美國銀行 (BAC) 2018 Q4 法說會逐字稿

Good day, everyone, and welcome to the Bank of America Fourth Quarter Earnings Announcement.

(Operator Instructions) Please note this call is being recorded.

It is now my pleasure to turn the conference over to Mr. Lee McEntire.

Please go ahead, sir.

Good morning.

Thanks for joining this morning's call to review our fourth quarter and full year 2018 results.

By now, everybody's, I'm sure, had a chance to review the earnings release documents on our Investor Relations section of bankofamerica.com, our website.

Before I turn the call over to our CEO, Brian Moynihan, let me remind you that we may make forward-looking statements during the call.

After Brian's comments, our CFO, Paul Donofrio, will review the details of the fourth quarter results, then we'll open up for questions.

For further information on our forward-looking statements, please refer to either our earnings release documents, our website or our SEC filings.

With that, take it away, Brian

Good morning, everyone, and thank you for joining us to review our fourth quarter results and 2018 results.

Before Paul walks you through some of the details of the latest quarter, I want to review what our 200,000 teammates produced for you in 2018.

This year, and in fact, this quarter, were continuing examples of how our shareholder model works for you.

So let's start on Slide 2.

We grew the top line a little better than the economy.

We managed costs and risks well.

We invested heavily in our leading capabilities and in our teammates.

And that benefited all of you as we returned almost all of our earnings to you.

Looking at full year results, reported record earnings for our company of $28 billion after tax or $2.61 per share.

Revenue grew a little better than GDP at 3%.

And when discussing the growth rate over 2017, we are increasing 2017 baseline as shown to add back the charges taken to the Tax Act last year.

Our client base has expanded, and in our key business, our market leadership positions continue to improve.

Deposits and loans within our business segments grew a little better than the economy.

We managed expenses well and hit our target in 2018, which we established a few years ago.

In fact, our expenses were down 2% for the year, and that helped achieve 6% operating leverage.

We also believe we managed risk well as net charge-offs remain at decade lows.

Driving these elements allowed us to grow pretax earnings at 15%.

And we used our capital to reduce shares, and that allowed us to grow EPS faster than our earnings growth rate.

And importantly, we believe the same focus on responsible growth with a laser focus on controlling what we can will allow us to continue to improve results for 2019.

As you can see on Slide 3, every line of business contributed to our growth and are well above our company's cost of capital.

And each line of business had superior efficiency through a focus on operating leverage.

I put 3 years on this page so you can see the improvement across the business for multiple years.

This is not a recent phenomenon and will continue in 2019.

We expect to continue to drive incremental improvement in these businesses as we take advantage of our very strong franchise and the continued investments in digitalization and operating efficiency as well as our relationship management capacity and core products and services.

Let me give you a few examples.

In our Consumer Banking, after a decade of simplifying our products, reviewing our focus on primary accounts, transforming our delivery network and driving deeper relationship with our customers, we have seen net new checking accounts growing, and those are growing with the same strong core attributes of our existing book.

Savings accounts and credit cards have seen the same progress.

In our Merrill Edge investment assets, we had a 21% year-over-year increase in funded brokerage assets and $25 billion of net client flows.

In Merrill Lynch, we grew net relationship 4x faster in 2018 than 2017.

We saw a record number of our experienced, $1 million dollar and $5 million producers in the financial adviser population.

In our U.S. Trust team, we grew households by 9% last year.

Andy Sieg and Katy Knox, who've been recently added to my management team, are driving continued successes in these businesses.

Our Commercial and Business Banking continues to build relationships.

Net new relationship additions increased 32% for Global Commercial Banking, our middle market business, and 28% for Business Banking comparing 2018 to 2017.

And when you go into the additional investor side of the house, through our investments in the business, increased balance sheet commitment to our clients, we have seen an expansion in our prime brokerage business.

And as a result, we had a record revenue year in our equities business.

In the fourth quarter alone, we added 70 new clients for our equities steam.

As you turn to Slide 4. One of the drivers of an expansion in our client base is the fruit of multiple years of continuous improvement in our franchise.

These investments have improved the capabilities and processes used to serve our customers.

And we've added this talent and these capabilities without net expense growth.

To enable this investment, we have driven a culture of expense management as we reduced cost significantly over the past 9 years while increasing our customer service scores and capabilities.

This is why, the $30 billion annual reduction in our expense base since 2010.

The team has done great work for you here, accomplishing significant savings to the bottom line, and at the same time, industry-leading investment levels in technology, physical platform and talent.

We face the same inflation and cost challenges everybody faces: Benefit increases, wage increases, real estate cost increases, more investment, everything that we face, and we still hit our 2018 expense target of approximately $53 billion.

And as Paul will reiterate in a bit, we expect that those expenses will remain in that neighborhood for 2019 and 2020.

And this year, our efficiency ratio was at 58%.

These expense reductions and increased revenue and result in substantial operating leverage.

Now take a look at Slide 5. 16 consecutive quarters of operating leverage, every quarter for 4 straight years.

Even in periods of revenue decline, we were able to reduce expenses even more.

During that 4-year period, we have invested $12 billion in new technology initiatives, retooled every single ATM in the company, rehabbed 1,500 branches, built hundreds of new branches, added new administrative facilities and added relationship management and sales teammates.

And we've also shared success with our teammates.

Our shared success program, we announced at the end of '17, we also continued into '18.

The 2 programs combined added over $1 billion to all but the top 5% of our team in annual compensation.

If you go to the next slide, Slide 6, one of the things that helped us deliver these earnings and growth has been the increase in net interest income over the last several years.

Once a while, I get asked by many -- by you, "Did you catch the value of the rate curve normalizing that you told us you would?" The simple answer is yes, and you can see it there.

But we delivered more than that.

On Slide 6, you see the improvement in NII every year since 2015.

NII is up $8 billion in the past 4 years.

But what we often miss here, it wasn't solely driven by higher rates.

It is driven by our business model, a business model which drives strong core deposit growth, coupled with strong pricing discipline.

But it's also not just about deposits.

Driving core NII takes good core loan growth as well, and we can -- and we have seen growth in loans across the business.

This continues to strongly help NII growth.

So you can see these on the right-hand side.

Average deposits grew more than $150 billion over the past 4 years at a 4% compound annual growth there.

Loans in our business grew $140 billion or 6% CAGR over the same 4 years.

But a specific point to demonstrate this.

We have grown consumer checking balances at Bank of America for 40 quarters in a row, a stat our consumer team can be proud of.

