Table of Contents
Description                                                  Page
  Forward-looking Information                                34
  Overview                                                   35
  Critical Accounting     Policies and     Estimates         38
  Results of Operations                                      40
  Performance Summary                                        40
  Consolidated Results of Operations Analysis                41
  Net Interest Income                                        41
  Provision for Credit Losses                                44
  Noninterest Income                                         45
  Noninterest Expense                                        47
  Income Taxes                                               48
  Reportable Segment Results                                 48
  Consolidated Financial Condition Analysis                  50
  Investment Securities                                      50
  Loans and Leases                                           51
  Credit Quality                                             55
  Liquidity Management                                       63
  Deposits                                                   63
  Borrowings                                                 64
  Contractual Obligations and Commitments                    65
  Capital Management                                         66
  Non-GAAP Financial Measures                                67
  Recent Accounting Developments                             73





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Forward-looking Information

Any statements contained in this Annual Report on Form 10-K regarding the
outlook for the Corporation's businesses and their respective markets, such as
projections of future performance, targets, guidance, statements of the
Corporation's plans and objectives, forecasts of market trends and other matters
are forward-looking statements based on the Corporation's assumptions and
beliefs. Such statements may be identified by such words or phrases as "will
likely result," "are expected to," "will continue," "outlook," "will benefit,"
"is anticipated," "estimate," "project," "management believes" or similar
expressions. These forward-looking statements are subject to certain risks and
uncertainties that could cause actual results to differ materially from those
discussed in such statements and no assurance can be given that the results in
any forward-looking statement will be achieved. For these statements, TCF claims
the protection of the safe harbor for forward-looking statements contained in
the Private Securities Litigation Reform Act of 1995. Any forward-looking
statement speaks only as of the date on which it is made and we disclaim any
obligation to subsequently revise any forward-looking statement to reflect
events or circumstances after such date or to reflect the occurrence of
anticipated or unanticipated events.

These statements include, among others, statements related to: our strategic
plan to develop customer relationships that will drive core deposit growth and
stability, management's belief that our commercial and commercial real estate
loan portfolios are generally well-secured, the impact of projected changes in
net interest income assuming changes to short-term market interest rates,
statements regarding our risk exposure, statements related to our planned merger
with Huntington Bancshares Incorporated ("Huntington"), including statements
related to the anticipated effects on results of operations and financial
condition from expected developments. All statements referencing future time
periods are forward-looking.

Furthermore, management's determination of the allowance for credit losses and
related provision; the carrying value of goodwill and loan servicing rights; the
fair value of investment securities (including whether there is any credit
impairment); and management's assumptions concerning postretirement benefit
plans involve judgments that are inherently forward-looking. There can be no
assurance that future loan losses will be limited to the amounts estimated. All
of the information concerning interest rate sensitivity is forward-looking. The
future effect of changes in the financial and credit markets and the national
and regional economies on the banking industry, generally, and on us,
specifically, are also inherently uncertain.

Certain factors could cause the Corporation's future results to differ
materially from those expressed or implied in any forward-looking statements
contained herein. These factors include the factors discussed in Part I, Item 1A
of this Annual Report on Form 10-K under the heading "Risk Factors", the factors
discussed below and any other cautionary statements, written or oral, which may
be made or referred to in connection with any such forward-looking statements.
Since it is not possible to foresee all such factors, these factors should not
be considered as complete or exhaustive: macroeconomic and other challenges and
uncertainties resulting from the COVID-19 pandemic, such as the extent and
duration of the impact on public health, the U.S. and global economies,
financial markets and consumer and corporate customers and clients, including
economic activity, employment levels and market liquidity, as well as the
various actions taken in response to the challenges and uncertainties by
governments, central banks and others, including TCF; a failure to manage credit
risk; cyber-security breaches involving us or third parties, hacking, denial of
service, loss or theft of information, or other cyber-attacks that disrupt TCF's
business operations or damage its reputation; adverse developments affecting
TCF's banking centers; inability to successfully execute on TCF's growth
strategy through acquisitions or expanding existing business relationships;
calculating an allowance for loan and lease losses insufficient to absorb actual
losses in our loan and lease portfolio; adverse effects related to competition
from traditional competitors, non-bank providers of financial services and new
technologies; technological difficulties, including those related to system
upgrades or the failure to keep pace with technological changes in response to
customer demands; risks related to developing new products, markets or lines of
business; adverse political or economic conditions; risks related to TCF's loan
origination and sales activity; lack of access to liquidity or ability to raise
capital that isn't dilutive; adverse changes in monetary, fiscal or tax
policies; litigation or government enforcement actions; heightened consumer
protection, supervisory or regulatory practices or requirements; deficiencies in
TCF's compliance programs, risk mitigation frameworks or ineffective internal
controls; dependence on accurate and complete information from customers and
counterparties; the failure to attract and retain key employees; soundness of
other financial institutions and other counterparty risk, including the risk of
default, operational disruptions, or diminished availability of counterparties
who satisfy our credit quality requirements; inability to grow deposits,
increase earnings and revenue, manage operating expenses, or pay and receive
dividends; interruptions, systems failures in information technology and
telecommunications systems failures of third-party services; deficiencies in
TCF's quantitative models; the effect of any negative publicity or reputational
damage; changes in accounting standards or interpretations of existing
standards; adverse federal, state or foreign tax assessments; and the effects of
man-made and natural disasters, any of which may negatively affect our
operations and/or our customers.

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This report also contains forward-looking statements regarding TCF's outlook or
expectations with respect to the planned merger with Huntington. Examples of
forward-looking statements include, but are not limited to, statements regarding
the outlook and expectations of TCF and Huntington with respect to the planned
merger, the strategic benefits and financial benefits of the merger, including
the expected impact of the merger on the combined corporation's future financial
performance, and the timing of the closing of the transaction. Such risks,
uncertainties and assumptions, include, among others, the following:

•the failure to obtain necessary regulatory approvals when expected or at all
(and the risk that such approvals may result in the imposition of conditions
that could adversely affect TCF or Huntington or the expected benefits of the
merger);
•the failure of either TCF or Huntington to obtain shareholder approval, or to
satisfy any of the other closing conditions to the merger on a timely basis or
at all;
•the occurrence of any event, change or other circumstances that could give rise
to the right of one or both of the parties to terminate the merger agreement;
•the possibility that the anticipated benefits of the transaction, including
anticipated cost savings and strategic gains, are not realized when expected or
at all, including as a result of the impact of, or problems arising from,
economic weakness, competitive factors in the areas where TCF and Huntington do
business, or as a result of other unexpected factors or events;
•the impact of purchase accounting with respect to the transaction, or any
change in the assumptions used regarding the assets purchased and liabilities
assumed to determine their fair value;
•diversion of management's attention from ongoing business operations and
opportunities;
•potential adverse reactions or changes to business or employee relationships,
including those resulting from the announcement or completion of the
transaction;
•the ability of either TCF or Huntington to repurchase their stock and the
prices at which such repurchases may be made;
•the outcome of any current or future legal proceedings against TCF or
Huntington related to the merger;
•the integration of the businesses and operations of TCF and Huntington, which
may take longer than anticipated or be more costly than anticipated or have
unanticipated adverse results relating to our existing businesses;
•business disruptions following the merger; and
•other factors that may affect future results of TCF and Huntington including
changes in asset quality and credit risk; the inability to grow revenue and
earnings; changes in interest rates and capital markets; inflation; customer
borrowing, repayment, investment and deposit practices; the impact, extent and
timing of technological changes; capital management activities; and other
actions of the Federal Reserve Board and legislative and regulatory actions and
reforms.

Additional factors that could cause results to differ materially from those
described above can be found in the risk factors described in Part I, Item 1A of
this Annual Report on Form 10-K under the heading "Risk Factors" and
Huntington's Annual Report on Form 10-K filed with the SEC for the year ended
December 31, 2020. Annualized, pro forma, projected and estimated numbers are
used for illustrative purpose only, are not forecasts and may not reflect actual
results. TCF disclaims any obligation to update or revise any forward-looking
statements contained in this communication, which speak only as of the date
hereof, whether as a result of new information, future events or otherwise,
except as required by law.

Overview

TCF Financial Corporation, formerly known as Chemical Financial Corporation, ("TCF") is a financial holding company incorporated in Michigan in 1973 and headquartered in Detroit, Michigan.



Through our wholly-owned bank subsidiary, TCF National Bank, a national banking
association ("TCF Bank") with its main office in Sioux Falls, South Dakota, we
provide a full range of consumer-facing and commercial services, including
consumer and commercial banking, trust and wealth management, and specialty
leasing and lending products and services to consumers, small businesses and
commercial customers. As of December 31, 2020, TCF had 478 branches primarily
located in Michigan, Illinois and Minnesota, with additional locations in
Colorado, Ohio, South Dakota and Wisconsin (our "primary banking markets"). We
also conduct business across all 50 states, Canada, New Zealand and Australia
through our specialty lending and leasing businesses.


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References herein to "TCF Financial" or the "Holding Company" refer to TCF
Financial Corporation on an unconsolidated basis. TCF Financial Corporation
(together with its direct and indirect subsidiaries, are referred to as "we,"
"us," "our," "TCF" or the "Corporation".

Supporting Team Members, Customers and Communities



To support our team members we have:
•Implemented health and safety policies, protocols and guidelines while ensuring
adequate PPE and cleaning supplies are available at all locations in response to
the COVID-19 pandemic;
•provided company-paid time off for team members not able to work for reasons
related to COVID-19 and enhanced compensation for team members required to work
in the office for a period of time;
•offered reimbursement to eligible team member who, due to COVID-19, had to find
back-up care for their child or dependent with health/developmental needs for a
period of time;
•provided equipment and resources to allow nearly all of our middle and back
office employees to work from home and developed a thoughtful return to work
approach where team members are returning in phases based on safety guidelines
and local restrictions while evaluating lessons learned and opportunities for a
more flexible workspace strategy in the future; and
•established various internal initiatives to increase awareness of diversity and
inclusion issues including launching the Executive Diversity and Inclusion
Council, providing executive office hours for team members to have candid
discussions with leaders regarding diversity issues, required unconscious bias
training for all team members, and organizing Employee Resource Groups to serve
as a resource to positively influence the culture, support efforts to attract,
develop and attract diverse team members.

To support our customers we have:
•Assisted customers in response to the COVID-19 pandemic via loan and lease
deferrals, evaluated under the CARES Act, with $329.8 million on deferral status
as of December 31, 2020 ($246.5 million of commercial balance and $83.3 million
of consumer balance); and
•assisted business and commercial customers via $1.9 billion of total loans
funded through the Paycheck Protection Program ("PPP"), of which $1.6 billion of
PPP loan balance was outstanding at December 31, 2020.

To support our communities we have:
•Established a $1 billion loan commitment for minority communities and minority-
and women-owned small businesses over 5 years;
•expanded closing costs assistance program through the Heart and Home Lending
Program providing up to $10 million of grants to help cover closing costs for
qualified low-to-moderate income home buyers over 5 years;
•partnered with Wayne County, Michigan to provide fast relief through
low-interest loans to help small businesses in the Detroit area; and
•committed $250 thousand for relief efforts supporting Great Lakes Bay Region
community organizations and a $10 million Hardship Lending Program to support
residents and business impacted by dam failures and historic flooding in the
Midland, Michigan area.


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The COVID-19 pandemic has resulted in historic job losses and decreases in
economic activity. While the duration and full extent of job losses and
magnitude of economic dislocation are not yet known, it is clear that they have
impacted, and may impact in the future, the ability of individuals and small
businesses to make payments, the value of underlying collateral and the ability
of guarantors to make payments in the case of default, which may decrease
consumer demand for our products and services and reduce our ability to access
capital. As a result of the decrease in economic activity and restrictions on
certain activities, we have faced and may continue to face a decrease in demand
for certain products, reduced access to our banking centers by our customers,
and disruptions in the operations of our vendors. The pandemic could also result
in the recognition of additional credit losses in our loan and lease portfolios
and increase our allowance for credit losses as both businesses and consumers
are negatively impacted by the economic downturn. In addition, reduced
origination volumes and credit losses triggered by COVID-19 may impact
significant estimates included within our fair valuation analyses. The extent of
such impact will depend on the outcome of certain developments, including but
not limited to, the duration and spread of the outbreak as well as its
continuing impact on our customers, vendors, employees and the financial markets
all of which are uncertain. See Part I, Item 1A, "Risk Factors - Market Risks -
We continue to face risks and uncertainties related to the outbreak of COVID-19"
for further discussion.

Merger of Equals between TCF and Chemical Financial Corporation



On August 1, 2019 (the "TCF/Chemical Merger Date"), TCF Financial Corporation, a
Delaware corporation ("Legacy TCF"), merged with and into Chemical Financial
Corporation, a Michigan corporation ("Chemical"), with Chemical surviving the
merger (the "TCF/Chemical Merger") and being renamed TCF Financial Corporation.
Immediately following the TCF/Chemical Merger, Chemical's wholly owned bank
subsidiary, Chemical Bank, a Michigan state-chartered bank, merged with and into
TCF Bank, with TCF Bank surviving the TCF/Chemical Merger. Upon completion of
the TCF/Chemical Merger, Chemical was renamed TCF Financial Corporation.

The TCF/Chemical Merger was accounted for as a reverse merger using the
acquisition method of accounting, therefore, Legacy TCF was deemed the acquirer
for financial reporting purposes, even though Chemical was the legal acquirer.
Accordingly, Legacy TCF's historical financial statements are the historical
financial statements of the combined company for all periods before the
TCF/Chemical Merger Date. Our results of operations for the periods before
August 1, 2019 reflect financial data of Legacy TCF, while periods after the
TCF/Chemical Merger reflect financial data for the combined company.
Accordingly, comparisons of our results for the year ended December 31, 2020
with those of prior periods may not be meaningful. The number of shares issued
and outstanding, earnings per share, additional paid-in-capital, dividends paid
and all references to share quantities of TCF have been retrospectively adjusted
to reflect the equivalent number of shares issued in the TCF/Chemical Merger.
See "Note 3. Business Combinations" of the Notes to Consolidated Financial
Statements for further information.

Business Overview



Net interest income, the difference between interest income earned on loans and
leases, investment securities and other earning assets (interest income) and
interest paid on deposits and borrowings (interest expense), represented 74.9%
of our total revenue for 2020, compared with 73.5% for 2019 and 68.9% for 2018.
Net interest income can change significantly from period to period based on
interest rates, customer prepayment patterns and the volume and mix of interest
earning assets, noninterest-bearing deposits and interest-bearing liabilities.
We manage the risk of changes in interest rates on our net interest income
through TCF's Asset & Liability Committee ("ALCO") and through related interest
rate risk monitoring and management policies. See "Part I, Item 1A. Risk
Factors" and "Item 7A. Quantitative and Qualitative Disclosures about Market
Risk" for further discussion.

Noninterest income is a significant source of our revenue and an important
component of our results of operations. The significant components of
noninterest income are leasing revenue, fees and service charges on deposit
accounts, net gains on sales of loans and leases, card and ATM revenue, wealth
management revenue and servicing fee revenue. Leasing revenue generates
noninterest income primarily from operating and sales-type leases. Primary
drivers of fees and service charges on deposit accounts include the number of
customers we attract, the customers' level of engagement and the frequency with
which the customer uses our solutions. Providing a wide range of consumer
banking services is an integral component of our business philosophy. We sell
loans, primarily secured by consumer real estate, which results in gains on
sales, as well as servicing fee income. Primary drivers of gains on sales
include our ability to originate loans, identify loan buyers and execute loan
sales.



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Proposed Merger with Huntington Bancshares Incorporated

TCF and Huntington Bancshares Incorporated ("Huntington") have entered into an
Agreement and Plan of Merger, dated as of December 13, 2020. Under the merger
agreement, TCF will merge with and into Huntington, with Huntington continuing
as the surviving entity. Immediately following the merger, TCF Bank will merge
with and into The Huntington National Bank, with The Huntington National Bank as
the surviving bank. The merger agreement was approved by the boards of directors
of TCF and Huntington, and is subject to shareholder and regulatory approval and
other customary closing conditions. The transaction is anticipated to close in
the second quarter of 2021. The transaction is discussed in more detail in "Note
3. Business Combinations" of the Notes to Consolidated Financial Statements
under Item 8 of this Annual Report. See Part I, Item 1A, "Risk Factors -
Strategic Risks - We face risks and uncertainties related to our proposed merger
with Huntington and Failure to complete our proposed merger with Huntington
could negatively impact our business, financial results and stock price" for
further discussion.

The following portions of this Management's Discussion and Analysis of Financial
Condition and Results of Operations ("Management's Discussion and Analysis")
focus in more detail on the results of operations for 2020, 2019 and 2018 and on
information about TCF's financial condition, loan and lease portfolio,
liquidity, funding resources, capital and other matters.

Critical Accounting Policies and Estimates



Our Consolidated Financial Statements are prepared in accordance with GAAP,
Securities and Exchange Commission ("SEC") rules and interpretive releases and
general practices within our industry. Application of these principles requires
management to establish accounting policies and make estimates, assumptions and
complex judgments that affect the amounts reported in our Consolidated Financial
Statements and accompanying notes. The estimates, assumptions and judgments are
based on historical experience and various assumptions that we believe to be
reasonable as of the date of the financial statements; accordingly, as this
information changes, our Consolidated Financial Statements could reflect
different estimates, assumptions and judgments. Actual results could differ
significantly from those estimates.

Certain accounting measurements inherently have a greater reliance on the use of
estimates, assumptions and judgments and, as such, have a greater possibility of
producing results that could be materially different than originally reported.
We use third-party sources to assist us with developing certain estimates,
assumptions and judgments regarding certain amounts reported in our Consolidated
Financial Statements and accompanying notes. When using third-party sources,
management remains responsible for complying with GAAP. To meet management's
responsibilities, we have processes in place to develop an understanding of the
third-party methodologies used and to design and implement internal controls.

We have identified the determination of the allowance for credit losses (loans
and leases and unfunded lending commitments), accounting for business
combinations (including fair value of acquired loans and leases and core deposit
intangibles), and the evaluation of goodwill impairment to be the accounting
areas that require the most subjective or complex judgments and, as such, could
be most subject to revision as new or additional information becomes available
or circumstances change, including overall changes in the economic climate
and/or market interest rates. Therefore, we consider these to be critical
accounting policies and estimates and discuss them directly with the Audit
Committee of our Board of Directors.

See "Note 2. Summary of Significant Accounting Policies" of Notes to Consolidated Financial Statements for further discussion of our significant accounting policies.


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Allowance for Credit Losses

The allowance for credit losses ("ACL") represents management's estimate of
current credit losses expected to be incurred in the loan and lease portfolios
over the remaining expected life of each financial asset at the balance sheet
date, including known or anticipated problem loans and leases, as well as for
loans and leases which are not currently known to require specific allowances.
The ACL includes the allowance for loan and lease losses ("ALLL") and a reserve
for unfunded lending commitments ("RULC"). Determining the amount of the ACL is
considered a critical accounting estimate because it requires significant
judgment and the use of estimates related to the amounts and timing of expected
future cash flows, adjustments for forward-looking information, estimates of
losses based on measurement date credit risk characteristics and consideration
of other qualitative factors, all of which may be susceptible to significant
change.

Events that are not within our control, such as changes in economic conditions,
could change and could cause the ACL to be overstated or understated. The amount
of ACL is affected by net charge-offs or recoveries and the provision or benefit
for credit losses charged to earnings, which increase or decrease the ACL.

