In the normal course of business, we originate or purchase loan products with contractual characteristics that, when concentrated, may increase our exposure as a holder of those loan products.
Possible product features that may create a concentration of credit risk would include a high original or updated LTV ratio, terms that may expose the borrower to future increases in repayments above increases in market interest rates, and interest-only loans, among others.
We also originate home equity and residential real estate loans that are concentrated in our primary geographic markets.
We originate interest-only loans to commercial borrowers.
Such credit arrangements are usually designed to match borrower cash flow expectations (e. g. , working capital lines, revolvers).
These products are standard in the financial services industry and product features are considered during the underwriting process to mitigate the increased risk that the interest-only feature may result in borrowers not being able to make interest and principal payments when due.
We do not believe that these product features create a concentration of credit risk.
At December 31, 2015, we pledged $20.2 billion of commercial loans to the Federal Reserve Bank (FRB) and $56.4 billion of residential real estate and other loans to the Federal Home Loan Bank (FHLB) as collateral for the contingent ability to borrow, if necessary.
The comparable amounts at December 31, 2014 were $19.2 billion and $52.8 billion, respectively.
Table 55: Nonperforming Assets
## Table 0 ##
(a) Excludes most consumer loans and lines of credit, not secured by residential real estate, which are charged off after 120 to 180 days past due and are not placed on nonperforming status.
(b) Nonperforming loans exclude certain government insured or guaranteed loans, loans held for sale, loans accounted for under the fair value option and purchased impaired loans.
(c) The recorded investment of loans collateralized by residential real estate property that are in process of foreclosure was $.6 billion and $.8 billion at December 31, 2015 and December 31, 2014, which included $.3 billion and $.5 billion, respectively, of loans that are government insured/guaranteed.
Nonperforming loans also include certain loans whose terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulties.
In accordance with applicable accounting guidance, these loans are considered TDRs.
See Note 1 Accounting Policies and the TDR section within this Note.
Total nonperforming loans in the nonperforming assets table above include TDRs of $1.1 billion at December 31, 2015 and $1.4 billion at December 31, 2014.
TDRs that are performing, including consumer credit card TDR loans, totaled $1.2 billion at December 31, 2015 and December 31, 2014 and are excluded from nonperforming loans.
These include TDRs that are not placed on nonaccrual status as permitted by regulatory guidance.
Nonperforming TDRs are returned to accrual and classified as performing after demonstrating a period of at least six months of consecutive performance under the restructured terms.
Loans where borrowers have been discharged from personal liability through Chapter 7 bankruptcy and have not formally reaffirmed their loan obligations to PNC and loans to borrowers not currently obligated to make both principal and interest payments under the restructured terms are not returned to accrual status.
Additional Asset Quality Indicators We have two overall portfolio segments – Commercial Lending and Consumer Lending.
Each of these two segments is comprised of multiple loan classes.
Classes are characterized by similarities in initial measurement, risk
(continued from previous page)
## Table 1 ##
(a) Amounts shown represent outstanding balance.
See Note 4 Purchased Loans for additional information.
(b) For the estimate of cash flows utilized in our purchased impaired loan accounting, other assumptions and estimates are made, including amortization of first lien balances, pre-payment rates, etc.
, which are not reflected in this table.
(c) The following states had the highest percentage of purchased impaired loans at December 31, 2015: California 16%, Florida 14%, Illinois 11%, Ohio 9%, North Carolina 7%, and Michigan 5%.
The remainder of the states had lower than a 4% concentration of purchased impaired loans individually, and collectively they represent approximately 38% of the purchased impaired portfolio.
The following states had the highest percentage of purchased impaired loans at December 31, 2014: California 17%, Florida 15%, Illinois 11%, Ohio 8%, North Carolina 7% and Michigan 5%.
The remainder of the states had lower than a 4% concentration of purchased impaired loans individually, and collectively they represent approximately 37% of the purchased impaired portfolio.
(d) Based upon updated LTV (inclusive of combined loan-to-value (CLTV) for first and subordinate lien positions).
Updated LTV is estimated using modeled property values.
These ratios are updated at least semi-annually.
The related estimates and inputs are based upon an approach that uses a combination of third-party automated valuation models (AVMs), broker price opinions (BPOs), HPI indices, property location, internal and external balance information, origination data and management assumptions.
We generally utilize origination lien balances provided by a third-party, where applicable, which do not include an amortization assumption when calculating updated LTV.
Accordingly, the results of these calculations do not represent actual appraised loan level collateral or updated LTV based upon lien balances held by others, and as such, are necessarily imprecise and subject to change as we enhance our methodology
establishing our ALLL.
Based upon outstanding balances at December 31, 2015, the following table presents the periods when home equity lines of credit draw periods are scheduled to end.
