Good morning. My name is Jamal, and I will be your conference operator today. At this time, I would like to welcome everyone to the Fifth Third Earnings Conference Call. [Operator Instructions] Thank you. I would now like to turn the call over to Mr. Jeff Richardson, Director of Investor Relations. Mr. Richardson, you may begin.

Thanks, Jamal. Good morning. Today, we'll be talking with you about our full year and fourth quarter 2011 results. This call may contain certain forward-looking statements about Fifth Third pertaining to our financial condition, results of operations, plans and objectives. These statements involve certain risks and uncertainties. There are a number of factors that could cause results to differ materially from historical performance in these statements. We've identified some of these factors in our forward-looking cautionary statement at the end of our earnings release and in other materials, and we encourage you to review them. Fifth Third undertakes no obligation and would not expect to update any such forward-looking statements after the date of this call. We're joined on the call by several people: Kevin Kabat, our President and CEO; Chief Financial Officer, Dan Poston; Chief Credit Officer, Bruce Lee; Treasurer, Tayfun Tuzun; and Jim Eglseder of Investor Relations. During the question-and-answer period, please provide the name -- your name and that of your firm to the operator. With that, I'll turn the call over to Kevin Kabat. Kevin?

Thanks, Jeff. Before going through the quarter, I want to make some comments regarding 2011. Although it was a fairly tough year environmentally, I believe our results demonstrate the many core strengths of Fifth Third, as well as the many steps we've taken to make it a better company. Net income to common shareholders of $1.1 billion is the highest since 2006 and more than doubled from last year. Pre-provision net revenue exceeded $2 billion for the third consecutive year, as we've managed the regulatory headwinds and a slow growth environment. We've posted a return on assets of about 1% for 5 consecutive quarters with the full year ROA of 1.2%, up about 50 basis points from our 2010 full year ROA. I'm pleased with our ability to produce these returns in the midst of a relatively weak economic recovery and significant regulatory changes. We remain committed to serving our markets, which is being demonstrated through our strong deposit and loan growth results. For the year, average transaction deposits increased 10%, and we grew portfolio loans 5%, with average balances increasing each quarter throughout the year. Credit quality metrics showed continued and significant improvement, with charge-offs approximately half of 2010's levels, and we continue to build equity capital despite our already strong capital position. Those trends are encouraging and provide a solid foundation to build on as we enter a new year. Now moving onto some highlights for the fourth quarter. Fifth Third reported fourth quarter net income to common shareholders of $305 million and earnings per diluted common share of $0.33. Earnings results included the impact of charges related to the Visa total return swap and our bankcard association membership, which Dan will discuss in more detail. Those charges were $68 million pretax or about $0.045 per share. Returns…

Thanks, Kevin. I will start on Slide 4 of the presentation and move into details of the quarter. In the fourth quarter, we reported net income of $314 million and recorded preferred dividends of $9 million. Net income to common was $5 million and diluted earnings per share were $0.33, down 18% or $0.07 from the third quarter. As we previously announced, this included $68 million of pretax charges or about $0.045 per share on an after-tax basis that we incurred in the fourth quarter associated with the Visa total return swap and increased bankcard association litigation reserves. As you may recall, in mid-2009, we sold our Visa B shares to a counterparty. Now that transaction was designed to insulate the purchaser from the effects of Visa's litigation costs on the conversion rate of those B shares into A shares, and that was done through a total return swap. Visa made a $1.6 billion deposit to its litigation escrow account in December, and so $54 million of the charges that we recorded were in other noninterest income, and those were designed to adjust the value of the associated swap liability. In light of this development, we also increased other reserves related to bankcard membership by $14 million. Turning to Slide 5. Net interest income on a fully taxable equivalent basis increased $18 million sequentially to $920 million, which was better than we expected, and net interest margin increased 2 basis points to 3.67%. Growth in C&I, residential mortgage, auto and credit card loans contributed to the increasing NII and NIM. This was partially offset by yield compression across most loan captions, which cost us 5 basis points in margin, as well as lower reinvestment rates on securities given the current interest rate environment. All in, net loan growth contributed 2…

Thanks, Dan. I'm glad to be here and look forward to reconnecting with many of you in my new role. Our overall credit results are encouraging with credit quality trends positive across all categories, including delinquencies, NPAs and charge-offs. Starting with charge-offs on Slide 11. Total net charge-offs of $239 million decreased $23 million or 9% from the third quarter. That was 119 basis points of loans and the lowest we've reported since the fourth quarter of 2007. The biggest improvement came from Florida, where charge-offs were down 37% sequentially. Commercial net charge-offs were $113 million in the fourth quarter and were down $23 million sequentially. At 1% of loans, that's the lowest levels since the first quarter of 2008. C&I charge-offs were $62 million, up $7 million sequentially. Commercial mortgage charge-offs were $47 million, consistent with the third quarter. And commercial construction charge-offs were $4 million, down $31 million or 88% sequentially. At 137 basis points, that is the lowest charge-off rate on the construction portfolio since prior to the crisis. I'd also note that our homebuilder portfolio balances are down to $512 million, less than 20% of peak levels and less than 1% of total loans. Total consumer net charge-offs were $126 million, consistent with last quarter. Trends were generally stable. Residential mortgage net charge-offs of $36 million were flat sequentially, and home equity net charge-offs of $50 million were down $3 million. Auto net charge-offs were $13 million versus $12 million last quarter and remained low at 44 basis points. And credit card net charge-offs were $21 million, a $3 million sequential increase and also relatively low at 4.29%. Looking ahead to the first quarter, we'd expect net charge-offs to be down another $10 million to $15 million or so, driven by lower commercial charge-offs. We also…

[Operator Instructions] And your first question comes from Erika Penala.

