Name of institution: CIT Group Inc. Submission date: March 31, 2010 

PART I. QUANTITATIVE OVERVIEW

SCHEDULE A: CONSUMER LENDING (Millions $) JAN FEB MAR Key 1. First Mortgagea. Average Loan Balance (Daily Average Total Outstanding) N/A N/A N/A

b. Total Originations N/A N/A N/A(1) Refinancings N/A N/A N/A(2) New Home Purchases N/A N/A N/A

2. Home Equity

a. Average Total Loan Balance N/A N/A N/Ab. Originations (New Lines+Line Increases) N/A N/A N/A

2010

TREASURY MONTHLY INTERMEDIATION SNAPSHOT

1

c. Total Used and Unused Commitments N/A N/A N/A

3. US Card ‐ Managed

a. Average Total Loan Balance ‐ Managed N/A N/A N/A

b. New Account Originations (Initial Line Amt) N/A N/A N/A

c. Total Used and Unused Commitments N/A N/A N/A

4. Other Consumer

a. Average Total Loan Balance $9,570 Consumer Lending assets consist primarily of our Student Lending business, which is in run‐off

mode and approximately 95% government guaranteed.

b. Originations $0

1
SCHEDULE B: COMMERCIAL LENDING (Millions $) JAN FEB MAR Key 

1. C & Ia. Average Total Loan and Lease Balance $34,007 Included in the C & I asset balances is approximately $10.9 Billion of operating leases

b. Renewal of Existing Accounts $2,419 The Renewal of Existing Accounts is predominately from our Trade Finance business.

c. New Commitments $320 The bulk of our new commitments were generated from Global Vendor Finance.

2. Commercial Real Estate

a. Average Total Loan and Lease Balance $261 Some of our other businesses‐ Small Business Administration lending, and Energy financing, m

also have some of their loans secured by real estate. Those businesses are included in the

appropriate section of the report

b. Renewal of Existing Accounts $0

c. New Commitments $04. Small Business Loans3

a. Average Total Loan Balance $1,078 

SCHEDULE C: MEMORANDA ‐ SMALL BUSINESS LENDING (Millions $)

2

g 

b. Originations $10

SCHEDULE D: OTHER INTERMEDIATION ACTIVITIES (Millions $)

1. MBS/ABS Net Purchased Volume

a. Mortgage Backed Securities N/A N/A N/Ab. Asset Backed Securities N/A N/A N/A

2. Secured Lending (Repo, PB, Margin Lending)

a. Average Total Matched Book (Repo/Reverse Repo)1 N/A N/A N/A

b. Average Total Debit Balances2 N/A N/A N/A3. Underwriting

a. Total Equity Underwriting N/A N/A N/Ab. Total Debt Underwriting N/A N/A N/A

Notes:3. Memoranda: these loans are already accounted for in either consumer lending, commercial lending, or a combination of both, and include loans guaranteed by the Small Business Administration and/or any other loans that are internally classified as small business loa

2. Applicable only for institutions offering prime brokerage or other margin lending services to clients.

1. Not applicable if matched book activity does not exceed $50 billion.

2
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:   CIT Group Inc

Reporting month(s):  March 2010   

Submission date:  April 30, 2010

Person to be contacted regarding this report: Peter Justini – 973‐422‐3678

PART II.  QUALITATIVE OVERVIEW

Please provide a brief overview of the intermediation activity during the month.  This discussion should

include a general commentary on the lending environment, loan demand, any changes in lending

standards and terms, and any other intermediation activity.

Transportation Finance – Business Aircraft

Even though conditions in the corporate aviation market have improved in recent months, indicators

continue to point to an uneven recovery.  Used jet inventories, after falling 200bps from Q2 2009, have

leveled off in the mid‐12% range with inventory of used in‐production models slightly lower.  After

showing signs of stabilization, prices remain under pressure with asking prices down 4.1% in 2010 after

contracting nearly 30% off the peak from 2008.  Largest decrease in asking prices over the past two

months were seen in the Heavy category (‐3.1%) and Light (‐1.4%) while Medium jet prices were

essentially flat.  Flight operations continue to increase year over year but the uptick has stalled a bit

since late 2009.  The competitive landscape remains in flux with many competitors having exited the

market but competition for the remaining quality transactions is intense.  These conditions also present

an opportunity for lenders that are competitively priced and have a dependable source of funds to

invest in new business while at the bottom of the cycle.

  

Transportation Finance – Commercial Aircraft

The aircraft lease market appears to be improving modestly, albeit from very low levels, as air passenger

and freight traffic show signs of recovery.  Consistent with the previous months, CIT continues to

experience pressure on margins, reflecting lower lease rates on new deliveries and newly remarketed

aircrafts.  CIT is focused on optimal deployment of assets, maintenance of critical relationships and

executing on opportunities for growth profitability.  Commercial air revenues remained strong for March

as a result of high asset utilization.  

Transportation Finance – Rail Cars

While market conditions have stabilized (weekly rail loadings have improved), weak car loadings and

improved train speeds have resulted in significant excess capacity in the rail network; approximately

27% of the North American fleet is being stored as carriers and shippers continue to reduce costs and

rationalize fleet size.  In this market environment, the goal for many companies is to sacrifice rate to

keep rail cars on lease to mitigate storage and freight charges, as well as position the fleet for industry

turn around.   

Leveraged Finance (relative to the Transportation Sector)

The leveraged finance transactions flow is beginning to improve and credit quality remains strong

overall.  Certain CIT portfolio accounts that are tied to business jet production and commercial airline

servicing have been weakened but appear to be bottoming out; no portfolio impact is expected on these

accounts.  The loan market has significantly improved; leverage is still reasonable, but pricing has

decreased as liquidity at banks and institutional buyers drives loan demand.  High yield market has

become increasingly available to middle market issuers, sometimes reducing senior debt opportunities.   

1
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:   CIT Group Inc

Reporting month(s):  March 2010   

Submission date:  April 30, 2010

Person to be contacted regarding this report: Peter Justini – 973‐422‐3678

Corporate Finance / Loan Syndication

Leveraged loan issuance increased to $20B in March from $12B in February, but the maturity of issuance

comprises re‐financings and dividend transactions versus new money deals as M&A activity remained

weak.  Investor demand from banks and institutional investors continues to outpace supply, and this is

reflected in further narrowing of secondary yields:

Mar 2010 Feb 2010

All Leveraged Loans 5.54% 6.01%

Middles Market Leveraged

Loans

8.74% 9.87%

Portfolio quality continues to improve.  The default rate reached a 13 month low of 5.82% in March, and

covenant relief amendments dropped to their lowest level since November 2007, 2 for the month versus

6 in February.

High yield issuance remains torrid, and proceeds from high yield re‐financings of leveraged loans remain

a significant source of new liquidity for the loan market.  High yield volume of $38B in March

represented an all‐time record.

Trade Finance

Conditions in the marketplace have changed somewhat from the previous month; loan demand from

our continuing client base is down compared with last year and demand from new clients has

significantly decreased.  Loan pricing has been coming down and after the return to higher standards

that we have commented on for a number of months, we have seen a loosening of terms and structures

(i.e. loan documentation, covenants and collateral perfection).  

   

Vendor Finance

CIT’s Vendor Finance’s “VF” lending levels are up month over month despite economic conditions

remaining soft.  New originations trends are beginning to turn positive even as the economy is slow to

recover; however overall economic conditions continue to contribute to soft sales by our vendor

partners.  

Consolidation of funding sources within the global vendor markets has increased the overall demand for

VF type products and services.  Pipelines are beginning to build in all regions; CIT’s March volume

increased 51% versus February primarily driven by activity in US, Canada, Europe and Latin America.  

CIT’s losses (charge offs + specific reserves) decrease 9% in March compared to February.  Decreases

were seen in most regions and can partially be attributed to improving economic conditions, continued

process improvements within CIT and the expectation of fewer larger balance problem accounts not

already identified and charged down.  CIT also experienced a slow down on restructure requests from its

customers and early stage delinquency trends continue to be stable and are improving in the majority of

regions.  

2
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:   CIT Group Inc

Reporting month(s):  March 2010   

Submission date:  April 30, 2010

Person to be contacted regarding this report: Peter Justini – 973‐422‐3678

Traditional syndication investors (one off deals and portfolio acquisitions) are being careful on their

investments and have moved to a “flight to quality”; investors are looking for:

• Investment grade deals  

• Focused on mid to large ticket transactions (no small ticket), resulting in higher margins  

• Opportunistic pricing

As for the macroeconomics across the Vendor Finance business segments, CIT is seeing/ experiencing

the following:

• Canada – While the economy performed better than anticipated in the last quarter of 2009 with

real GDP growth of 5% (annualized rate), the 2010 outlook is for moderate growth of 3% ‐3.5%.

This moderation is due to changes in drivers of the current growth namely personal

expenditures and investment in residential structures. The elimination of a Federal home

renovation tax credit in January could negatively impact consumer spending. Also the output

bolstered by increase in US demand in the later half of 2009 is forecasted to decrease since the

US growth appears to have been driven by temporary factors such as investment in inventories

and fiscal stimulus programs as captioned by recent reports from TD Bank. The anticipated

moderation of GDP growth and with the inflation rate currently at the projected target of 2%,

the Canadian Central Bank in Q1 decided to keep interest rates at their current low levels and is

expected to maintain current rates through the end of Q2 when a rate hike is forecasted. A

stabilized unemployment rate at the beginning of Q1 and an increase in exports in comparison

to imports are positive signs for 2010 GDP growth.  

• Latin American – While the overall regional economy contracted by 1% in 2009, the anticipation

is for GDP growth of about 2.5% in 2010 according to forecast by Moody’s. Brazil is forecasted to

top the region with the highest GDP growth for the period at 5.5% ‐6.5 %. Growth in Brazil is

mainly the result of recoveries experienced in the commodities market and an increase in

domestic demand. The resulting inflationary concerns caused by the this growth pattern

sparked the intervention of the Brazil central bank which tightened monetary policy in Q1 by

increasing minimum reserve requirements by 2% and is anticipated to increase interest rates in

Q2. Even Mexico which experienced a 6.7 % decline in GDP for 2009 heavily impacted by

economic contraction in U.S. is forecasted to for GDP growth of about 3%‐4% in 2010 as

outlined by a recent S&P report. This growth is based on the improvement in the U.S economy

(Mexico’s largest export market) and a better pricing benchmark for Crude Oil (Mexico’s largest

export) among others.

• Europe UK –  Core European Countries (France, Germany, UK) are now showing GDP growth and

stabilization however concern remains that if government spending / subsidies are cut too soon

there could be a return to negative growth. UK GDP increased by .3% in Q4, ending the

recession in the UK (statistically). 2010 is forecasted to have positive GDP with approximately

0.3% growth in 2010. Unemployment continues to remain high across the region. There are

concerns that removal of stimulus plans will negatively impact recovery and employment levels.

3
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:   CIT Group Inc

Reporting month(s):  March 2010   

Submission date:  April 30, 2010

Person to be contacted regarding this report: Peter Justini – 973‐422‐3678

4

• US ‐ US Economic conditions continue to indicate recovery but with ongoing weaknesses.

