1

Name of institution: KeyCorp Submission date: 4/27/11 Person to be contacted about this report: Robert L. Morris

PART I. QUANTITATIVE OVERVIEW

SCHEDULE A: CONSUMER LENDING (Millions $) JAN-11 FEB-11 MAR-11 Key Comments

1. First Mortgage

a. Average Loan Balance (Daily Average Total Outstanding) $2,995 $2,971 $2,951 First Mortgage includes loans secured by 1-4 family residential properties including home equity 

loans secured by first liens.

b. Total Originations $233 $179 $172 Total Originations include both portfolio and held-for-sale loan originations. 

(1) Refinancings $199 $147 $126

(2) New Home Purchases $34 $32 $46

2. Home Equity

a. Average Total Loan Balance $8,058 $7,999 $7,947 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) $56 $51 $67

c. Total Used and Unused Commitments $15,695 $15,648 $15,574

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 $9,259 $9,160 $9,075 Other Consumer includes all other non-revolving consumer loans.

b. Originations $11 $9 $13

March originations are reflective of flat application volume for the past three months. However, March 

application volume increased 25% from the level experienced in February.

March application volume was up 21% from the level experienced in February.

March application volume increased from the February level by 42% for auto loans and 50% for all other 

secured loan products.

TREASURY MONTHLY INTERMEDIATION SNAPSHOT
2

SCHEDULE B: COMMERCIAL LENDING (Millions $) JAN-11 FEB-11 MAR-11 Key

1. C & I

a. Average Total Loan and Lease Balance $22,829 $22,819 $22,698 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 $668 $745 $968 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 $683 $588 $1,559 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 $11,679 $11,514 $11,174 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 $248 $134 $219 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 $92 $106 $95 New commitments include outstanding balances and unused commitments. Commitment 

amounts exclude standby letters of credit.

4. Small Business Loans3

a. Average Total Loan Balance $2,955 $2,959 $2,951 Small Business includes loans guaranteed by the Small Business Administration ("SBA") and other 

loans internally classified as small business loans.

b. Originations $65 $43 $89

SCHEDULE D: OTHER INTERMEDIATION ACTIVITIES (Millions $)

1. MBS/ABS Net Purchased Volume

a. Mortgage Backed Securities $1 -$472 -$1,958 March mortgage backed securities ("MBS") net purchased volume includes $0 billion in 

purchases, $1.6 billion in sales, and $.4 billion in paydowns, calls and maturities. 

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 N/A N/A N/A

3. Underwriting

a. Total Equity Underwriting $104 $27 $349 Represents KeyCorp's equity underwriting commitments.

b. Total Debt Underwriting $289 $221 $657 Represents KeyCorp's taxable and municipal debt underwriting commitments.

Notes:

March loan approvals increased from January and February levels, consistent with seasonal experience. The 

Institutional Bank segment experienced the highest new loan approval volume at $670 million, followed by the 

Middle Market segment at $371 million. 

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.

March new commitment volume of $95 million was comparable to that experienced in February 2011, but with 

activity more broadly spread across KeyCorp's lines of business. The Middle Market segment accounted for 

35% of new volume followed by Business Banking at 27%, Real Estate Capital at 26% and Community 

Development at 9%. Renewals during the month were primarily within the Real Estate Capital segment. 

KeyCorp was the co-manager on twelve equity deals, totaling $349 million in underwriting commitments, 

compared to two deals totaling $41 million in March 2010. Taxable debt underwriting consisted of thirteen 

deals totaling $614 million in underwriting commitments, of which nine deals were investment grade and four 

were high yield. Municipal debt underwriting totaled $43 million in underwriting commitments.

Security sales of $1.6 billion along with no reinvestment of March paydown cashflows provided liquidity and 

addressed the funding requirements related to the loss of approximately $1.5 billion of escrow deposits 

associated with KeyCorp’s mortgage operations that were moved to another financial institution as a result of 

the previously reported ratings downgrade of KeyBank National Association by Moody’s in November 2010. 

