Wells Fargo & Company

Welcome and thank you for joining the Wells Fargo second quarter 2023 earnings conference call. All lines have been placed on mute to prevent any background noise. After the speaker's remarks, there will be a question and answer session. If you would like to ask a question during this time, simply press star 1. If you would like to withdraw your question, press star 2. Please note that today's call is being recorded. I would now like to turn the call over to John Campbell, Director of Investor Relations. Sir, you may begin the conference.

Good morning. Thank you, everyone, for joining our call today where our CEO, Charlie Sharp, and our CFO, Mike Santosimo, will discuss second quarter results and answer your questions. This call is being recorded. Before we get started, I would like to remind you that our second quarter earnings materials, including the release, financial supplement, and presentation deck, are available on our website at wellsfargo.com. I'd also like to caution you that we may make forward-looking statements during today's call that are subject to risks and uncertainties. Factors that may cause actual results to differ materially from expectations are detailed in our SEC filings, including the form 8-K filed today containing our earnings materials. Information about any non-GAAP financial measures referenced, including a reconciliation of those measures to GAAP measures, can also be found in our SEC filings and the earnings materials available on our website. I will now turn the call over to Charlie.

Thank you, John. Good morning, everyone. As usual, I'll make some brief comments about our second quarter results and then update you on our priorities. I'll then turn the call over to Mike to review second quarter results in more detail before we take your questions. Let me start with some second quarter highlights. We had solid results in the quarter with revenue, pre-tax, pre-provision profit, diluted earnings per share, and ROTCE all higher than a year ago. The revenue growth reflected strong net interest income growth as well as higher non-interest income. While our efficiency ratio improved and we continued to make progress on our efficiency initiatives, we had modest expense growth from a year ago. Net charge-offs have continued to increase from historical low levels, but overall credit quality was strong, and consumer and business balance sheets remained healthy. We increased our allowance for credit losses by $949 million, primarily driven by our office portfolio, as well as growth in our credit card portfolio. While we haven't seen significant losses in our office portfolio to date, Our detailed loan-by-loan review of the portfolio has given us a sense how the next several quarters could play out. We also considered a number of stress scenarios, all of which informed our actions this quarter. Mike will discuss this in more detail, but I want to make the point that it is very hard to look at any one statistic and determine the risk in the portfolio. Lost content will be driven by a combination of factors. including but not limited to property type, location, lease rates, lease renewal notice dates, loan structure, and borrower behavior. Most importantly, our CRE teams remain focused on working with our clients for portfolio surveillance and de-risking to minimize lost content. Both commercial and consumer average loans were up from a year ago, but were down from the first quarter as the economy has slowed actions. Credit card spending remains strong, but the rate of growth has slowed from the outsized growth rates we saw throughout 2022. Debit card spending was flat from a year ago, with growth in discretionary spend offset by declines in non-discretionary spend. Average deposits were down from the first quarter, driven by lower consumer deposits, while the decline in commercial deposits slowed. Now let me update you on progress we've made on our of our risk and control work. Regulatory pressure on banks with longstanding issues such as ours continues to grow, and as such, our continued intensive effort to complete the build out of an appropriate risk and control framework for a company of our size and complexity is critical. I continue to emphasize that this is our top priority and will remain so, and that while we have implemented substantial portions of the work required, we have more implementation to do as well as work to make sure the changes operate effectively over time. As I said before, we remain at risk of further regulatory actions until the work is complete. While we're devoting all necessary resources to our risk and control work, we're also continuing to invest in our business to better serve our customers and help drive growth. Our consumer customers have continued to increase their use of our mobile app, We added over 1 million mobile active customers over the past year, and mobile logins increased 9% from a year ago. Fargo, our new AI-powered virtual assistant, is now live on our mobile app for all consumer customers. Since launching at the end of April, our customers have interacted with Fargo over 4 million times. We continue to make important hires, bringing new expertise. We named Barry Simmons as the new head of national sales in wealth and investment management. He would be critical in our efforts to better serve clients and help advisors grow their business. We also continued to attract veteran bankers in corporate and investment banking, hiring new managing directors in our banking division in priority growth areas, including a co-head of global mergers and acquisitions, co-head of financial institutions, and new heads of financial sponsors, equity capital markets, healthcare, and technology, media, and telecom. We also continue to focus on better serving our communities. We announced a 10-year strategic partnership with TD Jakes Group that could result in up to $1 billion in capital and financing from Wells Fargo to drive economic vitality and inclusivity in communities across America. The Wells Fargo Foundation awarded $7.5 million to Habitat for Humanity to build and repair more than 360 homes nationwide. We've worked with Habitat for Humanity for nearly three decades and donated more than $129 million since 2010. Wells Fargo signed on as the first anchor funder of Unidos U.S. Home Initiative to create 4 million new Latino homeowners by 2030. We provided the initial grant to start a fund launched by FinTech Below Alice to improve access to credit and capital for small business owners who are members of underserved groups, including women. We continue to open Hope Inside centers in Wells Fargo branches, including six during the first half of 2023, with plans to reach 20 markets by the end of this year. The centers help empower community members to achieve their financial goals through financial education workshops and free one-on-one coaching. We published our 2023 diversity, equity, and inclusion report, which highlights the progress we've made in our DE&I strategy and initiatives, both inside our company and the communities where we live and work. However, we have more work to do to achieve enduring results that will require a long-term commitment. Looking ahead, the U.S. economy continues to perform better than many expected, And although there will likely be continued economic slowing and uncertainty remains, it is quite possible the range of scenarios will narrow over the next few quarters. This year's Federal Reserve stress test affirmed that we remain in a strong capital position, reflecting the value of our franchise and benefits of our operating model. This capital strength allows us to serve our customers' financial needs while continuing to prudently return excess capital to our shareholders. As we previously announced, we expect to increase our third quarter common stock dividend by 17% to $0.35 per share, subject to approval by the company's board of directors at its regularly scheduled meeting later this month. We repurchased $8 billion of common stock during the first half of this year, and the stress test results demonstrated that we have the capacity to continue to repurchase common stock. Regulators have signaled that the Basel III endgame proposal which could be out as soon as this summer, will include higher capital requirements that would be skewed to the country's largest banks. While there's some speculation that capital requirements could increase by 20%, we don't know what the impact will be to Wells Fargo. However, we do expect our capital requirements will increase. While any changes to regulatory capital requirements are expected to be phased in gradually over several years, We are considering the potential impact and contemplating the amount of our future purchases. Our balance sheet is strong. We have increased and remain focused on increasing our earnings capacity and continue to like our competitive position. We remain prepared for a variety of scenarios and our steadfast commitment to our risk and control build-out, coupled with our continued focus on financial and credit personality. We'll now turn the call over to Mike.

