfolios most impacted by COVID-related lockdowns, namely retail and hospitality-related and casual dining, as well as in selected retail products. We feel we are well-reserved at this point for extended pandemic and lockdown impacts in these sectors. Notwithstanding this sizable reserve bill, our set one ratio improved 20 basis points to 9.8% given our robust PPNR growth and lower RWAs. On page 13, we provide detail on our customer forbearance programs. In commercial, loans with payment deferrals declined to 1.4% of our commercial loan book, down from 5.2% at June 30th, and this has further decreased to 1.2% as of October 13th. For retail, loans and forbearance have declined to 3.8% compared to 6% at June 30th and have further declined to 3.4% as of October 13th. This would be approximately 2% if we reported forbearance ending immediately after the last deferred payment. The performance of customers that have exited forbearance is trending well with approximately 95% in current status. Also, for customers that have not taken any forbearance, the delinquency status is trending favorably. Deferrals in business banking are 8.1% and are expected to decrease to approximately 1% by the end of October, with about 40% of our customers having received PPP funds and reopenings alleviating some of the stress. Turning to page 14 on credit. Non-accrual loans increased 29% linked order, given a $254 million increase in commercial, which was driven by two credits to mall reads impacted by COVID-related lockdowns, as well as a $33 million increase in retail. Note that our total mall read exposure is approximately 400 million, with two credits now in NPA status and the other performing okay. Net charge-offs were 70 basis points this quarter, driven by two large credits in commercial, one to a mall read, and one in metals and mining. The increase in commercial was partially offset by an improvement in retail, reflecting the impact of forbearance and the improving economic backdrop in Q3. We took a prudent $209 million reserve bill this quarter, which increased our coverage ratio from 2.09% in 2Q to 2.29% in 3Q, excluding PPP loans. Despite the somewhat lumpy increase in NPAs and charge-offs during the quarter, We are seeing broad signs of progress in commercial credit quality as the economy recovers. In the appendix on page 23, we provide you with an update on our view of the commercial portfolio. In the commercial portfolio, as businesses have reopened and liquidity has improved from capital raising and federal stimulus, we have seen sectors begin to stabilize. These include a combination of food services credits, including quick service food concepts that have performed well during the pandemic. the retail trade sector, getting our portfolio of lower-risk gas stations and essential services, the less price-sensitive credits in the energy and related sector, and finally, the arts, entertainment, and recreation sector, as sports teams and stadiums that have further benefited from professional sports resuming. Given these positive trends, the areas we consider to be of elevated concern have dropped from 10% in 2Q to approximately 5% of total loans. The remaining areas of concern have been particularly hit by COVID-related closures, mainly across retail-related CRE and hospitality, casual dining, retail trade, educational services, and price-sensitive energy. On page 15, as I mentioned earlier, we feel well-positioned to manage through the current environment with strong capital and liquidity positions. Our set-one ratio improved to 9.8%, up 20 basis points linked quarter given our strong PPNR generation and reduction in risk-weighted assets. We are now back in our target range of 9.75% to 10%. PB&R as a percentage of average assets was 3.9% year-to-date on a nine-quarter DFAS calculation basis and has increased steadily over the last five years, reflecting the benefits of investment and increasingly diversified revenue base. Strong deposit growth outpaced loan growth, which improved our liquidity metrics and drove the spot LVR down to 87%. During third quarter 2020, the company completed a subordinated debt exchange that will benefit total capital going forward by increasing the percentage of qualifying Tier 2 debt. Turning to page 16, I'll update you on top six. We continue to execute on the transformational and traditional top programs, and they've clearly been instrumental in our ability to deliver positive operating leverage and drive RASI improvement. The initiative we launched are expected to achieve the original 2020 pre-tax run rate target of $225 million. And we are still on track to hit the 300 to $325 million by year end 2021. We are also adding significant work streams to top six, largely focused on accelerating our digital capabilities to create increased efficiencies and frictionless customer experiences. These should deliver at least $100 million run rate by the end of 2021, And we are working to increase this, though we are also working through the cost impact of how much we'll invest or reinvest in strategic initiatives to drive future growth. We will be updating our expense outlook, including the benefit of the expanded initiatives to upscale these programs as part of our 4Q earnings call in January. On pages 17 and 18, I want to highlight some exciting things that are happening across the company. As we continue to strategically invest through the crisis to position us well for the medium term, we are focused not only on digitization, but also initiatives that position the franchise well for the long term. On the consumer side, we are focused on national expansion with citizens' access, integrating some of our lending businesses to further develop our national value proposition. In merchant finance, we are continuing to add new merchants to our point-of-sale platform, launching five important new merchant finance partners with more in the pipeline. And we are piloting a new customer-led point-of-sale value proposition. In commercial, we continue to expand our capital and global markets capabilities, including completing our first lead-left high-yield fixed-income issuance. And we are also seeing increased client adoption of our digital treasury solutions. Now let's move to Phase 19 for high-level commentary on the outlook for the fourth quarter. We expect NII to be broadly stable with no expectation of PPP forgiveness benefit until next year. NIM is expected to be down low to mid-single digit. Loans should be stable, securities up modestly. Fee income is expected to be down mid-teens off the record third quarter level, reflecting lower mortgage banking fees. While we expect to see mortgage results come down from 3Q record levels, we do see a significant fee opportunity that should continue into 4Q and well into 2021 at attractive margins, albeit lower than recent historic highs. Non-interest expense is expected to be up modestly, reflecting seasonal factors, and we're on track for full-year operating leverage of around 4%. We expect relatively stable net charge-offs in the range of 60 to 80 basis points of average loans. We also expect a reserve release in Q4, given reserve bills taken year-to-date. and we should see a decline in NPAs. On slide 20, to sum up, we continue to navigate successfully through the COVID-19 crisis. The resilience of the franchise is again on display with record PPNR, record fee income, and positive operating leverage. We remain well-positioned to continue to strategically invest and deliver on key initiatives. Our ability to execute well drives our strong profitability, capital, and liquidity positions. With that, I'll hand it over to Bruce. Okay. Thank you, John.