New loans approved in March were strong at $118 million, representing an 88% increase from the February 

level. March’s approval level is the highest since May 2008. Loan demand improved across the KeyCorp 

footprint, with SBA approvals showing the strongest growth. SBA new loans approved in March represented 

36% of total Small Business approvals. March loan renewals increased 42% from the February level to $156 

million due to expected seasonality of line renewals.

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

1. Not applicable if matched book activity does not exceed $50 billion. 
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: KeyCorp

Reporting month(s): March 2011

Submission date: 4/27/11

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 $90.4 billion at March 31, 2011. 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, Key Community Bank

and Key Corporate Bank. Key Community Bank 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. Key Corporate Bank

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

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

General

KeyCorp’s overall new loan applications increased in March from February’s level. Loan application 

activity for Consumer loans continued to improve from 2010 levels in all areas with the exception of 

Mortgage loan refinancings, which have been impacted by the higher rate environment compared to 

last year. Commercial and Industrial (“C & I”) and Small Business new loan approvals increased in March 

from February. Commercial Real Estate (“CRE”) loan originations remained relatively stable during the 

past two months.

Consumer

March Consumer application volume was reflective of the typical seasonal increase in loan demand in 

the spring season. Originations continue to show improvement from the year-ago period, with 

exception of Mortgage activity, due to the current rate environment compared to last year.

C & I

C & I loan approval volume increased in March, led by strong increases in loan approvals for new and 

existing clients in the Institutional Bank, Middle Market and Leasing segments. Combined, those three 

areas generated loan approval volume of $1.3 billion in March.

Commercial Real Estate

New Commercial Real Estate originations were in line with January and February originations and much 

higher than the comparable period in 2010. Originations, however, did not offset repayments, as 

reflected in the 3% decline in average loan and lease balances outstanding. New loan application 

volume continues to be attributable to the commercial banking segments (primarily in the Key 

Community Bank business group), indicating some demand from business owners investing in their own 

properties. Demand for financing of new real estate development projects remains constrained.
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: KeyCorp

Reporting month(s): March 2011

Submission date: 4/27/11

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

2

Small Business

March’s new loan approval level of $118 million represents the highest approval volume since May

2008. SBA loan approvals showed the strongest growth from last month. SBA new loans approved in 

March represented 36% of total approvals, which is higher than the historic level of 24%. Loan demand 

has increased in all of KeyCorp’s footprint regions. The application pipeline for owner-occupied real 

estate is at its highest level since 2008.

Investment Portfolio

KeyCorp continues to use the available-for-sale securities portfolio to support strategies for managing 

overall balance sheet liquidity and interest rate risk. In March, the size of KeyCorp’s investment 

portfolio decreased by $2.0 billion as a result of the sale of $1.6 billion of securities along with a decision 

not to reinvest security cashflows during March. These actions provided liquidity and addressed the 

funding requirements related to the loss of approximately $1.5 billion of escrow deposits associated 

with KeyCorp’s mortgage operations that were moved to another financial institution as a result of the 

previously reported ratings downgrade of KeyBank National Association by Moody’s in November 2010. 
1

Name of institution: Marshall & Ilsley Corporation Submission date: 04/29/11 Person to be contacted about this report: Gregory A. Smith

PART I. QUANTITATIVE OVERVIEW

2011

SCHEDULE A: CONSUMER LENDING (Millions $) JAN FEB MAR Key Comments

1. First Mortgage

a. Average Loan Balance (Daily Average Total Outstanding) $6,008 $5,857 $5,732 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 $152 $95 $86 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 $122 $65 $50

(2) New Home Purchases $31 $31 $36

2. Home Equity

a. Average Total Loan Balance $2,482 $2,460 $2,423 Includes Home Equity Lines only.

b. Originations (New Lines+Line Increases) $22 $20 $20

c. Total Used and Unused Commitments $4,524 $4,510 $4,482

3. US Card - Managed

a. Average Total Loan Balance - Managed $283 $273 $264 Includes Consumer Card only.

b. New Account Originations (Initial Line Amt) $7 $6 $12

c. Total Used and Unused Commitments $1,331 $1,338 $1,336

4. Other Consumer 

a. Average Total Loan Balance $928 $927 $943 Includes consumer PRA & LOCs. Subcategories include Auto Leases, Dealer Finance, Personal, 

Securities Loans, and Student Loans.

b. Originations $42 $42 $55 Includes Additional Notes and Refinances to existing customers and notes to new customers.

TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Mortgage originations continue to decrease, driven primarily by the decrease in refinance activity due to 

fixed rate mortgage rates rising over the last several months. Purchase originations have held relatively flat.

Average Total Loan Balance was down month-over-month as paydowns continue to outpace new 

production. Originations were effectively flat while Total Used & Unused Commitments were down due to 

higher loan rates over the last several months.

Balances and New Account Originations were up month-over-month, led by Dealer Finance.

Average Balances decreased due to strong payment rates. New Account Originations increased month-overmonth, aided by a branch promotion. Total Used and Unused Commitments remained effectively flat.
2

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

1. C & I

a. Average Total Loan and Lease Balance $11,612 $11,675 $11,471 Includes A/R and Inventory, Dealer Commercial, Agricultural, IRB's and Muni, and Commercial 

Leases.

b. Renewal of Existing Accounts $153 $172 $122 Renewals include renewal of existing accounts where new money is requested, terms are 

modified, or new master line is established.

c. New Commitments $117 $89 $38 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 $15,542 $15,350 $15,012 Includes Business Purpose 1-4 and Construction, Development, & Vacant Land (Commercial and 

Residential).

b. Renewal of Existing Accounts $28 $48 $53 Renewals include renewal of existing accounts where new money is requested, terms are 

modified, or new master line is established.

c. New Commitments $11 $15 $12 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 $3,010 $2,976 $2,912 Includes SBA-guaranteed loans and Business Loans & Commitments < $1 million to customers 

with Revenue < $1 million. Excludes Letters of Credit.

b. Originations $12 $11 $14

SCHEDULE D: OTHER INTERMEDIATION ACTIVITIES (Millions $)

1. MBS/ABS Net Purchased Volume

a. Mortgage Backed Securities $1 $1 $1 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-notsettled transactions.

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 N/A N/A N/A

3. 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.

Continuing with past monthly trends, Commercial Real Estate Average Balances decreased month-overmonth led by Construction and Development loans. Renewals were higher month-over-month, reflecting 

variation in renewal cycles. Commercial Real Estate Average Balances are expected to continue contracting 

due to portfolio amortization.

Average Total Loan Balance decreased month-over-month led by Commercial Real Estate Loans. March 

Originations were higher than February, led by Commercial Real Estate-Consumer. Pipelines and 

Originations remain at historically low levels due to decreased demand as customers continue to address 

impacts from current economic conditions.

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

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

Average Balances decreased in March. Renewals decreased from February to March, reflecting variation in 

renewal cycles. New commitments decreased from February. Companies continue to defer capital 

expenditures, pay down debt, use internally generated cash and delay investments in infrastructure, all of 

which influences customer borrowing needs.
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: Marshall & Ilsley Corporation

Reporting month(s): March 2011

Submission date: 04/29/2011

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 (NYSE: MI) (M&I) is a diversified financial services corporation 

headquartered in Milwaukee, Wis. M&I Marshall & Ilsley Bank is the largest Wisconsin-based bank, with

188 offices throughout the state. In addition, M&I has 53 locations throughout Arizona; 36 offices along 

Florida’s west coast and in central Florida; 33 offices in Indianapolis and nearby communities; 26 offices 

in metropolitan Minneapolis/St. Paul, and one in Duluth, Minn.; 17 offices in the greater St. Louis area; 

15 offices in Kansas City and nearby communities; and one office in Las Vegas, Nev. M&I also provides 

trust and investment management, equipment leasing, mortgage banking, asset-based lending, financial 

planning, investments, and insurance services from offices throughout the country and on the Internet 

(www.mibank.com or www.micorp.com).