Thank you, Charlie, and good morning, everyone. Net income for the second quarter was 4.9 billion, or $1.25 for diluted common share, both up from a year ago, reflecting the progress we are making and improving our performance, which I'll highlight throughout the call. Starting with capital liquidity in slide 3, our CET1 ratio was 10.7%, down approximately 10 basis points from the first quarter. During the second quarter, we repurchased 4B in common stock, and as Charlie highlighted, subject to Board approval, we expect to increase our common stock dividend in the third quarter. Our CET1 ratio is 1.5 percentage points above our current regulatory minimum plus buffers, and was 1.8 percentage points above our expected new regulatory minimum plus buffers starting in the fourth quarter of this year. While we expect to repurchase more common stock this year, we believe continuing to maintain significant excess capital is appropriate until there is more clarity on the new capital requirements that Charlie highlighted. Our liquidity position remains strong in the second quarter with our liquidity coverage ratio approximately 23 percentage points above the regulatory minimum. Turning to credit quality on slide five. Overall credit quality remains strong, but as expected, net loan charge-offs continue to increase from historically low levels and were 32 basis points of average loans in the second quarter. Commercial net loan charge-offs increased $137 million from the first quarter to 15 basis points of average loans. Approximately half of the increase was in commercial banking, where the losses were borrower-specific with little signs of systematic weakness across the portfolio. The rest of the increase was driven by higher losses in commercial real estate, primarily in the office portfolio. I'll share some more details on the CRE office exposure on the next slide. Consumer net loan charge-offs increased modestly, up $23 million from the first quarter to 58 basis points of average loans. The increase primarily came from the credit card portfolio, as residential mortgage loans continue to have net recoveries and auto losses declined. While consumer credit performance remains solid overall and we continue to take incremental credit tightening actions across the portfolios, we expect consumer net loan charge-offs will continue to gradually increase. Non-performing assets increased 14% from the first quarter as lower non-accrual loans across the consumer portfolios were more than offset by higher commercial non-accrual loans, primarily in the commercial real estate portfolio. Our allowance for credit losses increased $949 million in the second quarter, primarily for commercial real estate office loans, as well as for higher credit card balances. We've updated slide 6, which highlights our commercial real estate portfolio. We had $154.3 billion of commercial real estate loans outstanding at the end of the second quarter. with $33.1 billion of office loans, which were down modestly from the first quarter and represented 3% of our total loans outstanding. The office market continues to be weak, and the composition of our office portfolio is relatively consistent with what we shared with you the first quarter. As Charlie mentioned, our CRA teams are focused on surveillance and de-risking, which includes reducing exposures and closely monitoring at-risk loans. This quarter we added a table to this slide that breaks down our CRE office exposure in the context of our broader CRE portfolio. As the slide shows, our office loans at the end of the second quarter were primarily in corporate investment banking, and that is also where we had the most not-a-cool loans and the highest level of allowance for credit losses. Last quarter, we disclosed for the first time the allowance for credit losses coverage ratio for the office portfolio in the corporate investment bank, which increased from 5.7% at the end of the first quarter to 8.8% at the end of the second quarter. This quarter, we are also providing our allowance for credit losses for our total CRE office portfolio, which was 6.6% at the end of the second quarter, up from 4.4% at the end of the first quarter. As we highlighted last quarter, we're providing this data to give you more insight into the portfolio, but each property situation is different and there are many variables that can determine performance, which is why we regularly review this portfolio on a loan by loan basis. For example, we have properties that are experiencing increased vacancies where borrowers have decided to inject equity and make investments to improve the property, even in cities with more difficult fundamentals. We also have properties that are well leased and performing, but borrowers need help refinancing. In those situations, we are working with borrowers to restructure, which in many cases includes some pay down of the balance. There are also situations that result in a sale or workout of the asset. We will continue to closely monitor this portfolio, but as has been the case in prior cycles, this will likely play out over an extended period of time as we actively work with borrowers to help resolve issues that they may be facing. On slide 7, we highlight loans and deposits. Average loans were relatively stable in the first quarter and were up 2% from a year ago, driven by higher commercial and industrial loans and commercial banking and credit card loans. I'll highlight specific drivers when discussing our operating segment results. Average loan yields increased 247 basis points from a year ago and 30 basis points from the first quarter due to the higher interest rate environment. Average deposits declined 7% from a year ago, predominantly driven by deposit outflows in our consumer and wealth businesses, reflecting continued consumer spending and customers reallocating cash into higher-yielding alternatives. While down from a year ago, average commercial deposits were relatively stable in the first quarter, and average deposits grew in corporate and investment banking. As expected, our average deposit costs continue to increase, up 30 basis points from the first quarter to 113 basis points, with higher deposit costs across all operating segments in response to the rising interest rates. Our mix of non-interest-bearing deposits declined from 32% in the first quarter to 30% in the second quarter, but remained above pre-pandemic levels. Turning to net interest income on slide 8. Second quarter net interest income was 13.2 billion, up 29% from a year ago, as we continue to benefit from the impact of higher rates. The $173 million decline from the first quarter was primarily due to lower deposit balances, partially offset by one additional day in the quarter. At the beginning of the year, we expected full-year net interest income to grow by approximately 10% compared with 2022. We currently expect full year 2023 net interest income to increase approximately 14% compared with 2022. There are a variety of factors that we've considered in our expectation for