Erika Penala from BofA Merrill Lynch. My first question was on capital allocation. We appreciate the comments in terms of the CCAR request and putting it in context of minimizing capital build going forward. But as you find yourself still being restricted in terms of what you'd like to pay out to shareholders, could you give us the sense of what your priorities are in terms of other strategic initiatives like M&A? And if so, where would you be looking? And what's the bid ask spread currently that you're seeing?

Yes, Erika, as you alluded to, while we are being given a bit more flexibility in terms of managing our own capital levels, we still don't have complete freedom to manage our capital the way that we would optimally like to. And that leaves us with a situation where we will probably continue to have capital levels in excess of what we might ideally want to have. I think relative to how we deploy that capital, our -- we've talked a lot in the past about priorities. Our first priority is organic growth. We continue to believe that we have good prospects for continuing to grow our loan portfolios. Relative to M&A, I think M&A remains an alternative that we monitor closely. It's not something that we are going to push before its time. I think we will be very disciplined. I expect that there may be some M&A opportunities in 2012, but frankly, based on the current bid ask spread that as you referred to, I don't expect that to happen in the near term. So in all likelihood, it would be later in 2012 rather than earlier, so -- and relative to kind of where we would see M&A activity occurring, I think there are a variety of geographies and a variety of sizes of organizations that may make sense at different points in time and perhaps for different reasons. I think one of our primary objectives would be to continue to increase the density in the markets that we're in. I think we would probably have a bias toward acquisitions that are not geography expanding but rather are fill-ins and help us achieve our increased density goals. But that shouldn't be taken to assume that there may not be opportunities that present themselves outside of that, but we would look at it and evaluate at the time.

And just my second question and I'll step off. Your guidance for the full year margin of 355 to 360, does that include a plan to redeem any of your TRUPs? And if so, how much and at which rate?

We've talked about TRUPs. We've talked about the possibility that we would redeem additional TRUPs. I think the TRUPs that we have, have contractual call provisions that will allow us to call some of them at least, to call them later in 2012 or early 2013. There's the possibility that something could happen that would present us with an opportunity under our regulatory call provision to do that earlier. Those are things that we consider, and I think our overall guidance includes a number of things that we anticipate during the year and attach certain probabilities to and certainly the potential for TRUPs redemptions would be part of that.

I think it'd be fair to say -- this is Jeff -- that guidance would accommodate several outcomes.

And your next question comes from the line of Ken Zerbe with Morgan Stanley.

In terms of -- I guess, I was just thinking about like the dynamics between loan growth and deposit growth, because obviously you're looking for growth in loans next year but also in deposits. But I guess normally, when we think about a modest economic recovery, we would assume some core deposit contraction on the part of borrowers. Can you just talk about are you seeing any of that so far or expect that going forward?

We are not seeing it thus far. And we've talked about fourth quarter results, and we continue to see expansion in deposits. We do expect that as the economic recovery continues and hopefully strengthens, we do expect that, that will result in some deposit outflow. We've not seen that yet. We're not expecting large amounts of that in the near term, but certainly, it is something that we would expect with an expansion and something that's built into our modeling and the way we manage the balance sheet.

Okay, great. And just very quickly, the increase that you had in the held-for-sale loans, does that meaningfully impact your margin in the quarter?

I don't think it had a tremendous impact on margin though. I mean, most of that increase, as you might expect, is a result of the residential mortgage pipeline, and it didn't have a dramatic impact on margin.

And your next question comes from the line of Ken Usdin with Jefferies. Kenneth M. Usdin - Jefferies & Company, Inc., Research Division: Two quick questions. First of all, credit, obviously continuing to be much improved and the reserve release also was still pretty sizable this quarter. I was just wondering if you'd give us some type of directional outlook for the magnitude of release you continue to expect based on what you've already seen in terms of the ongoing improvement in credit.