Table 32: Home Equity Lines of Credit – Draw Period End Dates
## Table 2 ##
(a) Includes all home equity lines of credit that mature in 2016 or later, including those with borrowers where we have terminated borrowing privileges.
(b) Includes approximately $40 million, $48 million, $34 million, $26 million and $534 million of home equity lines of credit with balloon payments, including those where we have terminated borrowing privileges, with draw periods scheduled to end in 2016, 2017, 2018, 2019 and 2020 and thereafter, respectively.
Based upon outstanding balances, and excluding purchased impaired loans, at December 31, 2015, for home equity lines of credit for which the borrower can no longer draw (e. g. , draw period has ended or borrowing privileges have been terminated), approximately 3% were 30-89 days past due and approximately 5% were 90 days or more past due.
Generally, when a borrower becomes 60 days past due, we terminate borrowing privileges and those privileges are not subsequently reinstated.
At that point, we continue our collection/recovery processes, which may include loan modification resulting in a loan that is classified as a TDR.
See Note 3 Asset Quality in the Notes To Consolidated Financial Statements in Item 8 of this Report for additional information.
Auto Loan Portfolio The auto loan portfolio totaled $11.2 billion as of December 31, 2015, or 5% of our total loan portfolio.
Of that total, $9.6 billion resides in the indirect auto portfolio, $1.1 billion in the direct auto portfolio, and $.5 billion in acquired or securitized portfolios, which has been declining as no pools have been recently acquired.
The indirect auto portfolio is the largest segment and generates auto loan applications from franchised automobile dealers.
This business is strategically aligned with our core retail business.
We have elected not to pursue non-prime auto lending as evidenced by an average new loan origination FICO score over the last twelve months of 758 for indirect auto loans and 773 for direct auto loans.
As of December 31, 2015, 0.3% of the portfolio was nonperforming and 0.5% of our auto loan portfolio was accruing past due.
We offer both new and used automobile financing to customers through our various channels.
The portfolio comprised 60% new vehicle loans and 40% used vehicle loans at December 31, 2015.
The auto loan portfolio’s performance is measured monthly, including updated collateral values that are obtained monthly and updated FICO scores that are obtained at least quarterly.
For internal reporting and risk management, we analyze the portfolio by product channel and product type, and regularly evaluate default and delinquency experience.
As part of our overall risk analysis and monitoring, we segment the portfolio by loan structure, collateral attributes, and credit metrics which include FICO score, loan-to-value and term.
Oil and Gas Portfolio Our portfolio in the oil and gas industry totaled $2.6 billion as of December 31, 2015, or 1% of our total loan portfolio and 2% of our total commercial lending portfolio.
This portfolio comprised approximately $1 billion in the midstream and downstream sectors, $.9 billion of oil services companies and $.7 billion related to energy and production companies.
Of the oil services portfolio, approximately $.2 billion is not asset-based or investment grade.
Our ALLL at December 31, 2015 reflects the incremental impact of the continued decline in oil and gas prices.
See Note 3 Asset Quality in the Notes To Consolidated Financial Statements in Item 8 of this Report for additional information.
Loan Modifications and Troubled Debt Restructurings Consumer Loan Modifications We modify loans under government and PNC-developed programs based upon our commitment to help eligible homeowners and borrowers avoid foreclosure, where appropriate.
Initially, a borrower is evaluated for a modification under a government program.
If a borrower does not qualify under a government program, the borrower is then evaluated under a PNC program.
Our programs utilize both temporary and permanent modifications and typically reduce the interest rate, extend the term and/or defer principal.
Loans that are either temporarily or permanently modified under programs involving a change to loan terms are generally classified as TDRs.
Further, loans that have certain types of payment plans and trial payment arrangements which do not include a contractual change to loan terms may be classified as TDRs.
Additional detail on TDRs is discussed below as well as in Note 3 Asset Quality in the Notes To Consolidated Financial Statements in Item 8 of this Report.
A temporary modification, with a term between 3 and 24 months, involves a change in original loan terms for a period
estimates of the probability of the ultimate funding and losses related to those credit exposures.
Other than the estimation of the probability of funding, this methodology is very similar to the one we use for determining our ALLL.
We refer you to Note 1 Accounting Policies and Note 3 Asset Quality in the Notes To Consolidated Financial Statements in Item 8 of this Report for further information on certain key asset quality indicators that we use to evaluate our portfolios and establish the allowances.
Table 36: Allowance for Loan and Lease Losses
## Table 3 ##
(a) A portion of the ALLL associated with purchased impaired pooled consumer and residential real estate loans was derecognized on December 31, 2015 due to the change in the derecognition policy for these loans.