Unemployment remains high at 9.7% and consumer sentiment continues to be weak. Unlike

previous recessions it is unlikely that the US consumer will lead the recovery due to high

unemployment, reductions in income and net worth. However, Business spending has improved

with businesses investing in new equipment and technology. January industrial output increased

0.9% followed by 0.1% in February. February results were impacted by particularly harsh

weather in most parts of the US. The stock markets have just passed the one year mark from the

low point with the Dow increasing 55%. At the March Federal Open Market Committee meeting

the Federal Reserve announced rates would remain at low rates as inflation remains tame and

short term GDP growth will be low. CEO Confidence Index and the Composite of Leading

Economic Indicators have both continued to increase for 3 and 4 quarters respectively. Semi‐

Conductor demand though improving moderately slightly last quarter. Clearly a recovery is in

progress but it remains to be seen how robust it will be.

Small Business Lending

Regardless of signs that the economy may be improving, owners of small businesses are generally

pessimistic. This may be partly due to anticipated higher taxes and health care cost as a result of the

recent healthcare legislation. Their pessimism also reflects persistent earnings pressure due to lower

sales and net income. In view of the lack of confidence, many small businesses are avoiding new

borrowing. Positive economic developments will eventually translate to improved sales and earnings for

small businesses which should contribute to greater loan demand.  Many small businesses have taken

action to lower costs and some are now well positioned to thrive as the economic recovery broadens.

These businesses are creditworthy and should have access to credit as needed.

Consumer spending, the driver of many small businesses, registered a fifth consecutive month of growth

while employment grew at the fastest pace of the last three years. The unemployment rate, however,

remains at 9.7% and consumer spending remains unstable. Based on these factors, the economic

environment for small business is still unfavorable.

Consumer Lending

The student lending spreads continue to be stable with new loan issuance in the L + 75bp range.

The private loan portfolio delinquency performance month over month, as well as charge‐offs were a bit

lower.  The Q1 2010 charge‐offs were only $200K higher than Q4 2009.  The seasonality increase in

delinquencies that was observed in the Federal Family Education Loan Program portfolio has stabilized;

CIT experienced a $40M decrease in the 60+ day category.

The Consumer unsecured portfolio continues to liquidate quickly and charge‐off and delinquency

numbers continues to show a positive trend month over month and we expect the trend to continue.  
Name of institution: Citigroup Submission date: April 30, 2010 Person to be c

PART I. QUANTITATIVE OVERVIEW

SCHEDULE A: CONSUMER LENDING (Millions $) JAN FEB MAR Key 1. First Mortgagea. Average Loan Balance (Daily Average Total Outstanding) $132,472 $131,308 $129,446 Consists of residential whole loans. Excludes assets classified as trading assets that are not part of

the core mortgage portfolio.

b. Total Originations $3,441 $3,525 $3,905 Originations includes new loans whether for refinancing of an existing home or the purchase of a

home. It does not include troubled debt restructurings which usually includes a restructuring of

terms and not additional extensions of credit.

(1) Refinancings $2,009 $1,897 $2,098 If on a refinancing, amounts were added to the existing loan balance, the total amount of the new

loan is reported. Originations include both loans originated for the balance sheet as well as loans

originated for sale.

(2) New Home Purchases $294 $341 $438

2. Home Equity

a. Average Total Loan Balance $59,815 $59,106 $58,408 Includes HELOC and 2nd mortgages.

b. Originations (New Lines+Line Increases) $74 $113 $104 If a line is increased, only the amount of the increase is included in originations. If we originated a

new HELOC or 2nd, we included the amount drawn in the Ending and Average Balances, and we

included the total new line in originations.

End of period Fi

sale and held fo

decreased due t

decreased due t

Home equity loans 

and are included in 

mediation efforts a

who have contacte

deemed to be at ri

mediation efforts. 

2010

TREASURY MONTHLY INTERMEDIATION SNAPSHOT

1

c. Total Used and Unused Commitments $77,565 $75,158 $73,887

3. US Card ‐ Managed

a. Average Total Loan Balance ‐ Managed $137,588 $132,393 $128,317 Balances do not include commercial card activity.

b. New Account Originations (Initial Line Amt) $4,033 $5,319 $5,057

c. Total Used and Unused Commitments $776,214 $749,435 $736,088

4. Other Consumer

a. Average Total Loan Balance $70,954 $70,784 $70,003 Includes auto, student and personal loans. Student loans includes related deferred fees and lines

of credit with schools (which are secured by student loans).

b. Originations $2,002 $770 $818

Average balance

to an increase in 

Purchase sales w

receivables were 

month. Total Us

to participate in 

40% vs. prior ye

1
SCHEDULE B: COMMERCIAL LENDING (Millions $) JAN FEB MAR Key 

1. C & Ia. Average Total Loan and Lease Balance $33,316 $43,040 $45,212 Renewals and new commitments are on a facility basis. Facilities may include L/Cs. Renewals

represent credit facilities that expired/matured and were renewed during the period.

b. Renewal of Existing Accounts $373 $513 $3,472

c. New Commitments $477 $1,013 $3,4662. Commercial Real Estate

a. Average Total Loan and Lease Balance $23,265 $23,267 $23,813 Renewals and new commitments are on a facility basis. Facilities may include L/Cs. Renewals

represent credit facilities that expired/matured and were renewed during the period.

b. Renewal of Existing Accounts $194 $26 $112

c. New Commitments $47 $132 $1,416SCHEDULE C: MEMORANDA ‐ SMALL BUSINESS LENDING (Millions $)

4. Small Business Loans3

a. Average Total Loan Balance $9,976 $9,781 $9,569

New commitme

Average balance

The increase in A

consolidations.

2

b. Originations $95 $98 $84SCHEDULE D: OTHER INTERMEDIATION ACTIVITIES (Millions $)

1. MBS/ABS Net Purchased Volume

a. Mortgage Backed Securities $1,249 $1,580 ‐$3,699 Does not include maturities and pay downs. Net Purchased Volume is reported using cost basis.

b. Asset Backed Securities $268 $402 $9292. Secured Lending (Repo, PB, Margin Lending)

a. Average Total Matched Book (Repo/Reverse Repo)1 $157,267 $147,686 $168,200 Average Total Matched Book (Repo/Reverse Repo) is before FIN 41 netting. Includes security

lending activity.

b. Average Total Debit Balances2 $15,463 $15,169 $14,932

3. Underwriting

a. Total Equity Underwriting $28 $10 $50 Equity Underwriting represents Citi's portion of underwritten issue.

b. Total Debt Underwriting $17,104 $8,416 $14,684 Debt underwriting represents Citi's portion of underwritten issue and extensions of credit to

finance specific individual Community Development projects that are in bond form.

Industry stats inclu

1. 79 High Yield de

2. 214 Investment 

3. 93 Equity and Lin

Gross MBS and A

Notes:3. Memoranda: these loans are already accounted for in either consumer lending, commercial lending, or a combination of both, and include loans guaranteed by the Small Business Administration and/or any other loans that are internally classified as small business loans.

2. Applicable only for institutions offering prime brokerage or other margin lending services to clients.

1. Not applicable if matched book activity does not exceed $50 billion.

2
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:    Citigroup

Reporting month(s):    March 2010   

Submission date:    April 30, 2010

Person to be contacted regarding this report:   Carol Hayles or Peter Bieszard

1

PART II.  QUALITATIVE OVERVIEW

Please provide a brief overview of the intermediation activity during the month.  This discussion should

include a general commentary on the lending environment, loan demand, any changes in lending

standards and terms, and any other intermediation activity.

Company description:  Citigroup Inc. (“Citi”) does business in the United States through Citibank, Citi

Institutional Clients Group, The Citi Private Bank, CitiFinancial, CitiMortgage and Citi Cards.   

All data cited below reflect comparisons to February 2010, unless otherwise noted.

Consumer Lending:  Citi originated $9.9 billion in new loans to U.S. consumers and small businesses in

March, up 2 percent from February.  Unemployment remained flat at 9.7 percent on a month‐to‐month

basis, as signs of further stability in the economy contributed to slightly higher loan volumes.

In March, first mortgage loan originations totaled $3.9 billion, up 11 percent from February volumes.  

Average mortgage loan balances declined moderately to $129.4 billion, or 1 percent from the prior

month.   Average balances were impacted once again by moderate reductions in “held for sale” loans

and investment loans.

Average home equity loan balances in March were $58.4 billion, declining 1 percent from February

balances.  Used and unused commitments totaled $73.9 billion, down 2 percent from the prior month.

As in previous months, Citi continued to expand participation in its loss mitigation efforts and programs

focused on helping homeowners facing financial difficulty to modify their loans.  Through initiatives like

the Citi Homeownership Assistance Program, the CitiFinancial Home Affordable Mortgage Program and

the Home Affordable Mortgage Program, Citi modified approximately 17,900 first mortgage and home

equity loans with a total value of approximately $3.2 billion in March.

In March, Citi issued new credit card lines totaling $5.1 billion, down 5 percent from February levels.  

Purchase sales increased 15 percent month‐to‐month, but were 10 percent lower than in February

2009.  Average total card balances declined 3 percent on a month‐to‐month basis.

Card members continued to participate in Citi’s expanded eligibility forbearance programs in March.  

More than 152,000 card members enrolled in these programs during the month, compared with

145,000 in February.  Total balances covered by Citi’s forbearance programs decreased moderately on a

month‐to‐month basis, but increased 40 percent from the prior year period.   

Originations in other consumer lending categories increased 6 percent from February to $818 million,

driven by higher personal installment loan application volumes.  
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:    Citigroup

Reporting month(s):    March 2010   

Submission date:    April 30, 2010

Person to be contacted regarding this report:   Carol Hayles or Peter Bieszard

2

Commercial Lending:  Commercial lending activity increased in March.  Citi originated $23.2 billion in

corporate loans, more than double February’s total of $10.1 billion.

New Commercial & Industrial (C&I) loan commitments increased more than three‐fold to $3.5 billion,

compared with $1.0 billion in February.  Loan renewals totaled $3.5 billion, up nearly seven‐fold from

the previous month.   Average total C&I loan balances rose 5 percent to $45.2 billion, reflecting the

continued impact of changes in accounting standards covering consolidations that went into effect in

January.

In March, new Commercial Real Estate (CRE) loan commitments increased more than ten‐fold to $1.4

billion, compared with $132.4 million in the previous month.  Loan renewals increased to $112.1 million,

from $25.8 million in February.  Average total CRE loan and lease balances rose to $23.8 billion, up from

$23.3 billion in February.

Other Intermediation Activities:  Citi recorded net sales of $2.8 billion in mortgage‐ and asset‐backed

securities (MBS/ABS) in March, reflecting higher volumes.  MBS and ABS activity reflected an increase in

customer demand for agency and corporate bonds, respectively.