the rest of the year. We are assuming modest growth in loans, some additional deposit outflows, and migration from non-interest bearing to interest bearing deposits, as well as continued deposit repricing, including competitive pricing on commercial deposits. Additionally, we are using the recent rate curve, which is shown on the slide. As a reminder, many of the factors driving that interest income are uncertain, and we will need to see how each of these assumptions plays out during the remainder of the year. Turning to expenses on slide 9, non-interest expense grew $125 million, or 1% from a year ago. At the beginning of the year, we expected our full year 2023 non-interest expense excluding operating losses to be approximately 50.2 billion. We currently expect our full year 2023 non-interest expense excluding operating losses to be approximately 51 billion. The increase includes higher severance expense due to actions we have taken and planned to take in 2023 as attrition has been slower than expected. Of note, we've reduced headcount each quarter since the third quarter of 2020, and headcount declined 1% from the first quarter and 4% from a year ago. As a reminder, we have outstanding litigation, regulatory, and customer remediation matters that could impact operating losses. Turning to our operating segments, starting with consumer banking and lending on slide 10. Consumer and small business banking revenue increased 19% from a year ago as higher net interest income, driven by the impact of higher interest rates, was partially offset by lower deposit-related fees, driven by the overdraft policy changes we rolled out last year. We continue to reduce the underlying costs to run the business as customers migrate to digital, including mobile. We've reduced our number of branches by 4% and branch staffing by 10% from a year ago. Home lending revenue declined 13% from a year ago, driven by lower net interest income due to loan spread compression and lower mortgage originations. We continue to reduce headcount in the second quarter, down 37% from a year ago, and we expect staffing levels will further decline during the second half of the year. Credit card revenue increased 1% from a year ago due to higher loan balances. Payment rates were down from a year ago but have been stable over the last three quarters and remained above pre-pandemic levels. New account growth remained strong, up 17% from a year ago, and importantly, the quality of the new accounts continued to be better than what we were booking historically. Auto revenue declined 13% from a year ago, driven by continued loan spread compression and lower loan balances. Personal lending revenue was up 17% from a year ago due to higher loan balances. Turning to some key business drivers on slide 11. Mortgage originations declined 77% from a year ago and increased 18% from the first quarter, reflecting seasonality. We funded our last correspondent loan in the second quarter, with our current focus being serving our paying customers as well as borrowers in minority communities. The size of our auto portfolio has declined for five consecutive quarters, and balances were down 7% at the end of the second quarter compared to a year ago. Origination buying declined 11% from a year ago, reflecting credit tightening actions as well as continued price competition. As Charlie highlighted, debit card spend was flat in the second quarter compared to a year ago, spending on fuel due to lower gas prices, home improvement, and travel had the largest declines compared to last year. Credit card spending continued to be strong. It was up 13% from a year ago. Growth rates were stable throughout the second quarter, with fuel the only category down year over year. Turning to commercial banking results on slide 12. Middle market banking revenue increased 51% from a year ago due to the impact of higher interest rates and higher loan balances. Asset-based lending and leasing revenue increased 13% year over year, primarily due to higher loan balances. Average loan balances were up 12% in the second quarter, Average loan balances have grown for eight consecutive quarters, though the pace of growth has slowed. Average loans grew up 1% from the first quarter, with loan growth in asset-based lending and leasing driven by seasonally higher inventory levels, while middle market banking loans were flat. Turning to corporate investment banking on slide 13. Banking revenue increased 37% from a year ago, driven by stronger treasury management results. reflecting the impact of higher interest rates and higher lending revenue. The growth in investment banking fees from a year ago reflected write-downs taken in the second quarter of 2022 on unfunded leveraged finance commitments. Commercial real estate revenue grew 26% from a year ago, driven by the impact of higher interest rates and higher loan balances. Markets revenue increased 29% from a year ago, driven by the higher trading results across most asset classes. Our strong trading results during the first half of the year were driven by underlying market conditions and also reflected the benefit of our investments in technology and talent, which have allowed us to broaden our client franchise and generate more trading flows. Average loans were down 2% from a year ago and 1% from the first quarter. The decline from the first quarter was driven by banking, reflecting a combination of slow demand and modestly lower line utilization. On slide 14, wealth and investment management revenue is down 2% compared to a year ago, driven by a decline in asset-based fees due to lower market valuations. Growth in net interest income from a year ago was driven by the impact of higher rates, partially offset by lower deposit balances as customers continue to reallocate cash into higher-yielding alternatives. However, outflows into cash alternatives slowed in the second quarter. As a reminder, the majority of WIM advisory assets are priced at the beginning of the quarter, so second quarter results reflected the market valuations as of April 1st, which were down from a year ago. Asset-based fees in the third quarter will reflect higher market valuations as of July 1st. Average loans were down 3% from a year ago, primarily due to the decline in securities-based lending. Slide 15 highlights our corporate results. Revenue increased $751 million from a year ago, driven by the impact of higher interest rates and lower impairments of equity securities in our affiliated venture capital and private equity businesses. In summary, our results in the second quarter reflected continued improvement in our earnings capacity. We grew revenue and had strong growth in pre-tax provision profit. As expected, our net charge-offs continued to slowly increase from historical lows, and our allowance for credit losses increased. We are closely monitoring our portfolios and taking credit tightening actions where we believe appropriate. Our capital levels remain strong. We continue to repurchase common stock. We will now take your questions.