Operator, let's open it up for the Q&A.

Okay. Ladies and gentlemen, if you'd like to ask a question, please press 1 then 0 on your telephone keypad. You may withdraw your question at any time by repeating the 1, 0 command. If you're using a speakerphone, please pick up the handset before pressing the numbers. Once again, if you have a question, please press 1 then 0 at this time. And one moment, please, for your first question. Your first question comes from the line of Peter Winter from Wedbush Securities. Please go ahead.

Good morning. Thanks. I was just curious, what gives you the confidence that nonperforming assets are going to decline? And, you know, at this point in the cycle, there still seems a lot of uncertainty that you'd be willing to release reserves next quarter.

Yeah, why don't I start, John, and then you can pick him. So, you know, if you look at what drove up the NPAs this quarter, it really was isolated to just two exposures we had to mall REITs. which, you know, frankly, had been really stellar performing companies, best in class, which we've had long relationships with. But obviously the COVID and lockdowns and changed behavior caused some stress there. And so we've recognized that. We do a pretty careful job of forecasting the migration through criticized assets and what could go NPA. And so we think beyond that, we don't really, as I think John said in his prepared remarks, we're seeing some broad signs of optimism and some improvement in the overall commercial books. So we really don't think we're going to be taking a lot new in, and then we'll have some charge-offs, some degree of charge-offs, which will reduce the NPAs. So you put that all together, and I think we're feeling pretty confident on the commercial side. And then if you look at consumer as well, we've had Really, really healthy trends, even surprising to the point of being surprising, but very solid in terms of delinquencies. So I feel really good there as well.

I just add, you know, just higher level. We have a pretty good line of sight when you think about over the next 60 to 90 days about what's going to migrate on the commercial side. I mean, we've got, you know, paydowns and charge-offs that are coming through. And, you know, things, you know, as we mentioned in our overall areas of market concern, we were at 10% last quarter. You know, that number has fallen to five. We delineated where the puts and takes are with respect to that in our slide deck. And so, you know, we've done bottoms-up cash burn analysis, which John can comment on. So we feel reasonably comfortable with that guide on the non-accrual spaces.

Just on the reserve levels, with releasing reserves, I feel like there's still enough uncertainty in the economy. What gives the decision to properly release reserves next quarter?

I'll go ahead and take that one. I think this comes back to the methodology of CECL in the first place. We've been, over time, there's been significant uncertainty with respect to the scenario, and you saw how that trajectory played out over the first and second quarter where we built in both quarters. This quarter, the scenario actually got a little better, and I think at least from what we can see, the level of uncertainty has started to shape into something that we feel comfortable with our outlook. I think the difference this quarter in terms of our build is we've been spending a lot of time with individual sector reviews, and that really was those management overlays and the qualitative factors are what drove our build this quarter. After we've gotten through all of that, if the scenario, barring a deterioration in the environment, We feel like after analyzing what we expect the loss content to be in these categories, that the reserving requirements have been satisfied. And so therefore, the loss content has been provided for. And therefore, on a go-forward basis, the way CECL works is that you would charge off against the reserves that you've already built. And the provisions would be driven by your origination and go-forward activity. So from our standpoint, that would mean reserve releases with provisions less than charge us.