Citi’s total debt underwriting was $14.7 billion in February, an increase of 75 percent from the prior

month, reflecting higher volumes and average principal per deal.  High yield underwriting activity

included 79 deals totaling $43.1 billion, compared with 27 transactions with a cumulative value of $11.2

billion in February.  Citi lead managed 24 deals with an aggregate value of $4.4 billion.  In March, Citi

also participated in 214 investment grade transactions with an aggregate value of $94.1 billion,

compared with 100 deals totaling $43.5 billion in February.  Citi lead managed 44 of these transactions

with a total value of $9.3 billion.  Citi participated in 93 equity and linked deals with an aggregate value

of $22.7 billion in March, compared with 49 deals totaling $9.2 billion in February.  Citi lead managed 5

of these deals with a total value of $430 million.  Total equity underwriting was driven by an increase in

deal volume and average principal per deal.
Name of institution: COMERICA INCORPORATED Submission date: 04/27/2010 Person to be contacted 

PART I. QUANTITATIVE OVERVIEWSCHEDULE A: CONSUMER LENDING (Millions $) JAN FEB MAR Key 1. First Mortgagea. Average Loan Balance (Daily Average Total Outstanding) $1,643 $1,634 $1,621 Consists of 1st lien 1‐4 family residential mortgage and construction loans originated by

Comerica Bank.

b. Total Originations $29 $24 $40 Consists of loans funded during the period, including those originated for sale.

(1) Refinancings $24 $13 $24(2) New Home Purchases $5 $11 $16

2. Home Equity

a. Average Total Loan Balance $1,797 $1,787 $1,773 Consists of both fixed and revolving home equity (2nd lien) loans.

b. Originations (New Lines+Line Increases) $6 $7 $8 Excludes commitments/originations where home equity collateral is provided for multiple

purposes (personal and business), which are included in Commercial Lending commitments

(Schedule B).

c Total Used and Unused Commitments $3 196 $3 082 $3 068

TREASURY MONTHLY INTERMEDIATION SNAPSHOT

First mortgage originations 

'10/$10M February '10/$12

March originations increase

2010

1

c. Total Used and Unused Commitments $3,196 $3,082 $3,0683. US Card ‐ Manageda. Average Total Loan Balance ‐ Managed $56 $58 $60 Consists primarily of commercial bankcard loans.

b. New Account Originations (Initial Line Amt) $19 $16 $24 Includes new card loans funded during the period and new referrals to our consumer card

partner.

c. Total Used and Unused Commitments $386 $387 $393

4. Other Consumer

a. Average Total Loan Balance $644 $638 $630 Consists of consumer installment loans (both secured and unsecured) and student loans.

b. Originations $33 $10 $17

March other consumer orig

New account originations i

'10/$14M January '10).

1
SCHEDULE B: COMMERCIAL LENDING (Millions $) JAN FEB MAR Key 

1. C & Ia. Average Total Loan and Lease Balance $23,631 $23,361 $23,278 Consists of loans for commercial and industrial purposes to both domestic and international

borrowers, lease financing and other non‐consumer, non‐real estate loans.

b. Renewal of Existing Accounts $1,014 $1,113 $1,832 Includes renewals of and increases to lines with existing customers.

c. New Commitments $175 $271 $573 Consists of binding commitments to new customers and new lines to existing customers, net of

participations sold. Includes commitments/originations where home equity collateral isprovided for multiple purposes (personal and business).

2. Commercial Real Estate

a. Average Total Loan and Lease Balance $13,850 $13,786 $13,686 Consists of loans made to businesses where 50% or more of the collateral is real estate

(primarily owner‐occupied) and loans made to businesses or developers for building

construction.

b. Renewal of Existing Accounts $150 $116 $350 Includes renewals of and increases to lines with existing customers.

c. New Commitments $98 $42 $31 Consists of binding commitments to new customers and new lines to existing customers, net of

participations sold.

4. SMALL BUSINESS LOANS3

a. Average Total Loan Balance $3,697 $3,656 $3,623 Includes Small Business Administration loans and loans to other entities generally with annual

March renewals increased $719

National/Other and Texas mark

respectively). By line of busines

in Specialty Businesses, $26M in 

$8M in National Dealer Services 

March new commercial (C & I) c

the Midwest, Texas, National/O

Western and Florida markets, re

Corporate Banking, Private Ban

Middle Market and National De

March commercial real esta

$58M and $11M in the Wes

decrease of $25M in the Flo

March new CRE commitme

market, partially offset by i

SCHEDULE C: MEMORANDA ‐ SMALL BUSINESS LENDING (Millions $)

March originations decreas

2

a. Average Total Loan Balance $3,697 $3,656 $3,623 Includes Small Business Administration loans and loans to other entities generally with annual

sales of less than $10 million at initial relationship.

b. Originations $133 $143 $141 Consists of renewals and new commitments to both existing and new customers.

SCHEDULE D: OTHER INTERMEDIATION ACTIVITIES (Millions $)

1. MBS/ABS Net Purchased Volume

a. Mortgage Backed Securities $100 $200 $0 Represents net purchases (gross purchases, net of gross sales) of mortgage‐backed securities

(AAA‐rated agency securities) for investment portfolio available‐for‐sale on a trade date basis.

Excludes principal paydowns.

b. Asset Backed Securities  ‐$4 ‐$29 ‐$11 Represents net purchases (gross purchases, net of gross sales) of asset‐backed auction‐rate

securities. Purchases were made as an accommodation to customers from October through

December 2008.

2. Secured Lending (Repo, PB, Margin Lending)

a. Average Total Matched Book (Repo/Reverse Repo)1 N/A N/A N/A

b. Average Total Debit Balances2 N/A N/A N/A3. Underwriting

a. Total Equity Underwriting $0 $0 $0 Amount of equity securities underwritten where the Corporation was manager or co‐manager

of the issue. All done on "best efforts" basis.

b. Total Debt Underwriting $3,454 $2,464 $7,938 Amount of debt securities underwritten where the Corporation had either a manager or co‐

manager role All done on "best efforts" basis

March originations decreas

markets, respectively, offse

manager role. All done on "best efforts" basis.

Notes:1. Not applicable if matched book activity does not exceed $50 billion.

2. Applicable only for institutions offering prime brokerage or other margin lending services to clients.

3. Memoranda: these loans are already accounted for in either consumer lending, commercial lending, or a combination of both, and include loans guaranteed by the Small Business Administration and/or any other loans that are internally classified as small business loans.

2
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:  COMERICA INCORPORATED

Reporting month(s):  March 2010   

Submission date:  April 27, 2010

Person to be contacted regarding this report:   Darlene Persons

1

PART II.  QUALITATIVE OVERVIEW

Please provide a brief overview of the intermediation activity during the month.  This discussion should

include a general commentary on the lending environment, loan demand, any changes in lending

standards and terms, and any other intermediation activity.

Comerica Incorporated is a financial services company headquartered in Dallas, Texas.  Comerica

Incorporated is strategically aligned into three major business segments: the Business Bank, the Retail

Bank and Wealth & Institutional Management, and operates in four primary markets: Texas, the

Midwest (primarily Michigan), Western (primarily California and Arizona) and Florida.   

The principal focus of Comerica Incorporated is to meet the needs of small and medium‐sized

businesses, multinational corporations and governmental entities through various products and services

including loans and lines of credit, letters of credit, deposits,  international trade finance and other

services.  The Business Bank, which includes all business customers except for small business,

traditionally accounts for at least two‐thirds of net interest income. In addition to serving the needs of

businesses, Comerica Incorporated also offers a variety of consumer products, including deposit

accounts, installment loans, credit cards, home equity lines of credit and residential mortgage loans.

Fiduciary services, private banking, retirement services and other wealth management services are also

provided.

Due to deteriorating economic conditions in our markets in early 2008, especially in California and

Michigan, management began a process intended to reduce business loans and commitments to

preserve capital and generate appropriate loan pricing for current risks. With the receipt of TARP

proceeds, management's focus moved toward establishing new and expanding existing lending

relationships, with appropriate pricing and credit standards. While economic recovery appears to be

underway, loan demand remains subdued as loan growth typically lags other economic indicators.  

Comerica Incorporated has historically focused on appropriate and consistent underwriting standards

and, while continuing to tighten controls, has not significantly tightened its underwriting standards

during the Snapshot reporting periods of October 2008 through March 2010.

Consumer Lending  

Consumer lending activity increased across all lending categories in March compared to February 2010.   

In the First Mortgage lending category, new home purchases and refinancings both increased.  In both

the Home Equity and Other Consumer lending categories, new originations increased in March

compared to February 2010.  Application volumes in all three lending categories also increased during

this period.

In addition to direct consumer residential mortgage activity, residential mortgage lending was also

facilitated through lending to commercial customers in our Mortgage Banker and Financial Services
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:  COMERICA INCORPORATED

Reporting month(s):  March 2010   

Submission date:  April 27, 2010

Person to be contacted regarding this report:   Darlene Persons

2

Divisions.  Renewals and new commitments of $133 million were booked in the Mortgage Banker and

Financial Services Divisions in March 2010.

Commercial Lending

C&I lending renewals increased in March from February 2010.  The increase was spread across most

lending divisions, with the largest increases in the Middle Market, Global Corporate Banking and

Specialty Business divisions.  The increases were partially offset by decreases in the National Dealer

Services and Small Business divisions.  By market, the increase was largely in the Midwest market.  C&I

new commitments increased in March from February 2010, with increases in most markets offset by

decreases in the Western and Florida markets.  By lending division, the increase was concentrated in the

Global Corporate Banking, Private Banking and Specialty Business divisions, partially offset by a decrease

in the Middle Market and National Dealer Services divisions.  

Commercial real estate renewals increased in March from February 2010.  The increase was

concentrated in the Western, National/Other and Texas markets, partially offset by a decrease in the

Florida market.  All lending divisions other than the Private Banking increased.  Commercial real estate

new commitments decreased in March from February 2010.  The decrease was largely concentrated in

the National/Other market and in the Mortgage Banker Finance lending division.

Small Business Lending

The Small Business division focuses on meeting the needs of entities with annual sales of generally less

than $10 million at initial relationship, which is consistent with the definition of a company that is not

national in scope.  The Small Business division includes SBA lending.  Small Business C&I renewals

decreased in March from February 2010.  By market, the C&I renewal decrease was in the Texas and

Midwest markets, partially offset by an increase in the Western market. C&I new commitments and CRE

renewals increased with the increases concentrated in the Western market.  CRE new commitments

were flat in March compared to February 2010.