On December 17, 2010, M&I entered into a definitive agreement under which BMO Financial Group will 

acquire all outstanding shares of common stock of M&I in a stock-for-stock transaction. Under the 

terms of the agreement, each outstanding share of M&I will be exchanged for 0.1257 shares of Bank of 

Montreal upon closing. The transaction is expected to close prior to July 31, 2011. The transaction is 

subject to customary closing conditions, including regulatory approvals and approval from shareholders 

of M&I.

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

conditions of the economy. Nonetheless, M&I extended approximately $325 million of new credit to 

new and existing customers in March for a total of over $11.6 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). Included in the figures above are small business new credit extensions of $16 million in

March and over $789 million since receipt of CPP capital. ("Small business" includes: (1) SBA-guaranteed 

loans and (2) Commercial purpose loans where the original note amount was $1 million or less, 

outstanding commitments were $1 million or less and the customer had (recorded) revenue of $1 

million or less). Additionally, M&I has a franchise-wide foreclosure moratorium program. The 

moratorium is on all owner-occupied residential loans for customers who agree to work in good faith to 

reach a successful repayment agreement.

In Commercial and Industrial loans, current line utilization from existing customers decreased reflecting 

lower working capital needs. Customers continue to resize their revolving credit facilities to match

working capital 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 
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: Marshall & Ilsley Corporation

Reporting month(s): March 2011

Submission date: 04/29/2011

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

2

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. The decrease in mortgage originations from February to March was primarily driven by a 

slow down in refinance activity due to a continued increase in interest rates on fixed rate mortgages

over the last several months. 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. 
1

Name of institution: Regions Financial Corporation Submission date: April 29, 2011 Person to be contacted about this report: David Turner, Chief Financial Officer

PART I. QUANTITATIVE OVERVIEW

SCHEDULE A: CONSUMER LENDING (Millions $) 2011

1. First Mortgage Jan Feb Mar Key Comments

a. Average Loan Balance (Daily Average Total Outstanding) $15,998 $15,906 $15,640 First and second residential 1-4 family mortgages, including residential mortgages held for sale.

b. Total Originations $581 $473 $502 Loan originations designated for the secondary market and those to be held in portfolio on 

Regions' balance sheet.

(1) Refinancings $413 $287 $247 Total originations designated as refinance status.

(2) New Home Purchases $168 $186 $255 Total originations designated as new purchase status.

2. Home Equity

a. Average Total Loan Balance $14,169 $14,052 $13,939 Average balances include Home Equity loans and HELOCs.

b. Originations (New Lines+Line Increases) $63 $90 $110 New Home Equity loans, lines and increases.

c. Total Used and Unused Commitments $23,233 $23,104 $22,971 Total portfolio of Home Equity loans and funded and unfunded HELOCs. Funded portion 

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/A

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

4. Other Consumer 

a. Average Total Loan Balance $2,834 $2,838 $2,836 Includes consumer direct, indirect, other revolving (i.e., overdraft lines) and student loans held 

for sale.

b. Originations $124 $121 $141 Includes direct and student lending origination activity.

TREASURY MONTHLY INTERMEDIATION SNAPSHOT

March Other Consumer Lending balances were flat with February at $2.8B. Balances are being favorably impacted by the reentry of Indirect Lending offset by the continued run-off of the legacy Indirect Lending portfolio as well as continued student 

loan sales.

N/A

The mortgage division originated mortgage loans totaling $502 million in March 2011. Overall production increased 6% from 

the prior month. New purchase originations increased 37% from prior month, and refinancing activity decreased from the 

prior month 14%. Application activity in March increased 28% as compared to prior month. 