Thank you. We will now begin the question and answer session. If you would like to ask a question, please press star 1 at this time. If at any time while waiting in queue your question has been answered, you can remove your request by pressing star 2. Once again, that is star one for questions at this time. Please stand by for our first question. Our first question will come from Ken Houston of Jefferies. Your line is open, Sir. Mr Houston, please check the mute button on your phone. Why don't we take another one, and then we'll come back to Ken. Certainly. The next question will come from Scott Seifers of Piper Sandler. Your line is open.

Morning, everyone. Thank you for taking the question. It was great to see the higher NII guide and the performance this quarter. That said, it seems likely that dollars of NII will come down from here. I guess just broadly speaking, are you able to chat about what factors – might be most important in your ability to arrest a downward move in NII? In other words, when and why would it end up flattening out if we're ideally getting close to the end of a Fed tightening cycle?

Yeah, thanks, Scott. It's Mike. I'll take that, and Charlie can jump in if you want. When you look at the assumptions that underpin that, and I highlighted some of this in my script, but I'll kind of go back through them. We've got a little bit of modest loan growth in there, so that's not a big driver of sort of what we're seeing. And I think you're probably seeing that from others where we're just not seeing that same demand that we saw a year or so ago on loans. We're also assuming, you know, that we'll see some additional outflows, you know, particularly in the consumer space as people continue to spend money. And then we'll see some more migration from not interest-bearing to interest-bearing deposits. And then, you know, deposit pricing will, you know, betas will, you know, will evolve over time. I think it's still very competitive on the commercial side, and I think that will continue on the consumer side, but it will evolve. So I think you've got to look at those combination of factors and, you know, make some assumptions around when you think they start to stabilize. And, you know, but I think we're assuming that, you know, those trends that we've been seeing now for the last couple quarters will continue at least through the year end.

Okay. Perfect. And maybe if we could drill down into one of those in particular, just the migration from non-interest bearing to interest-bearing, you know, they've come down but are still above pre-pandemic levels, I believe. Do you have a sense for where and why those would start to settle out?

Yeah, I mean, there's a few factors underneath that. As you pointed out, we're about 30% at the end of the quarter, down from about 32, I think, the prior quarter. And, you know, if you go back pre-COVID, they were in kind of the mid-20s, mid to upper 20s, depending on exactly when you look at it. So, And we've been trending downward. You know, part of that is excess deposits on, you know, the commercial side. You know, as people use up their earnings credits for the fees they're paying, you're seeing some migration there. That stabilizes. And then you've seen, again, on the consumer side, you know, people spending from their, you know, their primary checking accounts. So those are the factors that I'd look at on when that starts to, you know, slow down and stabilize. But it's been pretty consistent, at least for the last quarter or two.

Yeah.

Okay. All right. Thank you very much, Mike. Thank you. The next question will come from Ibrahim Poonawalla of Bank of America. Your line is open, sir.

Hey, good morning. So, Mike, thanks for the details on the CRE book. I think Charlie mentioned that you've gone through loan by loan in identifying, and I appreciate the idiosyncratic nature of every sort of CRE loan, but given the reserve you've taken this quarter, Give us a sense of your visibility around how well-deserved the bank is today, knowing what we know in terms of the macro outlook. And also, if you can comment on just the rest of the CRE book, particularly as it relates to San Francisco or California, and your level of comfort around just apartments, et cetera, within that market. Thank you.

Yeah, thanks. I'll take that, Mike. You know, broadly, I'll start on the broader point on Syria, and I'll come back to office. You know, I think, you know, we've gone, you know, through the multifamily portfolio in quite a lot of detail. And I think, you know, I'm talking about the broader portfolio first, right? And so you talked about apartments in some cities. And so I think when you look at, you know, the broader portfolio, including multifamily, it's all performing quite, you know, quite well. And I think you've seen certainly a slowing of growth rates in rents, but they're not declining in most cases. You're seeing good occupancy rates in many of the new construction that's coming online. And so, overall, it feels quite constructive still for multifamily. And that same theme really applies to the rest of the portfolio. On office, that's the place where we're certainly seeing weakness. And as you think about the allowance we put up, we do have some very specific borrower loan level estimates of what we think could play out over the next few quarters, and that's embedded in the allowance. And then as you look at the rest of the office portfolio, we've gone through a number of stress scenarios. and feel like at this point we're appropriately reserved to be able to deal with what could be a number of different scenarios, depending on how it plays out over time.