  

Other Intermediation Activities

  

Debt underwriting in which our broker/dealer subsidiary participated as a manager or a co‐manager

during March 2010 totaled $7.9 billion, providing access to liquidity for municipalities and corporate

customers.
Name of institution: Fifth Third Bancorp Submission date: April 30, 2010 Person to be c

PART I. QUANTITATIVE OVERVIEW

SCHEDULE A: CONSUMER LENDING (Millions $) JAN FEB MAR Key 1. First Mortgagea. Average Loan Balance (Daily Average Total Outstanding) $10,665 $10,230 $10,175 Average balance consists of 1‐4 family residential mortgage loans consistent with the classification

of the FR Y9C report. This includes loans held for sale and held for investment.

b. Total Originations $1,247 $990 $1,527(1) Refinancings $979 $737 $1,084(2) New Home Purchases $268 $254 $443

2. Home Equity

a. Average Total Loan Balance $11,962 $11,763 $11,652 Average balance consists of HELOC and HELOAN accounts consistent with the classification of the

FR Y9C report.

b. Originations (New Lines+Line Increases) $99 $72 $104

Total origination

billion of refinan

We also extende

2010

TREASURY MONTHLY INTERMEDIATION SNAPSHOT

1

c. Total Used and Unused Commitments $19,710 $19,646 $19,576

3. US Card ‐ Managed

a. Average Total Loan Balance ‐ Managed $2,259 $2,213 $2,155 Average balance consists of US cards for consumer obligors only, consistent with the classification

of the FR Y9C report. Business cards are included in C&I balances.

b. New Account Originations (Initial Line Amt) $88 $54 $74

c. Total Used and Unused Commitments $10,893 $10,794 $11,910

4. Other Consumer

a. Average Total Loan Balance $10,560 $10,636 $10,655 Average balance consists of auto and other consumer loans and leases consistent with the

classification of the FR Y9C report.

b. Originations $303 $344 $458

Other consumer 

increase of appr

March new cred

1
SCHEDULE B: COMMERCIAL LENDING (Millions $) JAN FEB MAR Key 

1. C & Ia. Average Total Loan and Lease Balance $27,915 $27,765 $27,807 Average balance consists of non‐real estate commercial loans and leases consistent with the

classification of the FR Y9C report. This includes business cards.

b. Renewal of Existing Accounts $1,109 $1,610 $2,550 Includes renewed funded loans and renewed commitments.

c. New Commitments $664 $732 $3,668 Includes new commitments both funded and unfunded

2. Commercial Real Estate

a. Average Total Loan and Lease Balance $17,400 $17,285 $17,169 Average balance consists of real estate secured commercial loans consistent with the classification

of the FR Y9C report.

b. Renewal of Existing Accounts $228 $392 $964 Includes renewed funded loans and renewed commitments.

c. New Commitments $106 $102 $288 Includes new commitments both funded and unfunded

4. Small Business Loans3

a. Average Total Loan Balance $5,200 $5,186 $5,141 Small business loans are those classified as small business under standards established by Fifth

Third Bank. These loans are already presented within the C&I and CRE categories. Thus, this

disclosure is a subset of schedule B items 1 and 2.

New C&I commi

February 2010 d

March 2010 of $

New CRE comm

2010. Renewal 

$392 million.Small Business cFebruary 2010.

SCHEDULE C: MEMORANDA ‐ SMALL BUSINESS LENDING (Millions $)

2

b. Originations $213 $246 $372SCHEDULE D: OTHER INTERMEDIATION ACTIVITIES (Millions $)

1. MBS/ABS Net Purchased Volume

a. Mortgage Backed Securities $482 $472 $0 Consists of MBS purchases less sales for the month.

b. Asset Backed Securities  ‐$805 $0 $0 Consists of ABS purchases less sales for the month.

2. Secured Lending (Repo, PB, Margin Lending)

a. Average Total Matched Book (Repo/Reverse Repo)1 NA NA NA

b. Average Total Debit Balances2 NA NA NA3. Underwriting

a. Total Equity Underwriting NA NA NA

b. Total Debt Underwriting $880 $237 $356

There were no p

Notes:1. Not applicable if matched book activity does not exceed $50 billion.

3. Memoranda: these loans are already accounted for in either consumer lending, commercial lending, or a combination of both, and include loans guaranteed by the Small Business Administration and/or any other loans that are internally classified as small business loans.

2. Applicable only for institutions offering prime brokerage or other margin lending services to clients.

2
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:   Fifth Third Bancorp

Reporting month(s):  March 2010   

Submission date:  April 30, 2010

Person to be contacted regarding this report: Blane Scarberry

1

PART II.  QUALITATIVE OVERVIEW

Please provide a brief overview of the intermediation activity during the month.  This discussion should

include a general commentary on the lending environment, loan demand, any changes in lending

standards and terms, and any other intermediation activity.

Commercial sections

CRE:  Average CRE balances decreased by approximately 0.7% in March 2010 compared to February

2010.  New CRE commitments originated in March 2010 were $288 million, compared to $102 million in

February 2010.  Renewal levels for existing accounts increased in March 2010 to $964 million versus

February 2010 at $392 million.  Payments and dispositions of troubled CRE outpaced the volume of

renewals and new originations in March causing the overall balances to continue to decline.  As

commercial vacancy rates continue to increase, Fifth Third continues to monitor the CRE portfolios and

continues to suspend lending on new non‐owner occupied properties and on new homebuilder and

developer projects in order to manage existing portfolio positions.  We feel this is prudent given that we

do not believe added exposure in those sectors is warranted given our expectation for continued

elevated loss trends in the performance of those portfolios.

C&I:  Average C&I balances increased by approximately 0.2% in March 2010 compared to February 2010.  

New C&I commitments originated in March 2010 increased to $3.668 billion compared to $732 million

in February 2010 due to season trends and a modest increase in demand.  Renewal levels for existing

accounts in March 2010 of $2.550 billion were up from February 2010 at $1.610 billion.  Lending in the

Commercial segment continues to qualified borrowers exhibiting average risk or better.  Continued

emphasis is placed on prudent underwriting and demonstrated ability to repay as well as industry

segment.  Overall loan demand has begun to slowly increase, however, we are still seeing caution in the

view of the strength of the recovery in the economy from our C&I borrowers, which varies by

geography.   Business investment growth has begun to increase however not all of that investment

requires debt financing.  In general, customers continue to remain deleveraged and liquid through

reduced inventories versus expanding operations and purchasing equipment.   

The primary market for syndicated credit and large corporate deals has seen a modest increase in March

2010.  Given a cautionary outlook for the economy, many companies continue to defer plans for

significant capital expenditures and inventory build, which in turn has reduced the need for large, new

financing.  Merger and acquisition activity continued to remain relatively slow in March.  Terms and

covenants continue to be somewhat tighter than usual, which has also served to constrain demand.  

Credit spreads have narrowed somewhat in recent months, including the non‐investment grade rating

categories, which could favorably impact volume if spreads continue to fall.

Small Business:  Average Small Business balances decreased by approximately 0.9% in March 2010

compared to February 2010.  Small Business commitments originated in March 2010 were $372 million,

which was up from $246 million in February 2010.  Demand for Small Business credit has been in a
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:   Fifth Third Bancorp

Reporting month(s):  March 2010   

Submission date:  April 30, 2010

Person to be contacted regarding this report: Blane Scarberry

2

relatively stable range with a slight bias to run off over new production.  Business Banking loan

originations continue to be made using prudent underwriting standards.     

Overall, average total commercial loan and lease balances were down 0.2% in March 2010 compared to

February 2010.  We continue to actively work out problem loans and receive principal payments from

borrowers, which more than offset new loan volume in the month of March 2010.  

Consumer section

Consumer:  March 2010 overall loan volume for non‐mortgage consumer credit (home equity, credit

card and auto) was up compared to February 2010 due to increases in all non‐mortgage consumer credit

demand.

March 2010 total mortgage originations for the month increased $537 million which totaled

approximately $1.5 billion driven by $1.1 billion of refinancing activity and $443 million of new home

purchases.  We also extended $104 million of new home equity lines of credit during the month.

March new credit card extensions were $74 million, an increase over our $54 million of extensions in

February.  Other consumer loan originations, which include new car loans, were $458 million in March.  

This was an increase of approximately $114 million from February.   

During the month of March, Fifth Third continued to monitor the need for prudent adjustments to

consumer lending standards, consistent with peer institutions as reported by the Federal Reserve and as

observed in the market.      

In March of 2010, Fifth Third’s consumer loan and lease outstanding balances remained flat relative to

February 2010.   

Treasury section

There were no purchases of ABS or MBS in the month of March.
Submission date: April 30, 2010 Person to be contacted about this report: Shanno

PART I. QUANTITATIVE OVERVIEW

SCHEDULE A: CONSUMER LENDING (Millions $) JAN FEB MAR Key Comm1. First Mortgagea. Average Loan Balance (Daily Average Total Outstanding) $196 $193 $190

b. Total Originations $0 $0 $0(1) Refinancings $0 $0 $0

(2) New Home Purchases $0 $0 $0

2. Home Equity

a. Average Total Loan Balance $9 $8 $8b. Originations (New Lines+Line Increases) $0 $0 $0c. Total Used and Unused Commitments $16 $16 $16

3. US Card ‐ Managed

a. Average Total Loan Balance ‐ Managed N/A N/A N/A

b. New Account Originations (Initial Line Amt) N/A N/A N/A

c. Total Used and Unused Commitments N/A N/A N/A

Name of institution: The Hartford Financial Services Group, Inc.

The Hartford's activities in Consumer Lending ‐ First Mo

which it acquired on June 24, 2009.

The Hartford's activities in Consumer Lending ‐ Home Eq

which it acquired on June 24, 2009.

Neither The Hartford nor Federal Trust Bank, acquired o

US Card‐Managed activity.

2010

TREASURY MONTHLY INTERMEDIATION SNAPSHOT

1

4. Other Consumera. Average Total Loan Balance $0 $0 $0b. Originations $0 $0 $0

The Hartford's activities in Consumer Lending ‐ Other Co

which it acquired on June 24, 2009.

1
SCHEDULE B: COMMERCIAL LENDING (Millions $) JAN FEB MAR Key Comm

1. C & Ia. Average Total Loan and Lease Balance $9 $9 $9 Reflects a daily average.

b. Renewal of Existing Accounts $0 $0 $3

c. New Commitments $0 $0 $02. Commercial Real Estate

a. Average Total Loan and Lease Balance $5,712 $5,427 $5,054 Average loan balance for loans issued by Federal Trust Bank is calculated as the mean of daily

closing balances. The average loan balance for all other commercial real estate mortgage loan

investments made by The Hartford is calculated as the mean of the beginning‐ and end‐of‐

period carrying amounts.

b. Renewal of Existing Accounts $0 $1 $9 The Hartford's activities in Commercial Real Estate ‐ Renewals are limited to those of Federal

Trust Bank, which it acquired on June 24, 2009.

c. New Commitments $0 $0 $04. Small Business Loans3

a. Average Total Loan Balance $0 $0 $0b. Originations $0 $0 $0SCHEDULE D: OTHER INTERMEDIATION ACTIVITIES (Millions $)

1. MBS/ABS Net Purchased Volume

a. Mortgage Backed Securities $13,778 $13,670 $13,633 Represents carrying value as of March 31, 2010, including CMBS of $8,716 million, CREs of $528

million and RMBS of $4,389 million.

b. Asset Backed Securities $5,067 $5,161 $5,147 Represents carrying value as of March 31, 2010, including ABS of $2,885 million, CLOs of $2,239

million and Other CDOs of $23 million.

The Hartford's activities in Commercial Lending ‐ C & I a

acquired on June 24, 2009. The Hartford's other C & I in

corporations by investing in their debt securities. As of 

corporate debt securities. (See further discussion on Th

Qualitative Overview)Given the economic environment, additional investmen

real estate are expected to be limited in the near term.

Net sales were approximately $20 million in ABS, CMBS

31, 2010, related primarily to certain ABS investments.

The Hartford's activities in Small Business Lending are li

acquired on June 24, 2009.

SCHEDULE C: MEMORANDA ‐ SMALL BUSINESS LENDING (Millions $)

2

2. Secured Lending (Repo, PB, Margin Lending)a. Average Total Matched Book (Repo/Reverse Repo)1 N/A N/A N/A

b. Average Total Debit Balances2 N/A N/A N/A3. Underwriting

a. Total Equity Underwriting N/A N/A N/Ab. Total Debt Underwriting N/A N/A N/A

Notes:3. Memoranda: these loans are already accounted for in either consumer lending, commercial lending, or a combination of both, and include loans guaranteed by the Small Business Administration and/or any other loans that are internally classified as small business loans.

