美國合眾銀行 (USB) 2018 Q3 法說會逐字稿

Welcome to U.S. Bancorp's Third Quarter 2018 Earnings Conference Call.

Following a review of the results by Andy Cecere, Chairman, President and Chief Executive Officer; and Terry Dolan, U.S. Bancorp's Vice Chairman and Chief Financial Officer, there will be a formal question-and-answer session.

(Operator Instructions)

This call will be recorded and available for replay beginning today at approximately noon, Eastern daylight time, through Wednesday, October 24 at 12 midnight Eastern daylight time.

I will now turn the conference call over to Jen Thompson, Director of Investor Relations for U.S. Bancorp.

Please go ahead.

Thank you, Casey, and good morning to everyone who has joined our call.

Andy Cecere and Terry Dolan are here with me today to review U.S. Bancorp's third quarter results and to answer your questions.

Andy and Terry will be referencing a slide presentation during their prepared remarks.

A copy of the slide presentation as well as our earnings release and supplemental analyst schedules are available on our website at usbank.com.

I'd like to remind you that any forward-looking statements made during today's call are subject to risk and uncertainty.

Factors that could materially change our current forward-looking assumptions are described on Page 2 of today's presentation in our press release and in our Form 10-K and subsequent reports on file with the SEC.

I'll now turn the call over to Andy.

Good morning, everyone, and thank you for joining our call.

Following our prepared remarks, Terry and I will be opening up the call to Q&A.

Let me begin on Slide 3. In the third quarter, we reported record net income and earnings per share, driven by record revenue and positive operating leverage.

In line with our expectations, loan growth accelerated in the third quarter, supported by continued strength in consumer lending and a pickup in commercial loan growth.

On the right slide (sic) [side] of Slide 3, you can see that credit quality improved in the third quarter, and our book value per share increased by 5.3% from a year ago.

During the third quarter, we returned 78% of our earnings to shareholders through dividends and share buybacks.

Slide 4 highlights our best-in-class performance metrics, including a 19.9% return on tangible common equity.

Our efficiency ratio, return on average assets and return on average common equity all improved sequentially and on a year-over-year basis.

Now let me turn the call over to Terry, who will provide more detail on the quarter as well as forward-looking guidance.

Thanks, Andy.

If you turn to Slide 5, I'll start with a balance sheet review and follow up with a discussion of earnings trends.

Average loans grew 0.9% on a linked-quarter basis and increased 1.8% on a year-over-year basis, excluding the impact of a student loan portfolio sale in the second quarter.

We saw continued growth in retail portfolio, such as mortgage and retail leasing.

Credit card loan growth was supported by expansion in both the number of active accounts and sales per active account.

We are seeing good momentum in digital acquisitions across platforms.

As expected, commercial loan growth accelerated in the third quarter, following modest growth in the first half of the year.

Pipelines remain strong, and we are seeing CapEx investment and M&A activity among our corporate clients.

Alternative funding sources, such as the capital markets and companies' own cash balances, are limiting the clients' need to access the loan markets, but to a lesser extent than during the last few several quarters.

As investment spending gains traction and companies work through their cash balances and tax repatriation, we expect commercial loan growth to continue to improve.

Consistent with the past several quarters, Commercial Real Estate loans declined, reflecting our decisions not to extend credit at unfavorable terms and continued paydowns as customers seek alternative financing.

This quarter, excluding the impact of the student loan sale, Commercial Real Estate contributed a 27 basis point drag to linked-quarter growth and a 122 basis point reduction to year-over-year loan growth.

While paydown activity remains a headwind, it is gradually diminishing in intensity, and we expect the trend to continue.

Turning to Slide 6. Deposits declined 1.4% on a linked-quarter basis.

This included the impact of an anticipated balanced migration related to the business merger of a large financial client, which represents about half of the balance decline.

This impact is expected to moderate in the fourth quarter.

About half of our deposits are retail customer balances within our Consumer and Business Banking business line, where we saw a 0.7% linked-quarter increase in average deposits, driven by a 2.7% increase in non-interest-bearing deposits.

Within Corporate and Commercial Banking, our business customers are deploying positive balances to support growth and are migrating balances to alternative investment vehicles.

This drove some of the decline this quarter.

Additionally, our Corporate Trust business saw seasonal declines in deposit balances associated with the timing of the receipt in distribution of funds.

These deposit goals are consistent with our asset liability modeling expectations.

Slide 7 indicates the credit quality improved in the third quarter due to improving economic conditions, with customer paydowns resulting in pressure on loan balances, but an improved credit profile.

Notably, our nonperforming assets declined 8.0% compared with the second quarter and decreased 19.7% compared with the third quarter of 2017.

Slide 8 provides highlights of third quarter earnings results, including a 3.9% increase in diluted earnings per share on a linked-quarter basis.

On Slide 9, linked-quarter and year-over-year net interest income growth was supported by higher interest rates and earning asset growth, which was partly offset by a shift in deposit and funding mix.

Year-over-year growth was negatively impacted by tax reform, which reduced the taxable equivalent adjustment benefit related to tax-exempt assets.

In the third quarter, the net interest margin was 3.15%, up 2 basis points linked-quarter and 1 basis point compared with the year ago.

The impact of tax reform on taxable-equivalent earning assets for year-over-year net interest margin expansion by 2 basis points.

Our interest-bearing deposit betas continue to perform in line with our expectations during the last few rate hikes.

As future rate hikes continue, we expect -- we continue to expect our deposit beta will trend towards 50%, which compares with the current level of about 45%.