The amount of the ACL significantly depends on management's estimates of key
factors and assumptions affecting valuation, appraisals of collateral,
evaluations of performance and status, the amounts and timing of future cash
flows expected to be received, forecasts of future economic conditions and
reversion periods. Such estimates, appraisals, evaluations, cash flows and
forecasts may be subject to frequent adjustments due to changing economic
prospects of borrowers, lessees, properties or economic conditions. These
estimates are reviewed quarterly and adjustments, if necessary, are recorded in
the provision for credit losses in the periods in which they become known.

See "Note 2. Summary of Significant Accounting Policies" and "Note 8. Allowance
for Credit Losses and Credit Quality" of the Consolidated Financial Statements
for additional disclosure regarding our ACL.

Accounting for Business Combinations



In determining the estimated fair value of assets acquired as part of the
TCF/Chemical Merger, including the estimated fair value of acquired loans and
leases and a core deposit intangible, management relied on a framework of
internal controls in place to evaluate the relevance and reliability of key
inputs and assumptions used in the fair value and to ensure the mathematical
accuracy used to determine an appropriate fair value. Acquired loans and leases
were valued using a discounted cash flow methodology with adjustments to
contractual cash flows for probability of default, loss given default, market
rates and prepayments speeds. Management based the assumptions used on
historical data or available market information. The fair value of the core
deposit intangible was estimated under the income approach based on discounted
net cash flows. This estimate was determined by projecting net cash flow
benefits derived from estimating costs to carry deposits compared to alternative
funding costs, and includes key assumptions related to deposit interest rates,
servicing costs, customer attrition rates, costs of alternative funding,
discount rate, and net maintenance costs.

These assumptions were based on both internal data and available market
information. Management reviewed the relevance and reliability of key valuation
inputs used to support key assumptions. In cases where management utilized a
third-party to assist with the valuation, management assessed the qualifications
of the third-party and reviewed all outputs provided by the third-party for
reasonableness. See "Note 3. Business Combinations" and "Note 2. Summary of
Significant Accounting Policies" for further information.

Goodwill

Goodwill represents the excess of the purchase price of our business
acquisitions and purchases of banking centers over the fair value of the net
assets acquired. Goodwill is not amortized, but rather is tested by management
annually in the fourth quarter for impairment, or more frequently if triggering
events occur and indicate potential impairment, in accordance with ASC Topic
350-20, Goodwill (ASC 350-20). ASC 350-20 allows an entity to assess qualitative
factors to determine whether it is more-likely-than-not that the fair value of a
reporting unit is less than its carrying amount. ASC 350-20 also allows an
entity to bypass the qualitative assessment approach and determine if goodwill
is impaired utilizing a quantitative assessment approach.


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During each quarter of 2020 we evaluated if there were any goodwill impairment
triggering events and whether it was more-likely-than-not that the fair value of
any reporting unit was less than its carrying amount. We assessed economic
conditions, including projections of the duration of current conditions and
timing of a potential recovery; industry and market considerations; government
intervention and regulatory updates; the impact of recent events to financial
performance and cost factors of the reporting units including TCF/Chemical
Merger synergies; the market price of our common stock and other relevant
events. At the conclusion of each assessment, we determined that it was not
more-likely-than-not that the fair value of each reporting unit was less than
its carrying amount. During the fourth quarter we completed our annual
impairment test, which did not indicate impairment for any reporting unit, nor
were any reporting units at risk. If economic conditions deteriorate, or the
pandemic's effects prolong or worsen, it may be more-likely-than-not that the
fair value of one or more of TCF's reporting units falls below its respective
carrying amount and would need to be evaluated for impairment.

Results of Operations



Performance Summary We reported net income of $222.8 million for 2020, compared
with $295.5 million for 2019 and $304.4 million for 2018. Merger-related
expenses included in net income totaled $203.9 million for the year ended
December 31, 2020 and $172.0 million for the year ended December 31, 2019.
Notable items, on a pre-tax basis, for the year ended December 31, 2020,
included $17.6 million of loan servicing rights impairment, $14.2 million of
gains on sales of branches, net of expense related to branch exit costs and
$4.0 million of expense related to the sale of the Legacy TCF auto finance
portfolio. Notable items, on a pre-tax basis, for the year ended December 31,
2019, included a $32.1 million loss on sale and expenses related to the Legacy
TCF auto finance portfolio, a $17.3 million loss on termination of interest rate
swaps, $9.4 million of expense associated with the write-down of company-owned
vacant land parcels due to an intent to sell and branch exit costs, $6.3 million
of expense related to pension fair valuation adjustment on plans with previously
announced terminations, and $3.9 million of loan servicing rights impairment,
partially offset by $5.9 million of gain on sales of certain investment
securities. The year ended December 31, 2019, also included $11.8 million of tax
basis adjustment benefits considered a notable item. For the year ended
December 31, 2018, net income included a $32.0 million pre-tax charge related to
the settlement to resolve certain matters with the Consumer Financial Protection
Bureau (the "CFPB") and Office of the Comptroller of the Currency (the "OCC")
considered a notable item. Adjusted net income, a non-GAAP financial measure
that excludes merger-related expenses and the identified notable items, net of
tax, was $389.5 million for the year ended December 31, 2020, compared to $461.2
million for 2019 and $329.9 million for 2018. See "Non-GAAP Financial Measures"
in this Management's Discussion and Analysis for further information.

We reported diluted earnings per common share of $1.40 for 2020, compared with
$2.55 for 2019 and $3.43 for 2018. Adjusted diluted earnings per common share, a
non-GAAP financial measure that excludes merger-related expenses and the
identified notable items, was $2.50 for the year ended December 31, 2020,
compared to $4.04 for 2019 and $3.73 for 2018. See "Non-GAAP Financial Measures"
in this Management's Discussion and Analysis for further information.

The following table provides our financial ratios and adjusted ratios
(non-GAAP), which exclude merger-related expenses and the identified notable
items.
Summary of Financial Ratios
                                                               Year Ended December 31,                                Change From
                                                                                                                         2020/
                                                  2020                   2019                   2018                      2019
Return on average assets ("ROAA")                    0.48  %                0.92  %                1.37  %            (44)    bps
Return on average common equity ("ROACE")            3.88                   7.67                  12.42              (379)
Return on average tangible common equity
("ROATCE')(1)                                        5.73                   9.81                  13.56              (408)
Efficiency ratio                                    74.34                  75.92                  69.34              (158)
Adjusted Financial Results (non-GAAP)
Adjusted ROAA(1)                                     0.82  %                1.41  %                1.48  %            (59)    bps
Adjusted ROACE(1)                                    6.92                  12.13                  13.51              (521)
Adjusted ROATCE(1)                                   9.88                  15.34                  14.74              (546)
Adjusted efficiency ratio(1)                        60.95                  60.58                  64.77                37


(1)See section entitled "Non-GAAP Financial Measures" in this Management's Discussion and Analysis for further information.


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Consolidated Results of Operations Analysis



Net Interest Income  Net interest income was $1.5 billion for 2020, compared
with $1.3 billion for 2019 and $1.0 billion for 2018. Net interest income, our
largest source of revenue (revenue is comprised of net interest income and
noninterest income), represented 74.9% of our total revenue for 2020, compared
with 73.5% for 2019 and 68.9% for 2018. The increases in net interest income in
2020, compared to 2019, as well as 2019, compared to 2018, was primarily
attributable to the increase in interest-earning assets acquired in the
TCF/Chemical Merger, partially offset by the increase in interest-bearing
liabilities acquired in the TCF/Chemical Merger.

Purchase accounting accretion and amortization included in net interest income
was $84.2 million for 2020, compared to $58.9 million for 2019. At December 31,
2020, the remaining fair value discount from purchase accounting on acquired
loans totaled $108.1 million. Additionally, 2020 net interest income recorded
included $43.4 million of interest and fee income from PPP loans less funding
costs. Fully taxable equivalent ("FTE") adjustments to net interest income
totaled $12.1 million for 2020, compared to $8.4 million for 2019 and $3.6
million for 2018. Adjusted net interest income, including FTE adjustments and
excluding purchase accounting accretion and amortization and the impact from PPP
loans, a non-GAAP financial measure, was $1.4 billion for 2020, compared to $1.2
billion for 2019 and $1.0 billion for 2018. See "Non-GAAP Financial Measures" in
this Management's Discussion and Analysis for further information. Net interest
income (FTE), a non-GAAP financial measure, was $1.6 billion for 2020, compared
with $1.3 billion for 2019 and $1.0 billion for 2018. Net interest income (FTE),
a non-GAAP financial measure, is the difference between interest income and
interest expense adjusted for the tax benefit received on tax-exempt loans,
leases and investment securities. The presentation of net interest income (FTE)
is not in accordance with GAAP but is customary in the banking industry. For
further information on the calculation of net interest income (FTE), see the
tables below.

Net interest margin was 3.47% for 2020, compared to 4.17% for 2019 and 4.66% for
2018. Net interest margin (FTE), a non-GAAP financial measure, is calculated by
dividing net interest income (FTE) by average interest-earning assets, expressed
as a percentage. Net interest income and net interest margin are affected by (i)
changes in prevailing short- and long-term interest rates, (ii) loan, lease and
deposit pricing strategies and competitive conditions, (iii) the volume and mix
of interest-earning assets, noninterest-bearing deposits and interest-bearing
liabilities, (iv) the level of nonaccrual loans and leases and other real estate
owned and (v) the impact of modified loans and leases. Net interest margin (FTE)
was 3.50% for 2020, compared with 4.20% for 2019 and 4.69% for 2018. The
decrease in both net interest margin and net interest margin (FTE) for the year
ended December 31, 2020, compared to 2019, was primarily due to a decrease in
the yield earned on loans and leases as result of the lower average yields added
to the portfolio through the TCF/Chemical Merger in addition to the impact of
the Federal Reserve's rate cuts and higher cash balances, partially offset by
lower cost of funds. The decrease in both net interest margin and net interest
margin (FTE) for the year ended December 31, 2019, compared to 2018, was
primarily driven by a decrease in loan and lease yields due to the impact of the
lower overall yield earned on loans and leases we acquired through the
TCF/Chemical Merger, the impact of the Federal Reserve's interest rate cuts on
our variable-rate loans and an increase in our cost of funds. The presentation
of net interest margin (FTE) is not in accordance with GAAP but is customary in
the banking industry. For further information on the calculation of net interest
income (FTE), see the tables below.

The following tables present the average balances of our major categories of
assets and liabilities, interest income and expense (FTE), average interest
rates earned and paid on assets and liabilities, net interest income (FTE), net
interest spread and net interest margin for the years ended December 31, 2020,
2019 and 2018. The presentation of net interest income (FTE) is not in
accordance with GAAP but is customary in the banking industry and ensures
comparability of net interest income arising from both taxable and tax-exempt
loans and investment securities.

                                       41

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  Table of Con    tents
                                                                                      Year Ended December 31,
                                                                2020                                                          2019                                                          Change
                                           Average                                 Yields and            Average                                 Yields and            Average                                Yields and
(Dollars in thousands)                     Balance              Interest             Rates               Balance              Interest             Rates               Balance             Interest           Rates (bps)
Assets:
Federal Home Loan Bank and Federal
Reserve Bank stocks                    $    379,482          $    13,356               3.52  %       $    210,001          $     6,030               2.87  %       $    169,481          $   7,326                 65
Investment securities held-to-maturity      141,604                1,842               1.30               144,318                2,950               2.04                (2,714)            (1,108)               (74)
Investment securities
available-for-sale:
Taxable                                   6,050,684              142,620               2.36             3,516,413              103,077               2.93             2,534,271             39,543                (57)
Tax-exempt(1)(2)                            713,658               20,470               2.87               541,525               14,746               2.72               172,133              5,724                 15
Loans and leases held-for-sale              351,898               11,394               3.24               336,292               18,599               5.53                15,606             (7,205)              (229)
Loans and leases(1)(2)(3)
Commercial and industrial                11,924,867              559,783               4.66             8,371,066              519,506               6.18             3,553,801             40,277               (152)
Commercial real estate                    9,547,701              405,173               4.17             5,523,347              298,414               5.33             4,024,354            106,759               (116)
Lease financing                           2,693,493              133,272               4.95             2,570,109              131,547               5.12               123,384              1,725                (17)
Residential mortgage                      6,053,036              233,723               3.86             3,902,959              170,706               4.37             2,150,077             63,017                (51)
Home equity                               3,405,718              179,628               5.27             3,272,760              101,687               5.51               132,958             77,941                (24)
Consumer installment                      1,412,510               71,392               5.05             1,844,714              214,116               6.54              (432,204)          (142,724)              (149)
Total loans and leases                   35,037,325            1,582,971               4.49            25,484,955            1,435,976               5.61             9,552,370            146,995               (112)
Interest-bearing deposits with banks
and other                                 1,352,825                5,096               0.38               534,979               14,326               2.66               817,846             (9,230)              (228)
Total interest-earning assets            44,027,476            1,777,749               4.01            30,768,483            1,595,704               5.17            13,258,993            182,045               (116)
Other assets                              4,373,462                                                     2,758,447                                                     1,615,015
Total assets                           $ 48,400,938                                                  $ 33,526,930                                                  $ 14,874,008
Liabilities and Equity:
Noninterest-bearing deposits           $  9,844,485                                                  $  5,622,092                                                  $  4,222,393
Interest-bearing deposits:
Savings                                   9,093,600               28,408               0.31             7,203,987               52,087               0.72             1,889,613            (23,679)               (41)
Certificates of deposit                   6,812,648               89,835               1.32             6,086,251              122,494               2.01               726,397            (32,659)               (69)
Checking                                  6,676,803               11,947               0.18             3,920,613               13,961               0.36             2,756,190             (2,014)               (18)
Money market                              5,289,371               36,796               0.70             2,729,156               37,615               1.38             2,560,215               (819)               (68)
Total interest-bearing deposits          27,872,422              166,986               0.60            19,940,007              226,157               1.13             7,932,415            (59,171)               (53)
Total deposits                           37,716,907              166,986               0.44            25,562,099              226,157               0.88            12,154,808            (59,171)               (44)

Borrowings:


Short-term borrowings                     2,023,374               17,279               0.84             1,279,073               20,836               1.61               744,301             (3,557)               (77)
Long-term borrowings                      1,459,004               42,996               2.93             1,592,915               51,236               3.19              (133,911)            (8,240)               (26)
Total borrowings                          3,482,378               60,275               1.72             2,871,988               72,072               2.49               610,390            (11,797)               (77)
Total interest-bearing liabilities       31,354,800              227,261               0.72            22,811,995              298,229               1.30             8,542,805            (70,968)               (58)
Total deposits and borrowings            41,199,285              227,261               0.55            28,434,087              298,229               1.05            12,765,198            (70,968)               (50)
Other liabilities                         1,528,080                                                     1,177,805                                                       350,275
Total liabilities                        42,727,365                                                    29,611,892                                                    13,115,473
Total TCF Financial Corp.
shareholders' equity                      5,649,567                                                     3,889,204                                                     1,760,363
Non-controlling interest in
subsidiaries                                 24,006                                                        25,834                                                        (1,828)
Total equity                              5,673,573                                                     3,915,038                                                     1,758,535
Total liabilities and equity           $ 48,400,938                                                  $ 33,526,930                                                  $ 14,874,008
Net interest spread (FTE)                                                              3.46                                                          4.12                                                         (66)
Net interest income (FTE) and net
interest margin (FTE)                                        $ 1,550,488               3.50                                $ 1,297,475               4.20  %                             $ 253,013                (70)
Reconciliation of Net Interest Income
(FTE) and Net Interest Margin (FTE)
Net interest income and net interest
margin (GAAP)                                                $ 1,538,401               3.47  %                             $ 1,289,032               4.17  %                             $ 249,369                (70)
Adjustments for taxable equivalent
interest
Loans and leases(1)(3)                                             7,785                                                         5,348                                                       2,437
Tax-exempt investment securities(1)(3)                             4,302                                                         3,095                                                       1,207
Total FTE adjustments                                             12,087                                                         8,443                                                       3,644
Net interest income (FTE) and net
interest margin (FTE)                                        $ 1,550,488               3.50  %                             $ 1,297,475               4.20  %                             $ 253,013                (70)


(1)Interest and yields are presented on a FTE basis.
(2)The yield on tax-exempt loans, leases and available-for-sale investment
securities is computed on a FTE basis using a statutory federal income tax rate
of 21%.
(3)Average balances of loans and leases include nonaccrual loans and leases and
are presented net of unearned income

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  Table of Con    tents
                                                                                       Year Ended December 31,
                                                                 2019                                                           2018                                                          Change
                                           Average                                 Yields and             Average                                 Yields and             Average                                 Yields and
(Dollars in thousands)                     Balance              Interest              Rates               Balance              Interest              Rates               Balance             Interest           Rates (bps)

Assets:

Federal Home Loan Bank and Federal
Reserve Bank stocks                    $    210,001          $     6,030                2.87  %       $     89,774          $     3,618                4.03  %       $    120,227          $   2,412                (116)
Investment securities held-to-maturity      144,318                2,950                2.04               154,619                3,970                2.57               (10,301)            (1,020)                (53)
Investment securities
available-for-sale:
Taxable                                   3,516,413              103,077                2.93             1,390,016               37,436                2.69             2,126,397             65,641                  24
Tax-exempt(1)(2)                            541,525               14,746                2.72               815,540               21,694                2.66              (274,015)            (6,948)                  6
Loans and leases held-for-sale              336,292               18,599                5.53               103,240                6,686                6.48               233,052             11,913                 (95)
Loans and leases(1)(2)(3)
Commercial and industrial                 8,371,066              519,506                6.18             6,171,331              386,541                6.25             2,199,735            132,965               (7.00)
Commercial real estate                    5,523,347              298,414                5.33             2,799,523              135,791                4.78             2,723,824            162,623               55.00
Lease financing                           2,570,109              131,547                5.12             2,459,823              125,185                5.09               110,286              6,362                3.00
Residential mortgage                      3,902,959              170,706                4.37             1,788,729               95,375                5.33             2,114,230             75,331              (96.00)
Home equity                               3,272,760              101,687                5.51             2,579,271              142,700                5.53               693,489            (41,013)              (2.00)
Consumer installment                      1,844,714              214,116                6.54             3,028,370              200,356                6.62            (1,183,656)            13,760               (8.00)
Total loans and leases                   25,484,955            1,435,976                5.61            18,827,047            1,085,948                5.75             6,657,908            350,028              (14.00)
Interest-bearing deposits with banks
and other                                   534,979               14,326                2.66               229,698                8,346                3.63               305,281              5,980                 (97)
Total interest-earning assets            30,768,483            1,595,704                5.17            21,609,934            1,167,698                5.39             9,158,549            428,006                 (22)
Other assets                              2,758,447                                                      1,452,214                                                      1,306,233
Total assets                           $ 33,526,930                                                   $ 23,062,148                                                   $ 10,464,782
Liabilities and Equity:
Noninterest-bearing deposits           $  5,622,092                                                   $  3,843,494                                                   $  1,778,598
Interest-bearing deposits:
Savings                                   7,203,987               52,087                0.72             5,621,723               20,009                0.36             1,582,264             32,078                  36
Certificates of deposit                   6,086,251              122,494                2.01             4,897,937               75,385                1.54             1,188,314             47,109                  47
Checking                                  3,920,613               13,961                0.36             2,438,040                  714                0.03             1,482,573             13,247                  33
Money market                              2,729,156               37,615                1.38             1,553,255               11,582                0.75             1,175,901             26,033                  63
Total interest-bearing deposits          19,940,007              226,157                1.13            14,510,955              107,690                0.74             5,429,052            118,467                  39
Total deposits                           25,562,099              226,157                0.88            18,354,449              107,690                0.59             7,207,650            118,467                  29
Borrowings:
Short-term borrowings                     1,279,073               20,836                1.61                 3,288                   77                2.33             1,275,785             20,759                 (72)
Long-term borrowings                      1,592,915               51,236                3.19             1,412,186               43,067                3.03               180,729              8,169                  16
Total borrowings                          2,871,988               72,072                2.49             1,415,474               43,144                3.02             1,456,514             28,928                 (53)
Total interest-bearing liabilities       22,811,995              298,229                1.30            15,926,429              150,834                0.94             6,885,566            147,395                  36
Total deposits and borrowings            28,434,087              298,229                1.05            19,769,923              150,834                0.76             8,664,164            147,395                  29
Accrued expenses and other liabilities    1,177,805                                                        761,723                                                        416,082
Total liabilities                        29,611,892                                                     20,531,646                                                      9,080,246
Total TCF Financial Corp.
shareholders' equity                      3,889,204                                                      2,506,179                                                      1,383,025
Non-controlling interest in
subsidiaries                                 25,834                                                         24,323                                                          1,511
Total equity                              3,915,038                                                      2,530,502                                                      1,384,536
Total liabilities and equity           $ 33,526,930                                                   $ 23,062,148                                                   $ 10,464,782
Net interest spread (FTE)                                                               4.12                                                           4.63                                                          (51)
Net interest income (FTE) and net
interest margin (FTE)                                        $ 1,297,475                4.20  %                             $ 1,016,864                4.69                                $ 280,611                 (49)
Reconciliation of Net Interest Income
(FTE) and Net Interest Margin (FTE)
Net interest income and net interest
margin (GAAP)                                                $ 1,289,032                4.17  %                             $ 1,008,495                4.66  %                             $ 280,537                 (49)
Adjustments for taxable equivalent
interest
Loans and leases(1)(3)                                             5,348                                                          3,813                                                        1,535
Tax-exempt investment securities(1)(3)                             3,095                                                          4,556                                                       (1,461)
Total FTE adjustments                                              8,443                                                          8,369                                                           74
Net interest income (FTE) and net
interest margin (FTE)                                        $ 1,297,475                4.20  %                             $ 1,016,864                4.69  %                             $ 280,611                 (49)


(1)Interest and yields are presented on a FTE basis.
(2)The yield on tax-exempt loans, leases and available-for-sale investment
securities is computed on a FTE basis using a statutory federal income tax rate
of 21%.
(3)Average balances of loans and leases include nonaccrual loans and leases and
are presented net of unearned income.