And by the way, that was $200 billion in core checking, of balances added, across that decade.

So as we look forward into 2019 and consider debate of whether NII can grow, short-term rate increases, stop or slow, we will drive what we control with loan to deposit growth.

And even in a unchanged rate environment, that should produce more NII.

One of the areas -- other areas for improvement has been a continued increase in the amount of capital we've been able to return to you, our shareholders.

Take a look at Slide 7. As we have increased earnings, we have also increased the return of those earnings in the form of both increased dividends as well as share repurchases.

This quarter, we crossed an important milestone for our team.

Fully diluted shares moved under 10 billion with more than 1.4 billion shares lower than the peak of 2013 and the lowest since 2009.

It's the same great company, has more earnings, more capital, but 14% less shares than the peak, and we see much more ahead.

So we strive to deliver what we control: More customers, more activities from those customers, whether it's loans, whether it's deposits, whether it's assets under management, whether underwriting fees, whether it's trading revenue.

We continue to drive what we control and we control the risk and expenses.

And we do this while driving our competitive advantage through increasing investments in people, technology and [physical plan].

What does that sound like?

It sounds like another year of driving responsible growth.

Now before I ask Paul to dive in the quarter, I wanted to give you -- we all facing a perceived change in the operating environment, with predictions in the year ahead reflecting a range of outcomes from GDP growth in the mid 2s, to lower growth, to recession.

I wanted to give you two perspectives, one from our research team; and the second, from what we see in our client base.

Let's first focus on the views of our research team, one of the best there is.

United States economy, largest in the world, grew at a rate -- the highest rate in a decade-long recovery in 2018.

We still have low inflation; rising wages; low unemployment; and despite the increases in rates, interest rates remain at all-time lows.

Our research team predicts economic growth to be lower in 2019 than it was in 2018 as do the general economic community.

However it is true, these estimates still point to solid growth.

For 2019, our research team has global GDP growth at 3.5%.

And the research team has the U.S. GDP growth at 2.5%, which is higher than any but 1 year in the last 7.

But the second view is -- our view is through our customers, and this strongly supports a solid growth view.

In our consumer business, we processed in 2018 more than $2.5 trillion in consumer payments and cash consumption.

That's a large sample of the U.S. GDP.

That data shows that the consumer spending was 8.5% higher for all of 2018 and 2017.

That growth rate remained solid in December and January even as comparables are increasing due to strong growth in the end of '17 and early '18.

We also see a lot of credit flows as one of the larger commercial and consumer lenders in the United States.

Those flows are solid, reflecting customer confidence, responsible borrowing and lending.

We talk to a lot of clients, we serve a lot of clients.

We monitor their asset quality, we've seen it remain strong as net loss ratios are at record lows.

We see no problems in the near-term horizon, expect charge-offs to remain around $1 billion or so for the rest of '19.

We also see those companies as healthy, making more money, continuing to invest.

Our small business clients remain optimistic, our most recent survey shows that.

The geopolitical comment, however, affects all of us.

It provides a backdrop of uncertainty.

Trade wars, government shutdown, China slowdown, EU slowdown, Brexit, you name it, both here and abroad, impact people's economic growth outlook.

We are mindful of those potential impacts, but we see in the U.S. strong indications of continued growth due to the benisons we have here in our economy.

So given the slowdown predicted, does not enervate us, it invigorates us.

We look forward to continue to produce strong results in 2019 by driving responsible growth.

With that, let me turn it over to Paul.

Thanks, Brian.

I'm starting on Slide 8 and referring to the highlights on Slide 9 as well.

Bank of America reported net income of $7.3 billion or $0.70 per diluted share.

As you recall, Q4 '17 included significant charges for the Tax Act.

All the year-over-year results that I will review adjust for those charges.

On that adjusted basis, comparing Q4 '18 to Q4 '17, we grew revenue 6%; pretax earnings, 22%; net income by 39%; and with a 6% reduction in shares, EPS by 49%.

This growth was driven by 7% operating leverage and strong asset quality.

The effective tax rate of 16% for the quarter included a net tax benefit of approximately $200 million related to a few items.

The benefit was driven by updated tax guidance with respect to the Tax Act and international earnings.

This benefit was partially offset by charges related to a variety of other tax matters.

Year-over-year, return on assets and equity improved significantly.

Turning to the balance sheet on Slide 10.

Overall, compared to the end of Q3, the balance sheet grew $16 billion, driven by commercial loan growth.

Liquidity remained strong with average global liquidity sources of $544 billion and all liquidity metrics remain well above requirements.

Long term debt declined $5 billion with maturities outpacing issuances.

We are comfortably in compliance with the TLAC rules that became effective in January, especially in light in the recent reduction in our Method I G-SIB.

Given our robust funding levels, we expect our parent debt issuances in 2019 will likely be less than maturities.

Total shareholder equity increased $3 billion from Q3 as AOCI benefited from increases in the value of our AFS debt securities given the decline in long-end rates.

We returned 95% of net income available to common or $6.7 billion through the combination of dividends and share repurchases in the quarter.

Turning to regulatory metrics.

Our CET1 standardized ratio improved 22 basis points to 11.6% from Q3 and remains well above our 9.5% requirement.

The improvement was driven by the increase in AOCI that I just mentioned, combined with a modest decline in RWA.

RWA declined, was driven by lower global markets RWA and the sale of noncore consumer loans, which offset the impact of loan growth across the businesses.

Looking at deposits on Slide 11.

Overall, average deposits grew 4% year-over-year.

A decline in non-interest-bearing deposits was isolated to mix shifts in Global Banking, given the interest rate environment.

While interest-bearing grew across every segment.

Consumer Banking deposits grew 3% as non-interest-bearing and low-interest checking, which account for over half of Consumer Banking deposits, grew 7%.

While the aggregate of money market accounts, savings and CDs were flat.

GWIM also grew deposits 3% year-over-year.

GWIM's deposit balances benefited from market volatilities as customers moved from investments to cash.

We also simplified client account structures for clients, which moved funds from off balance sheet sweep accounts to deposits.

Global Banking deposits continue to grow well, up 9% year-over-year, reflecting the investments we have made in client-facing bankers and global treasury services capabilities.

Also as mentioned earlier, in Global Banking, we saw expected rotation from non-interest-bearing to interest-bearing deposits.

Turning to Slide 12, total loans.

On an average basis, we're $935 billion (corrected by company after the call).

Total loan growth continued to be impacted by the runoff and sales of noncore consumer real estate loans.