Got it. And I guess just a separate question. You obviously have ample capital. Just, Charlie, from your standpoint, how impactful is the asset cap today, given the squeeze on the rest of the industry? Wells would actually be gaining market share, but is the asset cap and all the regulatory issues, I'm not going to ask you to give us a timeline, but is that still a meaningful challenge in terms of your ability to take market share?

Well, I mean, you can look at the size of our balance sheet and, you know, see where it is relative to the asset cap, which is, you know, $1.952 trillion, I think. It's the asset cap. Yeah, that's the actual cap, remember, which is a daily average over a couple of quarters. So, Relative to where we're operating today, we feel like we still have plenty of balance sheets to serve our customers, and it's not standing in the way of that. Hasn't always been the case, but I think that's where we are today. But putting just the pure economics of the asset cap aside, it is something that when we look at the work we have to get done, the fact that it's there is a statement of the reality that we still have more work to do. And so it's critical that we continue on our road to complete that work. And so that's the way we're thinking about it today.

And maybe I'll just add one thing. When you look at some of the growth opportunities we have, Charlie highlighted some of the investment banking hires we're making. In large part, we already have the exposure out to the client base there, so now it's about making sure we've got the right people to go after the fee opportunity, not necessarily extending a lot more balance sheet. Wealth management and the growth opportunity there, same theme. And even in the card space, as we look at, you know, the refreshed product line is doing really well. We've got more to come there. And I think we've got plenty of room to, you know, continue to support many of the growth opportunities we have, even if we didn't, you know, put out more, have more exposure to support it.

Good call. Thank you.

Thank you. The next question will come from Steven Chubik of Wolf Research. Your line is open, sir.

Hey, good morning. So I wanted to start off with a question just on the NII outlook, certainly encouraging to see the guidance increase. But you noted, Mike, that it does contemplate a modest level of loan growth. And just parsing some of your other comments where you alluded to credit tightening, signs of slowdown in the broader economy, what gives you confidence around some inflection in lending activity, especially given the flattish loan growth that we've seen this quarter?

Yeah, well, you know, I think we're seeing, you know, we're certainly seeing growth in cards. So I think we would expect that to continue. You know, and then in the rest of the, you know, portfolios, you know, we see a little bit of growth in the asset-based lending and leasing, you know, business in the commercial bank. You know, middle market's kind of flat at least this quarter. And then you can see the consumer items. So I think, you know, we're hopeful that we'll see some growth, you know, as we go into the second quarter. But as always, you know, Steve, what we try to do with guidance is give you guidance that, you know, it doesn't necessarily require every assumption to go in our favor. So, the bigger drivers of uncertainty around, you know, NII for the rest of the year continue to be the same ones we've been talking about now for the last couple quarters. It's really going to be deposits and deposit pricing. You know, the loan story will matter, but not anywhere near to the same degree.

No, it's helpful, Color. And just to follow up on expense, you cited the headcount reductions and higher severance costs driving some upward pressure this year, but just wanted to better understand how we should be thinking about the exit rate on expense once the headcount actions that you cited are fully captured in the run rate and whether there's any plans to maybe redeploy some of the NII windfall to reinvest back into business as we think about some of the potential benefits and the higher NII guidance you cited.

Yeah, I think our focus on expenses really hasn't changed over the last quarter or two. As we've talked about now for a while, we're going to continue to be very disciplined around the expense base. I think we're very much focused on making sure we execute and achieve the efficiencies that we've talked about. And as we get to year end, we'll sort of look at, you know, after we do our work around the budget for next year, we'll go back through, you know, all the ups and downs like we normally do and give you some perspective there. But really the thinking around it hasn't changed.

And let me just add, if it's okay, you know, I think when we laid out our expense guidance, we got a series of questions about, you know, how we think of, you know, the variability of that number and, you know, the environment and will the rest of our results impact that number. And I think, you know, as we look at how we're performing, I think we, you know, it wouldn't be hard for us to make a bunch of decisions to hit an expense number. But to the point is we, you know, our results have been relatively strong. And so we are doing a series of things. You know, I don't think about it as one-time expenses, but we have, you know, there is a fair amount of subjective expenses that relate to business development, product enhancements, and things like that, that we do have the ability to, you know, each year, each quarter, look at how we're performing and decide how much we want to spend. And so as we look forward, I think we're going to wait and see as we go through our budgeting process and we do a series of scenarios in terms of how things could play out next year and then make that determination. But as Mike said, I think we do separate out the fact that we continue to believe that there are you know, continued opportunities to drive efficiency throughout the company. We're not going to lose sight of that. And that is separate from how much do we want to spend away from that. And we'll talk more about that towards the end of the year.

Helpful caller. Thanks so much for taking my questions.

Thank you. The next question will come from John Pancari of Evercore ISI. Your line is open, sir.