Home Equity average balances declined $112.5MM or 0.8% in March to $13.9B. The HELOAN portfolio declined $13.3MM, 

0.91%, while HELOC balances declined $99.2MM or 0.8%. Portfolio run-off continues as payoffs/paydowns outpace 

production.
2

SCHEDULE B: COMMERCIAL LENDING (Millions $)

1. C & I Jan Feb Mar Key Comments

a. Average Total Loan and Lease Balance $35,225 $35,434 $35,482 Average outstanding funded balances (net of deferred fees and costs) for commercial related 

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

construction loans made to operating businesses.

b. Renewal of Existing Accounts $1,619 $1,331 $2,231 Renewal of existing funded and unfunded commitments for commercial and owner-occupied 

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

c. New Commitments $1,167 $869 $1,299 New funded and unfunded commitments for commercial and owner-occupied real estate related loans 

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

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

2. Commercial Real Estate

a. Average Total Loan and Lease Balance $16,053 $15,793 $15,509 Average outstanding funded balances (net of deferred fees and costs) for commercial investorowned real estate related loans. Also includes Commercial loans held for sale.

b. Renewal of Existing Accounts $751 $566 $1,137 Renewal of existing funded and unfunded commitments for commercial investor-owned real 

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

c. New Commitments $5 $65 $34 New funded and unfunded commitments for commercial investor-owned real estate related loans based 

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

fundings are excluded from new commitment activity.

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

4. Small Business Loans3

a. Average Total Loan Balance $13,092 $12,996 $12,977 Average outstanding funded balances (net of deferred fees and costs) for commercial and commercial real estate related 

loans made to small business clients, which we generally define as clients with revenues up to $20 million. These balances 

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

b. Originations $568 $561 $647 New and renewed production of funded and unfunded commitments made to small business 

clients, which we generally define as clients with revenues up to $20 million. These originations 

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 $1,535 $735 -$138

b. Asset Backed Securities $0 $82 $65

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 $1,263 $1,231 $1,196 Reflects average margin receivables as recorded on the general ledger.

3. Underwriting

a. Total Equity Underwriting $16 $145 $192 Total equity underwriting activity. Represents Regions' participation percentage.

b. Total Debt Underwriting $378 $435 $652 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 business loans.

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

In March, commercial real estate balances decreased $284 million from February levels. In March, new loan demand 

remained low. Developers are reluctant to begin new projects or purchase existing projects under current economic 

conditions. The focus in commercial real estate lending is on renewing and restructuring real estate loans with existing 

clients. 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.

The Morgan Keegan Equity department participated in 4 offerings during January 2011, 9 during February 2011, and 13 during 

March 2011. Gross debt issuance for January, February, and March was $15 billion, $9.9 billion, and $3.6 billion respectively.

Net purchase volume as captured in bond accounting system. Reflects settlement date. 

Consists of Government and Agency Fixed-Rate Mortgage-Backed Products. The Asset Backed securities consist of NonAgency Commercial Mortgage Backed products.

We expect small business demand to pick up modestly with improvement in capital investment as consumer spending has 

shown recent signs of improvement. We still believe business owners will remain cautious about adding jobs and expansion 

even as sales and profits pick up.

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

Loan demand in the middle market, while somewhat soft by historical standards, picked up some momentum throughout the 

fourth quarter and into 2011. The stagnant economy continues to drive more conservative leverage positions; however, more 

robust loan demand is seen in the upper end of the market and in certain industries. Outstanding loan balances increased $48 

million in March as compared to February levels. Commercial line utilization rates remained flat in March as compared to 

February.
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: Regions Financial Corporation

Reporting month(s): March 2011

Submission date: April 29, 2011

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, 2011, Regions had total consolidated assets of 

approximately $132 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 $1.9 billion to $5.5 billion for the month, while 

average balances declined $0.6 billion from February to $83.4 billion.

The month over month increase in new and renewed commitments was driven by a $0.9 billion increase 

in C&I renewals, a $0.4 billion increase in C&I new commitments, and a $0.5 billion increase in 

Commercial Real Estate renewals.