Near the end of the quarter and similar to last quarter, we sold a portfolio of mostly noncore consumer real estate loans with a book value of $5 billion, recording a small gain.

Focusing on loans and our business segments, they were up $25 billion or 3% year-over-year.

Consumer loans grew 4% year-over-year, led by mortgage and to a lesser degree, consumer credit card.

Commercial loans grew 2% year-over-year.

As you think about starting loan levels for the new year, note that towards the end of the quarter, we originated several large, primarily investment-grade financings, which resulted in loans ending the quarter $13 billion higher than the average for the quarter.

While we would not call this a trend, we were pleased with the late-quarter growth.

Turning to Slide 13.

Net interest income on a GAAP, non-FTE, was $12.3 billion or $12.5 billion on an FTE basis.

Compared with Q4 '17, GAAP NII was up $842 million or 7%.

The improvement was driven by the value of our deposits as interest rates rose as well as loan and deposit growth and was partially offset by higher funding cost in Global Markets and lower loan spreads.

On a linked-quarter basis, GAAP NII was up $434 million.

Linked-quarter growth reflects the benefit of the September rate hike, loan and deposit growth and lower long-term debt expense.

Net interest yield of 2.48% improved 9 basis points year-over-year and 6 basis points linked-quarter.

Strong improvement in our core banking activities was partially offset by the impact of lower yield in Global Markets assets.

Including our Global Market segment, which primarily reflects our trading-related assets, NII from core banking activities grew almost $1 billion year-over-year or 9%.

The net interest yield on that same basis crossed 3% and is up 14 basis points year-over-year, driven by broad improvement in asset yields relative to funding costs.

Average rate paid on interest-bearing deposits of 67 basis points rose 12 basis points from Q3 and is up 56 basis points versus Q4 '15, which was the beginning of this Fed rate hike cycle.

Turning to asset sensitivity.

As of 12/31, an instantaneous 100 basis point parallel increase in rates above the forward curve is estimated to increase NII by $2.7 billion over the subsequent 12 months.

The decrease since the end of September reflects the continued shift in Global Banking deposits to interest-bearing as well as modestly higher Global Banking pass-through rates.

Note that the short end represents approximately 75% of this sensitivity.

As you look forward to 2019, keep in mind, Q1 has 2 less days of interest accrual, which will negatively impact NII by about $200 million.

Turning to expenses on Slide 14.

We finished the year with another solid quarter of expense management.

Compared to Q4 '17, non-interest expense of $13.1 billion was down 1%, continuing our quarterly string of year-over-year improvements.

On a linked-quarter basis, expenses were flat as lower FDIC insurance costs were offset by a couple of increases.

First, we increased marketing in a few areas, including an investment to reposition our brand.

And second, in October, we announced another shared success bonus covering 95% of our teammates.

Despite these late-year investments, we reported full year expenses in line with our target which was established in the middle of 2016, and our efficiency ratio improved to 58%.

As we look ahead to 2019, we believe our full year expenses should approximate the 2018 expense level.

This expense level includes approximately $1 billion for increased spending in the aggregate in several areas: Normal yearly merit; health care benefits, primarily from inflation; marketing; and the previously announced new investment initiative spending in technology as well as expansion and modernization of financial centers.

On a full year basis, we believe we should be able to offset these investments through lower FDIC insurance and other efficiencies.

With respect to Q1, note that expenses seasonally increase compared to Q4.

In addition to any increase related to seasonal revenue in Q1, we anticipate that Q1 expense will be higher than Q4 '18 by approximately $500 million due to seasonal personnel costs, mostly payroll tax.

We expect expenses should trend lower than Q1 through the remaining quarters of 2019.

Turning to asset quality on Slide 15.

Asset quality continued to performed very well.

Total net charge-offs were $924 million, lower than both the prior quarter and the year ago quarter.

The net charge-off ratio declined to 39 basis points as losses declined while loans grew.

Provision expense of $905 million more closely matched losses this quarter as we had a modest $19 million net reserve release.

On Slide 16, we break out credit quality metrics for both our consumer and commercial portfolios.

The only thing I would note here is with respect to consumer seasoning drove credit card losses modestly higher, but the loss ratio remained below 3%.

Okay.

Turning to the business segments and starting with the Consumer Banking on Slide 17.

Q4 finished a strong year, generating $12 billion in full year earnings.

In Q4, earnings grew 52% year-over-year to $3.3 billion.

We created more than 1,000 basis of operating leverage this quarter as revenue grew 10% while expenses were held flat.

The all-in cost of running the deposit franchise was 159 basis points this quarter, which includes both the cost of deposits at 152 basis points and the average rate paid of 7 basis points.

This total cost ratio declined from 165 basis points in Q4 '17.

The efficiency ratio improved nearly 500 basis points year-over-year to 45%.

Credit costs showed a modest increase, but remained low.

As reviewed earlier, we grew Consumer Banking deposits 3% year-over-year and the percentage of checking accounts that are now the primary account of a household increased to 91%.

Consumer payments increased 7% year-over-year.

Lending was also solid, growing 5% year-over-year.

And Merrill Edge brokerage assets ended the quarter up $9 billion versus year-end 2017 as a $16 billion decline, driven by market valuations, masked strong client flows of $25 billion for the full year.

And customer activity in the quarter remained solid across all major product categories.

Turning to Slide 18.

You can see that 10% revenue growth was driven by NII as we realized the value of our deposits through our focused on relationship deepening.

You will also note noninterest income improved year-over-year from account growth and higher levels of consumer spending.

We experienced modest improvement in card income and service charges.

As discussed previously, to promote relationship deepening, we reduce certain fees and we provide rewards and offer discounts when customers do more with us.

This may reduce fees, but overall, drives revenue growth, especially NII.

We believe this approach to customers, combined with our leading capabilities, has produced superior deposit growth relative to the industry average.

We also believe it is driving customer satisfaction improvement, which is at an all-time high.

And given expense declines, it's important to note the significant platform enhancements accomplished in the first half -- excuse me, in the second half of 2018.

We expanded in 26 new and existing markets in 2018.

That included opening 81 new centers and renovating more than 500.

All our financial centers are now equipped with Wi-Fi.

Turning to digital trends on Slide 19, just a couple of things to highlight.

Mobile users continued to grow, crossing over 26 million.

We processed more than $2.5 trillion in total payments in 2018 and we saw digital, as a percentage of all payments, continue to grow in 2018, lowering costs, reducing errors and improving customer convenience.

Mobile and ATM now account for more than 3/4 of deposit transactions.