The December 31, 2015 ratio of ALLL to total loans was impacted by the derecognition.
For additional information see Note 4 Purchased Loans in the Notes To Consolidated Financial Statements in Item 8 of this Report.
The provision for credit losses decreased to $255 million for 2015 compared to $273 million for 2014 due to improved credit quality.
For 2015, the provision for commercial lending credit losses decreased by $45 million, or 45%, from 2014.
The provision for consumer lending credit losses increased $27 million, or 16%, from 2014.
At December 31, 2015, total ALLL to total nonperforming loans was 128%.
The comparable amount for December 31, 2014 was 133%.
These ratios are 98% and 85%, respectively, when excluding the $.6 billion and $1.2 billion, respectively, of ALLL at December 31, 2015 and December 31, 2014 allocated to consumer loans and lines of credit not secured by residential real estate and purchased impaired loans.
We have excluded consumer loans and lines of credit not secured by real estate as they are charged off after 120 to 180 days past due and not placed on nonperforming status.
Additionally, we have excluded purchased impaired loans as they are considered performing regardless of their delinquency status as interest is accreted in accordance with ASC 310-30 based on the recorded investment balance.
Additional allowance is recorded when the net present value of expected cash flows is lower than the recorded investment balance.
See Table 28 within this Credit Risk Management section for additional information.
The ALLL balance increases or decreases across periods in relation to fluctuating risk factors, including asset quality trends, net charge-offs and changes in aggregate portfolio balances.
The ALLL balance declined $.6 billion, or 18%, as of December 31, 2015 compared to December 31, 2014.
During 2015, the decline was driven by improved asset quality trends, including, but not limited to, delinquency status and improving economic conditions, as well as reduced net charge-offs, coupled with the derecognition of $468 million of ALLL related to purchased impaired pooled consumer and residential real estate loans.
These impacts to ALLL were partially offset by continued portfolio growth over the recent quarters.
See Note 1 Accounting Policies and Note 4 Purchased Loans in the Notes To Consolidated Financial Statements in Item 8 of this Report regarding changes in the ALLL and in the allowance for unfunded loan commitments and letters of credit.
Operational Risk Management Operational risk is the risk of loss resulting from inadequate or failed internal processes or systems, human factors, or external events.
This includes losses that may arise as a result of non-compliance with laws or regulations, failure to fulfill fiduciary responsibilities, as well as litigation or other legal actions.
Operational risk may occur in any of our business activities and manifests itself in various ways, including but not limited to: ?
Transaction processing errors, ?
Unauthorized transactions and fraud by employees or third parties, ?
Material disruption in business activities, ?
System breaches and misuse of sensitive information, ?
Regulatory or governmental actions, fines or penalties, and ?
Significant legal expenses, judgments or settlements.
PNC’s Operational Risk Management is inclusive of Technology Risk Management and Business Continuity Risk.
Enterprise Compliance is responsible for coordinating the compliance risk component of PNC’s Operational Risk framework.
Operational Risk Management focuses on balancing business needs, regulatory expectations and risk management priorities through an adaptive and proactive program that is designed to provide a strong governance

<table><tr><td>Dollars in millions</td><td>December 31 2015</td><td>December 312014</td></tr><tr><td>Nonperforming loans</td><td></td><td></td></tr><tr><td>Total commercial lending</td><td>$545</td><td>$626</td></tr><tr><td>Total consumer lending (a)</td><td>1,581</td><td>1,884</td></tr><tr><td>Total nonperforming loans (b)</td><td>2,126</td><td>2,510</td></tr><tr><td>OREO and foreclosed assets</td><td></td><td></td></tr><tr><td>Other real estate owned (OREO)</td><td>279</td><td>351</td></tr><tr><td>Foreclosed and other assets</td><td>20</td><td>19</td></tr><tr><td>Total OREO and foreclosed assets (c)</td><td>299</td><td>370</td></tr><tr><td>Total nonperforming assets</td><td>$2,425</td><td>$2,880</td></tr><tr><td>Nonperforming loans to total loans</td><td>1.03%</td><td>1.23%</td></tr><tr><td>Nonperforming assets to total loans, OREO and foreclosed assets</td><td>1.17</td><td>1.40</td></tr><tr><td>Nonperforming assets to total assets</td><td>.68</td><td>.83</td></tr><tr><td>Interest on nonperforming loans</td><td></td><td></td></tr><tr><td>Computed on original terms</td><td>115</td><td>125</td></tr><tr><td>Recognized prior to nonperforming status</td><td>22</td><td>25</td></tr></table>