2. Applicable only for institutions offering prime brokerage or other margin lending services to clients.

1. Not applicable if matched book activity does not exceed $50 billion.

2
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:  The Hartford Financial Services Group, Inc.

Reporting month(s):  March 2010   

Submission date:  April 30, 2010

Person to be contacted regarding this report: Shannon Lapierre

1

PART II.  QUALITATIVE OVERVIEW

Please provide a brief overview of the intermediation activity during the month.  This discussion should

include a general commentary on the lending environment, loan demand, any changes in lending

standards and terms, and any other intermediation activity.

The Hartford Financial Services Group, Inc. (together with its subsidiaries, “The Hartford”) is an

insurance and financial services company.  The Hartford, headquartered in Connecticut, provides

investment products, individual life, group life and group disability insurance products, and property and

casualty insurance products in the United States.

On March 31, 2010, The Hartford repaid the entire $3.4 billion investment made in June 2009 by the

Department of the Treasury (“Treasury”) under the Troubled Asset Relief Program (“TARP”) by

repurchasing from Treasury all 3.4 million shares of the Company’s Series E Fixed Rate Cumulative

Perpetual Preferred Stock issued to Treasury.  The repayment was funded with cash on hand plus

approximately $2.6 billion of the proceeds from a March 2010 capital raise that included issuances of

common stock, mandatory convertible preferred stock and debt.

The Hartford’s business model is different from those of traditional commercial banks.  As a result its

intermediation activities are also different.  In general, The Hartford provides capital to other financial

institutions, corporations, municipalities and governments and government agencies by investing in

their debt securities.  Indirectly, The Hartford supports consumer lending through its investments in

residential mortgage‐backed securities and securitized consumer asset‐backed securities.  The Hartford

also supports commercial lending through its investments in commercial mortgage loans on real estate

and commercial mortgage‐backed securities.  See the discussion that follows for more information on

The Hartford’s mortgage‐backed securities (MBS), asset‐backed securities (ABS) and commercial lending

activities.  In addition, The Hartford invests in limited partnerships and equity of publicly traded entities.   

CMBS/MBS/ABS Activity

One of The Hartford’s largest intermediation activities includes our investing activities in mortgage and

asset‐backed securities.  Mortgage‐backed securities primarily include Commercial Mortgage‐backed

Securities (CMBS), government sponsored entity (GSE) Mortgage‐backed Securities (MBS) and

Residential Mortgage‐backed Securities (RMBS) supported by mortgage loans that do not conform to

the GSE underwriting standards due to large loan balances and/or underwriting standards.  Asset‐

backed securities (ABS) consist primarily of collateralized loan obligations (CLOs) and consumer ABS.  

Our consumer ABS holdings consist of securities backed by credit cards, student loans and auto loans.

ABS, CMBS and RMBS remain depressed in relation to the securities’ original cost basis due to continued

weakness in the real estate market caused by deterioration in market fundamentals, rising

delinquencies and declines in property values.  Net sales were approximately $20 million in ABS, CMBS,

and RMBS securities for the month ending March 31, 2010, related primarily to certain ABS investments.
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:  The Hartford Financial Services Group, Inc.

Reporting month(s):  March 2010   

Submission date:  April 30, 2010

Person to be contacted regarding this report: Shannon Lapierre

2

Commercial Lending

Commercial lending, which consists of commercial mortgage loans and, to a lesser extent, agricultural

mortgages, represents 5% of our total investments, excluding equity securities held in trading accounts,

as of March 31, 2010.  These loans are collateralized by a variety of commercial and agricultural

properties and are diversified both geographically throughout the United States and by property type.  

Our loans take the form of whole loans, where we are the sole lender, as well as loan participations.  

Given the economic environment, additional investments by The Hartford in mortgage loans for

commercial real estate are expected to be limited in the near term.

Direct Consumer Lending

The Hartford’s consumer lending is contained entirely within Federal Trust Corporation and its bank

subsidiary.  As of March 31, 2010, Federal Trust Bank held $190 million (average loan balance) of

residential mortgage loans.

Other Intermediation Activities

Outside of MBS, ABS and mortgage loans on real estate, our invested asset portfolio consists largely of

investment grade corporate securities, municipal securities, U.S. treasuries and agencies, and short term

investments.

For the month of March 2010, The Hartford was a net purchaser of marketable securities of roughly $1.9

billion, primarily corporate credits of approximately $900 million and U.S. treasuries of approximately $1

billion.  In the investment grade corporate credit space, purchases were predominately in companies

and sectors well positioned in the current economic environment.
Name of institution: KeyCorp Submission date: 4/30/10 Person to be c

PART I. QUANTITATIVE OVERVIEW

SCHEDULE A: CONSUMER LENDING (Millions $) JAN FEB MAR Key 1. First Mortgagea. Average Loan Balance (Daily Average Total Outstanding) $3,159 $3,083 $3,076 First Mortgage includes loans secured by 1‐4 family residential properties including home equity

loans secured by first liens.

b. Total Originations $117 $88 $152 Total Originations include both portfolio and held‐for‐sale loan originations.

(1) Refinancings $71 $47 $90(2) New Home Purchases $46 $40 $62

2. Home Equity

a. Average Total Loan Balance $8,370 $8,353 $8,330 Home Equity includes home equity lines of credit only (Home equity loans secured by first liens are

included with First Mortgages above).

b. Originations (New Lines+Line Increases) $48 $58 $83

TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Application volu

While new appli

application volu

year‐ago period

2010

1

c. Total Used and Unused Commitments $16,318 $16,283 $16,263

3. US Card ‐ Managed

a. Average Total Loan Balance ‐ Managed N/A N/A N/A

b. New Account Originations (Initial Line Amt) N/A N/A N/A

c. Total Used and Unused Commitments N/A N/A N/A

4. Other Consumer

a. Average Total Loan Balance $10,249 $10,190 $9,784 Other Consumer includes all other non‐revolving consumer loans.

b. Originations $134 $29 $20

Originations of f

fundings of prev

May.

1
SCHEDULE B: COMMERCIAL LENDING (Millions $) JAN FEB MAR Key 

1. C & Ia. Average Total Loan and Lease Balance $26,567 $26,023 $25,510 C & I includes lease financing receivables, commercial and industrial loans, agricultural loans, loans

to depository institutions and other nonconsumer loans.

b. Renewal of Existing Accounts $581 $551 $1,028 Renewals of existing accounts include outstanding balances and unused commitments for which

the terms were extended or changed. A renewed commitment may or may not have an active

draw.

c. New Commitments $525 $337 $440 New commitments include outstanding balances and unused commitments. Commitment

amounts exclude standby letters of credit.

2. Commercial Real Estate

a. Average Total Loan and Lease Balance $15,427 $15,247 $15,028 Commercial Real Estate includes construction and land loans, loans secured by multi‐family

residential properties and by other nonresidential properties.

b. Renewal of Existing Accounts $233 $273 $560 Renewals of existing accounts include outstanding balances and unused commitments for which

the terms were extended or changed. A renewed commitment may or may not have an active

draw.

c. New Commitments $34 $25 $21 New commitments include outstanding balances and unused commitments. Commitment

amounts exclude standby letters of credit.

4. Small Business Loans3

a. Average Total Loan Balance $3,212 $3,186 $3,147 Small Business includes loans guaranteed by the Small Business Administration ("SBA") and other

loans internally classified as small business loans.

CRE new loan de

be extending an

CRE market. Ma

refinancing activ

agencies financi

Small Business l

level experience

since April 2008

SCHEDULE C: MEMORANDA ‐ SMALL BUSINESS LENDING (Millions $)

In March, new lo

highest level du

totaled $218 mi

2

b. Originations $24 $39 $59SCHEDULE D: OTHER INTERMEDIATION ACTIVITIES (Millions $)

1. MBS/ABS Net Purchased Volume

a. Mortgage Backed Securities ‐$282 ‐$244 $342 March mortgage backed securities ("MBS") net purchased volume includes $601 million in

purchases and $259 million in sales, paydowns, calls and maturities.

b. Asset Backed Securities $0 $0 $02. Secured Lending (Repo, PB, Margin Lending)

a. Average Total Matched Book (Repo/Reverse Repo)1 N/A N/A N/A

b. Average Total Debit Balances2 N/A N/A N/A3. Underwriting

a. Total Equity Underwriting $79 $104 $41 Represents KeyCorp's equity underwriting commitments.

b. Total Debt Underwriting $193 $103 $412 Represents KeyCorp's taxable and municipal debt underwriting commitments.

KeyCorp was the 

compared to the 

million in underw

Municipal debt u

The purchase of 

March supports 

p 

with the renewa

Notes:3. Memoranda: these loans are already accounted for in either consumer lending, commercial lending, or a combination of both, and include loans guaranteed by the Small Business Administration and/or any other loans that are internally classified as small business loans.

2. Applicable only for institutions offering prime brokerage or other margin lending services to clients.

1. Not applicable if matched book activity does not exceed $50 billion.

2
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:  KeyCorp

Reporting month(s):  March 2010

Submission date:  4/30/10

Person to be contacted regarding this report:  Robert L. Morris

1

PART II.  QUALITATIVE OVERVIEW

Please provide a brief overview of the intermediation activity during the month.  This discussion should

include a general commentary on the lending environment, loan demand, any changes in lending

standards and terms, and any other intermediation activity.

Cleveland‐based KeyCorp is one of the nation's largest bank‐based financial services companies, with

consolidated total assets of approximately $95 billion at March 31, 2010.  Through KeyBank and certain

other subsidiaries, KeyCorp provides a wide range of retail and commercial banking, commercial leasing,

investment management, consumer finance, and investment banking products and services to

individual, corporate and institutional clients through two major business groups, Community Banking

and National Banking.  The Community Banking group serves consumers and small to mid‐sized

businesses through the company's 14‐state branch network, which is organized into three internally

defined geographic regions:  Rocky Mountains and Northwest, Great Lakes, and Northeast.  The National

Banking group includes those corporate and consumer business units that operate nationally, within and

beyond KeyCorp's 14‐state branch network, as well as internationally.     

General

Overall consumer and commercial loan demand increased in March from the February levels, with many

segments reporting their highest application volumes in several months.  The March increase in loan

demand in the Commercial Lending (“C & I”) segment and Small Business portfolio continues the

improving trend, which started in the first quarter of 2010.   Commercial Real Estate (“CRE”) loan

demand remains weak overall, with some increase experienced in the Small Business portfolio.

Consumer loan application volume increased in March from February levels, with increases in both

mortgage and branch‐based applications.  

Consumer

As is typical with the spring borrowing season, mortgage and branch‐based application volumes

increased.  Loan application volumes in branch‐based products increased over 10%, while mortgage

application volumes increased over 20%.  Loan approval rates also appear to be improving, which is

consistent with a stabilizing economic environment.

There were no material changes in KeyCorp’s underwriting standards in March.

C & I

The C & I new loan approval volume continues to improve modestly.  The Middle Market, Institutional

and Leasing portfolios experienced increased approval volumes in March.  The approval volume in the

Business Banking segment also improved, notably within the SBA portfolio.   
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:  KeyCorp

Reporting month(s):  March 2010

Submission date:  4/30/10

Person to be contacted regarding this report:  Robert L. Morris

2

Commercial Real Estate

There was no change in loan demand trends in the CRE segment during March.  The CRE market outlook

continues to be weak. All new originations were in the Business Banking, Middle Market and Wealth

Management segments.  