And mobile, with all its benefits for our customers and our shareholders, is now approaching half of all digital sales.

Turning to Global Wealth and Investment Management on Slide 20.

GWIM produce another quarter of strong results, delivering client flows totaling $35 billion, one of the best quarters of client flows in the company's history, which is partially due to growth in net new households.

Net income of more than $1 billion was the best quarter ever for this segment, growing 43% year-over-year.

Pretax income was up 18% and our pretax margin improved to nearly 29%.

The business created more than 400 basis points of operating leverage, growing revenues 7% while holding expense growth to 2%.

Revenue included solid growth in NII and noninterest income, overcoming some of the negative impacts of a decline in the financial markets early in the quarter.

Asset management fees were up 3% versus Q4 '17, driven by a solid year of AUM flows but were mitigated by a decline in brokerage fees.

Revenue also included a roughly $100 million benefit from the sale of a noncore asset associated with indices sublicensing.

It's important to note, as you look at 2019, that the December drop in the equity markets doesn't actually impact AUM fees until Q1 '19 due to the 1-month lag in the determination of fees for assets under management.

Moving to Slide 21.

Trends reflected strong client engagement in Merrill Lynch and U.S. Trust.

Strong household growth and continued near-record-low attrition of experienced financial advisors contributed to the $35 billion in overall client flows this quarter.

AUM outflows in the quarter reflected market volatility, which impacted some clients' preferences versus cash and deposits.

At the same time, we had $17 billion of positive brokerage flows, which is a record.

We saw many of our new households begin their investment -- investing relationship with us through a new brokerage account.

On the banking side, we had deposit flows of $21 billion as some investors increased their allocation of cash.

And ending loan balances grew $3 billion.

Turning to Slide 22.

Global Banking earned $2.1 billion and generated a 20% return on allocated capital.

Global Banking achieved several records this quarter across revenue, net income, loan levels and deposit levels.

Earnings were up 25% from Q4 '17, driven by operating leverage and tax rate benefits.

Revenue of $5.1 billion and pretax earnings of $2.8 billion were both up modestly year-over-year.

But this growth is understated, given the impact of the Tax Act on tax-advantaged investments in Q4 '18 versus Q4 '17.

Revenue was led by 4% growth in NII from strong deposit growth and higher rate, but was offset by the small decline in investment banking fees.

The business created operating leverage as expense declined 2% versus Q4 '17.

Efficiency savings and lower deposit insurance costs more than offset continued investment in the business.

Looking at trends on Slide 23 and comparing to Q4 last year.

Since we already covered loan and deposits, I'll start with IB fees.

IB fees of $1.3 billion for the overall firm decreased 5% year-over-year.

For context, note the overall industry fee pool declined 13% from last year.

Compared to Q4 '17, modestly improved M&A fees only partially offset a decline in underwriting fees, given the significant weakness in financing fee pools as corporations and other participants assessed significant market volatility late in the quarter.

Switching to Global Markets on Slide 24.

I will talk about the results excluding DVA.

Global Markets produced roughly $450 million of earnings in a tough quarter where market volatility increased and credit spreads widened.

FICC and equity financial performance diverged, with equity achieving record revenue.

Overall revenue declined 10% compared to Q4 '17 while expenses declined 3%.

Q4 '17 revenue included a small gain from the sale of a noncore asset.

Sales and trading declined 6% year-over-year to $2.5 billion.

FICC declined at 15% while equities grew 11%.

FICC's lower revenue was due to weakness in credit and mortgage markets and lower client activity in credit products.

On the other hand, equities benefited.

Market volatility led to increased client activity, producing revenue and improvements in both derivatives and in client financing activities where we had been recently investing.

On Slide 25, I would just point out the chart on the bottom left, which shows, at roughly $13 billion in full year revenues, the relative stability of sales and trading revenue over the past 3 years.

It also shows the stability and benefit that comes from a full and diverse set of client solutions as growth in equity revenue has made up for the decline in FICC revenue.

On Slide 26, we show all other, which reported net income of $279 million.

Comparisons against the prior year are impacted by the charges in Q4 '17 associated with the Tax Act, which reduced revenue by $946 million and increased tax expense by $1.9 billion.

As I mentioned earlier, Q4 '18 included a $200 million net tax benefit.

Expenses improved $71 million year-over-year.

Okay.

Let me close with a couple of thoughts.

Q4 was a solid finish to a record year of earnings.

We controlled our costs well and invested in the future.

Asset quality remains excellent.

Our balance sheet is strong and we returned more earnings to shareholders.

And while the market may now believe interest rate hikes have stopped, we believe we can grow net interest income without rate hikes, assuming modest levels of loan and deposit growth.

With regard to things that are more in our control.

Because of all the hard work our employees are doing to eliminate duplicative work and root out inefficiencies, we expect expense in 2019 to be roughly the same as 2018.

And as Brian said, we also don't expect any meaningful change in net charge-offs in 2019, based on our years of responsible growth and our view of the credit horizon.

So we enter 2019 positively with a strong balance sheet and market share in businesses that positions us well for better earnings again in 2019.

Thanks for listening, and with that, let's open it up to questions.

(Operator Instructions) We'll take our first question from John McDonald with Bernstein.

Was wondering, on the loan growth front, what you saw this quarter in terms of demand trends.

You mentioned in commercial, you saw the late-quarter pick up.

Wondering if you attribute that to capital markets weakening.

But underneath that, how's the core commercial demand?

And overall, how are you feeling about loan growth prospects heading into 2019?

You still thinking about GDP, GDP-plus a little bit as you think about responsible growth in '19.

Yes, we did see some late-quarter pick up in loans and Global Banking.

I'm not sure I can attribute it to the shutdown that we saw in the quarter in parts of the debt markets from a bond perspective, but I wouldn't be surprised if some of that pickup was from that.

In terms of loan growth, in our consumer and GWIM segments, loan growth really continues to be solid and well within our expectations.

As I said, consumer grew 5% year-over-year; GWIM grew 4%, which importantly, is better than economic growth.

In Global Banking, loan growth in Q4 was more subdued, but that's also consistent with industry data, year-over-year, loans grew 2%.

I guess I would say that we think there are at least 2 factors impacting corporate clients.

First, tax reform has increased cash flow and repatriation has also increased cash available for debt paydowns.

But having said all that, our near-term expectations for loan growth are unchanged.

We still expect total loan growth to be in the low single digits and growth in our business segments should be in -- should be at mid-single digits.