Great. Thanks for taking my question.

Sure.

Your next question comes from the line of Erica Majerian from Bank of America. Please go ahead.

Hi. Good morning.

Morning.

Morning.

As we take a step back, obviously, unfortunately, given the timing of where we are in the year, I'm sure you'll get a lot of questions on 21, and I know you'll defer us to January for details. But as we take a step back and we think about all the work that you've done, either through the top programs and building your fee income generating capabilities, and weigh that against you know, obviously the interest rate challenges and the swap income roll-off, you know, as we think about normalized returns sort of post the spike in credit that we all expect for 21, you know, as we think about normalized ROTC for citizens sort of in a post-COVID recovery world with no help with rates, do you think that you have enough in the till with top or fee generation to to achieve, you know, like a 10% or low double-digit ROTC on the other side?

Yeah, I'll start, and then, again, John, you can add your perspective. But, yeah, I think that's certainly the case, Erica. If you look at what we delivered just this quarter was 9% with a huge reserve bill, which the bill basically cost us 5% of ROTC. So you can do the math on that. But, you know, we'll, I think, going forward have lower credit costs. We'll, you know, we'll have some NIM headwinds. But, again, we consider, you know, hedges as part of the strategy. in managing a low-rate environment, but our mortgage business was also part of that strategy as well. And so there seems to be a great fixation on hedging, and some folks have put hedges on. I think we've done a nice job there, but some folks may have some longer duration or more hedges. They don't have the size mortgage business that we have. And so I think if you look at our PP&R generation through this year, we're really top of the class in terms of how we've been performing. So we expect there to be room to run in the mortgage business through next year. Sixty percent of the households in the country would benefit from I'd say, by more than 50 basis points in terms of the math if they refinance their mortgage. So there's going to be continued demand on the refi side. As the market goes back to a purchase market, we also are very well positioned. We probably have the most diversified origination channels of any bank-owned mortgage company with exposure to retail, to correspondent and wholesale. We've worked really hard to digitize that business and gain market share and be able to handle volumes efficiently. So I feel really good about that. So, you know, I'd say we're kind of on the doorstep of crashing through double-digit ROTC. I think we can get there and certainly sustain it. But it's going to take all the levers of, you know, the fee investments that we've made, doing more top and continuing to focus on driving efficiencies, looking for volume in terms of loan growth. And we think there's going to be some opportunities. We think we uniquely have some niches on the consumer side that some of our peers don't have. And I think also in commercial, we've been able to achieve nice growth through the build-out of some of our regional geographies. We know what we have to do. We know what the objective is, and we're going to keep driving towards that original medium-term targets. I think you probably need a little help from rates to get all the way there, but certainly double digits seems like a bar we can hurdle. John?

Yeah, I think not too much to add other than I think we have been a self-help story in the past, and I think we absolutely remain so going forward in the NII space. our BSO actions, and with interest-bearing deposit costs at around 35 basis points, there's a lot of opportunity there for us. We are a completely different bank than this ZERP versus last, and so you can expect that our interest-bearing deposit costs are going to find new lows for the bank compared to where we were at the end of the last ZERP. On fees, it's night and day with respect to our diversification. A combination of the organic investments that we've made And the inorganic acquisitions that we've made have been extremely powerful in the fee generation space, as you're seeing in mortgage. But we shouldn't forget about wealth, which is hovering around record levels on its own, but sometimes gets overshadowed by the eye-popping numbers in mortgage. But the diversification there is great, and the capital markets business has never been more diversified. And then finally, expenses. We've had a history of our top six programs. That will continue. That will be a hallmark of what we do, and we have a lot more opportunity there as well. So those are the final points, I think. Okay. Thanks.

Your next question comes from the line of Scott Seifers from Piper Sandler. Please go ahead.

Good morning, guys. Thank you for taking the question. I just wanted to ask on credit broadly, you know, what is your sense for when – lost content will really begin to materialize. I think it kind of feels like it keeps getting pushed back and the consensus now seems to be sort of mid to even late 2021. So just curious to hear your thoughts. And then just at a very top level, what kind of cycle do you really think you're sort of setting yourselves up for? It seems like with current info, most of the economy will sort of slog through and it's just these isolated areas that we'll see the real So is this something where we could really resolve most of the credit cycle next year, or do we see this sort of bleeding on for a couple of years from here?