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Table of Con tents

Volume and Rate Variance Analysis


                                                       Year Ended December 31, 2020 vs. 2019                              Year Ended December 31, 2019 vs. 2018
                                                     Increase (Decrease)                                                Increase (Decrease)
                                                      Due to Changes in                                                  Due to Changes in
                                                                      Average                                                            Average
(Dollars in thousands)                       Average Volume          Yield/Rate           Total Change          Average Volume          Yield/Rate           Total Change
Changes in Interest Income on
Interest-Earning Assets:
Federal Home Loan Bank and Federal Reserve
Bank stocks                                 $       5,699          $     

1,627 $ 7,326 $ 3,699 $ (1,287)

       $       2,412
Investment securities held-to-maturity                (54)              (1,054)                (1,108)                  (251)                (769)                (1,020)
Investment securities available-for-sale:
Taxable                                            62,845              (23,302)                39,543                 62,055                3,586                 65,641
Tax-exempt(1)                                       4,901                  823                  5,724                 (7,450)                 502                 (6,948)
Loans and leases held-for-sale                        827               (8,032)                (7,205)                13,023               (1,110)                11,913
Loans and leases(1)                               471,293             (324,298)               146,995                377,736              (27,708)               350,028
Interest-bearing deposits with banks and
other                                               9,813              (19,043)                (9,230)                 8,746               (2,766)                 5,980
Total interest-earning assets               $     555,324          $  (373,279)         $     182,045          $     457,558          $   (29,552)         $     428,006
Changes in Interest Expense on
Interest-Bearing Liabilities:
Interest-bearing deposits:
Savings                                            11,186              (34,865)               (23,679)                 6,877               25,201                 32,078
Certificates of deposit                            13,241              (45,900)               (32,659)                20,769               26,340                 47,109
Checking                                    $       6,936          $    (8,950)                (2,014)         $         684          $    12,563                 13,247
Money market                                       23,783              (24,602)                  (819)                12,275               13,758                 26,033
Interest-bearing deposits                          55,146             (114,317)               (59,171)                40,605               77,862                118,467
Short-term borrowings                               8,993              (12,550)                (3,557)                20,791                  (32)                20,759
Long-term borrowings                               (4,176)              (4,064)                (8,240)                 5,721                2,448                  8,169

Total interest-bearing liabilities $ 59,963 $ (130,931) $ (70,968) $ 67,117 $ 80,278

$     147,395
Total change in net interest income
(FTE)(2)                                    $     495,361          $  (242,348)         $     253,013          $     390,441          $  (109,830)         $     280,611

(1)Changes attributable to the combined impact of volume and rate have been allocated proportionately to the change due to volume and the change due to rate. (2)Computed on a FTE basis using a federal income tax rate of 21%.



Provision for Credit Losses  The provision for credit losses was $257.2 million
for 2020, compared with $65.3 million for 2019 and $46.8 million for 2018. The
provision for credit losses is comprised of the provision for credit losses
related to loans and leases and the provision (benefit) for credit losses
related unfunded lending commitments as follows:

                                                                     Year Ended December 31,
(In thousands)                                               2020              2019              2018
Provision for credit losses
Provision for credit losses related to loans and leases  $ 252,073          $ 65,282          $ 46,768
Provision (benefit) for credit losses related to
unfunded lending commitments(1)                              5,078               233               (51)
Total provision for credit losses(1)                     $ 257,151

$ 65,515 $ 46,717




(1)Provision for credit losses related to loans and leases and the provision
(benefit) for credit losses related to unfunded lending commitments are included
within provision for credit losses in the Consolidated Statements of Income
beginning January 1, 2020 as a result of the adoption of CECL.


                                       44
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  Table of Con    tents
The increase in provision for credit losses related to loans and leases of
$186.8 million in 2020, compared to 2019, reflects a build to the overall
allowance for loans and leases primarily due to the impact of COVID-19 and
additionally impacted by the adoption of CECL. During 2020, the COVID-19
pandemic had a negative impact on current and forecasted macroeconomic
conditions and created uncertainty around the performance of certain sectors
that have been more heavily impacted, including motor coach, shuttle bus, hotel,
retail commercial real estate, franchise, retail trade and fitness. Prior to the
adoption of CECL on January 1, 2020, the allowance for credit losses was
calculated under an incurred loss model which delayed recognition of loss until
it was probable the loss had been incurred. The accounting under CECL considers
current credit losses expected to be incurred in the loan and lease portfolios
over the remaining expected life of each financial asset and considers expected
future changes in macroeconomic conditions. In addition, as a result of the
adoption of CECL, the provision for credit losses now includes the provision
(benefit) for unfunded lending commitments that was previously included within
other noninterest expense. The increase in provision for credit losses in 2019,
compared to 2018, was primarily due to an increase in originated loan growth
driven by increased activity in the loan and lease portfolio as a result of the
TCF/Chemical Merger, and to a lesser extent, an increase in commercial and
industrial net charge-offs, primarily due to one loan relationship, and a
decrease in recoveries on previous charge-offs related to sales of consumer
nonaccrual and TDR loans. The increase in provision for credit losses related to
unfunded lending commitments of $4.8 million in 2020, compared to 2019, was
primarily due to macroeconomic conditions impacted by the COVID-19 pandemic,
partially offset by a decline in the total unfunded commitment balance. The
provision for credit losses is predominantly a function of our reserving
methodology used to determine the appropriate level of the allowance for credit
losses, which is a critical accounting estimate.

For further information, see "Consolidated Financial Condition Analysis - Credit
Quality" in this Management's Discussion and Analysis and "Note 8. Allowance for
Credit Losses and Credit Quality" of Notes to Consolidated Financial Statements.

Noninterest Income  The components of noninterest income were as follows:
                                              Year Ended December 31,                                                     Change
                                                                                                  2020 / 2019                               2019 / 2018
(Dollars in thousands)            2020               2019               2018                 $                % / bps                 $                 % / bps
Leasing revenue               $ 142,723          $ 163,718          $ 172,603          $  (20,995)               (12.8) %       $    (8,885)                (5.1) %
Fees and service charges on
deposit accounts                112,681            127,860            113,242             (15,179)               (11.9)              14,618       

12.9


Card and ATM revenue             88,699             87,221             78,406               1,478                  1.7                8,815        

11.2


Net gains on sales of loans
and leases                       86,776             26,308             33,695              60,468                    N.M.            (7,387)       

(21.9)


Wealth management revenue        25,701             10,413                  -              15,288                146.8               10,413             

N.M.


Servicing fee revenue            10,603             20,776             27,334             (10,173)               (49.0)              (6,558)               (24.0)
Net gains on investment
securities                        2,338              7,425                348              (5,087)               (68.5)               7,077                    N.M.
Other                            46,542             21,811             28,769              24,731                113.4               (6,958)               (24.2)

Total noninterest income $ 516,063 $ 465,532 $ 454,397 $ 50,531

                 10.9          $    11,135                  2.5
Total noninterest income as a
percentage of total revenue        25.1  %            26.5  %            31.1  %                                 -140 bps                                  -460 bps


N.M. Not Meaningful

Noninterest income was $516.1 million for 2020, compared to $465.5 million for
2019 and $454.4 million for 2018. Noninterest income for the year ended
December 31, 2020 included notable items of $17.6 million of loan servicing
rights impairment and a $14.7 million gain on the sale of our Arizona branches,
and for the year ended December 31, 2019 notable items included a $27.5 million
net loss on sale of the Legacy TCF auto finance portfolio, a $17.3 million loss
on termination of interest rate swaps and $3.9 million of loan servicing rights
impairment, and $5.9 million of gains on sales of certain investment securities.
Adjusted noninterest income, a non-GAAP financial measure that excludes the
identified notable items, was $519.0 million for 2020, compared to $508.3
million for 2019 and $454.4 million for 2018. See "Non-GAAP Financial Measures"
in this Management's Discussion and Analysis for further information.

Leasing revenue Leasing revenue was $142.7 million for 2020, compared with
$163.7 million for 2019 and $172.6 million for 2018. Leasing revenue is impacted
by changes in our operating lease revenue and sales-type lease revenue through
our equipment financing activity. The decrease in leasing revenue for 2020,
compared to 2019 was primarily due to a decrease in sales-type lease revenue
through our equipment financing activity impacted by the COVID-19 pandemic.

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Table of Con tents



Fees and service charges on deposit accounts Fees and service charges on deposit
accounts were $112.7 million for 2020, compared with $127.9 million for 2019 and
$113.2 million for 2018. The decrease in 2020, compared to 2019, was primarily
attributable to customer account balances maintaining excess liquidity through
the COVID-19 pandemic resulting in a decline in fees charged, partially offset
by incremental fees resulting from the TCF/Chemical Merger. The increase in
2019, compared to 2018, was primarily attributable to incremental fees resulting
from the TCF/Chemical Merger.

Card and ATM revenue Card and ATM revenue was $88.7 million for 2020, compared
with $87.2 million for 2019 and $78.4 million for 2018. The increase in 2020,
compared to 2019, was primarily attributable to incremental revenue resulting
from the TCF/Chemical Merger, partially offset by the decline in debit card and
ATM activity related to the COVID-19 pandemic. The increase in 2019, compared to
2018, was primarily due to incremental revenue resulting from the TCF/Chemical
Merger.

Net gains on sales of loans and leases  Net gains on sales of loans and leases
were $86.8 million for 2020, compared with $26.3 million for 2019 and $33.7
million for 2018. The increase in 2020, compared to 2019, was primarily due the
higher volume of consumer loans sold resulting from the TCF/Chemical Merger and
the $27.5 million loss related to the sale of the Legacy TCF auto finance
portfolio during 2019. The decrease in 2019 from 2018 was primarily due to the
$27.5 million loss related to the sale of the Legacy TCF auto finance portfolio,
partially offset by the higher volume of consumer loans sold resulting from the
TCF/Chemical Merger and the recognition of a $3.7 million gain on sale of loans
and leases related to a nonaccrual and TDR loan sale. We sold $2.4 billion of
loans and leases in 2020, compared with $2.9 billion in 2019, or $1.8 billion
excluding the sale of the Legacy TCF auto finance portfolio, and $1.2 billion in
2018.

Wealth management Wealth management revenue is comprised of investment fees that
are generally based on the market value of assets within a trust account,
custodial fees and fees from the sale of investment products and is a revenue
stream added as a result of the TCF/Chemical Merger. Revenues from wealth
management were $25.7 million for 2020, compared with $10.4 million for 2019.
The increase in 2020, compared to 2019, was primarily attributable to it being a
new revenue stream as a result of the TCF/Chemical Merger.

Servicing fee revenue  Servicing fee revenue was $10.6 million for 2020,
compared with $20.8 million for 2019 and $27.3 million for 2018. The decreases
in 2020, compared to 2019, and in 2019, compared to 2018, were primarily due to
the continued run-off in the auto finance serviced for others portfolio,
partially offset by revenue added as a result of the servicing portfolio
acquired in the TCF/Chemical Merger.

Net gains on investment securities Net gains on investment securities were $2.3
million for 2020, compared to $7.4 million for 2019 and $348 thousand for 2018.
Net gains on investment securities decreased in 2020, compared to 2019 due to
lower sales activity and increased in 2019, compared to 2018, due to increased
sales activity. In 2019, we sold $1.6 billion of investment securities as a
result of balance sheet repositioning following the TCF/Chemical Merger
resulting in $5.9 million of net gains.

Other Other noninterest income was $46.5 million for 2020, compared to $21.8
million for 2019 and $28.8 million for 2018. The increase in 2020, compared to
2019, was primarily due to the $17.3 million loss on termination of interest
rate swaps recognized in 2019 and the $14.7 million gain on the sale of our
Arizona branches recognized in 2020, partially offset by an increase in loan
servicing rights impairment. The increase in 2019, compared to 2018, was
primarily due to a $17.3 million loss related to the termination of interest
rate swaps and the recognition of $3.9 million of loan servicing rights
impairment, partially offset by an increase in incremental revenue resulting
from the TCF/Chemical Merger.


                                       46

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  Table of Con    tents
Noninterest Expense  The components of noninterest expense were as follows:

                                              Year Ended December 31,                                                    Change
                                                                                                   2020 / 2019                              2019 / 2018

(Dollars in thousands)            2020               2019               2018                 $                 % / bps                 $                % / bps
Compensation and employee
benefits                      $ 702,702          $ 576,922          $ 502,196          $  125,780                  21.8  %       $   74,726                14.9  %
Occupancy and equipment         209,690            189,560            165,839              20,130                  10.6              23,721       

14.3


Lease financing equipment
depreciation                     73,204             76,426             73,829              (3,222)                 (4.2)              2,597        

3.5


Net foreclosed real estate
and repossessed assets            5,136             13,523             17,050              (8,387)                (62.0)             (3,527)              (20.7)
Merger-related expenses         203,888            171,968                  -              31,920                  18.6             171,968                   N.M.
Other                           332,751            303,716            255,486              29,035                   9.6              48,230       

18.9

Total noninterest expense $ 1,527,371 $ 1,332,115 $ 1,014,400 $ 195,256

                  14.7          $  317,715

31.3


Full-time equivalent staff
(at period end)                   6,881              7,762              5,278                (881)                (11.4)              2,484                47.1
Efficiency ratio                  74.34  %           75.92  %           69.34  %                                 (158) bps                                 658 bps
Adjusted efficiency ratio
(non-GAAP)(1)                     60.95              60.58              64.77                                           37                                   (419)


N.M. Not Meaningful
(1)See "Consolidated Financial Condition Analysis - Non-GAAP Financial Measures"
in this Management's Discussion and Analysis for further information.

Noninterest expense was $1.5 billion for 2020, compared to $1.3 billion for 2019
and $1.0 billion for 2018. Noninterest expense included merger-related expenses
of $203.9 million in 2020 and $172.0 million in 2019. Noninterest expense for
2020 included $4.0 million of expenses related to the sale of the Legacy TCF
auto finance portfolio ($1.6 million included in occupancy and equipment,
$1.4 million included in other noninterest expense and $1.0 million included in
compensation and employee benefits) and $0.6 million of expense related to
branch exit costs, included in other noninterest expense, considered notable
items. Noninterest expense for 2019 included $9.4 million of expense associated
with the write-down of company-owned vacant land parcels and branch exit costs,
included in other noninterest expense, and $4.7 million of expenses related to
the sale of the Legacy TCF auto finance portfolio ($2.2 million included in
other noninterest expense, $1.5 million included in occupancy and equipment and
$930 thousand included in compensation and employee benefits) and $6.3 million
of expense related to a pension fair value adjustment on plans with previously
announced terminations, included in other noninterest expense, considered
notable items. Noninterest expense for 2018 included a $32.0 million charge
related to the settlement with the CFPB and the OCC, included in other
noninterest expense, considered a notable item. Adjusted noninterest expense, a
non-GAAP financial measure that excludes merger-related expenses and the
identified notable items, was $1.3 billion for 2020, compared to $1.1 billion
for 2019 and $982.4 million for 2018. During 2020 we achieved our committed
merger expense synergies on schedule while completing our integration activities
by our target delivery date. See "Non-GAAP Financial Measures" in this
Management's Discussion and Analysis for further information.

Compensation and employee benefits Compensation and employee benefits expense
was $702.7 million for 2020, compared with $576.9 million for 2019 and $502.2
million for 2018. The increase in 2020, compared to 2019, was primarily due to
the staff additions beginning August 1, 2019 resulting from the TCF/Chemical
Merger. In 2020, compensation and employee benefits expense also included $21.6
million of executive severance expense and $1.0 million of expense related to
the sale of the Legacy TCF auto finance portfolio. The increase in 2019,
compared to 2018, was primarily due to the staff additions resulting from the
TCF/Chemical Merger. In 2019, compensation and employee benefits expense also
included $930 thousand of expense related to the sale of the Legacy TCF auto
finance portfolio.

Occupancy and equipment Occupancy and equipment expense was $209.7 million for
2020, compared with $189.6 million for 2019 and $165.8 million for 2018. The
increase in 2020, compared to 2019, was primarily due to the incremental
operating costs associated with the TCF/Chemical Merger in addition to expenses
related to COVID-19 safety protocols. The increase in 2019, compared to 2018,
was primarily due to the incremental operating costs associated with the
TCF/Chemical Merger in addition to $1.5 million of expense related to the sale
of the Legacy TCF auto finance portfolio. Depreciation and amortization expense
related to premises and equipment was $76.0 million, $75.3 million and $48.6
million for 2020, 2019 and 2018, respectively.

Lease financing equipment depreciation Lease financing equipment depreciation was $73.2 million for 2020, compared with $76.4 million for 2019 and $73.8 million for 2018. Shifts in lease financing equipment depreciation are the result of changes in balances of leased equipment.