Maybe, depending on economic growth, on the low end of mid-single-digits, but we're still -- think we can achieve mid-single digits.

Okay, great.

And Paul, just a follow-up in terms of deposit pricing.

What are your baseline expectations?

You've been able to hold deposit pricing very nicely while growing.

What are your baseline expectations for deposit pricing if the Fed does slow?

And just to clarify, your NII outlook as you go into the first quarter, what kind of offsets might you have to the day count headwind in terms of deposit growth and pricing?

Let's start with the NII outlook for Q1.

The December rate hike and loan and deposit growth are clearly tailwinds, and we just think they will be offset by 2 less trading days.

I mean, I -- that's the best perspective I can give you.

In terms of where do rates go from here, look, I think Bank of America, and indeed, the rest of the industry really haven't increased deposit pricing on traditional bank accounts appreciably.

And I think, again, as we've said in many times, I think at least for Bank of America, we deliver a lot of value to depositors between transparency, convenience, safety, mobile banking, online banking, our nationwide network of financial centers, the rewards we give our clients, the advice and counsel.

All that value, I think, has helped us keep deposit rates relatively flat in traditional retail accounts.

But again, we have been raising rates in accounts in GWIM and in Global Banking.

So we pass a lot of value through in the form of higher deposits to those clients.

At some point, the broader retail rates will rise, we just don't know when.

So I think we're just going to have to wait and see.

And we'll take our next question from Mike Mayo with Wells Fargo.

Can you elaborate more on the checking deposit balance growth over the last year?

It's up, what, 7% or 8%.

And I really want to get to the why.

And Brian, I know you always say that you have good team members and everything else, but how much of that growth is due to mobile banking and digital banking?

And of that component, how much would be due to millennials?

So just to -- Mike, to put it in perspective, I think we had $20-odd billion of third -- fourth quarter '17 to fourth quarter '18 checking account growth in consumer.

We actually -- as I said earlier, we have been in a decade-long repurposing of that business, including focusing on primary accounts.

So we're at 91% primary accounts.

Accounts we add are accretive and solid.

The average balance per account continues to grow.

The satisfaction in that business hit an all-time high across the board in terms of customer delight.

So it's good performance, it's strong performance.

But the key among all that is, basically, we are net growing checking accounts a few hundred thousand a year for the last couple of years, which we hadn't been for the last 8 or 9 years as we repositioned the old product lines and did all the consolidations, even sold some branches, you're well aware.

To go to your question on millennials.

There are 50 million households in consumer; 36 million digital households; 26 million mobile households.

There are not enough millennials to meet those statistics.

So this is a broad-based change going on.

And whether it's people 80 years old, 70 years old, 60 years old, the way people use the capabilities that we have built for them is across the board.

So any technology adoption, people often attribute to millennials, but when you think about that kind of penetration of digital practice, 1.5 billion log-ins a quarter, you have 77% of the checks deposited not at the branch, i.e.

through ATMs and mobile deposits, you just don't have enough millennials to go around.

So this is a broad-based trend that we've been driving.

And over the 10 years I talked about earlier, we had 6,100 branches, we have 4,200 branches.

We have grown checking balances.

It just isn't enough millennials to make that happen.

So it's a broad-based thing.

I'll give you a -- this quarter, we crossed 5 million Zelle users, 5 million Erica users.

Now remember, Erica is not even a year old.

And 5 million Preferred Rewards customers who have brought their total relationship to get the benefits.

That is what's driving this -- the checking growth, because you get -- if your bring all your relationships through the reward programs we have that are integrated across all products, not just card products, that provides a good benefit.

And so it's tremendous operating leverage, as Paul mentioned some statistics in costs.

It's tremendous client delight, it's tremendous capability, tremendous efficiency.

It is broad-based.

I mean, it's not -- it's -- millennials would score higher on something like Erica, but that would be expected.

Long term, it'll be broadly adopted in our franchise.

Great.

One follow up, if I could.

I've asked it before, but what is your market share of digital banking users?

Or at least, how much of that checking account growth over the last year is due to digital banking?

It's always hard to -- market share in consumer deposits, we think, is around, I don't know, 13%, 14%, 15%, depending on what you calculate, Mike, and it's growing.

And if you look in the top 30 markets, 30 or 40 markets that we play in across the country, excuse me.

You can see that if you just follow the FDIC data, you can see our deposit base continuing to grow.

So would it skew a little bit that way?

Sure, because younger people are opening up their relationships.

I'd say that -- it's a little -- if you look at it, the mobile adoption, just to give you a sense, millennials are about 80-plus percent, Gen Xs are 72% and boomers are 50-plus.

So it's across the board.

Our next question comes from Glenn Schorr with Evercore.

So the ROA and the ROTCE came in well above where I think a lot of us might have filled out a few years ago.

So I know credit's going to pick up someday, but I heard you loud and clear that the economy's good; credit, you expect flat; expenses, you expect flat, and you've seen some modest growth.

All that points towards -- while you shrink the share count, there's a lot better profitability.

So I'm just looking for your thoughts around where are the bounds of where ROA and ROTCE can go, because we're in good and uncharted territory here.

I'm not sure I'd agree -- I agree with everything you said until the very last part, Glenn, when you said good and uncharted.

I mean, this is -- the ROAs are solid and the -- if you think about it, 100 basis points plus, 100 a quarter, those are getting the numbers which are solid performance, the ROTCE.

So we had -- because of tax reform, those all moved up.

We moved that up to a higher level now.

And you're seeing us run at a rate which we'd expect to continue with the economy growing couple percent.

If the economy shrinks or something, that's a different question.

But we'd sort of stake that this model, all the things you cited in your opening to your question, is the model, right?

Which is grow revenue a little faster than the economy, keep the expenses flat, keep the credit risk in check and drive that operating leverage and bring the share count down.

So you're saying what we're doing, and I just -- I'm not sure the returns will incrementally move up.

There is a fundamental resetting, obviously, through not only the operating performance, but the tax reform, but now they're growing forward a little bit, but they will be in that range, 14%, 15%, 16% return on tangible common equity, then maybe move up higher than that on a given quarter.

But I think we're in a solid place right now.

I appreciate it.

Maybe one question on markets particularly.

I'll overgeneralize there, too.

Spreads widen out and the market does what it does.

Volatility becomes bad for a little while when happens quickly in fixed income, as we saw.

I know it's early, but spreads have tightened, liquidity's improved, markets are [indeed thawing].

Directionally, can you recoup what was lost without putting numbers on it, and -- if markets normalize?