Sure. So, you know, what I'd say on that is you have to look at commercial and you have to look at consumer. consumers have been extremely well behaved and we've had folks on forbearance. The people rolling off forbearance have actually been current and we haven't seen any uptick in charge-offs. But I think the residual folks who are on forbearance, there will be some charge-off content there. And I think that probably doesn't peak until sometime in the middle of next year, so whether that's Q2 or Q3, we'll see. I think on the commercial side, we got hit with two one-offs this quarter, and the pig is going through the python. I don't think there's significant jumps on the commercial side. I think we're probably nearing the peak charge-offs, but they'll stay elevated for a while before they move back down, I think, in the second half of the year. So, you know, I'd say our outlook is that most of this should resolve over the course of next year, setting us up for, I think, more normalized charge-off rates as we head towards 2022. Any comments, Brendan, you want to comment on the consumer side at all?

Yeah, let me just add a little specificity. So John quoted a few numbers in forbearance. We're increasingly confident that that portfolio is of high quality, particularly with some portfolios that were of high interest that hadn't gone through a cycle before. Our student portfolio is holding up incredibly well so far, and the merchant finance portfolio is equally holding up incredibly well. at all, and delinquency is still flat for pre-COVID. So we're feeling really, really strong about consumers. John mentioned the customers that are firmly still in forbearance. never forbearance at 8% to now 2%, and our delinquency rates have been flat to down at the same time. We're seeing a lot of gearing out of the forbearance portfolio with very minimal impact to distressed consumer behavior so far. We're out of the woods, but surprising on the green shoots that we're seeing are quite positive.

Don, maybe you want to talk about that.

I'd echo that. I do think it's elevated for next year, but we're peeking at where we are right now. Remember, and I'll just emphasize what Bruce said, our view is based on a client-by-client liquidity analysis where we project out current rates of cash generation versus current rates of cash burn. And we're seeing really positive trends. We've taken 25% of the companies that were in the high-risk category out of that category based on our last analysis. We're also seeing record level of customer deposits, so they have heavy levels of liquidity sitting with us. And we're seeing on a customer by customer basis, we're seeing the bigger customers, as everybody knows, going to the public markets and grabbing any amount of liquidity they can get in the high yield and the equity markets. And the smaller customers, you know, while they're having a little bit of a more difficult time, they're managing their businesses in a really conservative way for cash. So they kind of cut expense levels and they're positioning their businesses to survive an extended slowdown if there is an extended slowdown. So we feel good about what the customers are doing on an individual basis. Great.

That's perfect, Culler. Thank you very much. And I guess if I could sneak one in here. Just, Bruce, you noted the – kind of emerging emphasis on things like hedging programs, which you guys have benefited from. I've noticed the same thing. I guess maybe, John, as you sort of think about things into next year, you know, when and how do we see some of those hedges that you guys put in place roll off? And sort of what is the sense? Should we just sort of recast our focus onto the fee drivers such as mortgage and wealth that you alluded to earlier? Or, you know, how do we kind of replace those benefits as they do roll off?

Yeah, I mean, you know, basically the edges that are in place roll off throughout 2021. By the end of 2021, most of that benefit is starting to wane. But what I do is take a step back on NIM overall. The levers that we're pulling and have very large opportunity to get after is what I mentioned earlier with respect to interest-bearing deposit costs sitting at 35 basis points. We expect those to decline significantly in 2021. That's on the sort of funding side of things. We also are focusing on the asset side, so we have broader BSO efforts, you know, rotating, you know, our capital and allocating it into better risk return categories and profiles. And then, you know, you heard from Bruce earlier, the mortgage business has room to run. There are trillions of dollars of mortgages that have a refinance incentive. And I think that I would say that that business is rate sensitive and has been part of our hedging story and has done incredibly well. And a lot of the NIM headwinds, frankly, I guess I could say most of the headwinds, all of it in 2020 and probably on a cumulative basis through 2021, most of those rate headwinds will be offset by expected mortgage fee, elevated mortgage fee revenues. And then, of course, you heard, when you have rates falling, that's a big impact, and we'll have to look at all the levers across the self-help that we feel like is alive and well here, and that would include expenses and top six as part of that.

The last thing I would say, Scott, and I know hope is not a strategy, but If you consider that we could see real progress on the health front and you could get these treatments are progressing nicely, vaccines are progressing, you could see another stimulus bill. It seems like the folks in Washington are getting closer on that. You could actually see a fairly decent rebound next year, which could result in a steepener in the curve. which would create a lot of benefits and also opportunities to lay on some more hedges. So anyway, we're keeping our eye on that. When you run your scenarios, you have to consider that as a possible scenario.