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Table of Con tents



Net foreclosed real estate and repossessed assets  Net foreclosed real estate
and repossessed assets expense was $5.1 million for 2020, compared with $13.5
million for 2019 and $17.1 million for 2018. The decrease in 2020, compared to
2019, was primarily due to a decrease in repossessed asset expense, partially
offset by a reduction in gains on sales of repossessed assets. The decrease in
2019, compared to 2018, was primarily due to an increase in gains on sales of
repossessed assets.

Merger-related expenses Merger-related expenses were $203.9 million for 2020,
compared to $172.0 million for 2019. Merger-related expenses consisted primarily
of employment related expenses, professional fees and merger-related branch
closing expenses. Merger-related expenses for 2020 included $5.2 million related
to our pending merger with Huntington, while the remainder of merger-related
expenses in 2020 and all in 2019 related to the TCF/Chemical Merger. We had no
merger-related expense in 2018.

Other noninterest expense Other noninterest expense was $332.8 million for 2020,
compared with $303.7 million for 2019 and $255.5 million for 2018. The increase
in 2020, compared to 2019, was primarily due to incremental costs associated
with the TCF/Chemical Merger. Other noninterest expense for 2020 also included
$7.0 million of impairment, or $5.6 million after tax, of historic tax credits
placed into service, which is offset by income tax benefit within income tax
expense related to the same tax credits. The increase in 2019, compared to 2018,
was primarily due to incremental costs associated with the TCF/Chemical Merger
and notable items including: $9.4 million of expense related to write-downs of
company-owned vacant land parcels and branch exit costs, $6.3 million of expense
related to pension fair value adjustments on plans with previously announced
terminations and $2.2 million of expense related to the sale of the Legacy TCF
auto finance portfolio, partially offset by the settlement with the CFPB and the
OCC of $32.0 million that was recognized in 2018. Other noninterest expense for
2019 also included a $4.0 million impairment, or $3.2 million after tax, of
historic tax credits placed into service. See "Note 25. Other Noninterest Income
and Expense" of Notes to Consolidated Financial Statements for further
information.

Income Taxes  Income tax expense was $39.9 million, or 14.8% of income before
income tax expense, for 2020, compared with $50.2 million, or 14.1%, for 2019
and $86.1 million, or 21.4%, for 2018. The decrease in income tax expense for
2020, compared to 2019, was primarily due to a decrease in pre-tax income.
Income tax expense for 2020 included a benefit of $16.0 million attributable to
tax net operating loss ("NOL") carryback benefits associated with the
Coronavirus Aid, Relief and Economic Security ("CARES" Act). The $16.0 million
benefit included a $9.0 million benefit associated with pre-2020 depreciation
method changes and a $7.0 million benefit related to estimated current year
activity. The decrease in income tax expense for 2019, compared to 2018, was
primarily due to the inclusion of $11.8 million of tax basis adjustment
benefits, a $5.7 million benefit provided by the repricing of our net deferred
tax position in connection with the completion of the TCF/Chemical Merger and a
$4.6 million income tax benefit related to federal historic tax credits. The
remaining fluctuations in our effective income tax rate reflect changes for each
period in the proportion of tax-exempt interest income, nondeductible expenses
and credits relative to income before income tax expense. See "Note 2. Summary
of Significant Accounting Policies" and "Note 26. Income Taxes" of Notes to
Consolidated Financial Statements for further information.

The CARES Act was enacted in March 2020 in response to the COVID-19 pandemic.
The CARES Act, among other things, permits NOLs from 2018, 2019 and 2020 to be
carried back five years to generate refunds of previously paid income taxes.
Additionally, it provides retroactive changes in depreciation rules for certain
qualified improvement property. Guidance implementing the CARES Act's provisions
provided retroactive choices to opt into or out of the full expensing of
equipment purchases in the year of acquisition. During 2020, we implemented
these and other options provided by the CARES Act, which resulted in a
forecasted full year 2020 federal tax NOL. Carrying back 2020 federal tax NOLs
to pre-2018 years results in tax refunds and a permanent tax benefit associated
with the difference between the 21% federal tax rate in 2020 and the 35% federal
tax rate before 2018.

Reportable Segment Results Our reportable segments are Consumer Banking,
Commercial Banking and Enterprise Services. See "Note 27. Reportable Segments"
of Notes to Consolidated Financial Statements for further information regarding
net income (loss), revenues and assets for each of our reportable segments.

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  Table of Con    tents
Consumer Banking
Consumer Banking is comprised of all of our consumer and small business-facing
businesses and includes Retail Banking, Wealth Management, Residential and
Consumer Lending, and Business Banking. Our consumer banking strategy is
primarily to generate deposits and originate high credit quality loans for
investment and sale. Deposits are generated from consumers and small businesses
to provide a source of low cost funds, with a focus on building and maintaining
quality customer relationships.
                                                                   Year Ended December 31,
(In thousands)                                         2020                  2019                  2018
Consumer Banking
Net interest income                               $    834,106          $    676,552          $   569,220
Provision for credit losses                             16,945                16,550               24,661
Net interest income after provision for credit
losses                                                 817,161               660,002              544,559
Noninterest income                                     318,029               273,915              262,797
Noninterest expense                                    852,733               753,904              669,967
Income before income tax expense                       282,457               180,013              137,389
Income tax expense                                      62,654                38,353               31,645

Net income available to common shareholders            219,803               141,660              105,744
Total assets (at period end)                      $ 13,663,990          $ 

14,224,545 $ 6,414,228




Consumer Banking generated net income available to common shareholders of
$219.8 million for 2020, compared with $141.7 million for 2019 and $105.7
million for 2018. The increase in 2020, compared to 2019, was primarily due to
the incremental income resulting from the TCF/Chemical Merger and lower cost of
funds, partially offset by an increase in incremental operating costs and a
decrease in fees and service charges on deposit accounts primarily attributable
to customer account balances maintaining excess liquidity resulting in a decline
in fees charged. The increase in 2019, compared to 2018, was primarily due to
the incremental income resulting from the TCF/Chemical Merger and the 2018
expense associated with the settlement with the CFPB and the OCC of
$32.0 million, partially offset by an increase in incremental operating costs.
Commercial Banking Commercial Banking is comprised of commercial and industrial,
commercial real estate banking and lease financing. Our commercial banking
strategy focuses on building full commercial relationships including originating
high credit quality loans and leases and providing deposit and treasury
services.
                                                                     Year Ended December 31,
(In thousands)                                           2020                  2019                  2018
Commercial Banking
Net interest income                                 $    697,190          $    536,154          $   383,031
Provision for credit losses                              240,206                48,732               22,107
Net interest income after provision for credit
losses                                                   456,984               487,422              360,924
Noninterest income                                       186,304               198,898              190,442
Noninterest expense                                      430,158               383,390              308,727
Income before income tax expense                         213,130               302,930              242,639
Income tax expense                                        35,128                50,581               52,675
Income after income tax expense                          178,002               252,349              189,964
Income attributable to non-controlling interest            7,282                11,458               11,270

Net income available to common shareholders              170,720               240,891              178,694
Total assets (at period end)                        $ 24,063,599          $ 

20,395,308 $ 9,086,125




Commercial Banking generated net income available to common shareholders of
$170.7 million for 2020, compared with $240.9 million for 2019 and $178.7
million for 2018. The decrease in 2020, compared to 2019, was primarily due to
an increase in provision for credit losses and a decrease in leasing revenue,
partially offset by the incremental income resulting from the TCF/Chemical
Merger and lower cost of funds. The provision increase in 2020, compared to
2019, reflects a build to the overall allowance for loans and leases primarily
due to the impact of COVID-19 and additionally impacted by the adoption of CECL.
The increase in 2019, compared to 2018, was primarily due to the incremental
income resulting from the TCF/Chemical Merger.

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  Table of Con    tents
Enterprise Services

Enterprise Services is comprised of (i) corporate treasury, which includes our
investment and borrowing portfolios and management of capital, debt and market
risks, (ii) corporate functions, such as information technology, risk and credit
management, bank operations, finance, investor relations, corporate development,
internal audit, legal and human capital management that provide services to the
operating segments, (iii) TCF Financial and (iv) eliminations. Our investment
portfolio accounts for the earning assets within this segment. Borrowings may be
used to offset reductions in deposits or to support lending activities. This
segment also includes residual revenues and expenses representing the difference
between actual amounts incurred by Enterprise Services and amounts allocated to
the operating segments, including interest rate risk residuals such as funds
transfer pricing mismatches.
                                                                   Year Ended December 31,
(In thousands)                                         2020                  2019                  2018
Enterprise Services
Net interest income                               $      7,105          $     76,326          $    56,244

Noninterest income                                      11,730                (7,281)               1,158
Noninterest expense                                    244,480               194,821               35,706
Income (loss) before income tax (benefit) expense     (225,645)             (125,776)              21,696
Income tax (benefit) expense                           (57,881)              (38,693)               1,776
Income (loss) after income tax (benefit) expense      (167,764)              (87,083)              19,920

Preferred stock dividends                                9,975                 9,975               11,588
Impact of preferred stock call                               -                     -                3,481
Net (loss) income available to common
shareholders                                          (177,739)              (97,058)               4,851
Total assets (at period end)                      $ 10,074,898          $ 

12,031,700 $ 8,199,259




Enterprise Services generated net loss available to common shareholders of
$177.7 million for 2020, compared with net loss available to common shareholders
of $97.1 million for 2019 and net income available to common shareholders of
$4.9 million for 2018. The increase in net loss in 2020, compared to 2019, was
primarily due to increases in merger-related expenses and compensation and
employee benefits and a decrease in net interest income. The increase in net
loss in 2019, compared to 2018, was primarily due to an increase in
merger-related expenses, partially offset by an increase in net interest income
driven by investment securities acquired in the TCF/Chemical Merger.
Consolidated Financial Condition Analysis

Investment Securities Total investment securities available-for-sale, at fair
value, were $8.3 billion at December 31, 2020, compared with $6.7 billion at
December 31, 2019. Our investment securities available-for-sale are debt
securities consisting primarily of fixed-rate mortgage-backed securities issued
by the Federal National Mortgage Association ("FNMA") and the Federal Home Loan
Mortgage Corporation ("FHLMC"), and obligations of states and political
subdivisions. The increase in investment securities was primarily due to
purchases of additional residential mortgage-backed securities.

From time to time, we sell investment securities available-for-sale and utilize
the proceeds to reduce borrowings, fund growth in loans and leases or for other
corporate purposes. We sold $48.5 million of investment securities during the
year ended 2020, $2.0 billion during the year ended 2019 and $251.3 million
during the year ended 2018.

Total investment securities held-to-maturity were $184.4 million at December 31,
2020, compared with $139.4 million at December 31, 2019. Our investment
securities held-to-maturity portfolio consists primarily of fixed-rate
mortgage-backed securities issued by the FNMA. The increase in debt securities
held to maturity was primarily due to purchases of residential mortgage-backed
securities.

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The amortized cost and fair value of investment securities available-for-sale
and held-to-maturity were as follows:
                                                                                                 At December 31,
                                                        2020                                          2019                                          2018
(In thousands)                           Amortized Cost           Fair value           Amortized Cost           Fair value           Amortized Cost           Fair value
Investment securities
available-for-sale
Debt securities:
Residential mortgage-backed securities $     6,308,376          $ 6,467,760

$ 4,866,473 $ 4,929,717 $ 1,930,700

     $ 1,913,194
Obligations of states and political
subdivisions                                   827,191              870,181                  852,096              863,855                  566,304      

556,871


Commercial mortgage-backed securities          708,593              750,381                  685,212              691,614                        -                    -
Government and government-sponsored
enterprises                                    196,560              195,900                  235,045              234,385                        -                    -
Corporate debt and trust preferred
securities                                         453                  501                      451                  430                        -                    -

Total investment securities
available-for-sale                           8,041,173            8,284,723                6,639,277            6,720,001                2,497,004            2,470,065

Investment securities held-to-maturity



Residential mortgage-backed securities         180,946              190,141                  135,769              141,168                  146,052      

146,467


Corporate debt and trust preferred
securities                                       3,413                3,413                    3,676                3,676                    2,800                2,800
Total investment securities
held-to-maturity                               184,359              193,554                  139,445              144,844                  148,852              149,267
Total investment securities            $     8,225,532          $ 8,478,277          $     6,778,722          $ 6,864,845          $     2,645,856          $ 2,619,332



The carrying value and FTE yield of investment securities available-for-sale and
investment securities held-to-maturity by final contractual maturity were as
follows. The final contractual maturities do not consider possible prepayments
and therefore expected maturities may differ because borrowers may have the
right to call or prepay obligations with or without call or prepayment
penalties.
                                                                                                                                                                        At December 31, 2020
                                                                                    Obligations of States and Political                                                                                                                             Corporate Debt And Trust Preferred
                                  Residential mortgage-backed Securities                       Subdivisions                        Commercial

mortgage-backed Securities              Government and Government-sponsored Enterprises                           Securities                                      Total
(Dollars in thousands)                Amount                 Yield (1)                 Amount                Yield (1)                 Amount                 Yield (1)                        Amount                        Yield (1)                Amount                Yield (1)               Amount              Yield (1)
Investment securities
available-for-sale
Due in one year or less         $              -                      -  %       $        46,163                   2.66  %       $              -                      -  %       $                   -                               -  %       $            -                      -  %       $    46,163                   2.66  %
Due in 1-5 years                          14,287                   1.88                  141,458                   2.87                    12,380                   1.56                              -                               -                       -                      -              168,125                   2.69
Due in 5-10 years                        124,363                   2.02                  246,743                   2.53                   331,349                   1.95                         17,784                            1.60                       -                      -              720,239                   2.15
Due after 10 years                     6,329,110                   1.96                  435,817                   2.73                   406,652                   2.51                        178,116                            1.76                     501                   4.74            7,350,196                   2.03
Total                               $6,467,760                     1.96  %       $       870,181                   2.69  %       $        750,381                   2.25  %       $             195,900                            1.75  %       $          501                   4.74  %       $ 8,284,723                   2.06  %
Investment securities
held-to-maturity
Due in one year or less         $              -                      -  %       $             -                      -  %       $              -                      -  %       $                   -                               -  %       $          400                   3.00  %       $       400                   3.00  %
Due in 1-5 years                               -                      -                        -                      -                         -                      -                              -                               -                   2,150                   3.00                2,150                   3.00
Due in 5-10 years                             46                   6.50                        -                      -                         -                      -                              -                               -                       -                      -                   46                   6.50
Due after 10 years                       180,900                   1.86                        -                      -                         -                      -                              -                               -                     863                   6.00              181,763                   1.88
Total                           $        180,946                   1.86  %       $             -                      -  %       $              -                      -  %       $                   -                               -  %       $        3,413                   3.76  %       $   184,359                   1.90  %

(1)Interest and yields are presented on a FTE basis.

See "Note 6. Investment Securities" of Notes to Consolidated Financial Statements for further information regarding our investment securities available-for-sale and investment securities held-to-maturity.



Loans and Leases Held-for-Sale Our loans and leases held-for-sale were $222.0
million at December 31, 2020, an increase of $22.2 million, compared to $199.8
million at December 31, 2019.

Loans and Leases Our commercial loan and lease portfolio is comprised of
commercial and industrial loans, commercial real estate loans, and lease
financing. Our consumer loan portfolio is comprised of residential mortgages,
home equity loans and lines of credit and consumer installment loans. Our
lending markets primarily consist of communities throughout our primary banking
markets in addition to Florida, Texas, New York, California and Canada.


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  Table of Con    tents
Total loans and leases were $34.5 billion at both December 31, 2020 and December
31, 2019. At December 31, 2020, commercial and industrial loans included
$1.6 billion of PPP loans outstanding. Loans and leases excluding PPP loans, a
non-GAAP financial measure, decreased $1.6 billion from December 31, 2019
primarily due to a decrease in the commercial and industrial portfolio,
primarily inventory finance, related to strong dealer activity and the lack of
backfill from manufacturers as a result of logistical issues and the economic
slowdown, in addition to a decrease in our consumer loan portfolio, partially
offset by increases in our commercial real estate and lease financing portfolios
and loan and lease purchases. See "Non-GAAP Financial Measures" in this
Management's Discussion and Analysis for further information.

Information about our loans and leases was as follows:


                                                                                                                                                      Compound Annual
                                                                                                                                                        Growth Rate
                                                                       At December 31,                                                       1-Year                  5-Year
(Dollars in thousands)          2020                  2019                  2018                  2017                  2016               2020 / 2019             2020 / 2016
Commercial loan and lease
portfolio:
Commercial and industrial  $ 11,422,383          $ 11,439,602          $  6,298,240          $  5,920,423          $  5,180,864                  (0.2) %                   17.1  %

Commercial real estate        9,702,587             9,136,870             2,830,705             2,681,827             2,593,409                   6.2                      30.2
Lease financing               2,817,231             2,699,869             2,530,163             2,461,182             2,319,579                   4.3                       4.0
Total commercial loan and
lease portfolio              23,942,201            23,276,341            11,659,108            11,063,432            10,093,852                   2.9                      18.9
Consumer loan portfolio:
Residential mortgage          6,182,045             6,179,805             2,335,835             1,826,988             2,131,839                     -                      23.7
Home equity                   3,108,736             3,498,907             3,074,505             2,992,708             2,952,514                 (11.2)                      1.0
Consumer installment          1,233,426             1,542,411             2,003,572             3,222,156             2,666,511                 (20.0)                    (14.3)
Total consumer loan
portfolio                    10,524,207            11,221,123             7,413,912             8,041,852             7,750,864                  (6.2)                      6.3

Total loans and leases $ 34,466,408 $ 34,497,464 $ 19,073,020 $ 19,105,284 $ 17,844,716

                  (0.1)                     14.1



The contractual maturities of loans and leases outstanding were as follows:


                                                                                           At December 31, 2020(1)
                               Commercial and        Commercial real           Lease              Residential                                  Consumer
(in thousands)                   industrial              estate              Financing             mortgage             Home equity           installment             Total
Amounts due:
Within 1 year                 $   3,483,409             2,007,581         

$ 239,312 $ 11,912 $ 68,294 $ 35,415 $ 5,845,923 1 to 5 years

                      6,727,751             5,410,955            2,255,665                59,061               407,616               493,638           15,354,686
Over 5 years                      1,211,223             2,284,051              322,254             6,111,072             2,632,826               704,373           13,265,799
Total                            11,422,383             9,702,587            2,817,231             6,182,045             3,108,736             1,233,426           34,466,408
Amounts due after 1 year:
Fixed-rate loans and leases       5,453,114             2,233,537            2,577,919             3,781,885               306,012             1,172,105           15,524,572
Variable- and adjustable-rate
loans and leases                  2,485,860             5,461,469                    -             2,388,248             2,734,430                25,906           13,095,913
Total after 1 year            $   7,938,974          $  7,695,006          $ 2,577,919          $  6,170,133             3,040,442          $  1,198,011           28,620,485


(1)This table does not include the effect of prepayments, which is an important
consideration in management's interest-rate risk analysis. Our experience
indicates that loans and leases remain outstanding for significantly shorter
periods than their contractual terms.

Commercial Loan and Lease Portfolio



Our commercial loan and lease portfolio was $23.9 billion at December 31, 2020,
an increase of $665.9 million, or 2.9%, compared to $23.3 billion at December
31, 2019. We believe that our commercial loan and lease portfolio is well
diversified across business lines and has no concentration in any one industry.