In other words, in the old days, the opposite would happen.

Spreads tightened up and flows pick up and you can have great market environments.

Like, is anything changed from the past?

Yes.

I think the simple way to put it, it's all of 2 weeks into the quarter or whatever, is that it's -- we've seen the normal progression that you see from the fourth quarter to the first quarter.

And it's solid out there right now and the equities business stronger as we've referenced earlier.

But and all the thesis you had are all pieces of it, but overall, our trading revenue has been fairly consistent every year.

It came about it every quarter and every year differently, but it's basically been $13-odd billion sort of year after year after year, with a range -- I think a total range of $500 million, $600 million, $700 million, just to give you a sense.

I don't have numbers right in front of me.

So the model is a moving model.

And so there's not a lot of markdowns, markup stuff which you would have seen more in '08, '09.

All the stuff's marked to moving through at 100 miles per hour.

There's no storage going on.

So we've seen a recovery in the activity with the clients, that's good news.

And you've probably seen it with your clients, and that's been good.

So you've seen that pick up.

But let's -- we got to get through some things in the atmosphere out there to make sure that sustains for the quarter.

Okay.

A tiny, little follow-up on that is the average trading assets ticked up the last couple of years and your capital base improved.

You put up good results, so the VaR is going down while it's going.

Is there anything in that pick up in the trading-related assets that was just year-end parking as opposed to just bigger debt?

Remember, the team in equities, Fab Gallo and the team, they had to retool a lot of the platform, put a lot of technology in.

About 24 months ago, Tom Montag and the team said they're ready to start really pushing our capabilities out in the market.

And as I said earlier, we got 70 new clients in the fourth quarter in our equities business.

So the balance sheet growth has been in support of the equities business.

And it's -- remember, it's very low risk, very low RWA, but that's been fairly consistent build over time.

It will ebb and flow a little bit by market value because of the way it works.

But it's really because the equities business is, with the investments we made in technology and capabilities, have now out turned out into providing balance sheet capacity and capability as a prime brokerage business.

We'll take our next question from Betsy Graseck with Morgan Stanley.

A couple of questions.

One is, just a question on how you expect to be managing in the event that the downside happens.

So what if some of the negative things pan out and revenues come in a little bit lighter?

Can you talk through where you have expense leverage, if you have any, or do you keep the expenses flat in a tougher environment?

I think assuming an environment of -- with the GDP decline is, I think, what the base of your question is, you would obviously, probably, see a market decline.

That will bring incentive-related compensation down, that instantaneously happens.

And frankly, if we're not earning as much, that's obviously an outcome.

And so there would be those types of things.

We can always choose not to invest, but I think if you looked at what we're investing, then you'd say, "Keep going." Honestly, as a shareholder, it would be the better answer for the company because the technology investments allow us to take long-term expenses down and things like that.

So yes, there's always levers you can pull.

But that's -- the business model we've been operating for many years now has been to constantly be pulling those levers with time that allows you to manage the company much more carefully and allows attrition to be your friend in terms of headcount.

But the key is to just keep driving that operating leverage.

So if revenues flatten, you got to get the expenses down a little bit to make it all work and keep it positive, and we're focused on it.

So we'll see what happens.

We'll see -- you have to kind of have the -- what the constituent parts of the backdrop are.

But mechanically, some of the expenses come down just due to pure revenue-related incentives.

Got it.

So even if the revenue environment is a little weaker, you think you can generate positive operating leverage.

Well, we've been able to do it.

And if you look in the -- go back and look at that chart on quarterly operating leverage, it has come in quarters where revenue fell.

And so that -- and that's the -- the key is, it may not be as big, in other words, the net operating leverage, but the culture we built in this company to operating excellence and simplify and improve and the idea generation, worked through 4,200 ideas over the last 4 or 5 years.

We're continuing to generate them.

We're looking at every single process and taking apart, mapping and understanding, understand how data flows, how we can automate it.

And it's very incremental.

Those are not huge, spend $1 billion and see if works.

We add them all up.

We do spend $1 billion, but it's a bunch of small projects.

So those are always moving down into our benefit as we move through it.

And so I think if you look at that operating leverage, yes, if revenues were flat, just say, because say of whatever's going on up there, we should be able to manage expenses in underneath it.

And then could you speak a little bit that investment spend that you're making in the Investment Bank?

And in particular, in which geographies you're really looking to increase your market share.

Right.

I think the U.S. being the biggest fee pool as people talk about it, by far, we continue to do that.

We feel pretty good about the team we have.

In Asia, we feel -- in Europe, we're going to add some there.

But the real key is to cover deeper in the client base.

Outside the United States, we cover the largest companies in the world, the largest investors in the world.

Inside the United States, because of the nature of the business, we cover from small businesses all the way through the largest companies.

And the piece that we probably gave up coverage on that we got to go back in is sort of the upper end of the middle market in a broader base.

And so we're adding resources, middle market investment bankers that work with Alastair Borthwick's team, on Matthew Koder's team, working with them to drive it.

We're adding more coverage, deeper in the industry groups.

And so it's a broadening out of the U.S. will be the -- in North America will be the biggest sort of explicit build you'll see.

But a lot of it is just filling in the cracks and making sure that we got that coverage really owned from -- in the United States, from the smallest company to the largest company for all their capital markets needs and M&A needs.

And then outside, it's really picking our industries and are fine-tuning, which we've done.

We'll take our next question from Steven Chubak with Wolfe Research.

So wanted to start off with a question on capital return.

Capital ratios ended the year flat versus 4Q '17.

It stands at an impressive 11.6%.

I think it's fair to say that you're currently operating with substantial levels of excess capital.

And just given your strong track record in the stress test, as we look to benchmark against how much capital return you could support or what you're sufficiently comfortable with.

You did 96%, I think that was the number that was cited in the prepared remarks.

Are you in a position at this point, especially given some of the recent decline in the share price, to take full advantage and maybe exceed 100% payout in the coming stress test cycle?

Okay.

Well, look.

Let me just start off in a couple of level-setting points.

The -- we clearly, as everyone has seen, been growing our capital returned to shareholders consistently for many years now.

So that's one point.

We increased our dividend 25% last year.

We increased our buybacks by $8 billion.

And last year, when you put that all together, based upon what we submitted, we were at 100% payout -- a little over 100% payout ratio.

If you look at our CCAR results, which you alluded to, we did have a significant cushion using the Fed's results.