During March, KeyCorp continued to extend and modify existing credits given the lack of liquidity and

refinancing options available in the CRE market.  Renewal volume doubled from the February level to

$560 million and is comparable to levels experienced in April and May 2009.  Three‐fourths of the

renewal volume, totaling $420 million, was related to performing development projects for which

refinancing options remain constrained.  For CRE development projects, KeyCorp has created a fixed‐

rate 3‐5 year loan program to modify and extend qualifying loans for existing customers.  In the

Institutional CRE portfolio, most real estate investment trusts (“REITs”) have issued additional capital

and reduced debt levels over the last two quarters, allowing their credit lines to be modified and

extended.   

Small Business  

March new loan approvals were at their highest level since October 2008.  Increases occurred within

both the SBA loan portfolio and the traditional lending portfolio, which includes owner‐occupied real

estate.  SBA lending represents nearly one‐third of all Small Business loans approved year‐to‐date in

2010, as compared to a historic concentration of 10‐15% of total new loans approved.  Loan renewals in

March increased nearly 50% from February as the renewal season begins.
Name of institution: Marshall & Ilsley Corporation Submission date: 04/30/10 Person to be c

PART I. QUANTITATIVE OVERVIEW

SCHEDULE A: CONSUMER LENDING (Millions $) JAN FEB MAR Key 1. First Mortgagea. Average Loan Balance (Daily Average Total Outstanding) $6,901 $6,785 $6,736 Includes all closed end residential RE; First Mortgages and Home Equity Loans (Approximately 80%

of Home Equity Loans are held in first position). This excludes construction and vacant land loans

which are included in the Commercial Real Estate section as average loan balances.

b. Total Originations $155 $117 $192 1‐4 Family Residential Mortgage Originations ‐ includes loans held by M&I Portfolio and loans

originated to be sold into the secondary market. This excludes construction and vacant land loans

which are included in the Commercial Real Estate section as new commitments.

(1) Refinancings $111 $79 $123(2) New Home Purchases $44 $39 $69

2. Home Equity

a. Average Total Loan Balance $2,722 $2,707 $2,685 Includes Home Equity Lines only.

b. Originations (New Lines+Line Increases) $54 $56 $63

Mortgage origin

rates decreasing 

continued to inc

to originations b

the portfolio.Home Equity ou

March, consiste

2010

TREASURY MONTHLY INTERMEDIATION SNAPSHOT

1

c. Total Used and Unused Commitments $4,898 $4,884 $4,857

3. US Card ‐ Managed

a. Average Total Loan Balance ‐ Managed $287 $279 $274 Includes Consumer Card only.

b. New Account Originations (Initial Line Amt) $5 $5 $6

c. Total Used and Unused Commitments $1,295 $1,302 $1,303

4. Other Consumer

a. Average Total Loan Balance $2,073 $2,047 $1,996 Includes consumer PRA & LOCs. Subcategories include Auto Leases, Dealer Finance, Personal,

Securities Loans, and Student Loans.

b. Originations $56 $49 $74 Includes Additional Notes and Refinances to existing customers and notes to new customers.

Average Loan Ba

primarily by Dea

Average Balance

increased in Ma

1
SCHEDULE B: COMMERCIAL LENDING (Millions $) JAN FEB MAR Key 

1. C & Ia. Average Total Loan and Lease Balance $12,804 $12,688 $12,569 Includes A/R and Inventory, Dealer Commercial, Agricultural, IRB's and Muni, and Commercial

Leases.

b. Renewal of Existing Accounts $153 $127 $68 Renewals include renewal of existing accounts where new money is requested, terms are

modified, or new master line is established.

c. New Commitments $24 $51 $51 Includes New Loans to New Customers and Unused Commitments to C&I (Also includes Unused

Commitments to: Finance Agricultural Production and Other).

2. Commercial Real Estate

a. Average Total Loan and Lease Balance $19,139 $19,018 $18,889 Includes Business Purpose 1‐4 and Construction, Development, & Vacant Land (Commercial and

Residential).

b. Renewal of Existing Accounts $35 $52 $54 Renewals include renewal of existing accounts where new money is requested, terms are

modified, or new master line is established.

c. New Commitments $19 $46 $54 Includes New Loans to New Customers and Unused Commitments for CRE (Also includes Unused

Commitments to: New Construction, Land Development and Other Land; Farmland; 1‐4 Family

Residential Properties; Multi‐Family (5 or more) Residential Properties).

4. Small Business Loans3

a. Average Total Loan Balance $3,397 $3,379 $3,342 Includes SBA‐guaranteed loans and Business Loans & Commitments < $1 million to customers with

Revenue < $1 million. Excludes Letters of Credit.

Average balance

reduce capital e

infrastructure, a

Continuing with 

led by Construct

Construction an

average balance

Average Balance

Loans. March o

to a decrease in 

SCHEDULE C: MEMORANDA ‐ SMALL BUSINESS LENDING (Millions $)

2

b. Originations $13 $18 $22SCHEDULE D: OTHER INTERMEDIATION ACTIVITIES (Millions $)

1. MBS/ABS Net Purchased Volume

a. Mortgage Backed Securities $507 $39 $194 Includes Mortgage Backed security purchase activities net of any security MBS sale activities,

within the consolidated investment holdings. At Qtr‐end this may also include Traded‐not‐settled

transactions.

b. Asset Backed Securities $0 $0 $02. Secured Lending (Repo, PB, Margin Lending)

a. Average Total Matched Book (Repo/Reverse Repo)1 N/A N/A N/A

b. Average Total Debit Balances2 N/A N/A N/A3. Underwriting

a. Total Equity Underwriting N/A N/A N/A

b. Total Debt Underwriting N/A N/A N/A

Notes:3. Memoranda: these loans are already accounted for in either consumer lending, commercial lending, or a combination of both, and include loans guaranteed by the Small Business Administration and/or any other loans that are internally classified as small business loans.

2. Applicable only for institutions offering prime brokerage or other margin lending services to clients.

1. Not applicable if matched book activity does not exceed $50 billion.

2
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:  Marshall & Ilsley Corporation

Reporting month(s):  March 2010   

Submission date:  04/30/2010

Person to be contacted regarding this report:  Gregory A. Smith

1

PART II.  QUALITATIVE OVERVIEW

Please provide a brief overview of the intermediation activity during the month.  This discussion should

include a general commentary on the lending environment, loan demand, any changes in lending

standards and terms, and any other intermediation activity.

Marshall & Ilsley Corporation (M&I) is a diversified financial services corporation headquartered in

Milwaukee, Wisconsin.  M&I Marshall & Ilsley Bank is the largest Wisconsin‐based bank, with 192 offices

throughout the state.  In addition, M&I has 53 locations throughout Arizona; 32 offices in Indianapolis

and nearby communities; 36 offices along Florida’s west coast and in central Florida; 15 offices in Kansas

City and nearby communities; 26 offices in metropolitan Minneapolis/St. Paul, and one in Duluth, Minn.;

and one office in Las Vegas, Nev.  M&I’s Southwest Bank subsidiary has 17 offices in the greater St. Louis

area.  

The communities and customers M&I serves continue to face impacts from current recessionary

conditions of the economy.  Nonetheless, M&I extended approximately $275 million of new credit to

new and existing customers in March for a total of over $7.1 billion since the infusion of CPP capital in

mid‐November 2008 (The “new credit” amount includes new and expanded extensions of credit, or

commitments to extend credit, as well as renewals of existing credit where a new promissory note was

executed).  Additionally, M&I has continued with a franchise‐wide foreclosure abatement program

designed to keep families in their homes, including a foreclosure moratorium on certain owner‐occupied

residential loans through June 30, 2010.  

In Commercial and Industrial loans, loan demand continues to be weak across all of our markets.  

Economic uncertainty has resulted in borrowers reducing capital expenditures, delaying investment in

infrastructure (plants and equipment) and experiencing lower inventories and receivables, all of which

influence customer borrowing needs.

In Commercial Real Estate, Construction and Development concentrations continue to decline in‐line

with our corporate goal of reducing credit exposure in this sector.  Economic uncertainty has resulted in

increased challenges for customers across a variety of sectors including retail, office and hospitality.  

Commercial Real Estate average balances are expected to continue contracting due to portfolio

amortization.

In Residential Real Estate, we are primarily utilizing secondary market options to effectively address the

demand for fixed rate mortgage originations and selectively using the balance sheet for adjustable rate

mortgages.  Mortgage originations increased from February to March, driven by an increase in

refinancing activity (due to rates decreasing slightly in February).  During the same period, purchase

mortgage application volume continued to increase, as is seasonally typical.  The Average Loan Balance

decline year‐over‐year is attributed to originations being sold in the secondary market, periodic sales of

non‐performing loans and amortization of the portfolio.   
Name of institution: Regions Financial Corporation Submission date: April 30, 2010 

PART I. QUANTITATIVE OVERVIEW

SCHEDULE A: CONSUMER LENDING (Millions $)

1. First Mortgage Jan Feb Mar Key 

a. Average Loan Balance (Daily Average Total Outstanding) $16,323 $16,183 $16,047 First and second residential 1‐4 family mortgages, including residential mortgages held 

b. Total Originations $416 $393 $573 Loan originations designated for the secondary market and those to be held in portfoli

Regions' balance sheet.

(1) Refinancings $260 $212 $289 Total originations designated as refinance status.

(2) New Home Purchases $157 $181 $284 Total originations designated as new purchase status.

2. Home Equity

a. Average Total Loan Balance $15,342 $15,241 $15,128 Average balances include Home Equity loans and HELOCs.b O i i ti (N Li Li I ) $61 $70 $102 N H E it l li d i

2010

TREASURY MONTHLY INTERMEDIATION SNAPSH

b. Originations (New Lines+Line Increases) $61 $70 $102 New Home Equity loans, lines and increases.

c. Total Used and Unused Commitments $25,489 $25,339 $25,211 Total portfolio of Home Equity loans and funded and unfunded HELOCs. Funded portio

included in average balance above.

3. US Card ‐ Managed

a. Average Total Loan Balance ‐ Managed N/A N/A N/A N/A ‐ Regions Financial Corp is an Agent Bank.

b. New Account Originations (Initial Line Amt) N/A N/A N/Ac. Total Used and Unused Commitments N/A N/A N/A

4. Other Consumer

a. Average Total Loan Balance $4,117 $4,064 $3,696 Includes consumer direct, indirect, other revolving (i.e., overdraft lines) and student loa

for sale.

b. Originations $297 $117 $120 Includes direct and student lending origination activity.

1
SCHEDULE B: COMMERCIAL LENDING (Millions $)

1. C & I Jan Feb Mar Key 

a. Average Total Loan and Lease Balance $34,252 $34,276 $33,995 Average outstanding funded balances (net of deferred fees and costs) for commercial r

loans and leases. Also includes owner‐occupied commercial real estate mortgage and

construction loans made to operating businesses.

b. Renewal of Existing Accounts $1,260 $1,156 $1,557 Renewal of existing funded and unfunded commitments for commercial and owner‐occ

real estate related loans based upon posting date of renewal. Also includes letters of c

c. New Commitments $639 $714 $691 New funded and unfunded commitments for commercial and owner‐occupied real estate related 

based upon posting date of the commitment. Also includes letters of credit and leases. Variable R

Demand Note (VRDN) fundings are excluded from new commitment activity.