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Commercial and industrial Commercial and industrial ("C&I") loans and lines of
credit include loans to varying types of businesses, municipalities, school
districts and nonprofit organizations, for the purpose of supporting working
capital and operational needs and financing equipment. C&I loans are secured by
various types of business assets including inventory, floorplan equipment,
receivables, equipment or financial instruments. Origination levels related to
equipment dealers are impacted by the velocity of fundings and repayments with
dealers. C&I loans were $11.4 billion at December 31, 2020, a decrease of $17.2
million, compared to $11.4 billion at December 31, 2019. At December 31, 2020,
C&I loans included $1.6 billion of PPP loans.

Our C&I portfolio by North American Industry Classification System ("NAICS")
code was as follows:

                                                                             At December 31, 2020
                                                                                           Percent of total
                                                                                            loan and lease
(In thousands)                                                        Balance                 portfolio
Retail trade                                                      $   2,174,624                        6.3  %
Transportation and warehouse                                          1,446,765                        4.2
Manufacturing                                                         1,258,285                        3.7
Real estate rental and leasing                                          924,979                        2.7
Wholesale trade                                                         850,500                        2.5
Construction                                                            730,346                        2.1
Health care and social assistance                                       634,868                        1.8
Finance and insurance                                                   463,336                        1.3
Administration and Support and Waste Management and Remediation         422,708                        1.2
All other                                                             2,515,972                        7.3
Total                                                             $  11,422,383                       33.1  %



Commercial real estate Commercial real estate loans include loans that are
secured by real estate occupied by the borrower for ongoing operations,
non-owner occupied real estate leased to one or more tenants and construction
and development loans primarily originated for construction of commercial
properties. Construction and development loans often convert to a commercial
real estate loan at the completion of the construction period. Commercial real
estate loans were $9.7 billion at December 31, 2020, an increase of $565.7
million, compared to $9.1 billion at December 31, 2019.

Our commercial real estate loan portfolio by property and loan type was as
follows:

                                                                               At December 31,
                                                                             2020                                                        2019
                                                                                    Percent of total                                          Percent of total
                                                                                     loan and lease                                            loan and lease
(In thousands)                                                 Balance                 portfolio                           Balance               portfolio
Multifamily                                               $     1,900,898                      5.5  %                   $ 1,799,949                      5.2  %
Office                                                          1,383,043                      4.0                        1,219,618                      3.5
Retail                                                          1,256,064                      3.6                        1,323,773                      3.8
Warehouse                                                       1,121,502                      3.3                        1,081,165                      3.1
Hotel                                                             799,365                      2.3                          759,773                      2.2
Senior housing                                                    776,505                      2.3                          729,169                      2.1
Self­storage                                                      532,256                      1.5                          436,415                      1.3
Mixed use                                                         432,764                      1.3                          450,782                      1.3
Other                                                           1,500,190                      4.4                        1,336,226                      4.0
Total                                                     $     9,702,587                     28.2  %                   $ 9,136,870                     26.5  %


Lease financing We provide a broad range of comprehensive lease products addressing the diverse financing needs of small to large companies. Lease financing loans were $2.8 billion at December 31, 2020, an increase of $117.4 million, compared to $2.7 billion at December 31, 2019.


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Our lease financing portfolio by market type was as follows:
                                                                                       At December 31,
                                                                        2020                                       2019
                                                                          Percent of total                              Percent of total
                                                                           loan and lease                                loan and lease
(Dollars in thousands)                                 Balance             

 portfolio               Balance               portfolio
Specialty vehicles                                  $   613,941                      1.7  %       $   554,543                      1.6  %
Golf                                                    547,716                      1.6              469,451                      1.4
Healthcare                                              507,170                      1.5              523,244                      1.5
Construction                                            300,370                      0.9              246,750                      0.7
Manufacturing                                           224,062                      0.7              298,187                      0.9
Material handling                                       219,340                      0.6              131,367                      0.4
Technology                                              194,703                      0.6              221,152                      0.6
Agricultural                                            127,008                      0.4              117,198                      0.3
Other                                                    82,921                      0.2              137,977                      0.4
Total                                               $ 2,817,231                      8.2  %       $ 2,699,869                      7.8  %


Consumer Loan Portfolio

Our consumer loan portfolio was $10.5 billion at December 31, 2020, a decrease of $696.9 million, or 6.2%, compared to $11.2 billion at December 31, 2019.



Residential mortgage Residential mortgage loans consist primarily of one- to
four-family residential loans with fixed and adjustable interest rates, with
amortization periods generally from 15 to 30 years. The loan-to-value ratio at
the time of origination is generally 90% or less. Loans with more than an 80%
loan-to-value ratio generally require private mortgage insurance. Residential
mortgage loans also include loans to consumers for the construction of single
family residences that are secured by these properties. Residential mortgage
loans were $6.2 billion at both December 31, 2020 and December 31, 2019.

Home equity Home equity loans and lines of credit are comprised of loans to
consumers who utilize equity in their personal residence, including junior lien
mortgages, as collateral to secure the loan or line-of-credit. Our home equity
portfolio totaled $3.1 billion at December 31, 2020 (consisting of $2.8 billion
of home equity lines of credit and $332.0 million of amortizing home equity
loans), a decrease of $390.2 million, compared to $3.5 billion at December 31,
2019 (consisting of $3.0 billion of home equity lines of credit and $474.7
million of amortizing home equity loans). At December 31, 2020, $2.3 billion of
our home equity lines of credit were loans with a 10-year interest-only draw
period and a 20-year amortization repayment period, of which all were within the
10-year interest-only draw period and will not convert to amortizing loans until
2021 or later. At December 31, 2020, $505.2 million of the home equity line of
credits were interest-only revolving draw loans with no defined amortization
period and original draw periods of 0 to 40 years. Home equity lines of credit
mostly include junior lien mortgages where the first lien mortgage is held by a
unaffiliated financial institution.

Consumer installment Consumer installment loans consist of relatively small loan
amounts to consumers to finance personal items (primarily automobiles,
recreational vehicles and marine vehicles) and are primarily indirect loans
purchased from dealerships. Consumer rates are both fixed and variable, with
negotiated terms. Our consumer installment loans typically amortize over periods
up to 60 months. Consumer loans not secured by real estate are generally
considered to have greater risk than first or second mortgages on real estate
because they may be unsecured, or, if they are secured, the value of the
collateral may be difficult to assess and more likely to decrease in value, and
more difficult to control, than real estate. Consumer installment loans were
$1.2 billion at December 31, 2020, a decrease of $309.0 million, or 20.0%,
compared to $1.5 billion at December 31, 2019.



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Credit Quality  The following summarizes our loan and lease portfolio based on
the credit quality factors that we believe are the most important and should be
considered to understand the overall condition of the portfolio. The following
items should be considered throughout this section:

•Loans and leases that are over 90-days delinquent and accruing generally are a
leading indicator for future charge-off trends.
•Nonaccrual loans and leases have been charged down to the estimated fair value
of the collateral less estimated selling costs, or reserved for expected loss
upon workout.
•Within the performing loans and leases, we classify customers within regulatory
classification guidelines. Loans and leases that are "classified" are loans or
leases that management has concerns regarding the ability of the borrowers to
meet existing loan or lease terms and conditions, but may never become
nonaccrual or result in a loss.

Past due loans and leases  Delinquent balances are determined based on the
contractual terms of the loan or lease. See "Note 8. Allowance for Credit Losses
and Credit Quality" of Notes to Consolidated Financial Statements for further
information. Over 90-day delinquent loans and leases by type, excluding
nonaccrual loans and leases, were as follows.
                                                            90 Days or More Delinquent and Accruing                                                  

Percentage of Period-end Loans and Leases


                                                                                                                     At December 31,
(Dollars in thousands)                     2020               2019              2018             2017             2016             2020              2019              2018              2017              2016
Commercial loan and lease portfolio:
Commercial and industrial             $   1,458            $    331          $   760          $ 1,216          $    75              0.01  %              -  %           0.01  %           0.02  %              -  %
Commercial real estate                       22               1,440                -                -                -                 -              0.02                 -                 -                 -
Lease financing                           3,935               1,901            1,882              918            1,009              0.14              0.07              0.07              0.04              0.04
Total commercial loan and lease
portfolio                                 5,415               3,672            2,642            2,134            1,084              0.02              0.02              0.02              0.02              0.01
Consumer loan portfolio:
Residential mortgage                      1,965                 559            1,275              593            2,144              0.03              0.01              0.06              0.03              0.11
Home equity                                  63                   -                -                -                -                 -                 -                 -                 -                 -
Consumer installment                          -                 108            3,349            3,005            2,323                 -              0.01              0.17              0.09              0.09
Total consumer loan portfolio             2,028                 667            4,624            3,598            4,467              0.02              0.01              0.06              0.05              0.06
Portfolios acquired with deteriorated
credit quality(1)                             -              25,737              178            1,200                -                 -             10.43              4.65             10.13                 -
Total                                 $   7,443            $ 30,076          $ 7,444          $ 6,932          $ 5,551              0.02  %           0.09  %           0.04  %           0.04  %           0.03  %

(1)Prior to the adoption of CECL as of January 1, 2020, purchased credit impaired loans were not classified as nonaccrual loans because they were recorded at their net realizable value based on the principal and interest expected to be collected on the loans.


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Nonperforming assets  Nonperforming assets, consisting of nonaccrual loans and
leases and other real estate owned, were as follows:
                                                                                         At December 31,
(Dollars in thousands)                                   2020               2019               2018               2017               2016
Commercial loan and lease portfolio:
Commercial and industrial                            $ 259,439          $  53,812          $  26,061          $  10,958          $  10,587
Commercial real estate                                 154,439             29,735              4,518              6,785              5,564
Lease financing                                         90,822             10,957              7,993             10,247              5,782
Total commercial loan and lease portfolio              504,700             94,504             38,572             27,990             21,933
Consumer loan portfolio:
Residential mortgage                                    97,653             38,577             33,111             61,951            106,124
Home equity                                             69,383             35,863             25,654             21,274             46,346
Consumer installment                                     5,566                714              8,581              7,367              7,042
Total consumer loan portfolio                          172,602             75,154             67,346             90,592            159,512
Total nonaccrual loans and leases                      677,302            169,658            105,918            118,582            181,445
Other real estate owned                                 33,192             34,256             17,403             18,225             46,797
Total nonperforming assets                           $ 710,494          $

203,914 $ 123,321 $ 136,807 $ 228,242 Nonaccrual loans and leases as a percentage of total loans and leases

                                          1.97  %            0.49  %            0.56  %            0.62  %            1.02  %

Nonperforming assets as a percentage of total loans and leases and other real estate owned

                    2.06               0.59               0.65               0.72               1.28

Allowance for loan and lease losses as a percentage of nonaccrual loans and leases

                           77.64              66.64             148.65             144.24              88.33
Allowance for credit losses as a percentage of
nonaccrual loans and leases                              81.08              68.71              66.67              68.73             112.43



Nonperforming assets were $710.5 million at December 31, 2020, compared with
$203.9 million at December 31, 2019. The increase in nonperforming assets
reflected an increase in nonaccrual balances in our commercial loan and lease
portfolio, the adoption of CECL ($73.4 million of loans previously accounted for
as purchased credit impaired were reclassified to nonaccrual loans as of January
1, 2020 due to the adoption of CECL) and an increase in nonaccrual balances in
our consumer loan portfolio. The increase within the commercial portfolio was
primarily driven by certain portfolios more heavily impacted by COVID-19,
including the motor coach, shuttle bus, hotel, franchise, retail commercial real
estate, fitness and retail trade sectors, the majority of which have been on
deferral for over 180 days. At December 31, 2020, nonaccrual loans and leases
included $219.0 million within travel-related sectors ($104.0 million in motor
coach, $36.5 million in shuttle bus and $78.5 million in hotel) in addition to,
$25.5 million in the franchise sector, $18.7 million in the retail commercial
real estate sector, $5.3 million in the fitness sector and $1.3 million in the
retail trade sector. Due to the prolonged recovery of revenues for borrowers in
these sectors given the dependency on travel and related activity levels highly
impacted by COVID-19, we have taken a proactive approach by working with
borrowers to extend deferrals into 2021 where necessary, many of which have been
moved to nonaccrual status.

Loans and leases are generally placed on nonaccrual status when the collection
of interest or principal is 90 days or more past due unless, in the case of
commercial loans, they are well secured and in process of collection. Delinquent
consumer home equity loans with a junior lien are also placed on nonaccrual
status when there is evidence that the related third-party first lien mortgage
may be 90 days or more past due, or foreclosure, charge-off or collection action
has been initiated. TDR loans are placed on nonaccrual status prior to the past
due thresholds outlined above if repayment under the modified terms is not
likely after performing a well-documented credit analysis. In addition, under
the CARES Act, loans and leases that have been granted a deferral of greater
than 180 days are generally placed on nonaccrual status. Loans on nonaccrual
status are generally reported as nonaccrual loans until there is sustained
repayment performance for six consecutive months, with the exception of loans
not reaffirmed upon discharge in Chapter 7 bankruptcy, which remain on
nonaccrual status until a well-documented credit analysis indicates full
repayment of the remaining pre-discharged contractual principal and interest is
likely.

Commercial real estate, residential mortgage and home equity nonaccrual loans
are secured by real estate. Given the nature of these assets and the related
mortgage foreclosure, property sale and, if applicable, mortgage insurance
claims processes, it can take 18 months or longer for a loan to migrate from
initial delinquency to final disposition. This resolution process generally
takes much longer for loans secured by real estate than for unsecured loans or
loans secured by other property primarily due to state real estate foreclosure
laws.


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  Table of Con    tents
Changes in the amount of nonaccrual loans and leases were as follows:
                                                                  At or For 

the Year Ended December 31, 2020


                                                                                  Commercial Loan
                                                           Consumer Loan             and Lease
(in thousands)                                               Portfolio               Portfolio               Total
Balance, beginning of period                             $        75,154          $      94,504          $  169,658
Transfer in of loans previously accounted for as
purchased credit impaired(1)                                      20,560                 52,825              73,385
Adjusted balance, beginning of period                             95,714                147,329             243,043

Additions                                                        143,178                624,427             767,605
Charge-offs                                                      (10,619)               (61,887)            (72,506)
Transfers to other assets                                         (6,931)               (17,332)            (24,263)

Return to accrual status                                         (19,903)               (67,639)            (87,542)
Payments received                                                (28,849)              (119,172)           (148,021)

Other, net                                                            12                 (1,026)             (1,014)
Balance, end of period                                   $       172,602          $     504,700          $  677,302

                                                                  At or For

the Year Ended December 31, 2019


                                                                                  Commercial Loan
                                                           Consumer Loan             and Lease
(in thousands)                                               Portfolio               Portfolio               Total
Balance, beginning of period                             $        67,346          $      38,572          $  105,918
Acquired in the TCF/Chemical Merger                               16,414                 64,830              81,244
Additions                                                         77,841                156,436             234,277
Charge-offs                                                       (9,580)               (36,208)            (45,788)
Transfers to other assets                                        (17,126)               (19,779)            (36,905)
Return to accrual status                                          (7,770)               (39,356)            (47,126)
Payments received                                                (25,126)               (72,979)            (98,105)
Sales                                                            (26,722)                     -             (26,722)
Other, net                                                          (123)                 2,988               2,865
Balance, end of period                                   $        75,154          $      94,504          $  169,658

(1)Prior to the adoption of CECL as of January 1, 2020, purchased credit impaired loans were not classified as nonaccrual loans because they were recorded at their net realizable value based on the principal and interest expected to be collected on the loans.

Interest income recognized on loans and leases in nonaccrual status and contractual interest that would have been recorded had the loans and leases performed in accordance with their original contractual terms were as follows:


                                                               Year Ended December 31,
(in thousands)                                    2020                  2019                  2018
Contractual interest due on nonaccrual loans
and leases                                   $     58,002          $     17,310          $     10,921
Interest income recognized on nonaccrual
loans and leases                                   31,768                 5,514                 1,351
Unrecognized interest income                 $     26,234          $     

11,796 $ 9,570

See "Note 2. Summary of Significant Accounting Policies" and "Note 8. Allowance for Credit Losses and Credit Quality" of Notes to Consolidated Financial Statements for further information.



Loan and lease credit classifications We assess the risk of our loan and lease
portfolio utilizing numerous risk characteristics as outlined in the previous
sections. Credit classifications are an additional characteristic monitored in
the overall credit risk process. Loan and lease credit classifications are
derived from standard regulatory rating definitions, which include:
non-classified (pass and special mention) and classified (substandard).
Classified loans and leases have well-defined weaknesses, but may never result
in a loss.


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  Table of Con    tents
Loans and leases by portfolio and regulatory classification were as follows:
                                                                       At December 31, 2020
                                                            Non-classified                             Classified
(In thousands)                                      Pass               Special Mention                                     Total       Substandard
Commercial loan and lease portfolio:
Commercial and industrial                      $ 10,710,654          $        267,585                                  $   444,144                   $ 11,422,383
Commercial real estate                            8,807,045                   531,016                                      364,526                      9,702,587
Lease financing                                   2,681,307                    34,084                                      101,840                      2,817,231
Total commercial loan and lease portfolio        22,199,006                   832,685                                      910,510                     23,942,201
Consumer loan portfolio:
Residential mortgage                              6,078,865                       112                                      103,068                      6,182,045
Home equity                                       3,028,765                         -                                       79,971                      3,108,736
Consumer installment                              1,227,061                         -                                        6,365                      1,233,426
Total consumer loan portfolio                    10,334,691                       112                                      189,404                     10,524,207
Total loans and leases                         $ 32,533,697          $        832,797                                  $ 1,099,914                   $ 34,466,408


                                                                      At December 31, 2019
                                                                 Non-classified                                   Classified
(In thousands)                                           Pass               Special Mention                      Substandard              Total
Commercial loan and lease portfolio:
Commercial and industrial                           $ 10,930,939          $        315,097                      $   193,566          $ 11,439,602
Commercial real estate                                 8,891,361                   170,114                           75,395             9,136,870
Lease financing                                        2,646,874                    28,091                           24,904             2,699,869
Total commercial loan and lease portfolio             22,469,174                   513,302                          293,865            23,276,341
Consumer loan portfolio:
Residential mortgage                                   6,135,096                       565                           44,144             6,179,805
Home equity                                            3,457,292                       456                           41,159             3,498,907
Consumer installment                                   1,541,524                         -                              887             1,542,411
Total consumer loan portfolio                         11,133,912                     1,021                           86,190            11,221,123
Total loans and leases                              $ 33,603,086          $        514,323                      $   380,055          $ 34,497,464



Total classified loans and leases were $1.1 billion at December 31, 2020,
compared with $380.1 million at December 31, 2019. The increase was primarily
due to downgrades in our commercial loan and lease portfolio, largely occurring
due to economic impacts caused by COVID-19. We have identified certain sectors
within our commercial loan and lease portfolio that have been more heavily
impacted by COVID-19 including motor coach, shuttle bus, hotel, retail
commercial real estate, franchise, retail trade and fitness, excluding any PPP
loans within these sectors as they are guaranteed by the Small Business
Administration. At December 31, 2020, these previously identified higher
COVID-19 impacted sectors represent $725.3 million of the total commercial loan
and lease portfolio classified balance, of which $269.8 million are on
nonaccrual status. Sectors identified as having a higher impact due to COVID-19
may change in future periods depending on how economic environment conditions
develop over time.