<table><tr><td></td><td colspan="2">Home Equity (b) (c )</td><td>Residential Real Estate (b) (c)</td><td></td></tr><tr><td>December 31, 2014 – in millions</td><td>1st Liens</td><td>2nd Liens</td><td></td><td>Total</td></tr><tr><td>Current estimated LTV ratios (d)</td><td></td><td></td><td></td><td></td></tr><tr><td>Greater than or equal to 125% and updated FICO scores:</td><td></td><td></td><td></td><td></td></tr><tr><td>Greater than 660</td><td>$8</td><td>$243</td><td>$276</td><td>$527</td></tr><tr><td>Less than or equal to 660</td><td>9</td><td>125</td><td>144</td><td>278</td></tr><tr><td>Missing FICO</td><td></td><td>8</td><td>6</td><td>14</td></tr><tr><td>Greater than or equal to 100% to less than 125% and updated FICO scores:</td><td></td><td></td><td></td><td></td></tr><tr><td>Greater than 660</td><td>15</td><td>426</td><td>272</td><td>713</td></tr><tr><td>Less than or equal to 660</td><td>12</td><td>194</td><td>200</td><td>406</td></tr><tr><td>Missing FICO</td><td></td><td>11</td><td>5</td><td>16</td></tr><tr><td>Greater than or equal to 90% to less than 100% and updated FICO scores:</td><td></td><td></td><td></td><td></td></tr><tr><td>Greater than 660</td><td>12</td><td>207</td><td>186</td><td>405</td></tr><tr><td>Less than or equal to 660</td><td>9</td><td>93</td><td>123</td><td>225</td></tr><tr><td>Missing FICO</td><td></td><td>5</td><td>3</td><td>8</td></tr><tr><td>Less than 90% and updated FICO scores:</td><td></td><td></td><td></td><td></td></tr><tr><td>Greater than 660</td><td>102</td><td>339</td><td>626</td><td>1,067</td></tr><tr><td>Less than or equal to 660</td><td>109</td><td>200</td><td>515</td><td>824</td></tr><tr><td>Missing FICO</td><td>1</td><td>12</td><td>15</td><td>28</td></tr><tr><td>Missing LTV and updated FICO scores:</td><td></td><td></td><td></td><td></td></tr><tr><td>Greater than 660</td><td>1</td><td></td><td>14</td><td>15</td></tr><tr><td>Less than or equal to 660</td><td>4</td><td></td><td>10</td><td>14</td></tr><tr><td>Missing FICO</td><td></td><td></td><td>1</td><td>1</td></tr><tr><td>Total home equity and residential real estate loans</td><td>$282</td><td>$1,863</td><td>$2,396</td><td>$4,541</td></tr></table>
<table><tr><td>In millions</td><td>Interest OnlyProduct</td><td>Principal andInterest Product</td></tr><tr><td>2016</td><td>$1,121</td><td>$369</td></tr><tr><td>2017</td><td>2,107</td><td>538</td></tr><tr><td>2018</td><td>927</td><td>734</td></tr><tr><td>2019</td><td>648</td><td>576</td></tr><tr><td>2020 and thereafter</td><td>3,321</td><td>5,758</td></tr><tr><td>Total (a) (b)</td><td>$8,124</td><td>$7,975</td></tr></table>
<table><tr><td>Dollars in millions</td><td>2015</td><td>2014</td></tr><tr><td>January 1</td><td>$3,331</td><td>$3,609</td></tr><tr><td>Total net charge-offs</td><td>-386</td><td>-531</td></tr><tr><td>Provision for credit losses</td><td>255</td><td>273</td></tr><tr><td>Net change in allowance for unfunded loan commitments and letters of credit</td><td>-2</td><td>-17</td></tr><tr><td>Write-offs of purchased impaired loans (a)</td><td>-468</td><td></td></tr><tr><td>Other</td><td>-3</td><td>-3</td></tr><tr><td>December 31</td><td>$2,727</td><td>$3,331</td></tr><tr><td>Net charge-offs to average loans (for the year ended)</td><td>.19%</td><td>.27%</td></tr><tr><td>Allowance for loan and lease losses to total loans (a)</td><td>1.32</td><td>1.63</td></tr><tr><td>Commercial lending net charge-offs</td><td>$-15</td><td>$-55</td></tr><tr><td>Consumer lending net charge-offs</td><td>-371</td><td>-476</td></tr><tr><td>Total net charge-offs</td><td>$-386</td><td>$-531</td></tr><tr><td>Net charge-offs to average loans (for the year ended)</td><td></td><td></td></tr><tr><td>Commercial lending</td><td>.01%</td><td>.04%</td></tr><tr><td>Consumer lending</td><td>.50</td><td>.62</td></tr></table>

Question: What's the average of the Provision for credit losses in the years where Foreclosed and other assets for OREO and foreclosed assets is positive?
Answer: 264