That's perfect.

Your next question comes from the line of John Pancari from Evercore ISI. Please go ahead. Morning.

Morning. Also, on the credit front, I know you mentioned that you're closely tracking loss migration and that it's influenced your commentary around non-performing asset levels likely to decline. Can you just give us, do you have what your total criticized assets trends were for the third quarter and how that may break down in terms of the special mention versus classifieds?

Yeah, we publish that in the queue. I would say directionally it's up, and it's mostly special mention. So you'll stay tuned for the details on that.

Okay. All right. Thanks, Bruce. And then also on the credit side, I wanted to see if you could just give us a little bit of update on what you're seeing in your commercial real estate portfolio. Are you beginning to see stress there? I know you mentioned the mall REITs, but just curious about – other properties, how that portfolio is projecting. It looks like you added a fair amount to the reserve this quarter there.

Yeah, I think it's really what we mentioned. It's retail and hospitality where we're focused. If you click through the different asset classes, office looks like it's holding up pretty well with rents being paid. Well, multifamily looks like it's holding up pretty well. We've got our eye on trends there.

We don't have the big exposure to some of the cities, so it's like New York and San Francisco, fortunately.

And then you get into industrial and health care, and those are also holding up quite well. So the place we're focused is on the retail and hospitality. On the hospitality side, we've got an exposure to business travel. which is obviously slow, but we've got very diversified sponsors, and we've got some support provided by those sponsors in terms of flag chains, which have overlay guarantees on some of that. So it's really around the other areas of retail, and we feel like we're in pretty good shape with the reserves we put up at this point.

Yeah. I think what we tried to do here was really look at if we're in an extended period of either lockdowns or consumer behavioral shifts, that goes well into 2021, and that puts more stress on these narrow sectors, let's make sure we've taken credit off the table and put up a sizable reserve there.

And the other thing I mentioned is we are working with all of the sponsors. We really bank the best sponsors out there, and they're working with us, and they're restructuring the properties that are having temporary dislocations. So We've given some forbearance, but they're also putting some money in to pay interest and keep the properties operating.

Okay. Thank you. That's helpful. If I could just ask one more. On the efficiency, that $100 million, just to confirm, we do not yet know how much will fall to the bottom line of that $100 million?

Yeah, that's good, John. So we conveyed – we communicated appropriately. So we are going to – we're working on launching a number of work streams. Some of those are in Brendan's area in consumer, the big digitization push. And so far, the tally is up to at least $100 million. So that's good news, and we're going to keep trying to drive that higher. We also have a couple pages in there on some of our strategic initiatives. And so one of our objectives here is to really keep investing for our future so that we come out of this challenging period, an even better position with a stronger franchise that's positioned to grow and to continue to do well. And so we're working through the pacing of some of those investments and which ones to prioritize. We're kind of reluctant at this point to give you a full update on expense guidance until we complete that work, but I'm sure we knew there was going to be a clamoring for what have you got so far, so we put the number out there. Stay tuned to January. We'll give you all of that in the context of our full-year guidance that we do every January earnings call.

Got it. All right. Thanks, Bruce.

Sure. Your next question comes from the line of Ken Usden from Jefferies. Please go ahead.

Oh, thanks. Good morning, guys. Hi there. Hey, if I could just follow up on the last question a little bit. So top six, you're on track and you still have another 75 to 100 by year end. And then the new 100 on top of that. Not looking for expense guidance, but just can you help us understand of that 175 to 200 that you, you know, at minimum you expect to get next year, the approximate mix of like what comes through expenses of that and what comes through revenues of that? Because you're talking about like these new revenue opportunities, as you just alluded to, Bruce. Thanks.

Yeah. Yeah, I'll go ahead and take that. I mean, I think the majority of this is an expense-driven program. There are some revenue opportunities that are there in the traditional top program, as we have done historically. But, for example, the transformation piece of this is 100% expenses for the most part. And I would say that that's really the main driver of the program. But we also do use the program to fund revenue opportunities as well and to drive the upside on that front. I would hasten to add, though, that when you start doing the numbers, you're looking at the run rate target of around 225 by the end of this year. that rises to as high as 325. So there's 100 there. And then we also mentioned the additional 100, at least, that Bruce mentioned as well. So we wanted to make sure that we weren't losing track of those different hundreds.