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Loan modifications  Troubled debt restructuring ("TDR") loans are loans to
financially troubled borrowers that have been modified such that we have granted
a concession in terms to improve the likelihood of collection of all principal
and modified interest owed. TDR loans were as follows:
                                                                                 At December 31,
(Dollars in thousands)                           2020              2019               2018               2017               2016
Accruing TDR Loans:
Commercial loan and lease portfolio           $ 35,697          $ 12,986          $  12,665          $  22,512          $  25,106
Consumer loan portfolio                         16,658            12,403             85,794             91,559            100,935
Total                                           52,355            25,389             98,459            114,071            126,041
Nonaccrual TDR Loans:
Commercial loan and lease portfolio             23,575             5,356              6,153              1,972              3,877
Consumer loan portfolio                         22,804            14,875             22,554             39,634             77,465
Total                                           46,379            20,231             28,707             41,606             81,342
Total TDR loans:
Commercial loan and lease portfolio             59,272            18,342             18,818             24,484             28,983
Consumer loan portfolio                         39,462            27,278            108,348            131,193            178,400
Total                                         $ 98,734          $ 45,620          $ 127,166          $ 155,677          $ 207,383
Over 90-day delinquency as a percentage of
total accruing TDR loans                          0.99  %           0.52  %            0.14  %               -  %            0.30  %


Total TDRs were $98.7 million at December 31, 2020, compared with $45.6 million at December 31, 2019.



Loan modifications to borrowers who have not been granted concessions are not
considered TDR loans and therefore are not included in the table above. In
addition, Section 4013 of the CARES Act and the Interagency Statement on Loan
Modifications provide banks the option to temporarily suspend certain TDR
accounting guidance for loans modified due to the effects of COVID-19 when
certain conditions are met. On December 27, 2020, this provision of the CARES
Act was extended to the earlier of January 1, 2022 or 60 days after the
President of the United States declares a termination of the COVID-19 national
emergency. In March 2020, TCF began providing assistance to customers in
response to the COVID-19 pandemic, predominantly in the form of payment
deferrals. As of December 31, 2020, $329.8 million of loan and lease balance was
on deferral status, of which $218.0 million are on nonaccrual status, the
majority of which have been on deferral for over 180 days. TCF additionally
granted certain other loan modifications which provide temporary customer
assistance predominantly in the form of financial covenant concessions and
modification of borrowing base. As of December 31, 2020, other loan
modifications balance was $401.6 million. See "Note 2. Summary of Significant
Accounting Policies" of the Notes to Consolidated Financial Statements for
information regarding recent updated guidance on TDR accounting provided by the
CARES Act and Interagency Regulatory guidance. TDR loans with an interest rate
consistent with market rates on loans with comparable risk at the time of
restructuring and performing based on the restructured terms are no longer
disclosed as TDR loans in the calendar years after modification; however, these
loans are still considered impaired and follow our impaired loan reserve
policies.

TDRs typically involve a deferral of the principal balance of the loan, a reduction of the stated interest rate of the loan or, in certain limited circumstances, a reduction of the principal balance of the loan or the loan's accrued interest.

Interest income recognized on TDR loans and contractual interest that would have been recorded had the TDR loans performed in accordance with their original contractual terms were as follows:


                                                          Year Ended 

December 31,


         (in thousands)                               2020          2019         2018
         Contractual interest due on TDR loans     $   4,929      $ 6,157      $ 6,842
         Interest income recognized on TDR loans       1,448        4,325        4,673
         Unrecognized interest income              $   3,481      $ 1,832      $ 2,169

See "Note 8. Allowance for Credit Losses and Credit Quality" of Notes to Consolidated Financial Statements for further information regarding our loan modifications.




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Allowance for credit losses  The ACL includes the ALLL and the RULC. The ALLL is
a valuation account presented separately on the Consolidated Statements of
Financial Condition that is deducted from or added to loans' amortized cost
basis to present the net amount expected to be collected. The RULC for letters
of credit, financial guarantees and binding unfunded loan commitments is
recorded in other liabilities on the Consolidated Statements of Financial
Condition. The Corporation's reserve methodology used to determine the
appropriate level of the ACL is a critical accounting estimate. The ACL is
maintained at a level believed to be appropriate to provide for the current
credit losses expected to be incurred in the loan and lease portfolios over the
remaining expected life of each financial asset at the balance sheet date,
including known or anticipated problem loans and leases, as well as for loans
and leases which are not currently known to require specific allowances. The
collective evaluation of expected losses in these portfolios is based on their
probability of default multiplied by historical loss rates, as well as
adjustments for forward-looking information, including industry and
macroeconomic conditions. Factors utilized in the determination of the amount of
the allowance include historic loss experience and measurement date credit risk
characteristics such as product type, lien position, delinquency, collateral
value, credit bureau scores and financial statement ratios. The various
quantitative and qualitative factors used in the methodologies are reviewed
quarterly.

We consider our ACL of $549.2 million, or 1.59% of total loans and leases,
appropriate to cover current credit losses expected to be incurred in the loan
and lease portfolios over the remaining expected life of each financial asset at
December 31, 2020, including loans and leases which are not currently known to
require specific allowances. The increase in ACL and the ACL as a percentage of
total loans and leases from December 31, 2019 was primarily due to the adoption
of CECL at January 1, 2020, and the impact of COVID-19. During 2020 the COVID-19
pandemic had a negative impact on current and forecasted macroeconomic
conditions and created uncertainty around the performance of certain sectors
that have been more heavily impacted, including motor coach, shuttle bus, hotel,
retail commercial real estate, franchise, retail trade and fitness. In the
fourth quarter of 2020, we began to see improvement in current and forecasted
macro-economic conditions, however, these improvements were offset by continued
uncertainty around the performance of sectors more heavily impacted by COVID-19.
The ACL as a percentage of total loans and leases, excluding PPP loans was
1.67%, a non-GAAP financial measure. PPP loans are individually guaranteed by
the Small Business Administration and therefore the accounting under CECL does
not require reserves to be recorded on such loans. No assurance can be given
that we will not, in any particular period, sustain loan and lease losses that
are sizable in relation to the amount reserved or will not require significant
changes in the balance of the ACL due to subsequent evaluations of the loan and
lease portfolios, in light of factors then prevailing, including economic
conditions, information obtained during our ongoing credit review process or
regulatory requirements. Among other factors, economic slowdown, increasing
levels of unemployment, declines in collateral values and/or rising interest
rates may have an adverse impact on the current adequacy of our ACL by
increasing credit risk and the risk of potential loss. See "Non-GAAP Financial
Measures" in this Management's Discussion and Analysis for further information.

The total ACL is expected to absorb losses from any segment of the portfolio.
The allocation of our ACL disclosed in the following table is subject to change
based on changes in the criteria used to evaluate the allowance.

Prior to the adoption of CECL on January 1, 2020, the ACL was calculated under
an incurred loss model which delayed recognition of loss until it was probable
the loss had been incurred, in contrast to the accounting under CECL which
considers current credit losses expected to be incurred in the loan and lease
portfolios over the remaining expected life of each financial asset.




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In conjunction with "Note 8. Allowance for Credit Losses and Credit Quality" of
Notes to Consolidated Financial Statements, detailed information regarding our
allowance for loan and lease losses was as follows:
                                                                                      ACL(1)                                                                                       Reserve Rate
                                                                                  At December 31,                                                                                 At December 31,
(Dollars in thousands)                  2020             CECL(2)              2019               2018               2017               2016               2020         CECL(2)       2019       2018       2017       2016
Commercial loan and lease
portfolio:
Commercial and industrial           $ 155,665          $  93,884          $  42,430          $  41,103          $  35,451          $  33,193                1.36  %       0.82  %      0.38%      0.66%      0.61%      0.65%
Commercial real estate                192,331             67,620             27,308             22,877             24,842             22,785                1.98          0.74          0.29       0.79       0.90       0.86
Lease financing                        40,978             21,631             14,742             13,449             12,663             11,999                1.45          0.80          0.55       0.53       0.51       0.52
Total commercial loan and lease
portfolio                             388,974            183,135             84,480             77,429             72,956             67,977                1.62          0.79          0.36       0.66       0.66       0.67
Consumer loan portfolio:
Residential mortgage                   72,315             72,939              8,099             21,436             26,698             33,829                1.17          1.18          0.13       0.92       1.46       1.59
Home equity                            45,761             47,003             17,795             23,430             20,470             25,620                1.47          1.34          0.51       0.76       0.68       0.87
Consumer Installment                   18,818             15,967              2,678             35,151             50,917             32,843                1.53          1.04          0.17       1.75       1.58       1.23
Total consumer loan portfolio         136,894            135,909             28,572             80,017             98,085             92,292                1.30          1.21          0.25       1.08       1.22       1.19
Total allowance for loan and lease
losses                                525,868            319,044            113,052            157,446            171,041            160,269                1.53          0.92          0.33       0.83       0.90       0.90

Other credit loss reserves:
Reserves for unfunded commitments      23,313             18,235              3,528              1,428              1,479              1,115                   N.A.          N.A.       N.A.       N.A.       N.A.       N.A.
Total credit loss reserves          $ 549,181          $ 337,279          $ 116,580          $ 158,874          $ 172,520          $ 161,384                1.59  %       0.98  %      0.34%      0.83%      0.90%      0.90%


N.A. Not Applicable
(1) Allowance for credit losses effective January 1, 2020 are calculated under
the guidance of CECL. At December 31, 2019 allowance for credit losses were
calculated under the guidance of ASC Topic 310 and ASC Topic 450 prior to
adoption of CECL, See "Note 2. Summary of Significant Accounting Policies" and
"Note 8. Allowance for Credit Losses and Credit Quality" of Notes to
Consolidated Financial Statements for further information.
(2) Balances at December 31,2019 adjusted for the adoption of CECL as of January
1, 2020.




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The rollforwards of the allowance for credit losses were as follows:
                                                                        Year Ended December 31,
(Dollars in thousands)                      2020               2019               2018               2017               2016
Allowance for loan and lease losses
Balance, beginning of period            $ 113,052          $ 157,446          $ 171,041          $ 160,269          $ 156,054
Impact of CECL adoption                   205,992                  -                  -                  -                  -
Adjusted balance, beginning of period     319,044            157,446            171,041            160,269            156,054

Charge-offs:


Commercial loan and lease portfolio:
Commercial and industrial                 (48,816)           (39,566)           (16,005)            (8,840)            (7,450)
Commercial real estate                     (8,105)              (302)                 -             (3,608)              (752)
Lease financing                            (6,324)            (7,587)            (4,203)            (6,813)            (2,912)
Total commercial loan and lease
portfolio                                 (63,245)           (47,455)           (20,208)           (19,261)           (11,114)
Consumer loan portfolio:
Residential mortgage                       (2,131)            (3,456)            (3,417)            (5,592)            (9,710)
Home equity                                (4,346)            (3,219)            (3,710)            (6,270)            (8,915)
Consumer installment                      (16,793)           (43,805)           (57,393)           (47,969)           (34,346)
Total consumer loan portfolio             (23,270)           (50,480)           (64,520)           (59,831)           (52,971)
Total charge-offs                         (86,515)           (97,935)           (84,728)           (79,092)           (64,085)

Recoveries:


Commercial loan and lease portfolio:
Commercial and industrial                  21,930              5,120              1,606              1,840              1,924
Commercial real estate                      1,830                322                183                777                308
Lease financing                             2,145              1,289              1,427              1,119              1,343
Total commercial loan and lease
portfolio                                  25,905              6,731              3,216              3,736              3,575
Consumer loan portfolio:
Residential mortgage                        2,634              4,271              5,261              6,100              1,115
Home equity                                 3,346              5,689              6,488             14,681              5,949
Consumer installment                        9,547             13,693             14,738             10,135              8,211
Total consumer loan portfolio              15,527             23,653             26,487             30,916             15,275
Total recoveries                           41,432             30,384             29,703             34,652             18,850
Net charge-offs                           (45,083)           (67,551)           (55,025)           (44,440)           (45,235)
Provision for credit losses related to
loans and leases(1)                       252,073             65,282             46,768             68,443             65,874
Other(2)                                     (166)           (42,125)            (5,338)           (13,231)           (16,424)
Balance, end of period                  $ 525,868          $ 113,052          $ 157,446          $ 171,041          $ 160,269
Reserve for unfunded lending
commitments
Balance, beginning of period            $   3,528          $   1,428          $   1,479          $   1,115          $   1,044
Impact of CECL adoption                    14,707                  -                  -                  -                  -
Adjusted balance, beginning of period      18,235              1,428              1,479              1,115              1,044
Provision (benefit) for credit losses
related to unfunded lending
commitments(1)                              5,078                233                (51)               364                 71
Addition due to the TCF/Chemical Merger         -              1,867                  -                  -                  -
Balance, end of period                     23,313              3,528              1,428              1,479              1,115

Total allowance for credit losses $ 549,181 $ 116,580

$ 158,874 $ 172,520 $ 161,384




(1)Provision for credit losses related to loans and leases and the provision for
credit losses related to unfunded lending commitments are included within
Provision for Credit Losses.
(2)Primarily includes the transfer of the allowance for loan and lease losses to
loans and leases held-for-sale.

Net loan and lease charge-offs for 2020 were $45.1 million, or 0.13% of average
loans and leases, compared with $67.6 million, or 0.27% of average loans and
leases, for 2019 and $55.0 million, or 0.29% of average loans and leases, for
2018. The decrease in net loan and lease charge-offs in 2020 was primarily due
to a decrease in consumer installment loans, partially offset by an increase in
the commercial loan and lease portfolio. The increase in net loan and lease
charge-offs in 2019, compared to 2018, was primarily due to an increase in
charge-offs in commercial and industrial net charge-offs, partially offset by
$4.7 million of recoveries of previous charge-offs related to the sale of
consumer nonaccrual and TDR loans.


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Investment Securities Held-to-Maturity The investment securities
held-to-maturity portfolio consist primarily of fixed-rate mortgage-backed
securities issued and guaranteed by FNMA, GNMA and FHLMC which significantly
decreases credit risk. The most important credit quality factor we consider to
understand the condition of the residential agency mortgage-backed securities is
that all are AAA rated and agency-guaranteed.

Liquidity Management We manage our liquidity to ensure that our funding needs
are met both promptly and in a cost-effective manner. Asset liquidity arises
from liquid assets that can be sold or pledged as collateral, amortization,
prepayment or maturity of assets and from our ability to sell loans. Liability
liquidity results from our ability to maintain a diverse set of funding sources
to promptly meet funding requirements.

The TCF Financial Board of Directors have adopted a Liquidity Management Policy
for TCF Bank to direct management of the Corporation's liquidity risk and a
Holding Company Investment and Liquidity Management Policy, which establishes a
minimum target amount of cash or liquid investments TCF Financial will hold. See
"Item 7A. Quantitative and Qualitative Disclosures about Market Risk" for
further information.

TCF Bank had $434.3 million of net liquidity qualifying interest-bearing
deposits at the Federal Reserve Bank at December 31, 2020, compared with $489.7
million at December 31, 2019. Certain investment securities held-to-maturity and
investment securities available-for-sale provide the ability to liquidate or
pledge unencumbered securities as needed. At December 31, 2020, $1.0 billion of
our securities were pledged as collateral to secure certain deposits and
borrowings.

TCF Financial had net liquidity qualifying cash of $173.0 million at December 31, 2020, compared with $156.0 million at December 31, 2019.



Deposits are the primary source of our funds for use in lending and for other
general business purposes. In addition to deposits, we receive funds from loan
and lease repayments, loan sales and borrowings. Borrowings may be used to
compensate for reductions in normal sources of funds, such as deposit inflows at
less than projected levels, net deposit outflows or to fund balance sheet
growth. We primarily borrow from the Federal Home Loan Bank (the "FHLB") of Des
Moines. We had $6.5 billion of additional borrowing capacity at the FHLB of Des
Moines at December 31, 2020, as well as access to the Federal Reserve Discount
Window. In addition, we maintain a diversified set of unsecured and uncommitted
funding sources, including access to overnight federal funds purchased lines,
brokered deposits and capital markets. Lending activities, such as loan
originations, loan purchases and equipment purchases for lease financing, are
the primary uses of our funds.

On June 29, 2020, TCF Financial voluntarily prepaid the outstanding $80.0 million on its $150.0 million unsecured 364-day revolving credit facility with an unaffiliated bank and subsequently closed the credit facility.



Our wholly-owned subsidiary TCF Commercial Finance Canada, Inc. ("TCFCFC")
maintains a $20.0 million Canadian dollar-denominated line of credit facility
with an unaffiliated bank, which is guaranteed by TCF Bank. TCFCFC had no
outstanding borrowings under the line of credit with the counterparty at both
December 31, 2020 and December 31, 2019.

Deposits  Deposits were $38.9 billion at December 31, 2020, compared with $34.5
billion at December 31, 2019. The increase in deposits was primarily due to
increases in noninterest-bearing deposits of $3.1 billion, interest-bearing
checking account balances of $1.3 billion, savings account balances of $1.0
billion and money market deposits of $1.0 billion, reflecting PPP funding,
federal stimulus program infusions and lower consumer spending impacted by the
COVID-19 pandemic, partially offset by the continued run-off of certificates of
deposit which declined $1.9 billion.
Noninterest-bearing checking accounts represented 28.3% of total deposits at
December 31, 2020, compared with 23.1% of total deposits at December 31, 2019.
Our weighted-average interest rate for deposits, including noninterest-bearing
deposits, was 0.44% for 2020 compared with 0.88% for 2019.


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Certificates of deposit, including Certificate of Deposit Account Registry
Service ("CDARS") deposits, IRA deposits and brokered deposits, were $5.5
billion at December 31, 2020, compared with $7.5 billion at December 31, 2019.
The maturities of certificates of deposit with denominations equal to or greater
than $100,000 at December 31, 2020 were as follows:
(in thousands)
Three months or less             $   969,469
Over three through six months        971,200
Over six through 12 months           620,115
Over 12 months                       218,482
Total                            $ 2,779,266



Borrowings Borrowings were $2.0 billion at December 31, 2020, compared with $5.0
billion at December 31, 2019. The decrease in borrowings was primarily due to a
decrease in long and short-term FHLB advances, partially offset by the issuance
of $150.0 million of fixed-to-floating rate subordinated notes.