III. Consumer Lending

A. Mortgage Lending

The mortgage division originated mortgage loans totaling $502 million in March 2011. Overall 

production increased 6% from the prior month. New purchase originations increased 37% from prior 

month, and refinancing activity decreased from the prior month 14%. Application activity in March 

increased 28% as compared to prior 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 cannot exceed 125%. March originations included 

approximately $37.4 million related to 245 loans refinanced under the Home Affordable Refinance 

Program.
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: Regions Financial Corporation

Reporting month(s): March 2011

Submission date: April 29, 2011

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. On March 26, 2010, the U.S. Treasury announced program modifications to the existing HMP 

program. These program modifications are designed to expand flexibility for mortgage servicers and 

originators to assist more unemployed homeowners and to help more people who owe more on their 

mortgage than their home is worth because their local markets saw large declines in home values. In 

accordance with the program guidelines, Regions has distributed approximately 2,326 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 75 modifications totaling 

$11 million in unpaid principal. Regions currently services approximately $ 25.7 billion of Agency 

mortgages.

B. Home Equity Lending

Home Equity production increased 22% to $110MM from prior month and increased 7% versus same 

period prior year as a result of increased bookings from the January branch loan focus week combined 

with seasonality. Equity Lending activities for March included: branch loan focus week including call 

nights activities, daily pre-approved point of sale Equity offers at DDA account opening, pre-approved 

direct mail offer with lead lists to the branches, payment savings/utilization mailing to existing 

customers as well as continued momentum from targeting the lending needs of customers that do not 

qualify for the traditional HELOC product but are NOT considered subprime borrowers. 

Overall Home Equity average balances declined $112.5MM or 0.8% in March to $13.9B. The HELOAN 

portfolio declined $13.3MM, 0.91%, while HELOC balances declined $99.2MM or 0.8%. Portfolio run-off 

continues as payoffs/paydowns outpace production.

C. Other Consumer Lending

Other Consumer Lending production increased 17% in March to $141.4MM from prior month and 

increased 18% versus same period prior year due in part to seasonality and continued momentum from 

our re-entry into Indirect Auto Lending. Other Consumer Lending activities for March included: 

continued expansion of the Indirect Auto Lending sector to 788 active dealerships, daily pre-approved 

point of sale Auto/Unsecured LOC offers at DDA account opening; pre-approved direct mail offer with 

lead lists to the branches, and continued momentum from targeting the lending needs of customers 

that do not qualify for traditional credit products but are NOT considered subprime borrowers.

Overall, March Other Consumer Lending balances were flat with February at $2.8B. Balances are being 

favorably impacted by the re-entry of Indirect Lending offset by the continued run-off of the legacy 

Indirect Lending portfolio as well as continued student loan sales.
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: Regions Financial Corporation

Reporting month(s): March 2011

Submission date: April 29, 2011

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

3

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 serviced first mortgage 

loans in the foreclosure process is less than half the national average. (1.92% for Regions vs. 4.63% 

nationally in the fourth quarter of 2010.) Since inception of the program, Regions has restructured 

more than $3.1 billion in mortgages, including $53 million in March 2011. Regions has assisted more 

than 35,000 homeowners with solutions.

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 2009. To date, we have 

initiated 2,326 trial period modifications for $352 million and of those 1,589 have been completed for 

$241 million.

IV. Commercial Lending

A. Commercial and Industrial Lending

Loan demand in the middle market, while somewhat soft by historical standards, picked up some 

momentum throughout the fourth quarter and into 2011. The stagnant economy continues to drive 

more conservative leverage positions; however, more robust loan demand is seen in the upper end of 

the market and in certain industries. Outstanding loan balances increased $48 million in March as 

compared to February levels. Commercial line utilization rates remained flat in March as compared to 

February.

Regions defines small business, in general, as clients with revenues up to $20 million. Small business 

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

Mortgage outstanding loan balances and production. 

We expect small business demand to pick up modestly with improvement in capital investment as 

consumer spending has shown recent signs of improvement. We still believe business owners will 

remain cautious about adding jobs and expansion even as sales and profits pick up. Small business line 

utilization rates decreased slightly in March as compared to February.
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: Regions Financial Corporation

Reporting month(s): March 2011

Submission date: April 29, 2011

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

4

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. 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. The demand for financing for purchase of existing 

properties also remains limited as transaction volume remains low.