Yeah, exactly. Yep. Okay, very good. And then second question, just, John, on the PPP in general. Many banks have thought through that forgiveness might start in the fourth quarter. It seems like you guys are conservative in terms of not at least putting it in your core, your NII guide. But can you just help us understand, and I know it's more of a timing question, but just what you expect and how do you expect us to all go with regards to forgiveness timing and also just how much was PPP in the 3Q NII as well? Thanks, guys. Appreciate it.

Yeah, sure. I'll start off and maybe Brendan will comment on it. But, you know, in terms of process, I mean, the forgiveness process can take up to five months. There's many steps that have to be made. Maybe Brendan can talk about the invitation approach that we're taking in the fourth quarter, but I think that our view is given the complexity there, that it would be appropriate in the outlook to not include any acceleration with respect to forgiveness benefit. That said, we do, as you know, the way the accounting works is that we are incorporating the expected fees on a level yield basis over the life of the 24 months of these loans. And so every quarter that goes by, we are recognizing P&L that is attributable to the PPP program. You know, in the third quarter, you know, the yield on the program is nearing, you know, somewhere between, you know, nearing 3% in terms of the yield. And from a pre-tax standpoint, if you, you know, it's maybe in the $25 million range for the third quarter. So that gives you a sense. And all of that, and I call it pre-tax, all of that, that's really after the expenses. That's a tiny bit higher on the NII line. So, and that number will be, you know, with no forgiveness, we'll see that again in a similar number in the fourth quarter, given the way that the accounting works. And if forgiveness really is really a 1H 2021 number, as we are forecasting.

I would say one thing on that, Bruce, and then I'll let Brendan go. But, Ken, initially, you know, we take it out over roughly eight quarters, and I think we had 140, 150 million roughly to amortize on a straight-line basis. But we thought that forgiveness would occur much sooner. We had thought some of that would trickle into Q3 and Q4. But, you know, now it looks like that will largely be a first half 21 event. but the spike is going to be lower since the longer this goes towards the end of the period, then you won't get the same spike as if you had a massive acceleration into, say, Q3. That would have really altered the timing in a material way. But at this point, since we are steadily recognizing, and then there's less time remaining to accelerate, the spike shouldn't be as dramatic, just to make that mathematical point.

On the timing, the one thing I would just add is keep in mind the customer doesn't need to incur interest charges until October of next year. And so there's no huge pressure point for our customers to apply for forgiveness right this second. They don't have to pay. They don't have to pay. with the various bills going through Congress that would possibly be quite positive to these customers, there's a bit of a waiting game. And that's what we're hearing from most customers is that they'd rather wait and see what flexibility is afforded to them before they jump in and start the forgiveness process. So we're getting a handful trickled in. And then to John's point, once the customer provides all their documentation, the SBA still has a three-month window to stamp it and say, yes, it's able to be forgiven. And that's the recognition event is on the SBA stances. So there's a bit of a tail on this. We expect it, as Bruce pointed and John pointed out, to be a first time.

And I do think some small business owners are being cautious here and just holding on to that cash to see what the forgiveness terms are. They might have to pay it back, which is one of the reasons we still have elevated cash balances. So they've dipped into their own pocket to keep the lights going in the business. And so, you know, I think there's just a bit of caution generally, as you said.

Understood. Hey, one just quick clarification, John. That $25 million pre-tax, was that the fee part of it, or was that also with the NII, just from the loan yield?

Yeah, that's the fee part of it and the NII. It's all in. And that's consumer and commercial.

Okay, so that's the all-in what you had from PPP. Thanks.

Your next question comes from the line of Ken Zerbe from Morgan Stanley. Please go ahead. Okay, thanks.

So just in terms of credit, it sounds like the management overlays drove most of the reserve bill this quarter. What did your CECL model, if we look at CECL by itself, actually tell you to do with reserves?

I think it's hard to parse it, Ken, actually, because to us, the CECL model is not just a macro forecast. It's a process that involves many, many, many variables. and management judgment is one of those variables. So I think it's just hard to parse that.

Got it. Okay. And then maybe just on the same topic, I guess why apply the management overlays this quarter? I'm sure you had some earlier in the year, but it seems like maybe this quarter had – more of the qualitative adjustments rather than .