Information regarding short-term borrowings (borrowings with an original maturity of less than one year) was as follows:


                                                                      At or For the Year Ended December 31,
(Dollars in thousands)                                          2020                       2019                2018
FHLB advances
Maximum outstanding at any month-end                     $    3,200,000               $ 2,450,000          $        -
Balance outstanding at end of period                            400,000                 2,450,000                   -
Weighted average interest rate at end of period                    0.33   %                  1.85  %                -  %
Average balance outstanding                              $    1,781,421               $ 1,173,879          $        -
Weighted average interest rate                                     0.88   %                  1.69  %                -  %
Federal funds purchased
Maximum outstanding at any month-end                     $            -               $         -          $        -
Balance outstanding at end of period                                  -                         -                   -
Weighted average interest rate at end of period                       -   %                     -  %                -  %
Average balance outstanding                              $           57               $       156          $      156
Weighted average interest rate                                     1.78   %                  2.51  %             1.91  %
Collateralized deposits
Maximum outstanding at any month-end                     $      253,960               $   271,249          $        -
Balance outstanding at end of period                            217,363                   219,145                   -
Weighted average interest rate at end of period                    0.11   %                  0.64  %                -  %
Average balance outstanding                              $      218,745               $   103,931          $    1,977
Weighted average interest rate                                     0.32   %                  0.67  %             2.19  %
Line-of-credit: TCF Financial Corporation
Maximum outstanding at any month-end                             80,000                         -                   -
Balance outstanding at end of period                                  -                         -                   -
Weighted average interest rate at end of period                       -   %                     -  %                -  %
Average balance outstanding                                      22,568                         -                   -
Weighted average interest rate                                     2.40   %                     -  %                -  %
Line-of-credit: TCF Commercial Finance Canada,
Inc.
Maximum outstanding at any month-end                     $        3,066               $    10,455          $    8,565
Balance outstanding at end of period                                  -                         -                   -
Weighted average interest rate at end of period                       -   %                     -  %                -  %
Average balance outstanding                              $          583               $     1,107          $    1,155
Weighted average interest rate                                     1.93   %                  3.00  %             2.63  %




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Long-term borrowings were as follows:
                                                      At December 31,
              (in thousands)                       2020             2019
              FHLB advances                    $   709,848      $ 1,822,058
              Subordinated debt obligations        586,145          428,470
              Discounted lease rentals              75,770          100,882
              Finance lease obligation               2,969            3,038
              Total long-term borrowings       $ 1,374,732      $ 2,354,448



On May 6, 2020, TCF Bank issued $150.0 million of fixed-to-floating rate
subordinated notes (the "2030 Notes"), at par. The 2030 Notes, due May 6, 2030,
bear an initial fixed interest rate of 5.50% per annum until May 6, 2025,
payable semi-annually in arrears on May 6 and November 6, commencing on November
6, 2020, resetting quarterly thereafter to the then-current three-month LIBOR
rate plus 509 basis points.

See "Note 15. Borrowings" of Notes to Consolidated Financial Statements for further information regarding our long-term borrowings.

Contractual Obligations and Commitments As discussed in the Notes to Consolidated Financial Statements, we have certain obligations and commitments to make future payments under contracts.



At December 31, 2020, the aggregate contractual obligations and commitments were
as follows:
                                                                             Payments Due by Period
                                                                Less than               1-3                 3-5             More than
(in thousands)                               Total                1 year               years               years             5 years
Contractual Obligations:
Certificates of deposit                  $ 5,524,381          $ 5,012,121          $   444,023          $  58,827          $   9,410
Long-term borrowings                       1,363,757              186,318              495,908            352,590            328,941
Lease obligations(1)                         366,073               27,808               58,739             50,480            229,046
IT related contracts                         265,966               52,887               91,207             88,781             33,091
Investments in affordable housing            107,764               83,393               23,341                417                613
Marketing related contracts                   51,451                6,105               10,332              6,756             28,258
Construction contracts and land purchase
commitments for future branch sites           23,294               16,760                6,534                  -                  -
Liabilities related to acquisition and
portfolio purchase (2)                         5,203                4,149                1,054                  -                  -
Other contractual obligations (3)            122,503               22,409               35,999             37,667             26,428
Total                                    $ 7,830,392          $ 5,411,950          $ 1,167,137          $ 595,518          $ 655,787

(1)Includes obligations for leases that have not yet commenced. (2)Relates to acquisition of a leasing business in 2017. (3)Includes card contracts, certain tax investment projects, private equity capital investments and other similar types of investments.


                                                                  Amount of 

Commitment - Expiration by Period


                                                               Less than               1-3                 3-5              More than
(in thousands)                              Total                1 year               years               years              5 years
Commitments:
Commitments to extend credit:
Commercial                              $ 4,396,191          $ 2,001,118

$ 1,564,168 $ 647,046 $ 183,859 Consumer

                                  2,126,327              119,426              142,046            153,502            1,711,353
Total commitments to extend credit        6,522,518            2,120,544            1,706,214            800,548            1,895,212
Standby letters of credit and
guarantees on industrial revenue bonds      114,636               78,825               27,022              8,638                  151
Total                                   $ 6,637,154          $ 2,199,369          $ 1,733,236          $ 809,186          $ 1,895,363



Unrecognized tax benefits, projected benefit obligations, demand deposits with
indeterminate maturities and discretionary credit facilities that do not
obligate us to lend have been excluded from the contractual obligations table
above.


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Capital Management  We are committed to managing capital to maintain protection
for shareholders, depositors and creditors. We employ a variety of capital
management tools to achieve our capital goals, including, but not limited to,
dividends, public offerings of preferred and common stock, common stock
repurchases, redemption of preferred stock and the issuance or redemption of
subordinated debt and other capital instruments. We maintain a Capital Planning
and Dividend Policy which applies to TCF Financial and incorporates TCF Bank's
Capital Planning and Dividend Policy. These policies are intended to ensure that
capital strategy actions, including the addition of new capital, if needed,
common stock repurchases, redemption of preferred stock or the declaration of
preferred stock, common stock and bank dividends are prudent, efficient and
provide value to our shareholders, while ensuring that past and prospective
earnings retention is consistent with our capital needs for growth, as well as
asset quality and overall financial condition. TCF Financial and TCF Bank manage
capital levels to exceed all regulatory capital requirements.

On October 24, 2019, our board of directors approved an authorization to
repurchase up to $150 million of our common stock. The repurchase program has no
expiration, and permits shares to be repurchased in compliance with Rule 10b-18
of the Exchange Act, through one or more broker-dealers as part of "block
purchases" made by TCF, and/or through privately negotiated purchases,
accelerated stock repurchase agreements, or Rule 10b5-1 plans at our discretion.
During the year ended December 31, 2020, we repurchased 873,376 shares of our
common stock totaling $33.1 million, all of which occurred during the first
quarter. Between October 24, 2019 and December 31, 2019, we repurchased 657,817
shares of our common stock totaling $27.5 million. We have $89.4 million
available for repurchase under the repurchase program. In accordance with the
TCF/Huntington Merger Agreement, we are not permitted to repurchase shares of
common stock without Huntington's prior approval.

Effective January 1, 2020, the Corporation adopted CECL. Consistent with the
treatment of the ACL under the capital rule's standardized approach, the ALLL
(excluding PCD loans) and RULC are eligible for inclusion in TCF's Tier 2
capital up to 1.25 percent of standardized total risk weighted assets. In
response to the COVID-19 pandemic, the regulatory agencies published a final
rule that provides the option to delay the cumulative effect of the day 1 impact
of CECL adoption on regulatory capital, along with 25% of the change in the
adjusted allowance for credit losses (as computed for regulatory capital
purposes which excludes PCD loans), for two years, followed by a three-year
phase-in period. Management elected the 5-year transition period consistent with
the final rule issued by the regulatory agencies.

At December 31, 2020 and December 31, 2019, TCF Bank's capital ratios exceeded
the quantitative capital ratios required for an institution to be considered
"well-capitalized." Significant factors that may affect capital adequacy
include, but are not limited to, economic uncertainty, deteriorating economic
conditions, a disproportionate growth in assets versus capital and a change in
mix or credit quality of assets. There are no conditions or events since
December 31, 2020 that management believes have changed TCF Bank's status as
well-capitalized. See "Note 18. Regulatory Capital Requirements" of Notes to
Consolidated Financial Statement for further information.

Equity Total equity was $5.7 billion, or 11.9% of total assets, at December 31, 2020, compared with $5.7 billion, or 12.3% of total assets, at December 31, 2019.

Preferred Stock Preferred stock was $169.3 million at both December 31, 2020 and December 31, 2019. See "Note 17. Equity" of Notes to Consolidated Financial Statements for further information regarding our preferred stock.



Other Other equity was a reduction to total equity of $26.7 million at December
31, 2020, compared with a reduction of $28.0 million at December 31, 2019. Other
equity was comprised of shares held in trust for deferred compensation plans.
See "Note 17. Equity" of Notes to Consolidated Financial Statements for further
information.

Common Stock Dividends Dividends to common shareholders on a per share basis
were $1.40 for the year ended December 31, 2020. Dividends to common
shareholders on a per share basis, adjusted to reflect the exchange ratio in the
TCF/Chemical Merger Exchange for dividends paid prior to the completion of the
TCF/Chemical Merger, were $1.29 for the year ended December 31, 2019. Our common
stock dividend payout ratio was 100.0% for the year ended December 31, 2020,
compared with 50.4% for the year ended December 31, 2019 and 34.3% for the year
ended December 31, 2018. TCF Financial's primary funding sources for dividends
are dividends received from TCF Bank.


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On January 26, 2021, our board of directors declared a regular quarterly cash
dividend of $0.35 per common share payable on March 1, 2021 to shareholders of
record at the close of business on February 12, 2021, and declared a quarterly
cash dividend of $0.35625 per depositary share representing a 1/1,000th interest
in a share of the 5.70% Series C Non-Cumulative Perpetual Preferred Stock,
payable on March 1, 2021 to shareholders of record at the close of business on
February 12, 2021.

Common Shareholders' Equity Total common shareholders' equity was $5.5 billion,
or 11.51% of total assets, at December 31, 2020, compared with $5.5 billion, or
11.87%, at December 31, 2019. Tangible common equity was $4.0 billion, or 8.72%
of total tangible assets, at December 31, 2020, compared with $4.1 billion, or
9.01%, at December 31, 2019. Book value per common share was $36.06 at
December 31, 2020, compared with $36.20 at December 31, 2019. Tangible book
value per common share was $26.49 at December 31, 2020, compared with $26.60 at
December 31, 2019. Tangible common equity and tangible book value are non-GAAP
measures that exclude goodwill and other intangible assets. See "Consolidated
Financial Condition Analysis - Non-GAAP Financial Measures" in this Management's
Discussion and Analysis for further information.

Non-GAAP Financial Measures This Annual Report on Form 10-K contains references
to financial measures that are not defined in GAAP. Such non-GAAP financial
measures include our tangible book value per common share; tangible common
shareholders' equity; presentation of net interest income and net interest
margin on a fully tax-equivalent ("FTE") basis; our adjusted efficiency ratio
(which excludes merger-related expenses, sale of legacy TCF auto finance
portfolio and related expenses, gains on sales of branches, termination of
interest rate swaps, write-down of company-owned vacant land parcels and branch
exit costs, gain on sale of certain investment securities, pension fair
valuation adjustment, loan servicing rights and goodwill impairment, the impact
of the Tax Cuts and Jobs Act, CFPB/OCC settlement adjustment, lease financing
equipment depreciation, net interest income FTE adjustment, amortization of
intangible assets and historic tax credit amortization); composition of loans
and leases, excluding PPP loans, the adjusted allowance for credit losses as a
percentage of loans and leases, excluding PPP loans; adjusted net interest
income and margin (which excludes purchased accounting accretion and
amortization and the impact of PPP loans); and other adjusted information
presented excluding merger-related expenses and notable items (defined as sale
of legacy TCF auto finance portfolio and related expenses, gains on sales of
branches, termination of interest rate swaps, write-down of company-owned vacant
land parcels and branch exit costs, gain on sales of certain investment
securities, pension fair valuation adjustment, loan servicing rights and
goodwill impairment and CFPB/OCC settlement adjustment) including net income,
diluted earnings per share, return on average assets, return on average common
shareholders' equity and return on average tangible common shareholders'
equity), tangible book value per common share and tangible common equity to
tangible assets. Management believes that the presentation of these non-GAAP
financial measures (i) provides important supplemental information that
contributes to a proper understanding of our operating performance, (ii) enables
a more complete understanding of factors and trends affecting our business and
(iii) allows investors to evaluate our performance in a manner similar to
management, the financial services industry, bank stock analysts, and bank
regulators. Management uses non-GAAP financial measures internally in the
preparation of our operating budgets, monthly financial performance reporting,
and in our presentation to investors of our performance. Non-GAAP financial
measures are not defined by GAAP and other entities may calculate them
differently than we do. Non-GAAP financial measures have inherent limitations
and are not required to be uniformly applied. Although these non-GAAP financial
measures are frequently used by stakeholders in the evaluation of a company,
they have limitations as analytical tools and should not be considered in
isolation or as a substitute for analyses of results as reported under GAAP.

The following tables provide a reconciliation of each non-GAAP financial measure
to the most directly comparable GAAP financial measure. A reconciliation of net
interest income and net interest margin (FTE) to the most directly comparable
GAAP financial measure can be found within the Net Interest Income subheading of
this Annual Report on Form 10-K.

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Table of Con tents

The computation of the adjusted diluted earnings per common share and adjusted net income attributable to TCF was as follows:


                                                                                            Year Ended December 31,
(Dollars in thousands, except per
share data)                                              2020                   2019                  2018                  2017                  2016
Net income available to common
shareholders                                       $     212,784          $     285,493          $    289,289          $    242,954          $    192,736
Earnings allocated to participating
securities                                                     -                    (20)                  (42)                  (42)                  (49)

Earnings allocated to common
shareholders                               (a)           212,784                285,473               289,247               242,912               192,687
Merger-related expenses                                  203,888                171,968                     -                     -                     -
Notable items:
Sale of Legacy TCF auto finance
portfolio and related expenses(1)                          3,964                 32,128                     -                     -                     -
Termination of interest rate swaps(2)                          -                 17,302                     -                     -                     -
Gain on sale of certain investment
securities(3)                                                  -                 (5,869)                    -                     -                     -
Gains on sales of branches, write-down
of company-owned vacant land parcels
and branch exit costs, net(4)                            (14,166)                 9,384                     -                     -                     -
Loan servicing rights impairment(2)                       17,605                  3,882                     -                     -                     -
Pension fair valuation adjustment(5)                           -                  6,341                     -                     -                     -
CFPB/OCC settlement adjustment(5)                              -                      -                32,000                     -                     -
Re-measurement of net deferred tax
liability(6)                                                   -                      -                     -              (130,653)                    -
Goodwill impairment(5)                                         -                      -                     -                73,041
Total notable items                                        7,403                 63,168                32,000               (57,612)                    -
Total merger-related items and notable
items                                                    211,291                235,136                32,000               (57,612)                    -
Related income tax expense, net of
benefits(7)                                              (44,583)               (69,372)               (6,491)                    -                     -
Total adjustments, net of tax                            166,708                165,764                25,509               (57,612)                    -
Adjusted earnings allocated to common
stock                                      (b)     $     379,492          $ 

451,237 $ 314,756 $ 185,300 $ 192,687



Weighted-average common shares
outstanding used in diluted earnings
per common share calculation(8)            (c)       151,887,559            111,818,365            84,324,686            85,734,575            

85,006,293

Diluted earnings per common share (a) / (c) $ 1.40 $


       2.55          $       3.43          $       2.83          $       2.27
Adjusted diluted earnings per common
share                                   (b) / (c)           2.50                   4.04                  3.73                  2.16                 

2.27



Net income attributable to TCF                     $     222,759          $ 

295,468 $ 304,358 $ 268,637 $ 212,124 Total adjustments, net of tax

                            166,708                165,764                25,509               (57,612)                    -
Adjusted net income attributable to
TCF                                                $     389,467          $     461,232          $    329,867          $    211,025          $    212,124


(1)Year ended December 31, 2020 amount included within occupancy and equipment
($1.6 million), other noninterest expense ($1.4 million) and compensation and
employee benefits ($1.0 million). Year ended December 31 2019 amount included
within net gains on sales of loans and leases ($27.5 million) (inclusive of the
transfer of the Legacy TCF auto finance portfolio in the third quarter of 2019),
other noninterest expense ($2.2 million), occupancy and equipment ($1.5 million)
and compensation and employee benefits ($930 thousand).
(2)Included within other noninterest income.
(3)Included within net gains on investment securities.
(4)Year ended December 31, 2020 amount included within other noninterest income
($14.7 million net gain) and other noninterest expense ($0.6 million). Year
ended December 31, 2019 amount included within other noninterest expense.
(5)Included within other noninterest expense.
(6)Includes the impact of the re-measurement of our estimated net deferred tax
liability as a result of the enactment of the Tax Cuts and Jobs Act.
(7)Included within income tax expense.
(8)Assumes conversion of common shares, as applicable.


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The computation of the adjusted net interest income and margin was as follows:


                                                                         Year Ended December 31,
(Dollars in thousands, except per share data)                 2020                 2019                 2018
Net Interest Income                                      $ 1,538,401          $ 1,289,032          $ 1,008,495
Adjustments for taxable equivalent interest (FTE)             12,087                8,443                8,369
Net interest income (FTE)                                  1,550,488            1,297,475            1,016,864
Purchase accounting accretion and amortization               (84,174)             (58,934)                   -
Net fees recognized on PPP loans                             (35,762)                   -                    -
Interest recognition on PPP loans(1)                          (7,634)                   -                    -
Total PPP loans impact                                       (43,396)                   -                    -

Adjusted net interest income, including FTE adjustments and excluding purchase accounting accretion and amortization and PPP impact

$ 1,422,918          $ 1,238,541          $ 1,016,864
Net interest margin (GAAP)                                      3.47  %              4.17  %              4.66  %
FTE impact                                                      0.03                 0.03                 0.03
Net interest margin (FTE)                                       3.50                 4.20                 4.69  %
Purchase accounting accretion and amortization                 (0.29)               (0.26)                   -

PPP loans impact(2)                                                -                    -                    -

Adjusted net interest margin, excluding purchase accounting accretion and amortization and PPP loans impact (FTE)

                                                    3.21  %              3.94  %              4.69  %


(1)Interest income on PPP loans less funding costs. (2)The exclusion of PPP loans additionally reduces average earning assets by $1.2 billion in the year ended December 31, 2020.