The betas in our commercial and deposit -- and trust deposit basis, which represents about half of our total deposits, are in line with our estimated terminal betas.

We expect that movement in the overall beta going forward will primarily be driven by our consumer deposit base.

Slide 10 highlights trends in non-interest income.

On a year-over-year basis, we had strong growth in payments revenue and trust and investment management revenue, partially offset by a decrease in commercial product revenue, mortgage banking revenue and treasury management fees.

Commercial product revenue pressure reflected market dynamics in corporate bond underwriting and loan syndications.

Mortgage revenue was affected by lower refinancing activity and lower gain on sale margins.

Despite lingering market headwinds, we expect the year-over-year decline in mortgage banking revenue to moderate in the fourth quarter.

We're well positioned as a waning refi market transitions to a more robust purchase mortgage market.

We are optimistic that gain on sale margins in this business have stabilized and will expand as excess capacity leaves the origination market.

The decline in treasury management fees reflects the impact of changes in earnings credits, which is typical in a rising rate environment.

Turning to our payments business.

We had strong growth in credit and debit card revenue and double-digit growth in corporate payment revenue, each reflecting higher sales volumes.

As we have been signaling for several quarters, merchant processing revenue returned to a mid-single-digit base in the third quarter, as we lapped the impact of the exit of joint ventures in the second quarter of 2017.

Merchant acquiring sales volume growth continues to be strong.

We expect merchant processing revenue to continue to strengthen in the fourth quarter of 2018.

Trust and investment management revenue growth was driven by business growth as well as favorable market conditions.

Turning to Slide 11.

Noninterest expense decreased 1.3% on a linked-quarter basis, partly reflecting typical seasonality, and increased 1.5% on a year-over-year basis.

Compensation expense increased, principally due to the impact of hiring to support business growth and compliance programs, merit increases and higher variable compensation related to business production.

Notably, within non-personnel expenses, professional services expense declined from a year ago, primarily due to fewer consulting services as compliance programs near maturity.

We expect compliance-related costs to continue to moderate through the year.

Other expense declined from a year ago due to lower deposit insurance and litigation costs as well as a reduction in costs related to tax-advantaged projects as we syndicate tax credits in the secondary market.

Slide 12 highlights our capital position.

At September 30, our Common Equity Tier 1 capital ratio, estimated using the Basel III standardized approach, was 9.0%.

This compares to our capital target of 8.5%.

I'll now provide some forward-looking guidance.

For the fourth quarter, we expect fully taxable equivalent net interest income to increase in the low single digits on a year-over-year basis, strengthening from the third quarter growth rate.

We expect fee revenue to increase in the low to mid-single digits year-over-year.

On a year-over-year basis, we expect to deliver positive operating leverage on a quarterly basis in the fourth quarter and for the full year of 2018.

We expect credit quality to remain relatively stable compared with the third quarter.

Now I'll hand it back to Andy for closing remarks.

Thanks, Terry.

The second half of 2018 is shaping up as we had anticipated, and momentum is building in our core businesses as we head into the end of the year.

We expect loan growth to continue to accelerate in the fourth quarter, and our fee businesses remain on a good trajectory.

Merchant acquiring revenue growth is gaining momentum.

And our other 2 payments businesses, retail card issuing and corporate payment services, are firing on all cylinders.

In Wealth Management and Investment Services, we are benefiting from favorable market conditions even as we continue to grow new accounts and reap the benefits of our strong market position in Corporate Trust.

We remain diligent in our focus on managing expenses for whatever revenue environment we are operating in, and we are committed to delivering positive operating leverage in the upcoming quarter, for the full year 2018 and 2019.

We manage our company for the long term, while balancing shorter term financial objectives.

This approach means that we will be prudent with expense management, but continue to make traditional investments in our businesses and accelerate investments to enhance our digital and payments capabilities.

In terms of more traditional investments, we recently announced the expansion of our middle market commercial banking team in the New York metro area, where we have a strong presence in a large corporate space for over 10 years, and we'll be able to leverage that existing platform.

On a technology and innovation front, we announced the creation of a new fully digital capability for small businesses to apply for and receive a loan or line of credit.

The application of funding time is often less than an hour, improving on a process that can take weeks within the industry.

During the third quarter, we acquired Electronic Transactions Systems, which enhances our integrated software capabilities within our merchant processing business.

It expands us into the new municipality industry vertical, where we can leverage our government banking relationships within Corporate and Commercial Banking.

These investments and future investments will enable us to stay at the forefront in banking and will drive improved operating leverage over the next several years.

We understand that the value we create for our shareholders starts with the value we create for our customers.

As the banking industry evolves in this new era of digital capabilities, we continue to look for ways to use technology and innovation to make our customers financial lives simpler and more productive, while at the same time protecting their data, their personal information and their privacy.

If we do it right, and we will do it right, our customers win, our employees win and our shareholders win.

In closing, I'd like to thank our U.S. Bank team members across the country for bringing their A-game to work every day, to deliver on the promise of one U.S. Bank and driving outstanding results for each of our stakeholders.

That concludes our formal remarks.

Terry and I will now be happy to answer your questions.

(Operator Instructions) And your first question comes from John McDonald with Bernstein.

I wanted to ask a little bit about the positive operating leverage.

Yet a nice print on positive operating leverage this quarter.

It looks about 80 basis points.

Just wondering, how much help you got on the expense line this quarter from some of the accrual reversals?

And any other one-timers that you mentioned?

And then more importantly, as you look out into next year, Andy, I think you've talked about shooting for operating leverage gap of 1% to 1.5% next year.

What do you see as the drivers for that to accelerate next year to that range you talked about?