Considering, I guess, the severity of last year's scenario, as you point out, our capital cushion, we would hope, expect, to have room to, at a minimum, sustain that payout ratio, if not increase it.

But we got to see the scenario first.

That's the one caveat.

Understood.

And just one follow up on some of the remarks relating to TLAC.

Increased issuance of TLAC-eligible debt, while this is maybe an underappreciated fact, it's been a substantial dampener of NII expansion over the last few years.

And Paul, assuming you update us on where that ratio sits today.

Just trying to get -- and whether there's a target level that you're thinking about.

I'm just trying to gauge what the opportunity is to optimize that TLAC ratio.

How we could think about a substantial -- the potential benefit from replacing that with cheaper deposit funding.

Yes.

We are not disclosing what our TLAC ratio is, but I will say that as we sit here today, we have a comfortable cushion.

And as you also heard in my prepared remarks, the debt issuances this year are going to be -- likely to be less than maturities.

Okay, looking forward to more updates in the future.

Just one final follow-up from me on credit loss expectations.

Brian, you made an interesting remark at a conference recently in December, noting that you expect through-the-cycle loss expectations to come in well below 90 basis points.

But at the same time, didn't really commit to an explicit level or expectation.

And given the late cycle rhetoric, the focus on -- particularly from long-onlys, with longer horizons, as to what through-the-cycle loss expectations might be.

And all the balance sheet cleansing you accomplished, I was wondering if you can maybe provide us with some sort of benchmark or target expectation that we can compare you guys against versus peers, just given many have provided at least medium-term or through-the-cycle loss expectations already.

Earlier, I said what I expected for '19, charge-offs in the range of where they are kind of now.

The point that I think we were talking about at the conference is around the construction of the portfolio versus what they were last cycle -- for this cycle for us.

We had a $250 billion unsecured consumer credit card and other types of unsecured debt.

So just sheer volume, that is completely different.

And that took, frankly, a lot of work to get us repositioned to where we have it.

So just using that example, and if you look at charge-offs, go back in 2010, I think there were $30-odd billion dollars in the year, and big part of it was credit card and related unsecured debt, restructured credit card loans.

That was due to the fact in the mid 2000s, with the best data analytics, the best underwriting team in the business, we were underwriting with a 5% charge off expectation in a good economy.

And it turned out to be a bad economy and it turned out to be consumer-led problem, and that led to much higher charge-offs.

So you can then run that same story through home equities and other things.

And so if you look at the size of the consumer book, it's much smaller.

Then you turn -- flip it over talk about the quality of the underwriting.

So now our expectations are 3.5%, 4% charge-off rate in a 7%, 8% unemployment type levels versus five 5%, 6% before and moving on beyond there.

So you both the rate and the volume question on home equity, in unsecured consumer credit, that is much different.

And then you go to mortgage, same story.

Then you flip over to commercial credit, and we've always had wonderful commercial credit experience.

Go back the '90s, the mid-late '90s through the fallen angel crisis, go back through the last crisis, and we underwrite commercial credit, I think, better than anybody in the business.

And yet, we still have balance there and you see us -- the ray of risk is across the board.

We've managed the limits at the industry level, at the country level and all that stuff.

And so we expect the outcome to even be better than it was last time there.

And we watch the SNC and all the different things that give us that comfort.

And then -- but the real acid test is look at the stress test.

And so if you look at the stress test and say, "Under that scenario with no preparation, no ability to change during that 9 quarters," if you look at card, if I remember right off the top of my head, I think the total charge-offs for the -- for 9 quarters are around -- I don't know, 11%, 12%, something like.

If you de-annualized that, you think of that -- under that scenario, of unemployment going 4-ish to the pace it goes up, and you end up with about a 5% to 6% per year, a 5% per year.

That just shows the difference in the underlying quality.

But it was a conscious effort to give up a lot of revenue to get the company more balanced, so that through a crisis, it would perform completely different.

All that, I'm not going to give you a target because you -- I don't have the scenario I'm giving that target, but it will be much better than the last time.

I know it's difficult to target.

Very helpful color.

Our next question is from Matt O'Connor with Deutsche Bank.

I was wondering if you could talk about just your thoughts on managing interest rate risk, given the drop in most parts of the curve, lowered expectations for future short hikes, and then maybe specifically, the securities book.

Is it worth kind of reinvesting proceeds into securities?

Or do you keep it shorter, hoping for a backup in rates?

So first thing to think about as we look at that securities book, we're always, always, always balancing earnings against capital and liquidity.

That's dynamic process that happens daily, certainly weekly.

We don't take any credit risk in that investment portfolio.

That's the other thing I always like to stress when we talk about it.

So we're -- we look at it and we're always sort of trying to figure out whether we should do a little bit more of this or a little bit less of that.

If you looked at this quarter, by the way, we did -- we have a little bit less sitting at the Fed because we did some overnight, very high-quality reverse repo because the yields were just higher.

So yes, we're looking at it.

We look at it all the time.

And I guess from a NIM percent perspective, I realize there's some puts and takes specifically with the trading book.

But in a stable rate environment, you did mention you can grow the net interest income dollars.

Can you get ability in NIM?

So should we really think about it as the NII meeting driven by balance sheet?

Or is there some risk that the NIM erodes a little bit in a stable rate environment?

We look at it.

I mean, if you look at Q1, I would expect NIM to edge up a little bit driven by loan growth funded by low-cost deposits.

Longer term, NIM's really going to depend on the forward curve and our ability to lag deposit rate paid.

Okay.

And then just separately, if I could squeeze in.

Did you guys comment on the tax rate for 2019?

Sorry if I missed that.

Yes, we're -- I don't think we did, actually.

We were expecting an effective tax rate for 2019 of approximately 19%, absent unusual items.

Our next question is from Jim Mitchell with Buckingham Research.

Maybe if you could just talk a little bit about leveraged lending risk, how you think about it, how you manage it.

Obviously, that's been a big topic lately, given the freezing of the markets in December in particular.

Just your thoughts, I guess, from here around your own book and maybe the industry.

Sure.

So the first thing I would say is, look, we're staying focused and have been focused on responsible growth.

So we're maintaining underwriting standards and we're staying within, and have now for years, stayed within our portfolio limits.

Our exposure to leveraged lending is primarily through underwriting and distributing leveraged loans.

We have very little, for example, CLO exposure at the company because as I just pointed out, we don't hold that kind of risk in our investment portfolio.

Having said that, leveraged finance is a very important part of our franchise.

And if it's done well, it supports economic growth.

Our leveraged finance franchise does well over $1 billion.