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The computation of the adjusted return on average assets, common equity and average tangible common equity was as follows:


                                                                                      Year Ended December 31,
(Dollars in thousands)                                2020                 2019                 2018                 2017                 2016
Adjusted net income after tax expense:
Income after tax expense                  (a)    $   230,041          $   

306,926 $ 315,628 $ 278,784 $ 221,717 Merger-related expenses

                              203,888              171,968                    -                    -                    -
Notable items                                          7,403               63,168               32,000              (57,612)                   -
Related income tax expense, net of tax
benefits                                             (44,583)             (69,372)              (6,491)                   -                    -
Adjusted net income after tax expense
for ROAA calculation                      (b)    $   396,749          $   

472,690 $ 341,137 $ 221,172 $ 221,717 Net income available to common shareholders

                              (c)    $   212,784          $   

285,493 $ 289,289 $ 242,954 $ 192,736 Other intangibles amortization

                        21,992               11,660                3,417                2,345                1,388
Related income tax expense                            (4,678)              (2,752)                (799)              (1,046)                (493)
Net income available to common
shareholders used in ROATCE
calculation                               (d)    $   230,098          $   

294,401 $ 291,907 $ 244,253 $ 193,631



Adjusted net income available to
common shareholders:
Net income available to common
shareholders                                     $   212,784          $   285,493          $   289,289          $   242,954          $   192,736
Notable items                                          7,403               63,168               32,000              (57,612)                   -
Merger-related expenses                              203,888              171,968                    -                    -                    -
Related income tax expense, net of tax
benefits                                             (44,583)             (69,372)              (6,491)                   -                    -
Net income available to common
shareholders used in adjusted ROACE
calculation                               (e)        379,492              451,257              314,798              185,342              192,736
Other intangibles amortization                        21,992               11,660                3,417                2,345                1,388
Related income tax expense                            (4,678)              (2,752)                (799)              (1,046)                (493)
Net income available to common
shareholders used in adjusted ROATCE
calculation                               (f)    $   396,806          $   460,165          $   317,416          $   186,641          $   193,631
Average balances:
Average assets                            (g)    $   48,400,938       $  

33,526,930 $ 23,062,148 $ 22,051,967 $ 21,075,415 Total average equity

                               5,673,573            3,915,038            2,530,502            2,535,938            2,394,701
Non-controlling interest in
subsidiaries                                         (24,006)             (25,834)             (24,323)             (22,514)             (21,525)
Total TCF Financial Corporation
shareholders' equity                               5,649,567            3,889,204            2,506,179            2,513,424            2,373,176
Preferred stock                                     (169,302)            (169,302)            (176,971)            (264,474)            (263,240)

Average total common shareholders' equity used in ROACE calculation (h) $ 5,480,265 $ 3,719,902 $ 2,329,208 $ 2,248,950 $ 2,109,936 Average goodwill, net

                             (1,310,071)            (620,253)            (154,757)            (219,144)            (225,640)
Average other intangibles, net                      (157,824)             (99,038)             (22,136)             (12,799)              (2,379)
Average tangible common shareholders'
equity used in ROATCE calculation         (i)    $ 4,012,370          $ 3,000,611          $ 2,152,315          $ 2,017,007          $ 1,881,917

ROAA                                    (a)/(g)         0.48  %              0.92  %              1.37  %              1.26  %              1.05  %
Adjusted ROAA                           (b)/(g)         0.82                 1.41                 1.48                 1.00                 1.05
ROACE                                   (c)/(h)         3.88                 7.67                12.42                10.80                 9.13
Adjusted ROACE                          (e)/(h)         6.92                12.13                13.51                 8.24                 9.13
ROATCE                                  (d)/(i)         5.73                 9.81                13.56                12.11                10.29
Adjusted ROATCE                         (f)/(i)         9.88                15.34                14.74                 9.25                10.29





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Table of Con tents The computation of the adjusted efficiency ratio, noninterest income and noninterest expense was as follows:


                                                                                    Year Ended December 31,
(Dollars in thousands)                              2020                 2019                 2018                 2017                 2016
Noninterest expense                     (a)    $ 1,527,371          $ 

1,332,115 $ 1,014,400 $ 1,059,934 $ 909,887 Merger-related expenses

                           (203,888)            (171,968)                   -                    -                    -
Expenses related to the sale of
Legacy TCF auto finance portfolio                   (3,964)              (4,670)                   -                    -                    -
CFPB/OCC settlement adjustment                           -                    -              (32,000)                   -                    -
Write-down of company-owned vacant
land parcels and branch exit costs                    (551)              (9,384)                   -                    -                    -
Pension fair valuation adjustment                        -               (6,341)                   -                    -
Goodwill impairment                                      -                    -                    -              (73,041)                   -
Adjusted noninterest expense                   $ 1,318,968          $ 

1,139,752 $ 982,400 $ 986,893 $ 909,887 Lease financing equipment depreciation

                                       (73,204)             (76,426)             (73,829)             (55,901)             (40,359)
Amortization of intangibles                        (21,992)             (11,660)              (3,417)              (2,345)              (1,388)
Historic tax credit amortization                    (7,050)              (4,030)                   -                    -                    -
Adjusted noninterest expense,
efficiency ratio                        (b)    $ 1,216,722          $ 

1,047,636 $ 905,154 $ 928,647 $ 868,140



Net interest income                            $ 1,538,401          $ 

1,289,032 $ 1,008,495 $ 937,474 $ 859,725 Noninterest income

                                 516,063              465,532              454,397              436,063              454,281
Total revenue                           (c)    $ 2,054,464          $ 

1,754,564 $ 1,462,892 $ 1,373,537 $ 1,314,006



Noninterest income                             $   516,063          $   

465,532 $ 454,397 $ 436,063 $ 454,281 Loss on transfer of Legacy TCF auto finance portfolio to held-for-sale

                       -               27,458                    -                    -                    -
Termination of interest rate swaps                       -               17,302                    -                    -                    -
Gain on sales of certain investment
securities                                               -               (5,869)                   -                    -                    -
Gain on sales of branches                          (14,717)                   -                    -                    -                    -
Loan servicing rights impairment                    17,605                3,882                    -                    -                    -
Adjusted noninterest income                        518,951              508,305              454,397              436,063              454,281
Net interest income                              1,538,401            1,289,032            1,008,495              937,474              859,725
Net interest income FTE adjustment                  12,087                8,443                8,369               14,542               10,813
Adjusted net interest income                     1,550,488            1,297,475            1,016,864              952,016              870,538
Lease financing equipment
depreciation                                       (73,204)             (76,426)             (73,829)             (55,901)             (40,359)
Adjusted total revenue, efficiency
ratio                                   (d)    $ 1,996,235          $ 1,729,354          $ 1,397,432          $ 1,332,178          $ 1,284,460

Efficiency ratio                      (a)/(c)        74.34  %             75.92  %             69.34  %             77.17  %             69.25  %
Adjusted efficiency ratio             (b)/(d)        60.95                60.58                64.77                69.71                67.59




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The computations of tangible common equity to tangible assets and tangible book
value per common share were as follows:
                                                                                                   At December 31,
(Dollars in thousands, except per share data)                 2020                  2019                  2018                 2017                 2016
Total equity                                             $     5,689,297

$ 5,727,241 $ 2,556,260 $ 2,680,584 $ 2,444,645 Non-controlling interest in subsidiaries

                        (18,484)              (20,226)             (18,459)             (17,827)             

(17,162)

Total TCF Financial Corporation shareholders'
equity                                                         5,670,813             5,707,015            2,537,801            2,662,757            2,427,483
Preferred stock                                                (169,302)             (169,302)            (169,302)            (265,821)            (263,240)
Total common shareholders' equity                (a)           5,501,511             5,537,713            2,368,499            2,396,936            2,164,243
Goodwill, net                                                (1,313,046)           (1,299,878)            (154,757)            (154,757)            (225,640)
Other intangibles, net                                         (146,377)             (168,368)             (20,496)             (23,662)              (1,708)
Tangible common shareholders' equity             (b)     $     4,042,088       $     4,069,467       $    2,193,246       $    2,218,517       $    1,936,895

Total assets                                     (c)     $    47,802,487       $    46,651,553       $   23,699,612       $   23,002,159       $   21,441,326
Goodwill, net                                                (1,313,046)           (1,299,878)            (154,757)            (154,757)            (225,640)
Other intangibles, net                                         (146,377)             (168,368)             (20,496)             (23,662)              (1,708)
Tangible assets                                  (d)     $    46,343,064       $    45,183,307       $   23,524,359       $   22,823,740       $   21,213,978

Common stock shares outstanding                  (e)      152,565,504           152,965,571           83,289,382           87,225,232           86,881,005

Common equity to assets                        (a)/(c)          11.51  %              11.87  %              9.99  %             10.42  %             10.09  %
Tangible common equity to tangible assets      (b)/(d)           8.72                  9.01                 9.32                 9.72                 9.13

Book value per common share                    (a)/(e)   $      36.06

$ 36.20 $ 28.44 $ 27.48 $ 24.91 Tangible book value per common share

           (b)/(e)          26.49                 26.60                26.33                25.43                

22.29

The computations of loans and leases and the related allowance for credit losses excluding PPP loans were as follows:


                                                                                                                 Change from
                                                           At December 31,                                    December 31, 2019
(Dollars in thousands)                           2020                           2019                           $                 %
Commercial and industrial              $             11,422,383       $             11,439,602       $          (17,219)       (0.2)%
Commercial real estate                             9,702,587                  9,136,870                         565,717         6.2
Lease financing                                    2,817,231                  2,699,869                         117,362         4.3
Total commercial loan and lease
portfolio                                         23,942,201                 23,276,341                         665,860         2.9
Residential mortgage                               6,182,045                  6,179,805                           2,240          -
Home equity                                        3,108,736                  3,498,907                        (390,171)       (11.2)
Consumer installment                               1,233,426                  1,542,411                        (308,985)       (20.0)
Total consumer loan portfolio                     10,524,207                 11,221,123                        (696,916)       (6.2)
Total loans and leases                               34,466,408                     34,497,464                  (31,056)       (0.1)
PPP (Commercial and industrial)                       1,553,908                              -                1,553,908         N.M.
Loans and leases excluding PPP loans
Commercial and industrial                             9,868,475                     11,439,602               (1,571,127)       (13.7)
Commercial real estate                             9,702,587                  9,136,870                         565,717         6.2
Lease financing                                    2,817,231                  2,699,869                         117,362         4.3
Total commercial loan and lease
portfolio                                         22,388,293                 23,276,341                        (888,048)       (3.8)
Residential mortgage                               6,182,045                  6,179,805                           2,240          -
Home equity                                        3,108,736                  3,498,907                        (390,171)       (11.2)
Consumer installment                               1,233,426                  1,542,411                        (308,985)       (20.0)
Total consumer loan portfolio                     10,524,207                 11,221,123                        (696,916)       (6.2)
Total loans and leases, excluding PPP
loans                                  $             32,912,500       $     

34,497,464 $ (1,584,964) (4.6)% Allowance for credit losses

            $                549,181       $                116,580       $          432,601         N.M.
Allowance for credit losses as a % of
total loans and leases                                    1.59%                          0.34%                      125         bps
Allowance for credit losses as a % of
loans and leases, excluding PPP loans                      1.67                           0.34                      133




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Recent Accounting Developments

For a description of new accounting standards issued, but not yet adopted, see
"Note 2. Summary of Significant Accounting Policies" of Notes to Consolidated
Financial Statements.
Item 7A. Quantitative and Qualitative Disclosures About Market Risk

Our results of operations depend, to a large degree, on our net interest income
and our ability to manage interest rate risk. Although we manage other risks in
the normal course of business, such as credit risk, liquidity risk and foreign
currency risk, we consider interest rate risk to be one of our more significant
market risks.

Interest Rate Risk

Our ALCO and the Finance Committee of our Board of Directors have established
interest rate risk policy limits. Interest rate risk is defined as the exposure
of net interest income and fair value of financial instruments (interest earning
assets, deposits and borrowings) to movements in interest rates. The major
sources of our interest rate risk are timing differences in the maturity and
repricing characteristics of assets and liabilities, changes in the shape of the
yield curve, changes in consumer behavior and changes in relationships between
rate indices (basis risk). Management measures these risks and their impact in
various ways, including through the use of simulation and valuation analyses.
The interest rate scenarios may include gradual or rapid changes in interest
rates, spread narrowing and widening, yield curve twists and changes in
assumptions about consumer behavior in various interest rate scenarios. A
mismatch between maturities, interest rate sensitivities and prepayment
characteristics of assets and liabilities results in interest rate risk. We,
like most financial institutions, have material interest rate risk exposure to
changes in both short- and long-term interest rates, as well as variable
interest rate indices (e.g., the prime rate or London Interbank Offered Rate).

Our ALCO is responsible for reviewing our interest rate sensitivity position and
establishing policies to monitor and limit exposure to interest rate risk. ALCO
manages our interest rate risk based on interest rate expectations and other
factors. The principal objective in managing our assets and liabilities is to
provide maximum levels of net interest income and facilitate our funding needs,
while maintaining acceptable levels of interest rate risk and liquidity risk.

ALCO primarily uses two interest rate risk tools with policy limits to evaluate
our interest rate risk: net interest income simulation and economic value of
equity ("EVE") analysis.

Management utilizes net interest income simulation models to estimate the
near-term effects of changing interest rates on our net interest income. Net
interest income simulation involves forecasting net interest income under a
variety of scenarios, including the level of interest rates, the shape of the
yield curve and the spreads between market interest rates. Management exercises
best judgment in making assumptions regarding events that management can
influence, such as non-contractual deposit repricings and events outside
management's control, including consumer behavior on loan and deposit activity
and the effect that competition has on both loan and deposit pricing. These
assumptions are subjective and, as a result, net interest income simulation
results will differ from actual results due to the timing, magnitude and
frequency of interest rate changes and changes in market conditions, consumer
behavior and management strategies, among other factors. We perform various
sensitivity analyses on new loan spreads, prepayment rates, basis risk and
deposit assumptions.

The following table presents changes in our net interest income over a twelve
month period if short- and long-term interest rates were to sustain an immediate
change. These projections were based on our assets and liabilities remaining
static over the next twelve months and factored into the simulation model.
                                                                 Impact on 

Net Interest Income



(Dollars in thousands)                            December 31, 2020                        December 31, 2019
Immediate change in interest rates:
+200 basis points                         $       61,700             4.2  %       $         32,200             2.1  %
+100 basis points                                 32,700             2.2                    20,900             1.4
-100 basis points(1)                             (39,500)           (2.7)                  (60,900)           (4.0)

(1) Sensitivity measure is calculated assuming market rates do not decline below 0%.




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The increases in sensitivity to rising rates at December 31, 2020, compared to
December 31, 2019, was primarily driven by increased deposits, lower wholesale
borrowing and overall lower rate environment. The decrease in sensitivity to a
declining rate at December 31, 2020, compared to December 31, 2019, is primarily
driven by a lower rate environment. The sensitivity measure is calculated
assuming market rates do not decline below 0%. It is expected that a rate below
0% could cause further net interest income compression.

Management also uses EVE to measure risk in the balance sheet that might not be
taken into account in the net interest income simulation analysis. Net interest
income simulation highlights exposure over a relatively short time period, while
EVE analysis incorporates all cash flows over the estimated remaining life of
all balance sheet positions. The valuation of the balance sheet, at a point in
time, is defined as the discounted present value of asset cash flows minus the
discounted present value of liability cash flows. EVE analysis addresses only
the current balance sheet and does not incorporate the planned changes to assets
or liabilities. As with the net interest income simulation model, EVE analysis
is based on key assumptions about the timing and variability of balance sheet
cash flows and does not take into account any potential responses by management
to anticipated changes in interest rates.

Credit Risk



Credit risk is defined as the risk to our current or anticipated earnings or
capital arising from an obligor's failures to meet the terms of any contract
with us or otherwise failing to perform as agreed, such as the failure of
customers and counterparties to meet their contractual obligations, as well as
contingent exposures from unfunded loan commitments and letters of credit.

Our Enterprise Risk Management Committee meets at least quarterly and is
responsible for monitoring the loan and lease portfolio composition and risk
tolerance within the various segments of the portfolio. The Enterprise Risk
Management Committee and TCF Financial's Board of Directors have adopted a Risk
Appetite Statement to manage our credit risk by setting (i) a desired balance
between asset classes, (ii) concentration limits based on loan type and business
line and (iii) maximum tolerances for credit performance. To manage credit risk
arising from lending and leasing activities, management has adopted and
maintains underwriting policies and procedures and periodically reviews the
appropriateness of these policies and procedures. Customers and guarantors or
recourse providers are evaluated as part of initial underwriting processes and
through periodic reviews. For consumer loans, credit scoring models are used to
help determine eligibility for credit and terms of credit. These models are
periodically reviewed to verify that they are predictive of borrower
performance. Limits are established on the exposure to a single customer
(including affiliates) and on concentrations for certain categories of
customers. Loan and lease credit approval levels are established so that larger
credit exposures receive managerial review at the appropriate level through the
credit committees.

Management continuously monitors asset quality in order to manage our credit
risk and to determine the appropriateness of valuation allowances, including, in
the case of commercial loans, inventory finance loans and equipment finance
loans and leases, a risk rating methodology under which a rating of one through
nine is assigned to each loan or lease. The rating reflects management's
assessment of the potential impact on repayment of the customer's financial and
operational condition. Asset quality is monitored separately based on the type
or category of loan or lease. The rating process allows management to better
define our loan and lease portfolio risk profile. Management also uses various
risk models to estimate probable impact on payment performance under various
scenarios, both expected and unexpected.

We also have credit risk in our investment securities available-for-sale
portfolio related to obligations of states and political subdivisions and
non-agency collateralized mortgage obligations. We maintain a set of
underwriting criteria and regularly monitor credit performance under the
direction and supervision of the TCF Bank Credit Committee to manage this risk.
The remainder of the investment securities available-for-sale portfolio and the
investment securities held-to-maturity portfolio consist primarily of fixed-rate
mortgage-backed securities issued and guaranteed by the FNMA and the FHLMC, and
therefore credit risk is minimal. All investment related counterparties and
transaction limits are reviewed and approved annually by both ALCO and the TCF
Bank Credit Committee.

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  Table of Con    tents
Liquidity Risk

Liquidity risk is defined as the risk to earnings or capital arising from our inability to meet our obligations when they come due without incurring unacceptable losses.

TCF Financial's primary source of cash flow is capital distributions from TCF
Bank. TCF Bank may be required to receive regulatory approval prior to making
any such distributions in the future and such distributions may be restricted by
its federal banking regulators. TCF Bank's ability to make any such
distributions will also depend on its earnings and ability to meet minimum
regulatory capital requirements in effect during future periods. See "Item 1.
Business - Regulation - Restrictions on Distributions", "Note 18. Regulatory
Capital Requirements" and "Note 29. Parent Company Financial Information" of
Notes to Consolidated Financial Statements for further information.

TCF Financial's Board of Directors have adopted a Liquidity Management Policy
for TCF Bank to direct management of TCF's liquidity risk. The objective of the
Liquidity Management Policy is to ensure that TCF Bank meets its cash and
collateral obligations promptly, in a cost-effective manner and with the highest
degree of reliability. The maintenance of adequate levels of asset and liability
liquidity will provide us with the ability to meet both expected and unexpected
cash flows and collateral needs. Key liquidity ratios, asset liquidity levels
and the amount available from funding sources are reported to ALCO on a monthly
basis. TCF Bank's Liquidity Management Policy defines liquidity stress scenarios
and establishes asset liquidity target ranges based on those stress scenarios
that are deemed appropriate for its risk profile.

Our asset liquidity may be held in the form of on-balance sheet cash invested
with the Federal Reserve Bank or other highly liquid marketable securities that
are not pledged and can be sold or pledged to various counterparties under
established agreements. Our liability liquidity is sourced primarily through
deposits and other secured sources of funding. See "Item 7. Management's
Discussion and Analysis - Consolidated Results of Operations Analysis -
Liquidity Management" for further information.

Foreign Currency Risk



We are also exposed to foreign currency risk as changes in the exchange rates of
the Canadian, New Zealand and Australian dollars may impact our investment in
TCFCFC. We enter into forward foreign exchange contracts in order to minimize
the risk of changes in foreign exchange rates on its investment in and loans to
TCFCFC. The values of forward foreign exchange contracts vary over their
contractual lives as the related currency exchange rates fluctuate. We may also
experience realized and unrealized gains or losses on forward foreign exchange
contracts as a result of changes in foreign exchange rates. See "Note 2. Summary
of Significant Accounting Policies" and "Note 19. Derivative Instruments" of
Notes to Consolidated Financial Statements for further information.

LIBOR Transition



In 2017, the U.K. Financial Conduct Authority (the "FCA") noted that market
conditions raised serious questions about the future sustainability of LIBOR
benchmarks. Many financial products, including mortgages and other consumer
loans, commercial loans, corporate loans, various types of debt, derivatives and
other securities, reference LIBOR to determine their applicable interest rate.
As part of the expected upcoming cessation of publication of LIBOR rates, TCF
created a company-wide LIBOR transition plan and has already taken several
important steps to ensure TCF's operational readiness for the transition,
including completing an inventory of existing LIBOR-indexed products and
developing LIBOR fallback language for inclusion in loans that contemplates the
transition away from LIBOR. As part of our plan, we have and will continue to
engage with industry working groups and regulators in order to monitor and
respond to risks associated with the discontinuation, unavailability, or
non-representativeness of LIBOR, and will continue to actively engage with our
clients to facilitate the transition to alternative reference rates.

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