Good morning. I want to see if we can get just some of your updated thoughts on buybacks here. CET won 10.7 and, you know, you indicated the $4 billion buyback and 2Q when you expect to continue to buy back from here. But obviously Basel III endgame is a factor, and I heard you on that you're contemplating buybacks as you look out from here. So could you maybe help frame that for us, what that could mean in terms of the pace of repurchases? Thanks.

You know, not really any more than, I think what we said is, you know, as much clarity as, you know, we want to give at this time. I think, you know, we are, you know, we have substantial excess capital above the regulatory requirements and regulatory buffers and on top of, you know, the level of buffers that we have talked about running at. And so we think that's prudent given the fact that, you know, it's likely that capital requirements are going up. But, you know, the reality, you know, to answer the question, you know, just in terms of the timing and in terms of the ability to answer the question, you know, from everything that we read is the same thing that you read. It's, you know, likely that we will learn later this month or early next month exactly what the proposal is. And, you know, based upon that, it'll help us inform exactly how much room we have for buybacks. But in most of the scenarios that we see, there is room for us to continue the buyback program in a prudent way and still build the required capital to whatever levels we'd have to be required to build them at and keep the kind of buffers that we want to keep. So there are a bunch of moving pieces here. And so it just doesn't make sense to put any more numbers on it until we actually see what those proposals are.

okay thank you that's helpful and then separately on the nii side um again appreciate the updated guide for 23 of the 14 maybe can you talk about when you look at the forward curve you know what could be the forward curve implications for nai as you look further out into 2024 if we do reach a you know fed funds of around four percent implied by the forward curve How much of a headwind to NII could that be for you? And maybe also if you could just talk about the near-term deposit trajectory. I know you mentioned still continued decline. I don't know if you can help frame that, size it up. Thanks.

Yeah, John, I'm not going to, you know, give you much clarity on 2024, but I think the things you should think about, obviously, are going to be, you know, on the commercial side, you know, rate betas on the way up are pretty high. Betas on the way down are pretty high. And, you know, the consumer side really hasn't moved much at this point. And so I do, you know, you sort of have to go into your modeling looking at each of the components a little bit differently. And as we and I think many others have talked about over time, like once rates peak, there is likely some lag of continued repricing, you know, for a while after rates peak. And so you've got to think about all of all of how that, you know, goes in your model. And then I think, as I said in my script, I think, you know, we've seen pretty consistent, you know, performance across deposits over the last couple quarters. And we're not seeing, you know, big shifts in behavior at this point. And so we'll see how that goes over the, you know, coming quarters. But there's, you know, there's still a lot of, you know, uncertainty in the assumption set that you go through, that you have here. And so you've got to make your best judgment on what you think is going to happen. But as you get closer, you know, to the end of the rate cycle, you've probably seen, you know, a lot of the, you know, mix shift and repricing happening already. And so, we'll see how that goes.

And can I just add? Thank you.

Yeah.

You know, just even just more broadly, just to, you know, be clear about, you know, we don't, you know, we're not looking specifically at giving guidance in terms of 2024 yet. But at the same time, just more broadly speaking, we are and have been out earning in NII. And we've been very clear about that as we talk about getting towards our 15% RO2 CE targets. It's in a more normalized environment. But at the same time, you know, there are, you know, a series of things that, you know, we expect to be able to do as we look forward. You know, a big part of it is growing the fees in the business as Mike spoke about. We're not constrained by the asset cap. They're in our existing businesses. And a lot of the things that we're doing, whether it's in our wealth business, whether it's in the card business, whether it's in the corporate investment bank or middle market as well. We do expect to, you know, see the fruits of that labor. At the same time, we continue to stay very focused on expenses. And then the other thing I would just remind everyone is, you know, there's lots of conversations around charge-offs and things like that. But, you know, remember, we are all required when we think about CECL, you know, to be as forward-looking as we possibly can. You all know how we come up with the different scenarios. And so the level of reserving that's been running through our P&L, I think this is the fifth consecutive quarter we've added to reserves, which is what's impacting the EPS of the company. you know, has been, you know, based upon an environment which at some point will be very different than what the expectation is sitting here. So I think you add all those things together, and I just think it's important you think about all those things as opposed to just NII itself.

Next question, operator. Certainly. We'll move on to Betsy Gracek of Morgan Stanley. Your line is open.

hi good morning um just two follow-ups one on the reserve build in commercial real estate that i know you discussed a bit already i just wanted to understand how much of that was coming from you know really california you know we all know there was a property that traded on california street that sold a discount so i'm just wondering how much of it is you know california office versus anything more broader-based beyond that? Thanks.

Yeah, Betsy, it's not isolated California. I mean, I think you see weakness in a lot of cities these days, and it really comes down to property-specific stuff. And even in California, you know, we've got, you know, as many examples where, you know, clients are actually reinvesting in buildings, even if lease rates are or low or even empty in some cases as they are going into a workout. So I think it really depends on building, borrower, and all the things we sort of talked about in the script, and it's less focused on just California.