I'm going to ask Terry to start, then I'll jump in.

Yes.

John, let me talk a little bit about the expense question that you had.

Again, our focus is around being able to deliver that positive operating leverage.

But at the end of looking at expenses, we're kind of focused on a lot of different areas.

You mentioned the litigation accruals, that actually is not a very big driver of the overall change.

If you think about it on a year-over-year basis, the biggest drivers is that is -- one is related to tax credit amortization costs, which are lower this year versus last year.

And if you think about it with tax reform and us having lower tax expenses, the capacity that we generate in tax credit production allows us to generate both fee revenue through tax credit syndication, but also reduce our tax credit amortization.

And that's something that we believe is both sustainable over the long haul.

The second thing, so we've kind of talked about our FDIC insurance is a little bit lower than what we expected.

And then if you think about our mortgage servicing costs, we continue to -- just as the refi market has changed, et cetera, the mortgage-servicing type of costs have come down and foreclosure-related costs, et cetera.

So those are probably the biggest drivers.

On a quarter -- on a linked-quarter basis, the tax credit amortization represents the majority of the change.

So those are the things I would focus on.

And John, Andy.

As we look at next year, I would highlight a couple of things.

As we've talked about, we've lapped the payments -- merchant revenue issue.

And you saw that that's growing 4%.

We continue to expect that to accelerate as we go into next quarter and next year.

Mortgage revenue, which has been a little bit of a headwind in the industry, I think, will start to come back.

We're seeing accelerated loan growth, continued economic growth.

And then across all our business is we're seeing an increase in market share and customer acquisitions.

So those are all things that post positive opportunities for 2019 revenue.

Okay.

And Andy, just a quick follow-up.

Is the 1% to 1.5% still kind of a good target as you sit here now and look out to '19 for the operating leverage that you're going to shoot for?

Yes, it is.

Okay.

And then one quick follow-up, Terry.

The FDI insurance fees lower that you mentioned, what was the driver of that?

And do you still have a step-down coming from the end of the surcharge later, either fourth quarter or next year?

Yes.

The biggest driver is really the FDIC rate as much as anything.

And as we make capital decisions and other things, and then if you think about kind of our risk profile, we are getting an FDIC kind of benefit from a rate standpoint.

That's probably the biggest driver.

And then I think your second question was really related to the surcharge.

If you think about the surcharge, so if we think about the fourth quarter, we expect the surcharge to continue.

And until it ends, we're going to continue to expect it to be there.

So we'll wait for that decision.

The impact to us on a quarterly basis is about $20 million related to that surcharge.

So that kind of gives you some sense in terms of the size of it as well as you're kind of thinking about that for the future.

And John, importantly, we're not assuming that surcharge goes away as we think about positive operating leverage in 2019.

Your next question comes from John Pancari with Evercore.

On the loan growth front, I heard you're on the expectation that we're going to see some good acceleration and growth in coming quarters, or at least for next quarter.

What is really driving that for you?

What is changing that you're calling out?

Is it more about the paydown abatement that you think is going to continue or the bond market flow finding its way back to the bank loan market?

Or is it more about just outright demand?

Yes.

I mean, I think it's actually a combination of all of those things if you think about it, I mean, we've been talking about the fact that our pipelines have been getting stronger and M&A activity has been picking up.

We've seen in our corporate payments business the spend by businesses in both discretionary and CapEx getting stronger.

So I think a part of it is demand, at least in terms of what we are seeing.

I do -- we're also seeing the paydowns that we saw in late 2017 and in the second -- in the first half of this year those starting to moderate.

They're still continuing, but I think they are moderating.

And so it is kind of a combination of all those different activities.

I also think that as the long end of the curve has moved up, the opportunity within the capital market space is that dynamic has changed a little bit.

So I think it's a combination of all those different things.

And we think -- as we think about the third quarter, linked-quarter was up 0.9%.

In the fourth quarter, we'll get a little stronger.

And we expect that to get stronger as we move into 2019 as well.

And related to that, the line utilization on Slide 16, despite some of those trends, you're still seeing it trend down.

I mean, is that -- are you signaling an inflection that you expect that we should start to see next quarter?

Yes.

Well, I guess, when we end up looking at utilization rates, we think it's kind of stable.

It ends up bouncing kind of up and down.

I do believe that when you end up thinking about the optimism and the capital expenditure that they are -- that we are seeing, I do think that there's the opportunity for utilization to expand.

And so as we kind of think about that, that's a part of the equation, let's say.

Okay, Terry.

And then just one last thing on the deposit side.

How should we think about overall deposit growth trends going forward?

I know you flagged the volatility from the customer merger and all that, that you flagged, but how should we think about growth from this level going forward on total deposit trends?

Yes.

So I mean I think as -- I really kind point to 3 things.

And I talked about some of those, but let me just kind of reiterate them.

One is that our consumer deposits are growing.

They grow -- they grew nicely both on a linked quarter and year-over-year basis.

So I think that that's good.

And that tells us that from a pricing standpoint, we feel pretty good about that.

And what we're seeing in that market is good.

The large customer or the financial customer that was part of a business combination, we've known and we've anticipated that those balances are going to be migrated, and we've been working with that customer to kind of know and understand timing.

But to kind of give you some perspective, on a year-over-year basis, the decline is nearly 100% related to the fact that, that customer migration is occurring.

On a linked-quarter basis, it represents about half of it.

So when we kind of take that into consideration, we know that that's going to moderate in the fourth quarter.

When we look at the fourth quarter, we think about 2019 in particular.

We actually think that it's going to moderate and allow us to be able to grow deposits again.