So nothing's really changed for us.

If you're going to be in this business, if you're going to be a leader in this business as we are, you've got to be there when the market's good and when the market's not, and we are.

But we're doing it our way, sticking to our standards.

And how do you manage sort of size, getting -- just any thoughts?

And have you taken down the amount you're willing to put on the balance sheet, at least in the short term?

Or how do we think about how you manage today versus what you did a year ago?

As I said earlier in response to another question, we're in the moving business, not the storage business as the [words] go.

So we have limits for the transitory process of doing the underwritings.

And so we mark them and move them out and it's gone.

And so this is not how much -- as Paul said, we don't -- we make lots of commercial credit available to our clients, but in this part of the -- in the underwriting part of the business, which is what you're talking about, it all goes out the door.

It's not a hold business.

Right, that's helpful.

And maybe just a question on CECL.

Any thoughts on the impact?

And I guess, given some of the pushback, do you see any parts of it changing?

Just your thoughts on CECL.

Sure.

So in terms of the impact, we're not at the point yet where we're providing an estimate.

We have made a ton of progress on our efforts towards adoption.

However, there's still a lot of things that need to be finalized before we're really ready to talk about impacts.

I would point out that we're not overly concerned at this point and it certainly is not going to changed how we're going to serve our clients.

Having said that, we may see an increase in allowance upon adoption, maybe, maybe not.

It's ultimately going to depend on the economic outlook and credit conditions as of the adoption date in 1/1/2020.

The only other issue out there sort of the double count in CCAR and how it's going to affect capital.

And with respect to that, I think the regulators and us are also think about a lot of things.

But the only two I would point out is you just need to understand implications on capital and how it affects the willingness of banks to extend credit.

As I said before, I don't think it's going to change how we operate our company.

If CECL is in, the company runs its stress test, but not in the Feds, what are the implications of that?

There are still a lot of things to work out here between now -- and I think that's why they delayed the implementation of CECL in the stress test until 2022?

Yes, 2022, I think.

Yes.

Our next question is from Saul Martinez with UBS.

Most of my questions have been asked.

But I'll just follow up, I guess, on the earlier question on your -- what a Fed pause would mean for your NIM.

And I think you mentioned, Paul, that it really depends on the forward curve and the ability to lag on deposit rates.

But I guess, on that point, how much of a risk do you see of a lag effect on deposits rates?

Specifically on retail deposit rates, which really haven't moved much in this rate-tightening cycle.

How much of a risk do you see that, in an environment where because the economy is still doing okay, that we do see sort of a lag effect, and you start to see some -- a bit more deposit cost pressure on the retail side than maybe we've seen up until now?

Yes, what we -- so think about it.

I think if I got it right, it was 2 Fed rates 3 years ago; 3, 2 years ago; and 4 last year, something like that.

So if you just sort of noodle in and look at the different movement from the end of '17 to the end of '18, given, I think -- and think of it as a live basis.

Think that what was embedded in it, there just isn't a lot of movement because they're checking accounts, and checking accounts never have high interest rates on them; and half of them are non-interest-bearing, so they don't have any interest rate on them.

So I think it really comes down to who the customer is, how they use the cash.

Is it transactional cash?

Is it investment cash, either short term or long term?

And each business line is different.

But in the consumer business, what is driving our deposit growth is the $20 billion from fourth quarter '17 to fourth quarter '18 and checking balance growth, which will always be tremendously advantaged from the perspective you're coming at it, which is a funding basis.

And as they grow, and we don't feel -- there's not a lot of pressure because half of it's non-interest-bearing accounts.

I mean, it's not -- you can just go back and look at the pricing across time in these businesses and see what's happened if you sort of look at it.

And I think you'll feel that we should be able to consistently drive that.

In the rate-sensitive side, i.e., where it's investment cash, the rates have moved up substantially already and we're growing those balances.

So we tell our team to price to grow deposits 3%, 4% better than the -- i.e., better than the economy.

And they've got to achieve that balance, and they've done a great job.

That's helpful.

I guess, on the -- you may also -- just another question.

You made the point that the equity market downturn in December will hit fees in the first quarter.

And we can obviously do our own calculations and look at the roll forward in the asset values.

But is there any way to sort of size up the magnitude of the downturn in the fourth quarter in the market could mean for fees in that business?

Look, it's a good question.

I wouldn't -- or hesitate to give you a number because the revenue is based upon a lot of different things besides just what the level of the markets are.

I think it would be kind of be misleading to come up with a number just based upon the markets to everybody on this call.

So you maybe you could back and Lee and his team can help you think through what the issues are more broadly, but we're not going to give a number today.

Okay, I think that's all -- do we have one more question?

Yes, we do have one final question from Brian Kleinhanzl.

Great.

Yes, I hear you on the net charge-off guidance for 2019 relative to 2018, but how are you thinking about reserve builds?

I mean, reserve releases were $500 million this year.

Are you still thinking about you're able to release reserves at that pace next year as well?

Yes, look we think -- just to run through it for everybody, we think that provision -- we think credit's going to continue to perform well.

Hopefully, everybody heard that on the call.

And we would expect provision to roughly match net charge-offs, depending on loan growth.

You heard us talk about what we're expecting for net charge-offs.

The releases are coming down, you saw there $19 million this quarter.

And we just rough -- you're going to see our provision much more closely match net charge-offs going forward because we've seen a lot of improvement in that consumer real estate portfolio.

So that's the best guidance I can give you.

Okay.

And then just one follow-up, still on credit.

I mean, you did say that kind of the commercial NPLs tick up this quarter, and it's been a pretty steady downward trend in those since 2016.

Is it just because of market conditions?

Or could you give a little bit more color there as to why the uptick in this quarter?

Yes, sure.

Look, at 22 basis points, NPLs as a percentage of loans is basically at a historic low here.

There was an increase in the quarter driven by a couple or a few names that were downgraded.

If you look at reservable criticized exposure, it continued to fall in the quarter.

So again, we don't see anything suggesting a broad-based decline in the overall credit quality.

Okay.

I think that's all the questions.

So thank you for joining us again.

It was a -- we had a strong, solid quarter, and 2018 was a strong year for this company with record earnings.

As we look forward in 2019, as I said earlier, the predictions of potential slowdown in the economy don't enervate us, they invigorate us.

We've built this company to operate in that setting.

We'll continue to drive responsible growth and we look forward to talking to you next quarter.

And this will conclude today's program.

Thanks for your participation.

You may now disconnect, and have a great day.