I think we've had – overlays and qualitative factors are part of the process every quarter. I think the reason to call these out was you had a slight divergence. It looked like the macro forecast was a little better. The backdrop was a little better. But what we're seeing is that consumer behavior and the effect of lockdowns is going to be more prolonged than I think we saw when we were assessing it in the first quarter and second quarter. We think it could be well into 2021 before we get back to life as we knew it and to normal lifestyle, which means these retail and hospitality, entertainment, travel, all of that genre is could still be in a difficult situation for longer. So you wouldn't necessarily pick that up from your macro forecast. I mean, that's a kind of unique aspect of certain businesses are disproportionately impacted from the new normal about how we're living our life. And so that's why we're calling that out.

All right, great. Thank you.

Your next question comes from the line of Vivek Junaidjia from JP Morgan. Please go ahead.

Hi. A couple of, I'm going to just follow up on some of the themes that have been coming up. The release in reserves, Bruce and John, that you're expecting in the fourth quarter, which loan categories do you think that you're expecting to see that at this point? Where is that visibility coming from?

Yeah, I mean, I'll go ahead and take that. It's kind of like the way CECL works, as you know. I mean, we provide for all of the loans that are outstanding at September 30th, both for the loss content that we see after considering our macroeconomic scenario and then our qualitative factors that we review by loan category. And if we're right, and it's very hard to say that you can be, there's so much uncertainty, that, you know, a lot of that building, you know, in the third quarter came through the commercial portfolios. And, you know, as we mentioned earlier, create retail and hospitality, and we also mentioned casual dining as sectors where we built reserves. So once that's done, then theoretically at least, you're just going to charge off against those reserves going forward, assuming you were right about what the loss content is and what the scenario will be. The rest of your provisioning then would only be focused on your front book activity and growth. So where we're going to grow going forward, let's say, for example, in the residential mortgage and student and merchant spaces, we would provide additional reserves for those loans as they come on, as well as the C&I loans that we're going to see as you get to the end of the fourth quarter. So it really is...

you have to sort of look at it in those two buckets as ways to... And just make an assumption that the environment won't deteriorate in a meaningful way so that you wouldn't need to add to any further reserves around the back book. Now, there could be some of that, but we don't see a sufficient amount of it to result in a need for a reserve bill.

And what are you thinking about... student loan book because that your forbearance rate has stayed pretty high it hasn't come down it's higher than even resi mortgages can you comment on why that's the case have they just not come up for um you know how long is the forbearance period have they just not come up yet or have they gone in what percentage have gone in for an extension of the deferral so so we're actually starting to see it gear down a little bit in the recent in the recent weeks uh it was lagging a

The majority of our student loan book is student loan refi and a lot of those customers also automatically granted, and so customers were triggered by the government event, and they called all the private lenders and banks and raised their hand for forbearance, and there's sort of no reason for them to de-link those two. So, you know, we've been, you know, aggressively working with our customers to make sure we try to understand where they're at and if they have the capacity to pay, but if they are still of leeway to land on their feet. But every underlying dynamic we see in that portfolio is quite positive. Recall, it's a super prime portfolio. The credit is 780 plus in that portfolio, and particularly in the refi portfolio, they all make six-figure income, and that's the sector that's been the least impacted by unemployment. And so we feel quite strong that there's no significant underlying dynamic that's different in student than any other portfolio and consumer.

Great. Thank you.

Your next question comes from the line of Saul Martinez from UBS. Please go ahead.

Hey, good morning, guys. So good morning. A couple questions. First, John, you mentioned that the hedges should mostly roll off and the headwinds from the hedges rolling off should be pretty, for the most part, fully realized by the end of 21 and early 22. And I think we've estimated that the headwinds probably in the $250 million annualized from the hedges rolling off. Can you just give us a sense of the magnitude of the incremental headwinds, if our number is more or less right, and how should we see those incremental headwinds sort of materializing in 21 and in 22?

Yeah, it would be a fraction of that. You know, without really getting into the numbers, it's not nearly that big. It's nowhere near that from what we can see. How we track through 2020, I mean, you've got to think about, what the terms are on, which we publish, and you can see what the terms are on those swaps, I believe. But it's much, much lower than that. And I'd say I could just bring it back, bigger picture, to, sure, those are running off, but mortgage business has been part of our hedging strategy all along. The majority of the NIM headwinds on a cumulative basis are being offset by you know, in 2020 and 2021 by the mortgage business. And we also have a very significant lever with respect to interest-bearing deposit costs this time around in ZERP, given all of the investments we've made in the analytics and product capabilities and orientation of our bank across consumer and commercial with respect to the relationship-driven deposit gathering that we have embarked upon, which takes years to do. But that started, you know, many years ago. So we're starting to see that bear fruit. Those are the things I think about when you're trying to, you know, consider the puts and takes for next year.