Your next question comes from Matt O'Connor with Deutsche Bank.

Another one on loan growth, because you're one of the few banks that had accelerating loan growth this quarter, and it seemed a bit more optimistic than others.

Any idea why maybe you're seeing a slowdown in paydowns and a couple of other of your peers have pointed to an acceleration?

Is there something different in the mix?

Or is it just the way the lumpiness in that business can be?

Well, yes.

I mean, I think it's -- again, it's probably a combination of different things.

It could be lumpiness.

We're in different markets.

We end up having a much bigger community banking market than maybe some of the other competitors have been describing.

So it probably is a combination of things.

It's not necessarily one thing that we can kind of pinpoint, let's put it that way.

Okay.

And then when you talk about accelerating loan growth in 4Q, is that versus the kind of 4% annualized growth that you had in 3Q versus 2Q?

Or are you talking about on a year-over-year basis, where loans were only up 1% in the third quarter?

Matt, this is Andy.

We're talking about that -- the 0.9% accelerating to a higher number on a linked-quarter basis.

Your next question comes from Ken Usdin with Jefferies.

First question.

Just on the balance sheet and repricing characteristics.

So it's getting harder to talk about sequential betas per se.

So deposit costs up 10 basis points, how would you characterize that in terms of your expectations of the rate of change in terms of what you saw this quarter and how that might go forward?

In the context of that, you had previously talked about NIMs continuing to expand.

So can you help us understand that dynamic within?

Yes.

So maybe a couple of things.

When we end up looking at net interest margin, of course, how it expands, how much, et cetera, is always a function of how your balance sheet ends up changing what sort of loan mix you have, et cetera.

Certainly, as we kind of think about deposits or funding costs, let me kind of step back.

I think there's other reasons.

Our investment portfolio continues to be accretive as we see roll-off.

And that will continue at least through the vast majority of next year.

So I think there's a couple of things on the asset side that's positive.

On the deposit side, I really think that -- and we've talked about this, deposit betas, they are at about 45%.

We think they'll migrate up to 50%, whether it's this next rate hike or the following, but it's slowly moving in that direction.

And our Corporate Trust and our wholesale deposit pricing is pretty much at terminal levels.

So the movement of the deposit beta's really going to be more a function of how fast consumer deposits end up moving.

And we are maybe seeing a little bit more competition in that particular space, but it hasn't been significantly greater.

So I think it's just kind of a function of all those different things.

And Terry, our deposit beta assumptions have been consistent with what's happening.

Yes, exactly.

Yes, fair.

And Terry, to that point you mentioned on the asset side, can you help us dig in a little bit?

Can you talk to us about front book, back book on the securities yield?

And also the types of loan growth you're expecting to see increase, is that also the types of stuff that's also accretive to the existing loan yield?

Yes.

So on the investment side of the equation, if you think about our portfolio, our investment portfolio, it has a duration of around 4 years, which is what we've talked about.

We are seeing a fairly significant amount of low-yielding treasuries and those types of securities that are now rolling off.

The -- it's pretty consistent with what we talked about last quarter.

That roll-off is accretive at 100 to 125 basis points.

So that continually gives you the opportunity to be able to see some accretion with respect to that to our portfolio.

On the loan side, again, I would point to the fact that we've seen nice growth in residential, and we've seen nice growth in our credit card and our consumer type of products.

And that type of mix would be beneficial to us as we kind of look in the future.

And we would expect and anticipate that to continue.

Your next question comes from Erika Najarian with Bank of America.

So my first question is a follow-up to the competitive aspects on for commercial.

The bond market was brought up, but I'm wondering if you could give us a sense of how much competition, nonbanks, like private equity firms, how much competition that's posing to U.S. Bancorp?

And as an add-on to that, what is your on-balance sheet exposure to broadly syndicated leverage lending and private equity backed transactions?

Why don't you start on that second question, Terry?

Yes.

So with respect to leverage lending, that is something, in terms of our balance sheet, we have never really had any significant amount of lending in that particular space.

And so it's an area that we manage pretty tightly.

And again, it kind of is reflective of our credit risk profile.

So as we think about the next downturn, we feel like we would be in a pretty good spot from a leverage lending point of view.

And then, Erika, on your question on private equity or nonbank competition, I would say that is evident in some of the wholesale categories.

I think it's probably most prominent in our Commercial Real Estate category, where some of the paydowns that are occurring are because of nonbank competition coming into the marketplace.

But as we said -- as Terry said in his remarks, that is starting to abate here as we come into the third and fourth quarter.

Got it.

And another follow-up question on the expense side.

I wanted to make sure I understood the run rate in particular for other expenses.

So as I think about the 3-year sort of average for other expenses, the averages is about $450 million, and it was $414 million last quarter and $377 million this quarter.

Terry, am I right to think that that's all the tax credit amortization expense that you were discussing earlier?

And I'm wondering if that $377 million is a good run rate for us to think about and whether or not there is an offset in the tax rate line that we need to consider.

Yes.

Well, it's already incorporated into the tax rate that we have because when you think about -- when you establish your tax rate for the year, you think about the entire year in terms of what your tax credit production is going to be.

So it's already in the tax rate.

Here's the way that I would think about it, Erika.

I do think that the tax credit amortization is going to be an opportunity.

It's going to be something that's going to continue.

But it also -- it has a quarterly cycle to it.

The third and fourth quarter happen to be your strongest production quarters.

And so tax credit amortization and the impacts associated with it tend to be more dramatic in the third and fourth quarter.

So there's a little bit of a seasonality.