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 $-137.96 million, which consists of Government and Agency Fixed-Rate Mortgage-Backed 

Products. Asset-Backed security activity in March totaled $65.2 million, which consisted of Non-Agency 

Commercial Mortgage Backed products. 

VI. Equity and Debt Activities at Morgan Keegan

March was a busy month for Equity issuance, both for the “street” and for Morgan Keegan. The dollars 

raised in March haven’t been seen since March 2000. There were 103 equity offerings with Morgan 

Keegan being in thirteen. The REIT sector had the highest deal count, seeing 20 transactions completed. 

Even though the March Debt issuance was much lower than last year, the volume increased significantly 

over the first two months of 2011 and we expect that increase to continue into April. Conversely, we 

expect corporate underwriting to remain strong for the foreseeable future due to a continued favorable 

rate environment and tightening spreads.
1

Name of institution: SunTrust Banks, Inc. Submission date: 04/29/11 Person to be contacted about this report: Craig Smith

PART I. QUANTITATIVE OVERVIEW

2011 2011 2011

SCHEDULE A: CONSUMER LENDING (Millions $) JAN FEB MAR Key Comments

1. First Mortgage

a. Average Loan Balance (Daily Average Total Outstanding) $32,525 $32,200 $31,505 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 $2,284 $1,746 $1,721 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 $1,798 $1,271 $1,008

(2) New Home Purchases $486 $475 $713

2. Home Equity

a. Average Total Loan Balance $16,461 $16,192 $16,051 Average balance, originations, and commitments include both Home Equity Lines and Home 

Equity Loans.

b. Originations (New Lines+Line Increases) $127 $114 $160

c. Total Used and Unused Commitments $30,236 $30,060 $29,894

3. US Card - Managed

a. Average Total Loan Balance - Managed $1,024 $998 $1,014 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) $18 $20 $34 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 $3,648 $3,625 $3,610 This is the line commitment total for all credit card accounts of record.

4. Other Consumer 

a. Average Total Loan Balance $16,197 $16,255 $16,231 Average balances and originations include student loans, direct installment loans (auto and nonauto), indirect installment loans (auto and marine), and unsecured personal credit lines. 

b. Originations $502 $544 $526

TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Average balances decreased fractionally compared to February. Other Consumer originations decreased $18 

million, or 3%, compared to February.

March originations increased to $34 million. Total line commitments and usage declined slightly from 

February. Average line utilization remained stable at 28% compared to February.

Originations decreased 1% from prior month to $1.7 billion in March 2011. March refinancings decreased 

while originations for new purchases increased. Average balances decreased $695 million in March.

Average balances outstanding decreased 1% in March. Originations increased $46 million compared to 

February. The average line utilization rate decreased slightly to 54%.
2

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

1. C & I

a. Average Total Loan and Lease Balance $34,491 $34,542 $35,042 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 $921 $1,152 $1,095 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 $1,343 $1,100 $1,926 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 $17,898 $17,646 $17,388 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 $177 $198 $288 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 $151 $163 $216 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 $4,776 $4,877 $4,844 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.

b. Originations $30 $41 $37

SCHEDULE D: OTHER INTERMEDIATION ACTIVITIES (Millions $)

1. MBS/ABS Net Purchased Volume

a. Mortgage Backed Securities $913 $1,015 $2,765 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 -$37 -$8 $27 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 $8 $7 $441 Includes total dollars allocated to STRH in equity underwriting transactions that settled within the 

reporting period.

b. Total Debt Underwriting $881 $414 $943 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.

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.

Commercial real estate average balances declined $258 million in March compared to February. Loan 

demand has remained soft. There was a $143 million increase in March originations of new and renewing 

credit facilities resulting in a 40% increase compared to February.