Yeah, I get that. But maybe we can go with mechanics offline. But there does seem to be a sense from – The investment community that the headwinds we're talking about on a static basis, not factoring in some of the offsets, are in the hundreds of millions of dollars. But just to be clear, you're saying that that estimate just on a static basis, nothing else, just the hedges rolling off, that that number is way too high. Is that right?

That's correct. That's correct, and we can take you through the map on that offline with some publicly available information, and we'll just make sure that you're seeing it the way we see it. Okay.

Just one other question on NII. What are you assuming for forgiveness ultimately throughout the course of the first half of next year? What percentage of loans?

So there's a 15% tail that we think won't be forgiven on the back end, and so the other 85% will come through mostly in one age, but there's some that will come through in the third quarter as well.

Got it. Okay. Thanks a lot.

Okay. Is that it? No, one more. One more question. Okay, we'll take one more question.

That question comes from the line of Dave Rochester from Compass Point. Please go ahead.

Hey, good morning, guys. On your NIM guidance, I was just curious how much deposit growth you're assuming that feeds into that, if any, or if you're looking for more of that continued favorable mixed shift that you've been having there, favoring the lower cost of the deposit.

Yeah, it's primarily a mixed shift story. I mean, we've gotten surge deposits like many other banks. You know, we think some of that may stick around for quite a while and through well into 2021. So there's that benefit. We've paid down everything you can pay down, and we're sitting around with some excess cash. And so excess cash is a drag on them, call it about a two basis point drag or so on a quarter over quarter basis in the fourth quarter. But it's getting up to mere, call it eight to 10 basis points on an absolute basis in the fourth quarter, all that excess cash. We'll look to see that pay down over time. But as it relates to deposits, really we're seeing great, you know, mix shift into DDA. We've had, you know, I think three years running now, peer-leading DDA growth, and that's part of the next story. And it's just accelerating that trend that already was happening with us that's nice to see on the deposit side.

Yeah. Well, you mentioned the cash that's sitting there. I mean, are there any lumpy maturities on the borrowing side that maybe you can take advantage of and use some of that cash to pay those down? Anything over the next year that we can look for that will help support them?

Yeah, I mean, not a lot. So, you know, our flood funds are down to zero. And then our senior debt, we only have very, very modest. And, you know, maturity is coming in, you know, in early 2021.

We just called one issue and we did a sub-debt exchange. So we're working that as much as we can, but not a huge amount of opportunity there. Yep.

All right. And then if you guys have any color on new loan yields and securities purchase yields that you guys are seeing today, I'm just trying to, Get a sense for where we could ultimately be going on the average earning asset yield if we continue to see this flat curve over the next couple of years.

Yeah, and, you know, so for securities I'll take, and, you know, maybe Don or Brendan want to talk about spreads, but I mean on the loan side. But, you know, it's not a great story on the security side. There's a 40, 45 basis point. Call it negative front book, back book, you know, in terms of runoff, which comes off at around, call it, 190 basis points. And you've got, you know, reinvestment coming on at around 140 or 145 on the front book of securities. So that's the story there. I think in commercial, we're seeing strong sort of spreads are up, but rates are down. So that's good. In the consumer side of things, we're seeing some interesting positive trends there. And in auto, which has been quite good, and really strong spreads there. And maybe I'll just let Don or Brendan add anything else.

I think auto has been very strong. Student loan refi has also been very strong. We're seeing a significant increase in margin across basically all the products.

You may want to also talk merchant. We just had a nice string of wins, and Apple just is launching their new product.

Our merchant business kind of has the profile of a credit card business. Apple, we're gearing into the new product release for them right now with the 5G phone, so we're enthusiastic about that. Microsoft All Access has geared up for its big launch right now, seasonally. And we just launched, as John pointed out earlier, five new merchant partners, really centered in home improvement, electronics, and fitness, similar to our Peloton relationship with the firm. So we're really bullish about the growth there. We're actually getting some really decent momentum that should really help offset some of the yield headwinds on some of the other portfolios by bringing in something of that high yield.

And on commercial, we're generally getting anywhere from 10 to 30 basis points better spreads on new originations. And we're also putting LIBOR floors on a lot of transactions, which are helping the overall yield. That seems to be holding.

Okay. All right. Thanks for the question.

Appreciate it.

Okay. I think that's it for the queue. Thanks again for dialing in today, everyone. We appreciate your interest and support. Have a great day, and everybody stay well.

Ladies and gentlemen, that does conclude your conference for today. Thank you for your participation and for using AT&T Teleconference. You may now disconnect.