I guess, if I were looking at it, I think the $377 million might be a little bit on the lower end of that range, but reasonable.

And the fourth quarter, Terry, is actually higher than the third quarter on tax [rate].

So we'll see a little bit of an increase in that in the fourth quarter because of that.

Yes, yes, yes.

And last year, it went up above $60 million.

This year, it's probably closer to $40 million that it will increase just because of tax credit amortization.

Third quarter to fourth quarter.

Yes.

Got it.

And just a follow-up question for you, Andy.

I think that the performance in bank stocks lately have -- seem to reflect some revenue concerns rather than credit concerns for 2019, although, of course, you buck the trend in loan growth this quarter.

And I'm wondering what your message is on that positive operating leverage on 1% and 1.5%.

So I guess, this is a 2 part question.

Where is the company in terms of its less traditional investment spend?

So let's talk about the technology, for example.

And if the revenue environment is less robust for the whole industry than we'd hope, will you still be able to deliver that positive operating leverage for '19?

Short answer to your question, Erika, is yes.

The longer answer is we do expect credit to continue to be favorable.

It's 46 basis points in charge-offs this quarter.

The loan growth is the only reason we add it to our reserve.

Credit quality underlying that is very stable.

But we had good loan growth, so we add it to reserve, as we have done in the past.

As we think about next year in terms of the revenue, we have some positives, as I talked about earlier.

It's both the combination of less -- fewer headwinds as well as continued momentum in certain businesses.

But as we've also said, we'll manage expenses consistent with what we see from the revenue side of the equation, sort of like what we did in this quarter.

So we expect an accelerated revenue opportunity next year.

And we're managing expenses with that in mind.

If the revenue doesn't happen as we think, we'll manage expenses more prudently.

And Erika, maybe one thing that I would just kind of add to that, I think when you end up looking at our business mix, and this is one of the things that we've talked about in the past, the business mix, having the strong fee-based sort of businesses and payments, et cetera, and with consumer spend continuing to get stronger, I just see that as something that differentiates us as we think about the future.

And your next question come from Scott Siefers with Sandler O'Neill + Partners.

I just wanted to go back to the deposit dynamics for a quick second.

First, just to make sure I understand the large customer migration you talked about.

That just went from deposits out of deposits, right, rather than a move within the categories of total deposits?

Yes, yes.

Those are deposit outflows from the company.

And if you think about it, it was acquired by another financial institution.

And they wanted that -- bring those deposits under their balance sheet.

And it's something that we have been anticipating.

It's been a part of our NIM and our asset liability modeling process for well over a year.

Yes, okay.

And then just within the categories, same directional trend at you guys versus others, which is sort of money coming out of noninterest-bearing into other categories.

But the order of magnitude seemed a little larger for you guys than I've seen at others.

So I guess, one, given you guys are a little unique in terms of business mix with like Corporate Trust in there, for example, so there's an element of apples-to-oranges, but if maybe you could just briefly walk through how you guys differ from just sort of a typical bank.

And then more importantly, I guess, how will that dynamic flesh out or play out here as we move forward just given the uniqueness of your business mix?

Yes.

Well, I mean, again, the thing that we end up really focus on in terms of the uniqueness is our Corporate Trust business.

And I mean, within those trust structures, as yields have gone up, they continue to look for opportunities to be able to get as much yield as they can within that structure.

And so migration from noninterest-bearing to interest-bearing is something that we kind of anticipate and expected.

There is a portion of those structures, though, that is very operational in nature and is sticky within the noninterest-bearing.

And so while that migration has been occurring, I don't know whether that will continue to be as strong as it has been in the past.

I don't know, Andy, if you have...

Yes.

So the Corporate Trust business is a great -- not only a great fee business, but it's a great deposit gathering business.

And as Terry mentioned, there's 2 components to it.

One is operational in nature.

And the flows that occur will continue to occur regardless of the rate environment because it is a flow between the bond issuer and the bondholder; the second component are -- what I would call more short-term investments.

And that's where we're seeing more of the volatility.

But it's as we expected, and it's particularly in this rate environment as new investment opportunities present themselves.

So bottom line, Scott, I don't think there's anything that we didn't anticipate.

We're going to be a little bit lumpier because of that because of that second component.

But it's in line with what we expect.

Yes.

The other thing is that because of the Corporate Trust business, the size of our total deposits as a percentage of our -- excuse me, our total funding cost that even though our deposit pricing might be a little bit higher, our total funding cost is very competitive.

Okay.

That's perfect.

And then If can ask one last sort of tic-tac question.

You had the Elan unit sale that you announced a few weeks back.

Any revenue or expense impact as we look into like '19 that you guys would call out from the loss of that business from the sale that you did?

Yes.

So -- yes.

So I mean, that sale is still in process -- maybe I can just step back a little bit.

That is very specific to third-party ATM processing, and it's also the sale of our MoneyPass debit card network.

And so it's not related to our payments business as I -- there was a little bit of confusion on that early.

So I just want to make sure that...

It actually [goes] up to Consumer Banking business, right?

Yes, yes.

And the -- if you end up kind of dimensioning it.

So 2017 revenue for that business, on an annualized basis, was $170 million.

On a quarterly basis, third quarter, I believe the revenue was around $45 million.

And then the efficiency ratio of that business pretty similar to the rest of our company, maybe slightly higher, but pretty similar to the rest of our company.

So if you kind of take that information, you can get some sense, both in terms of fourth quarter and 2019.

From a fourth quarter perspective, right now, we anticipate that the sale will close at the end of October.

But if not the end of October, then the end of November.

And we just have to kind of wait and see based upon regulatory approval.