2. Commercial Real Estatea. Average Total Loan and Lease Balance $21,916 $21,606 $21,184 Average outstanding funded balances (net of deferred fees and costs) for commercial i

owned real estate related loans. Also includes Commercial loans held for sale.

b. Renewal of Existing Accounts $932 $1,046 $1,295 Renewal of existing funded and unfunded commitments for commercial investor‐owne

estate related loans based upon posting date of renewal. Also includes letters of credi

c. New Commitments $17 $28 $97 New funded and unfunded commitments for commercial investor‐owned real estate related loans 

upon posting date of the commitment. Also includes letters of credit. Variable Rate Demand Note 

fundings are excluded from new commitment activity.

SCHEDULE C: MEMORANDA ‐ SMALL BUSINESS LENDING (Millions $)

4. Small Business Loans3

a. Average Total Loan Balance $13,712 $13,639 $13,424 Average outstanding funded balances (net of deferred fees and costs) for commercial and commercial real esta

loans made to small business clients, which we generally define as clients with revenues up to $10 million. The

are reflected as components of C&I, Commercial Real Estate and First Mortgage reported above.

b. Originations $470 $487 $606 New and renewed production of funded and unfunded commitments made to small bu

clients, which we generally define as clients with revenues up to $10 million. These ori

are reflected as components of C&I and Commercial Real Estate reported above.

SCHEDULE D: OTHER INTERMEDIATION ACTIVITIES (Millions $)

1. MBS/ABS Net Purchased Volume

a. Mortgage Backed Securities $1,038 $1,919 $0.4 Net purchase volume as captured in bond accounting system. Reflects settlement date

b. Asset Backed Securities $0 $0 $0

2. Secured Lending (Repo, PB, Margin Lending)

a. Average Total Matched Book (Repo/Reverse Repo)1 N/A N/A N/A

b. Average Total Debit Balances2 $767 $814 $825 Reflects average margin receivables as recorded on the general ledger.

3. Underwriting

Ttl E it U d iti $91 $21 $49 Ttl it d iti ti it R t Ri ' ti i ti t 

a. Total Equity Underwriting $91 $21 $49 Total equity underwriting activity. Represents Regions' participation percentage.

b. Total Debt Underwriting $740 $821 $1,371 Debt issuances delivered monthly. Represents Regions' participation percentage.

Notes:3. Memoranda: these loans are already accounted for in either consumer lending, commercial lending, or a combination of both, and include loans guaranteed by the Small Business Administration and/or any other loans that are internally classified as small 

2. Applicable only for institutions offering prime brokerage or other margin lending services to clients.

1. Not applicable if matched book activity does not exceed $50 billion.

2
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: Regions Financial Corporation

Reporting month(s):    March 2010      

Submission date:  April 30, 2010

Person to be contacted regarding this report:  David Turner, Chief Financial Officer

1

PART II.  QUALITATIVE OVERVIEW

Please provide a brief overview of the intermediation activity during the month.  This discussion should

include a general commentary on the lending environment, loan demand, any changes in lending

standards and terms, and any other intermediation activity.

I. Company Description

Regions Financial Corporation (“Regions” or the “Company”) is a financial holding company

headquartered in Birmingham, Alabama, which operates throughout the South, Midwest and Texas.

Regions provides traditional commercial, retail and mortgage banking services, as well as other financial

services in the fields of investment banking, asset management, trust, securities brokerage, insurance

and other specialty financing.  At March 31, 2010, Regions had total consolidated assets of

approximately $137 billion.   

Regions conducts its banking operations through Regions Bank, its brokerage and investment banking

business through Morgan Keegan & Company, Inc. (“Morgan Keegan”), and its insurance brokerage

business through Regions Insurance Group, Inc.

II. Overall Summary  

In March, new and renewed commitments increased by $0.9 billion to $4.4 billion for the month, and

average balances were down $1.3 billion from February to $90.1 billion.

The month over month increase in new and renewed commitments was driven by a $0.4 billion increase

in C&I renewals and a $0.2 billion increase in Mortgage originations.

III. Consumer Lending

A. Mortgage Lending

The mortgage division originated mortgage loans totaling $573 million in March 2010.  Overall

production increased 45.8% from the prior month.  New purchase originations increased from the prior

month 57.5%, and refinancing activity increased 35.9%.  Application activity in March increased 38% as

compared to prior month due to the increase in home purchase activity experienced during the month.  

Regions’ mortgage division rolled out the U.S. Treasury sponsored Home Affordable Refinance Program

(HARP) in late March 2009, which provides borrowers who have an existing loan owned or securitized by

Fannie Mae or Freddie Mac, the ability to refinance to more beneficial financing terms with no new or

additional mortgage insurance required, even if their current loan‐to‐value ratio is higher than it was on

the original loan.  The loan‐to‐value ratio can not exceed 125%.  March originations included

approximately $45 million related to 265 loans refinanced under the Home Affordable Refinance

Program.
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: Regions Financial Corporation

Reporting month(s):    March 2010      

Submission date:  April 30, 2010

Person to be contacted regarding this report:  David Turner, Chief Financial Officer

2

Regions’ has implemented the U. S. Treasury sponsored Home Affordable Modification Program (HMP)

for FNMA/FHLMC loans serviced by Regions. This program is designed to assist mortgage borrowers who

have an existing loan owned or securitized by Fannie Mae or Freddie Mac, and who are in imminent

danger of default or are already in default to obtain modified financing terms prescribed by the

program.  In accordance with the program guidelines, Regions has distributed approximately 1,341

modification packages to eligible borrowers subject to a ninety‐day trial period. The first modifications

under this program were seen in July 2009.  In the month of March, Regions completed 112

modifications totaling $16.9 million in unpaid principal.  Regions currently services approximately $20.7

billion of Fannie Mae and Freddie Mac mortgages.  

B. Home Equity Lending

Home Equity production increased 45% in March to $102MM. The increase in production can be

attributed to the March Loan Focus week that included activities such as pre‐approved equity mailings

and corresponding call lead lists to the branches, branch call nights, increased lending advertising spend,

and lender refresher training for the sales force. While up over prior month, Home Equity Lending

production remains low, down 17% compared to same period prior year, due to declining home values

limiting the qualifying amount for homeowners.

Overall Home Equity average balances declined $113 million or 0.7% in March to $15.1 billion.  The

HELOAN portfolio declined $25.5 million, 1.5%, while HELOC balances declined $87.2 million, 0.7%,

reflecting portfolio paydowns in excess of new production.

C. Other Consumer Lending

Overall, Other Consumer Lending balances decreased 9% in March compared to February primarily

driven by the continued run‐off in the Indirect Lending portfolio and routine student loan sales.   

D. Customer Assistance Program

Regions’ continues to work to meet the unique needs of financially troubled borrowers to stem

foreclosures and keep customers in their homes. Well before the full effects of the credit crisis were

realized, Regions launched an extensive Customer Assistance Program (CAP) for troubled borrowers.  As

unemployment levels continue to be elevated and the housing crisis lingers our goal remains the same ‐ 

to ensure customers who encounter financial difficulty know they have options and that Regions wants

to work with them.

As a result, Regions has taken steps including renegotiating the terms of mortgages and home equity

loans, keeping families in their homes and allowing Regions to maintain a foreclosure rate well below

industry average for residential first mortgages.  Overall, the number of Regions first mortgage loans in

the foreclosure process is less than half the national average. (1.95% for Regions vs. 4.58% nationally in

the fourth quarter of 2009.)  Since inception of the program, Regions has restructured more than $2.0

billion in mortgages, including $42 million in March 2010. Regions has assisted more than 29,000

homeowners with solutions. 
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: Regions Financial Corporation

Reporting month(s):    March 2010      

Submission date:  April 30, 2010

Person to be contacted regarding this report:  David Turner, Chief Financial Officer

3

In addition, Regions introduced the U.S. Treasury sponsored Home Affordable Modification Program for

loans serviced on behalf of Fannie Mae and Freddie Mac back in late March.  To date, we have initiated

1,341 trial period modifications for $205 million, and of those, 699 have been completed for $107

million.

IV. Commercial Lending

A.  Commercial and Industrial Lending

Loan demand remained soft in March as the stagnant economy continues to drive more conservative

leverage positions.  Outstanding loan balances were down in March as compared to February levels.  

Commercial line utilization rates decreased slightly in March as compared to February; however, line

utilization rates have remained relatively flat since October 2009.

In the middle market, client appetite for additional debt remains low.  Lower sales volumes have

resulted in lower inventory and accounts receivable financing requirements.  Businesses are less likely to

invest in or expand their operations given the current economic outlook.

  

Lending activity continues to increase in the not‐for‐profit/public institution sector, as many large

investment‐grade borrowers are exiting the bond market and seeking senior bank debt. With the

expansion of the rules for bank qualified lending, the Stimulus Act is providing additional opportunities

to extend credit to public entities.

Regions defines small business, in general, as clients with revenues up to $10 million.  Small business

lending activity is reflected within our Commercial and Industrial, Commercial Real Estate and

Residential Mortgage outstanding loan balances and production.   

Small businesses are experiencing lower working capital requirements resulting from lower sales

volumes and are reluctant to make capital investments given the current economic outlook.  As a result,

we are seeing small businesses build cash in their operating accounts.  Small business line utilization

rates decreased nominally in March compared to February.

B.  Commercial Real Estate Lending

The focus in commercial real estate lending continues to be on renewing and restructuring real estate

loans with existing clients versus active pursuit of new real estate loans.  Renewal activity includes loan

restructuring, remargining and repricing, consistent with the current credit quality of the sponsor, the

performance of the project and the current market.  As homebuilders sell existing inventory, we

continue to convert lot loans to residential construction loans, in turn, reducing our land and lot

portfolio.  

In March, new loan demand remained low.  Developers are reluctant to begin new projects or purchase

existing projects under current economic conditions.
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: Regions Financial Corporation

Reporting month(s):    March 2010      

Submission date:  April 30, 2010

Person to be contacted regarding this report:  David Turner, Chief Financial Officer

4

V. Treasury Activities  

Management of interest rate risk is among the most fundamental tenets in banking.  Banking

institutions utilize the Available for Sale investment portfolio as a primary tool to balance the inherent

interest rate risk arising from core banking activities.  Agency Mortgage‐Backed securities provided an

efficient means to offset asset sensitivity and maintain the desired liquidity profile, while offering a

compelling risk adjusted return on the use of capital.  Mortgage‐Backed security activity in March

totaled $0.4 million, which consists of Agency Fixed‐Rate Mortgage‐Backed Products.