Total debt underwriting consisted of investment-grade debt of $700 million, including $400 million of notes 

issued by SunTrust Banks, Inc. Additional underwriting in March included municipal debt of $53 million and 

high-yield debt of $190 million. Equity underwriting transactions for March totaled $441 million, including 

$260 million related to the Company's common stock offering.

Average loan balances decreased $33 million, or less than 1%, compared to February. Originations declined 

slightly to $37 million in March. 

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

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

Average loan balances increased $500 million, or 1%, compared to February. March originations of new 

commitments increased 75% compared to February while renewing credit facilities decreased 5% compared 

to February.

In March, SunTrust purchased $2.8 billion of U.S. government and agency issued mortgage-backed securities 

and $27 million of asset-backed securities as part of a repositioning of the investment portfolio. 
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: SunTrust Banks, Inc.

Reporting month(s): March 2011

Submission date: 04/29/11

Person to be contacted regarding this report: Craig 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.

SunTrust Banks, Inc., with total assets of $170.8 billion on March 31, 2011, 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 1,665 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 $117.2 billion, declining $0.6 billion from 

February. 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 billion, an increase of 18% from February, 

driven mostly by increased Commercial activity.

Consumer Lending

Mortgage originations totaled $1.7 billion during March, representing a 1% decrease from February. 

Mortgage refinancings decreased in March by 21%, while loans funded for new home purchases

increased in March by 50% relative to February. Total average mortgage balances declined $695 million,

or 2%, compared to February.

Home equity total used and unused commitments decreased $166 million representing a decrease of 

1% from February. Total equity loan and line originations increased 40% to $160 million in March and

average home equity loan balances declined $141 million, or 1%, compared to February. 
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: SunTrust Banks, Inc.

Reporting month(s): March 2011

Submission date: 04/29/11

Person to be contacted regarding this report: Craig Smith

2

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 $34 million, with $25 million related to new consumer accounts and $9 million 

related to new business accounts. 

Other Consumer loans are primarily composed of student, auto, and other loans. Average Other 

Consumer loan balances decreased fractionally by $24 million during March and indirect auto, student, 

and other consumer loan originations decreased $182 million, or 3%, compared to February.

Commercial Lending

Average C&I loan balances increased $500 million in March. Total Commercial Lending new 

commitments and renewals were $3 billion in March, a 34% increase from February. Renewals of 

existing credit facilities and stand-alone notes totaled $1.1 billion in March, a decrease of 5% from 

February. Combined new credit facilities, notes and leases increased in March by $826 million, or 75%,

compared to February. C&I originations and renewals are often impacted by client timing preferences 

and seasonality. 

Commercial Real Estate

Average Commercial Real Estate loans decreased $258 million, or 1%, 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. In March, Commercial Real Estate renewals of existing accounts increased $90 million, or 45%, 

and new Commercial Real Estate commitments grew $53 million, or 33%, compared to February. 

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 $4.8 billion, down 1% 

from February. March originations totaled $37 million, decreasing $4 million, or 10%, compared to 

February.
TREASURY MONTHLY INTERMEDIATION SNAPSHOT

Name of institution: SunTrust Banks, Inc.

Reporting month(s): March 2011

Submission date: 04/29/11

Person to be contacted regarding this report: Craig Smith

3

Other Intermediation Activities

Beyond lending to consumers and businesses, SunTrust participates in various additional intermediation 

activities. In March, SunTrust purchased $2.8 billion of U. S. government and agency issued mortgagebacked securities and $27 million of asset-backed securities as part of a repositioning of the investment 

portfolio. 

SunTrust participated in twenty-two debt issues in March with a total notional value of $9.6 billion. 

SunTrust’s allocation of underwritten debt included $700 million in investment-grade issues, including 

$400 million of notes issued by SunTrust Banks, Inc. Additional underwriting in March included 

municipal debt of $53 million and high-yield debt of $190 million. Total debt underwriting in March 

increased $529 million compared to February. 

In March, SunTrust participated in seven equity offerings with a total notional value of $7.3 billion, of 

which our allocation was $441 million, including $260 million related to the Company's common stock 

offering.