Your next question comes from Betsy Graseck with Morgan Stanley.

Andy, can you talk a little bit about the different levers that you've got on the expense side when we're thinking about the operating leverage for next year?

I know we talked through some of the revenue line items already, but what's in your back pocket there?

Well, one of the things we talked about is we're investing in both traditional, as we talked about the expansion in our Commercial Banking business, as well as more of the digital and payments businesses.

So we made an acquisition in the third quarter, as we talked about.

We are continuing to expand our capabilities on our mobile application, our capabilities in terms of sales activity on that application.

And everything you think about from an investment standpoint has a little bit of a digital focus on it.

So that will continue.

We do have continued opportunity in terms of optimization of different business processes, which we are working across the company, in terms of our branch optimization across structures and where we are and space and so forth.

So we have a number of things, a number of initiatives we're working on.

And at a high level, Betsy, I would describe it as continue to invest in the future, while recognizing that some of the things that we've done in the past, we could do better or do less of.

And your tech investment spend, am I right in thinking it's around $1.5 billion?

Is that accurate?

Yes.

So the CapEx related to technology is about $1.2 billion.

And as Terry and I have talked about in the past, our operating expense related to that is probably another $1.2 billion, $1.5 billion.

So if you combine the 2, it's just over $2.5 billion.

But the CapEx that we talked about is at $1.2 billion.

Got it.

Okay.

And so that line kind of holds in, but then the headcount or occupancy associated with these other things you're talking about pull back.

That's the push-pull in the line items?

Yes, that's a fair way to think about it.

And just to be clear, we've been at that spend level for 1.5 years, 2 years.

So that's in the numbers as we think about what we're reporting today.

Got it.

And then could I shift gears a little bit and just ask thoughts around CECL?

I know that's not coming into play until 1Q '20, but I'm sure you're prepping for it and going parallel over next year.

So maybe you can give us some thoughts as to how you're thinking about it from an early-look perspective?

Yes.

I mean, as you said, we're still kind of in the process of dimensioning it.

2019 is kind of our parallel year.

If you end up looking across the entire industry, the entire industry is really in the process of kind of refining their models that they'll use as part of that particular process.

I would anticipate that we'll have better dimension around what the size of that is later this year.

And of course, one of the factors that comes into play is, what is your outlook with respect to the economy, et cetera, as you get closer to the adoption of it?

So a lot of moving parts, but we're on track.

We feel good about at least the position that we're in, in terms of us being able to adopt it.

Are there areas you think there's like a little giveback?

Because some of these ratios look pretty high.

Part of it is because we've got very low losses right now, but I'm also wondering if there's some parts of the portfolio, which could be a net giver of reserves as opposed to a taker.

Yes.

You know what?

The interesting thing about CECL is it is very product-dependent in terms of -- within a company in terms of what the impact of it's going to be.

To the extent that you have longer life or longer duration assets like mortgages and that type of a product, you going to actually have a bigger negative impact or increase in the reserve that's going to come into play.

The area kind of -- to me, it's a little bit counterintuitive.

But Commercial Real Estate is one of those, especially on the construction side, where you tend to get a little bit above benefit.

But we really have to kind of look at the total mix.

It's a little bit of a moving dynamic.

Your next question comes from Mike Mayo with Wells Fargo Securities.

You mentioned digital banking quite a bit, the digital platform.

You've disclosed that you have 18 million customers if that's correct in prior annual reports.

Can you tell us the percentage of customers for online and the percentage of customers that use mobile banking?

I think your other 5 large bank peers all disclosed this, and it'd be great if you could give that to us.

If not now, then sometime in the future.

I can give it to you now.

So we have 18 million total customers.

If I exclude single-service customers, so some of our mortgage customers, card customers and indirect customers, who outside of our market aren't what I would call a full banking customer, were about 11 million.

And of the 11 million, about 50% use our digital platform.

And how many -- what percent mobile?

The majority of that is mobile.

Okay, great.

Got my wish.

And as far as [the present], you've got one price for doing well and one price for not doing so well.

Just a follow-up on those 2 other issues.

So when it comes to deposit growth, when we look year-over-year, it still doesn't look great.

So I guess, that would kind of neutralize this -- the seasonal aspects.

And so I get the one-off merger of a client you lost to deposits, and then some other ins and outs.

Is there anything else going on?

Or maybe just what's your forecast for deposit growth over the next year or so?

Yes.

I mean, I think we've kind of covered the dynamics that are taking place on a year-over-year basis.

Again, the decline is 100% related to this particular customer.

Consumer deposits are growing.

Now when we think about 2019, we do expect growth in deposits, and I think that will be kind of consistent with low-single digits.

It'll be kind of tied to economic growth, et cetera.

But I don't think that we -- there's any unusual sort of dynamics that we haven't talked about.

And then on the positive side, the loan growth -- commercial loan growth, and I know there's been a lot of questions on that.

And I'm just trying to think of the main takeaway.

Are you executing better?

Are you taking more risk?

Or is it simply mix?

If you were to characterize that, kind of what's the main take?

Because other are a lot more cautious.

Yes, Mike, it's not -- yes, I want to be clear on one thing, it's not taking any more risk.

Our credit box has not changed at all.

And we've been very prudent and strict around that and disciplined for a long time.

And that is not changing at all.

I think it's a function of all the things we talked about.

It's expanding our customer base.

It's gaining market share.

It's a diversified portfolio.

It's not in any one area or geography, it's a function of all those things.

And that's why we're feeling pretty good about it going forward.

And you opened up a new office in the New York area.