Yeah, and I just want to reemphasize what, you know, Mike is saying, and we talked about this in the prepared remarks, which is, you know, we have all spent, you know, a bunch of time going through a very detailed review of the office portfolio. Just the other day we went through just a whole series of things that we're seeing. And I just really want to make the point, which I said in my script, it's not—it's a very big mistake to think about lost content by looking at just where the property is. Again, we have examples in cities that are struggling where the structure of our loan is quite good. The underlying property has very high lease rates, you know, for an extended period of time. And then we can have a loan in a market which is doing well, but for whatever reason that property is a specific issue in that property. There are a bunch of, you know, potential termination dates in the shorter term. And so that's the level of detail that we've used to look at to come up with, you know, what we think the appropriate level of reserving is. And, you know, I think, you know, we've tried to, you know, be as, you know, as diligent as we can in stressing the scenarios that we see play itself out so that when we look at ourselves and we understand what CECL reserving requires us to do, that's what we're trying to accomplish.

So would you, and I think we all know, like, for the most part, commercial real estate loans are bullets, right, where the stress comes at the role. And I guess I'm wondering, is this reserve ad reflecting the entirety of the Cree book for, you know, that entirety of roll rate risk? Or is this, you know, like a two-year forward? And part of the reason for asking the question is trying to understand if there's, you know, how much risk there is for further increases in Cree-related reserve builds.

Yeah, Mike, I'll start and then either chime in or give your opinion. We have tried to take into account all of the risks, including refinance risks, that exist in the portfolios, looking at, you know, the current rate environment, cap rate expectations, and things like that. You know, is it possible that we have to add something in the future because we learn more as time goes on? We would never say no. But again, what we're trying to do is be holistic in the review of the portfolio based upon everything that we know. And just as you can imagine, when we sit in the room with the people that run the real estate business and all the risk people, there's a range of opinions. There are people in there that say it's hard to see losing this amount of money based upon what that individual thinks all of the underlying assumptions will play themselves out as. And then, you know, there are others where we say we actually, you know, want to stress the scenario because it is possible and we have to give weighting to that. And so that's how we come up with what this is. But again, you know, we're trying to, again, I don't know, you know, just we're trying to be forward-looking. We're trying to be holistic in all the risks that exist. And part of the reason to show you that additional disclosure we made is so you can see exactly where the issues are relative to the rest of the office portfolio and the rest of CRE and isolate just the, you know, the level of reserving that exists, which is, you know, at this point is substantial. Got it.

I understand. Thank you.

Thank you. The next question will come from Gerard Cassidy of RBC Capital Markets. Your line is open.

Thank you. Good morning, guys. Mike, can you share with us, you touched on this a little bit in the response to one of the earlier questions, but when you guys are looking at your balance sheet and you're measuring your treasury functions on your assets and liabilities, can you share with us what you're thinking for the second half of the year or into next year in terms of how you're managing that and how that may be different than how you positioned the balance sheet a year ago?

Yeah, Gerard, sure. You know, it's not that different, right? On the margin, you know, you may be making decisions, you know, to, you know, add a little duration here or there, but I'd say it's marginal at this point, and we really haven't changed substantially how the balance sheet's positioned.

Very good. And then just to follow up, I know you guys have given some good details here on working through the commercial real estate portfolio. And Mike, I think you said in your prepared remarks, in some cases, you've been able to get additional payments or equity investments from your borrowers to cure maybe a potential problem. Can you share with us some of the other workout solutions you're using so, you know, you can get through this, you know, this period of adjustment that we're seeing in commercial real estate?

Yeah, I mean, sure. You know, there's plenty of little structural, you know, enhancements you can make to feel better about it. And then you're also, in a lot of cases, getting some partial paydowns. And then you look at and you're trading those for, you know, refinancing term. And I think you give people a bit more time to work through the sets of issues. You know, I think we try really hard not to punt issues down the road. And so if there are real issues that we need to deal with, we try to deal with them in the moment. But there are a number of structural enhancements that we sort of work on with borrowers to get ourselves comfortable with. that we're setting the loan up for success.

Very good.

Thank you. Thank you. The next question will come from Erica Najarian of UBS. Your line is open.

Hi. Thanks for taking my question. I wanted to ask a question on how you're interpreting the OCC and Fed joint statement that they put out on June 29th, you know, encouraging lenders, you know, fine short-term or temporary loan accommodation solution for their borrowers, is that really anything new? Is that just standard operating procedure that they're reiterating? Or can this sort of help, you know, provide a solution that would, you know, allow you to work with your borrowers and perhaps delay a classification, you know, deterioration of classification or a classification to TDR?

Yeah, it's Mike. I'll take that. Well, TDR doesn't exist anymore, but the – that classification. But the guidance is very similar to what was issued, you know, originally back, I think, in 2009. It hasn't really changed much. It doesn't really change the way we've been interacting with our borrowers already. in terms of really being proactive to work with them to find solutions to help them work through what could be difficult circumstances in some cases. And it doesn't give you any leeway for how you classify criticized loans or other classifications. So the intent is really to just be clear that people should continue to work with borrowers to find solutions, which is what we do all the time anyway.

Got it. And just a follow up question here. Thank you for the disclosure again, on slide six, you know, with your 22 billion of your loans in CIB, I think investors are wondering, you know, what is the average loan size there?

Yeah, I don't think that's something we give, and there's a wide range. Averages sometimes are very misleading, and so there's a wide range. And what really matters is not the loan size. It really matters, you know, what really matters is all the variables Charlie talked about earlier in terms of what's happening with that property. So I think that would be, I think I would focus there.

And just squeezing in one more question, and before I ask this expense question, Charlie, I think your investors very much appreciate it, that you're not just doing whatever you can to hit an expense number and you're reinvesting back into the company. So to that end, I'm wondering, have you disclosed how much of the $800 million increase in the outlook for this year has to do with severance?