VI. Equity and Debt Activities at Morgan Keegan

March proved to be a busy month for equity underwriting with the most deals completed in March since

2004. The 108 equity deals completed in March outperformed the January and February activity by

approximately 3%. The most active industry sectors were finance, REIT’s and technology. Morgan

Keegan’s equity activity is still somewhat slow with only five transactions. We are beginning to see a

backlog of deals and expect to see more activity in April.  The volume in the Morgan Keegan Debt

underwriting department was relatively high, which was as expected.  We expect volume to stay high

through May, and then begin to taper off as summer approaches.
Name of institution: SunTrust Banks, Inc. Submission date: 04/29/10 Person to be c

PART I. QUANTITATIVE OVERVIEW

SCHEDULE A: CONSUMER LENDING (Millions $) JAN FEB MAR Key 1. First Mortgagea. Average Loan Balance (Daily Average Total Outstanding) $31,866 $31,413 $31,429 Consists of (1‐4 family) residential whole loans and closed end loans secured by junior liens

originated as part of a home purchase or refinance transactions. Includes loans retained in

SunTrust's loan portfolio and loans currently recorded in loans held for sale.

b. Total Originations $1,913 $1,515 $2,217 Includes all loans originated or purchased by SunTrust through the Retail and Wholesale channels.

Volumes include all activity regardless of whether the loans are retained in the loan portfolio, or

recorded in loans held for sale and ultimately sold to a third party.

(1) Refinancings $1,290 $904 $1,246(2) New Home Purchases $623 $611 $971

2. Home Equity

a. Average Total Loan Balance $17,509 $17,392 $17,239 Average balance, originations, and commitments include both Home Equity Lines and Home Equity

Loans.

b. Originations (New Lines+Line Increases) $85 $97 $126

Originations inc

seasonally low d

home purchases 

impending dead

February 2010.Average balance

seasonally‐low F

2010

TREASURY MONTHLY INTERMEDIATION SNAPSHOT

1

c. Total Used and Unused Commitments $32,936 $32,742 $32,468

3. US Card ‐ Managed

a. Average Total Loan Balance ‐ Managed $1,068 $1,070 $1,065 Purchases drawn against SunTrust consumer and commercial credit card lines of credit are booked

in the calendar month transacted.

b. New Account Originations (Initial Line Amt) $13 $12 $14 SunTrust issues both commercial and consumer credit card lines of credit. New line commitments

are recognized when approved and cards are issued.

c. Total Used and Unused Commitments $4,125 $4,089 $4,021 This is the line commitment total for all credit card accounts of record.

4. Other Consumer

a. Average Total Loan Balance $12,393 $12,620 $12,704 Average balances and originations include student loans, direct installment loans (auto and non‐

auto), indirect installment loans (auto and marine), and unsecured personal credit lines.

b. Originations $649 $573 $563

Average balance

A $113 million in

in student loan o

March originatio

from February.

1
SCHEDULE B: COMMERCIAL LENDING (Millions $) JAN FEB MAR Key 

1. C & Ia. Average Total Loan and Lease Balance $33,635 $33,553 $33,227 Includes average outstandings for Commercial & Industrial loans and leases extended to small

business, commercial, middle market, and large corporate clients.

b. Renewal of Existing Accounts $723 $778 $1,328 Renewals represent credit facilities and stand‐alone notes that matured and were renewed during

the reporting period. Includes funded loans and unfunded commitments, but does not include

letters of credit or derivatives.

c. New Commitments $702 $1,063 $1,286 Includes new facilities, stand‐alone notes, and leases extended to new or existing clients. Reflects

both funded loans and unfunded commitments. Does not include takedowns under existing

commitments, letters of credit, or derivatives.

2. Commercial Real Estate

a. Average Total Loan and Lease Balance $21,893 $21,581 $21,389 Includes commercial loans secured by owner occupied or non‐owner occupied real estate.

Includes loans extended for real estate financing as well as loans made for other purposes and

collateralized by real estate.

b. Renewal of Existing Accounts $150 $201 $349 Renewals represent credit facilities and stand‐alone notes that matured and were renewed during

the reporting period. Includes funded loans and unfunded commitments, but does not include

letters of credit or derivatives.

c. New Commitments $157 $124 $228 Includes new facilities and stand‐alone notes extended to new or existing clients. Reflects both

funded loans and unfunded commitments. Does not include takedowns under existing

commitments, letters of credit, or derivatives.

4. Small Business Loans3

a. Average Total Loan Balance $5,288 $5,244 $5,210 Average balances and originations include loans originated in the business banking group which

includes loans guaranteed by the SBA. Business Banking primarily serves clients with annual sales

of $5 million or less.

Commercial rea

increased signifi

originations wer

The precipitous 

increased over s

SCHEDULE C: MEMORANDA ‐ SMALL BUSINESS LENDING (Millions $)

Reported averag

of new and rene

client timing pre

2

of $5 million or less.

b. Originations $36 $35 $48SCHEDULE D: OTHER INTERMEDIATION ACTIVITIES (Millions $)

1. MBS/ABS Net Purchased Volume

a. Mortgage Backed Securities ‐$550 ‐$1,969 $508 The numbers represent net purchase volume within the reporting period. These securities are

reported in SunTrust's available‐for‐sale and trading portfolios.

b. Asset Backed Securities $758 $0 $0 The numbers represent net purchase volume within the reporting period. These figures include

securities reported in SunTrust's available‐for‐sale and trading portfolios.

2. Secured Lending (Repo, PB, Margin Lending)

a. Average Total Matched Book (Repo/Reverse Repo)1 n/a n/a n/a SunTrust Bank has less than $50 billion in matched book repos. SunTrust Robinson Humphrey

“STRH”, an institutional broker dealer, is fully disclosed on the equity side through a third party

service provider and does not hold customer accounts.

b. Average Total Debit Balances2 n/a n/a n/a Although STRH self‐clears institutional fixed income transactions, STRH does not carry customer

accounts.

3. Underwriting

a. Total Equity Underwriting $0 $36 $57 Includes total dollars allocated to STRH in equity underwriting transactions that settled within the

reporting period.

b. Total Debt Underwriting $324 $140 $763 Includes total dollars allocated to STRH in investment grade fixed income, high yield fixed income,

and municipal debt underwriting transactions that settled within the reporting period.

In March, SunTr

backed securitie

Total debt unde

underwriting of 

transactions for 

Notes:3. Memoranda: these loans are already accounted for in either consumer lending, commercial lending, or a combination of both, and include loans guaranteed by the Small Business Administration and/or any other loans that are internally classified as small business loans.

2. Applicable only for institutions offering prime brokerage or other margin lending services to clients.

1. Not applicable if matched book activity does not exceed $50 billion.

2
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:  SunTrust Banks, Inc.

Reporting month(s):  March 2010   

Submission date: 4/29/10

Person to be contacted regarding this report:  Barry Koling

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PART II.  QUALITATIVE OVERVIEW

Please provide a brief overview of the intermediation activity during the month.  This discussion should

include a general commentary on the lending environment, loan demand, any changes in lending

standards and terms, and any other intermediation activity.

SunTrust Banks, Inc., with total assets of $171.8 billion on March 31, 2010, is one of the nation’s largest

financial holding companies.  Through its banking subsidiaries, the Company provides deposit, credit,

trust, and investment services to a broad range of retail, business, and institutional clients. Other

subsidiaries provide mortgage banking, brokerage, investment management, equipment leasing, and

capital market services.  SunTrust operates 1,678 retail branches in Alabama, Arkansas, Florida, Georgia,

Maryland, Mississippi, North Carolina, South Carolina, Tennessee, Virginia, West Virginia, and the

District of Columbia.  In addition, SunTrust services clients in select markets nationally.   

Average loans in March, including loans held for sale, totaled $117.1 billion, down $576 million or 0.5%

from February, with 90% of the decline attributable to commercial lending categories.  These totals do

not include loans extended to clients and sold to third parties.  This fact is particularly relevant when

considering the mortgage portfolio, since the majority of new originations and refinanced mortgage

loans are sold to third parties.    Total new loan originations, commitments, and renewals extended to all

borrowers in March totaled $6.1 billion, an increase of 40% above February originations which were

seasonally low due to unusually inclement weather and fewer days.

Consumer Lending

Mortgage originations totaled $2.2 billion during March, representing a 46.3% increase from February.  

Loans funded for new home purchases and refinancings in March increased by 58.9% and 37.8%,

respectively, relative to February.    Specific factors influencing the increase in mortgage originations in

March included the response to favorable mortgage rates and the impending deadline for a federal

home‐buyer’s tax credit.  Average mortgage balances increased fractionally by $16 million during March.  

Home equity borrowing remains stagnant as evidenced by the continuing fractional monthly decline of

both total commitment and outstanding balances over the last three months.   During March, total

commitments decreased $274 million while average funded balances decreased $153 million.   Both

changes represent relative decreases of less than 1% in comparison to the corresponding February

totals.  The proportion of home equity commitment utilization for the last three months is 53%.  New

equity loan and line originations increased for the third consecutive month in March to $126 million, but

growth levels remain constrained by the decline in home values and the generally reduced demand for

credit.

Credit card balances represent a small percentage of SunTrust’s loan portfolio and drive a relatively

immaterial percentage of SunTrust’s total annual loan originations.  In March, new credit card

originations totaled $14 million, with $9 million related to new consumer accounts and $5 million

related to new business and corporate accounts.    
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution:  SunTrust Banks, Inc.

Reporting month(s):  March 2010   

Submission date: 4/29/10

Person to be contacted regarding this report:  Barry Koling

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Other consumer loans are primarily composed of student, auto, and other loans.  March fundings for

indirect auto, student, and other consumer loans decreased 1.7% from February, as March student loan

originations decreased $145 million, or 56.3% from February due to seasonality associated with

semester tuition payments and student enrollments.  However, partially offsetting the decline in

student loan originations, March indirect auto production increased $113 million, or 46.8% from

February.  

Commercial Lending

Average C&I loan balances decreased approximately 1.0% in March to $33.2 billion.  Renewals of

existing credit facilities and stand‐alone notes totaled $1.3 billion in March, an increase of 70.7% from

February.  New commitments and new funded loans also increased in March by $223 million, a 21.0%

increase compared to February.  C & I originations and renewals are often impacted by client timing

preferences and seasonality.  March C & I  originations represent 44% of the total first quarter C & I

originations in 2010.   

Commercial Real Estate

Average Commercial Real Estate loans decreased $192 million, or 0.9%, compared to the February

average.  New residential home builder loan demand was negligible and demand for commercial

development projects remained low as property values remained depressed and investment activity was

limited.  Total Commercial Real Estate renewals and originations in March increased $252 million, or

77.5%, compared to seasonally low February activity.  The majority of originations were associated with

large commercial or corporate businesses.  For the first quarter of 2010, 48% of total quarterly

Commercial Real Estate originations occurred in March.  During March, average balances of commercial

real estate loans secured by owner‐occupied real estate remained stable.

Small Business Lending

Most small business loans are originated in the business banking group which primarily serves clients

with annual sales of $5 million or less.  In March, the average loan balance was $5.2 billion, down 0.6%

from February.  March originations increased slightly to $48 million.

Other Intermediation Activities

Beyond lending to consumers and businesses, SunTrust participates in various additional intermediation

activities.  In March 2010, SunTrust purchased an additional $508 million of U. S. government and

agency issued mortgage‐backed securities for the available for sale portfolio.

SunTrust participated in twenty‐nine debt issues in March with a total notional value of $15.1 billion.  

SunTrust’s allocation of underwritten debt included $519 million in investment‐grade fixed‐income

issues, $70 million in municipal debt issues, and $174 million in high‐yield fixed‐income offerings, which

in the aggregate was $623 million above February totals.

In March, SunTrust participated in four equity offerings with a total notional value of $2.2 billion, of

which our allocation was $57 million.