Are there some other newer offices that are getting traction that's helping with that commercial loan growth?

Yes.

We've opened up a few offices in the South, the Dallas area and the Southeast, New York.

We'll look at other opportunities like this.

And it's typically leveraging presence that we already have in the market.

We talked about that also thinking about our consumer expansion doing the same, building that customer base that we already have.

Your next question comes from Marty Mosby with Vining Sparks.

Two questions.

One, if you look at merchant processing, there's kind of an anomaly in the growth rates.

If you look at over last year, it's 4% growth quarter-over-quarter.

If you look at sequentially annualized, it's a 5% growth.

So it looks like an acceleration there.

But if you look at year-to-date, it's only growing 3%.

So it's kind of strange how those 3 numbers are all kind of working.

But is there really -- is the momentum finally picking up here in the sense that we are seeing same-store sales and we're seeing some retail purchases, and we're getting that lift from the economy we've been waiting on for so long?

Yes.

If you end up looking at the dynamics, we certainly are seeing a lift from consumer spending getting stronger.

Our sales volumes have been quite strong, kind of in that 8% sort of range, if you will.

The biggest issue on kind of -- in terms of both year-over-year growth and then kind of how it's starting to accelerate is really the fact that, a year ago, we're starting to overlap the joint ventures that we had that we've kind of talked a little bit about.

But the overall business, we've been making some investments in terms of both capabilities, industry verticals and all variety of different things, which I think, as we kind of think about the future, is going to continue to enable us to be able to expand revenue.

We saw one of your peers yesterday actually announce a restructuring in the securities portfolio to accelerate that 100 to 125 basis points of net difference between the market and the portfolio rates.

Any consideration since that's already kind of being taken out of tangible book value anyway in the mark-to-market, that you just go ahead and realize that loss -- take it as there's an extraordinary towards end of this year, and then accelerate the benefit in the sense of what you get from what the market's going to give you over the next couple of years?

Yes.

I mean, short answer is we really don't have any plans to restructure our investment portfolio at this time.

And we've been managing and optimizing it all along, right?

Yes, yes.

You have excess capital.

So given the excess capital that you have, it is a way to temporarily deploy it and actually accelerate the benefit, while locking in rates.

If we wake up 6 months from now, and all of a sudden, rates have somehow fallen back down, you kind of lose that opportunity or that window.

So I just was curious since it's already marked in.

You got the extra capital anyway if that wouldn't be something that couldn't lock in those higher rates while you got them.

Yes.

Well, like I said, we don't necessarily have any particular plans to do it.

So...

(Operator Instructions) Your next question comes from Kevin Barker with Piper Jaffray.

Just a follow-up on some of the deposit flows and some of the deposit questions you mentioned.

The movement out of noninterest-bearing deposits, specifically around the commercial deposits, do you have any offsets on fee income, specifically around treasury management, that could increase fee income as some of the balances come off of noninterest-bearing deposits?

Yes.

I don't necessarily -- I can't necessarily kind of point to something like that.

I mean, I do think that when you end up looking at -- and a lot of people end up talking about compensating balance as kind of being that offset or whatever, but I mean, our core treasury management growth is about a little under 1%.

And the drag is really related to the rising rate environment, but there's nothing that I would specifically point to, Kevin.

Okay.

And then just a follow-up on the expense side.

Your expense growth was below your long-term target this quarter on a year-over-year basis.

I think you pointed to about 3% to 5% long-term target on a year-over-year.

And obviously, there's some puts and takes associated with the tax accrual and the amortization.

But when you look out into the first half of '19 and maybe in full year '19, do you think it's possible you could see expense growth run below your long-term target and maybe see that for the foreseeable future?

Kevin, it depends a bit on the revenue side of the equation.

So we're managing the company for positive operating leverage, and we will manage expenses as we think about it being consistent with the revenue opportunities.

So the numbers aren't going to be specific.

It's going to be relative to what we think on the revenue side.

Your next question comes from Vivek Juneja with JPMorgan.

Sorry to go back to the expense question.

Just trying to understand, Andy, Terry.

The $377 million, I hear it will go up $40 million or so for the seasonal increase.

But so should we think of that $377 million as a good run rate going forward?

Is there anything like -- you talked about legal accrual changes?

Is there anything like that that's unusual that we need to factor in as we think about -- I know it'll be beyond '18.

I mean, is this really the new base?

Yes.

I mean, I think Erika kind of talked a little bit about the averages associated with other expenses.

I mean, other expenses tends to be a little bit lumpy.

It depends upon what businesses are growing, foreclosure or reserves, and I mean foreclosure costs and those types of things in terms of how those are changing.

So I would say that the $377 million is probably on the lower end of that band.

And so when you kind of think about the future, I really think looking at kind of the averages associated with other expense is probably a reasonable way to look at it.

Okay, great.

Similar one on the other income side.

You called out private equity gains.

That's also -- that number is also running above if you look at the last 6 quarter average, which is more like $191 million.

You're at $226 million.

Again, how much of it was private equity?

And what's a good sort of run rate to think about?

Yes.

So more of that was really related to the tax credit syndications that we were able to do in the third quarter.

And again, in the third quarter, in the fourth quarter, those tend to be a little bit stronger, and will tend to be a little bit stronger.

Now we have the opportunity to be able to do that if you think about it on a kind of a full year basis because of the fact that we have a very good and strong production base of tax credits.

And because we can't -- we don't have the capacity to use all of them, we have the opportunity to be able to syndicate them.

So I think when you think about it on a full year basis, there's kind of a little bit of a step-up associated with it, but it tends to be a little lumpy in the third and fourth quarter because of the -- just the timing of when that production occurs.