We didn't give an exact number, but that is by far the single largest piece of it. That's part of it. And there's some other exit costs for properties as we exit some lease space and other things. But the severance is by far the largest piece.

Got it.

Thank you. Thank you. Thank you. The next question comes from Matt O'Connor of Deutsche Bank. Your line is open.

Good morning. I want to follow up, Charlie, on some of your prepared remarks. You talked about there's still some things that you're implementing to address regulatory issues. I'm wondering if you could give a couple examples of what still needs to be done in terms of implementation and when you expect that to be completed.

Listen, I think, as we've said, there's a lot of work to do. It is multi-years. worth of deliverables. What I've said is that we've implemented a lot, but we still have more to do. And when I say that, I just want to be clear. Everyone generally thinks I'm speaking about one of the consent orders, which has the asset cap. We're thinking about all of the work that we have to do related to all the consent orders and the work to build the control environment. And there is a lot getting done, but ultimately what matters, you know, you don't get an A for effort in this. It's about getting things over the finish line on time and getting them done to the, you know, with the quality that our regulators and we expect from each other. And so, you know, as you know, you know, we've been very careful not to put dates out there because we have to do our work and then our regulators have to you know, take a look at it and see if it's done to their satisfaction. We don't want to get ahead of that process, but we continue to move forward.

And I understand that, you know, you can't speak for them signing off on what you've done, but, you know, in terms of you accomplishing what you want to accomplish, you know, where are you on that kind of process, like whether you want to frame it from an innings perspective or or percent basis, any way to frame that, you know, acknowledge that there's a lot to do and that you've done a lot, but how far along are you in terms of what you can control on implementing these things?

Yeah. Now, listen, I appreciate, you know, your desire to have me answer those questions, but, again, all that matters, you know, Our view of accomplishing the work doesn't matter. What matters is that our regulators look at it and say it's done to their satisfaction. So, I really don't think it's helpful or productive to, you know, go beyond what I've said at this point. But again, I do understand and appreciate why you're asking.

Understood, and fair enough. Thank you.

Thank you. The next question comes from Vivek Jeneja of JP Morgan. Her line is open.

Hi, thanks. Quick one. Mike or Charlie, can you give us the maturity schedule? What percentage or amount of your office CRE loans are maturing in the second half and into 2024?

Not specifically, Vivek. We don't disclose that, but you should assume these are standard course loans in the commercial real estate space, which are generally three- to five-year loans.

Okay. And you haven't really been originating much in the last couple of years, so I guess we could go back to looking at when did you slow down the origination of new Was it two years ago? Was it three? Any color on that?

Yeah, look, I think you have to remember that we've been refinancing, you know, existing facilities along that time period. But I think if you take the portfolio and assume some kind of basic average life based on what I said, I think you'll get a pretty good sense of, you know, the approximate maturity schedule.

Okay. And how about multifamily? What's the average life of those loans and maturities there? I heard your comments that those are in a much better position, given all the factors you already cited.

Slightly longer, a few years longer than office. Okay.

All right. Thank you. And our final question for today's call will come from Charles Peabody of Vertalis Partners. Your line is open, sir.

Good morning. Most of my questions were already asked and answered, but just I wanted to follow up on the consent order issues. If I recall correctly, and please correct me if I'm wrong, there's six consent orders remaining, and three of them, if I remember, deal somewhat with the mortgage banking operation. And I know starting last fall, you started the planning effort to simplify and downsize that and you've been executing on that this year. Can you give us a sense of what it is you need to do in mortgage banking related to those consent orders?

Yeah, so this is Mike. So first of all, there are nine public consent orders out there that are all there, so you can see those. When you look at the mortgage ones, I think that each of the consent orders is actually quite clear in terms of you know, what needs to happen to satisfy those. So I would just point you back to the documents themselves, which can give you a pretty good sense of what it is. And each one's a little bit different.

Paul Upton, do you talk to the regulators about the progress you're making in mortgage banking on a monthly basis or quarterly basis, semiannual, or do you present something at the end? How does the interaction with the regulators go?

We talk to our regulators all the time at all parts of the company, at all levels of the company. And so, you know, you should assume we're actively engaged consistently with our regulators all the time.

But the only thing I would add to that is, but again, you know, they're here, they're on site. We talk to them literally all the time.

Right. No, I understand that. But specifically related to the progress you're making.

No, I know. Just give me a second. We talk to them about everything. And given the importance of the consent orders, you can assume it's about the work that's going on in the underlying consent order. But having said all of that, what matters is the work that they do at the end of the consent order after we submit it to them. And so, you know, they can be up to speed on what we're doing. They can know how we feel about the progress that we're making. But when we submit a consent order to them, they come in and do their holistic review. And so that's really where their determination is made about whether or not it's done to their satisfaction. So, again, that just gets to, you know, the reason why I want to be very careful about not drawing any conclusions from our view on our work or any interim comments we might get from them. What really matters is the holistic review that they do and the process that they go through internally in the regulatory organizations.

So that was part of my first question. Have you submitted anything yet on mortgage banking?

We're not going to talk about that. I've said that over and over and over again.

Thank you.

Okay. Thank you very much, everyone. We appreciate the time, and we'll talk to you all soon.

Thank you all for your participation on today's conference call. At this time all parties may disconnect.