Okay.

Okay, great.

One last thing.

At the Barclays Conference, you raised your long-term return on average common equity target by 100 basis points.

When I -- when we do the math on the tax fund benefit, the benefit to you is 150 basis points.

So is there a plan to catch up on that additional 50 basis points at some point?

At the high level, back when we announced the tax improvement in the fourth quarter of '17, we also announced the step-up in some spend activity particularly related to digital and payments and so forth.

So that -- the numbers that we talked about incorporate both sides of the equation, which is what we're seeing right now.

Your next question comes from Saul Martinez with UBS.

Two quick -- a couple of questions.

Just changing gears a little bit.

I wanted to ask you how you're seeing the regulatory environment.

Quarles has indicated that -- a preference for prudential regulations to be based more on complexity than size.

He highlighted that very recently.

But do you feel like once we get the proposals out of the way for the $1 billion to $250 billion asset banks you could see some relief for banks of your size and complexity as well?

I'm hopeful, Saul.

As you think about our balance sheet, our business mix, our risk profile, our trading book, which is minimal, all those characteristics are more like a small regional bank or a medium-size regional bank.

They aren't like a large money center bank.

So as you know, 2155 talks about the tailorings shall occur.

And if you think about tailoring based on risk characteristics, I'm hopeful that we'll get some relief.

Okay, okay.

And just changing gears, and I hate to beat a dead horse on the other expense question.

I just want to make sure I understand it, right?

But I think you -- Terry, you mentioned the $377 million should be new to sort at the lower end of what a reasonable range would be.

But am I right in saying that, that reasonable range should also be lower than maybe what it's been in the recent past, which is average about $450 million for some of the reasons you talked about changing the tax credit amortization business, lower FDIC surcharges and whatnot.

But I guess, is that the right way to think about it, that, that range should be a little bit lower than what we've seen historically?

Yes.

I mean, whatever your assumption is with respect to the surcharge in the future, I mean, that's kind of where that ends up getting -- end up impacting -- I mean, you're point is well taken.

I think that I wouldn't just focus on other expenses though, I'd focus on how we're managing overall expenses.

We've got opportunity with respect to compliance and risk programs and mortgage servicing and a whole variety of different things.

So I know there's been -- and I think my horse might be dead.

I wouldn't just focus on other expenses.

Let's put it that way.

Your next question comes from Gerard Cassidy with RBC.

Can you guys share with us -- when we go back and look at your noninterest-bearing deposits to total deposits during the '94-'95 tightening cycle or even the '04 to '06 tightening cycle, they held in pretty constant.

Particularly in '04 to '06, you really didn't lose much in noninterest-bearing deposits.

Can you give us some color?

Do you feel your mix is similar to those time periods?

I know, Andy, you've obviously -- and both of you have been at the bank a long time.

Maybe you can share with us some comparisons to those time periods?

Yes, Gerard, I don't think our mix is all that different.

I do think in those time periods, we were in the midst of acquiring Corporate Trust businesses that may have impacted the activity in the deposits because we were growing -- we've done 22 acquisitions in Corporate Trust over the years, many of them in the years that you describe.

So that may be a factor in the comps.

Very good.

And then following up on regulatory.

I know you guys have done everything required from your BSA/AML issues.

Can you just give us an update on where that stands now?

We have.

We completed our activity and our verification from an audit -- internal audit standpoint on June 30 consistent with our schedule.

It now sits with the regulators, and we're hopeful.

Okay.

And just one quick question.

What's the duration of the securities portfolio?

Yes.

The duration is about 4 years.

Your next question comes from Brian Klock with Keefe, Bruyette, & Woods.

So I promise I won't ask anything about other expenses.

But I know that you guys talked about the average Commercial Real Estate loan growth, and it seems like maybe even some of the headwinds that others have seen in the industry that the paydowns and those sort of headwinds might be abating.

But it seemed like on an end-of-period basis, if we go to Page 20 of your sup, if I'm right, Commercial Real Estate loans, it's the first time your end-of-period loans have actually grown since the first -- or third quarter of '16.

I'm just wondering, is there's anything that you're seeing?

Is this sort of the inflection point when you think about overall end of period balance growth going forward?

Yes, it's a good question.

I -- we certainly hope that it is.

At the end of looking at Commercial Real Estate, as we said, paydowns were particularly strong.

Before tax reform, a lot of Commercial Real Estate developers were derisking, taking a lot of things off -- a lot of their chips off the table.

And they were paying down, and then they had the opportunity to be able to be in the capital market space.

So those were definitely some headwinds.

We haven't necessarily changed.

We haven't changed with respect to our credit box.

We're still not -- we're not doing anything crazy from a structural standpoint.

So we are optimistic that it is an inflection point.

And a big part of it is just the paydowns that we saw earlier in the year have really started to slow.

Got it.

Got it.

And then just trying to triangulate.

I haven't tried to put it back through my model yet.

But the big-picture guidance you gave for the fourth quarter, it seemed like it's implying at least a continued upward trend, nearly flattish to upward in the NIM.

I know you don't give NIM guidance, but is that a fair assumption even with your beta assumption that the NIM could be better in the fourth quarter than the third?

Yes.

Well, as we said, I mean, when we think about the opportunity for NIM to expand, we still think there's opportunity for expansion.

And there are no further questions at this time.

I will turn the call back over to the presenters for any closing remarks.

That concludes our earnings call.

Thanks for listening, and please contact the Investor Relations department if you have any follow-up questions.

And ladies and gentlemen, this concludes today's conference call.

You may now disconnect.