Yes. The reserve release is obviously governed by accounting rules. It's governed by methodologies and models that we have adopted and we'll continue to follow in the future. And it's difficult to predict at any particular point in time how or what the reserve release will look like. That being said, I think 2 things come to mind in terms of impacts on kind of the continued pace of reserve release. One is that we are starting to see stronger loan growth, and with loan growth comes the need to provide reserves for those additional loans. And those reserves on those additional loans will mitigate or offset any reserve release associated with credit improvement that's taking place. And then secondly, while credit continues to improve very nicely, we were very encouraged by our credit results this quarter. As the recovery wears on, one would only expect that the pace of those credit improvements would slow. So I think those 2 things will tend to probably act as mitigating factors in terms of the level of our expected reserve releases as we go forward over time. I don't -- I'm not sure that any of those things have any dramatic immediate impact, but certainly over time, I think those are things that would tend to make that reserve release lower rather than higher. Kenneth M. Usdin - Jefferies & Company, Inc., Research Division: Right, okay. Second question is on expenses. I know you talked about the fact that expenses should come down in the second and third after the first. But just wondering -- I think the expense feedback you're getting is at the -- obviously, the expenses for this quarter were higher than expected and even look to be higher than expected for the first quarter. So I know Fifth Third continues to be a continuous improvement type of place, but can you talk about perhaps the magnitude of expense declines that we could see after the first? And then what else can you do behind the scenes to mitigate some of the extra expense growth that still seems to be coming through?

Yes, as you mentioned, I think we did see expense growth in the fourth quarter, a lot of that. And I think we touched on most of those in our prepared remarks. We're associated with unusual or unique items that aren't necessarily kind of run rate items. So I think the key, and you touched on it, is that while the expense declines in the first quarter are mitigated by or offset by some seasonality in our FICA expenses -- and we have that every year. It's relates to the fact that the -- that you kick into a new calendar year, and we also have payouts of incentive compensation and so forth from the prior year. So the first quarter is always elevated. That's about $25 million. It's not an insignificant sum. So if you look at a $15 million decrease in the first quarter that we've guided to on -- that is despite a $25 million kind of seasonal bump in the first quarter related to FICA, you can see that fourth quarter to first, absent the FICA increase, we're looking at $40 million or so decrease in expenses. And we would expect that $25 million to go away as we go forward. So in terms of the magnitude of expense improvements from first quarter forward, one of the items certainly would be the $25 million that we talked about. We would also expect that expenses in the first quarter would continue to be impacted by strong levels of mortgage servicing or excuse me, of mortgage origination activity, which brings with it increased incentive compensation and increased expenses related to mortgage fulfillment. And I think some of those things would be expected to moderate expenses as we go forward. On the revenue side, I think the mortgage revenue, as we move on through the year, we would expect to be replaced by actions that we're taking relative to mitigation activities on Durbin that would have a fairly sizable impact in the second half of the year.

And your next question comes from Craig Siegenthaler with Crédit Suisse. Craig Siegenthaler - Crédit Suisse AG, Research Division: Maybe just to go back a little deeper on that last question on expenses. So guidance was for a $50 million decline in the first quarter, but that includes a $25 million seasonal bump, so it looks like we have a step-down in the second quarter. As we think longer term, I realize your credit-related expenses will probably continue to decline in NIE [ph], but how should we think about kind of core operating expenses trending kind of on the other side of the second quarter?

Yes, I mean, I think from an expense trend perspective, you should expect that we will continue to manage expenses very closely the way we always have. We talked about first quarter and the impacts seasonally. But as we go forward, we would expect to make steady progress in terms of our efficiency ratio. We've talked in the past, in the recent past about having a targeted efficiency ratio in the mid-50s. We're not going to get there this year, but we do believe we will make a very steady progress in -- toward our efficiency goals during 2012 and that we would approach a 60% or so efficiency ratio by the time we get to the end of the year. So on longer-term basis, I think meeting our efficiency targets will involve -- will need to involve increases on a revenue side. And clearly, the interest rate environment in particular is something that will allow us to make progress on that front, as well as the balance sheet growth that we expect we will accomplish during 2012 and into the future as the recovery gets a bit stronger. So we would anticipate that a stronger revenue environment, as well as kind of continued cost efficiency, will allow us to meet our goals on that front. Craig Siegenthaler - Crédit Suisse AG, Research Division: And just to get to that mid-50s ratio, is that roughly 100% driven by revenues? And from your comments, it sounds like to get there, you need higher rates, that it's almost -- it will be very difficult to achieve that mid-50s in the absence of a Fed rate hike. Is that true?

Yes, I think that's fair.

And your next question comes from Paul Miller with FBR Capital Markets. Paul J. Miller - FBR Capital Markets & Co., Research Division: On -- we saw over the last couple of days that USB, PNC and this morning, SunTrust talked about being invited into the AG settlement. That's supposed to be settled very shortly. Have you been at any talks with regulators about -- in joining the settlement? And what are your thoughts on it because my guess is whatever it is, you might have -- you probably have to live by whatever they settle.

Yes, well first of all, we're not a party to any of the discussion with the state attorneys general, and therefore, we don't really have any insight into those discussions relative to that [ph]. We're not a large servicer particularly relative to the big 5 firms that were initially involved in those discussions, and perhaps, that's been expanded now. But that has not included us, so I think we're something like the 15th, 16th largest servicer in the country. So we don't really have a lot of information that allows us to evaluate that. Certainly, relative to those discussions and how those discussions bear out, we do expect that whatever standards, new standards may develop with respect to those discussions or out of those discussions would apply to the rest of the industry as well. But the settlement discussions that occur, those relate to specific states. They relate to specific activities that specific firms may have engaged in, and they discuss specific revenues given all that. And the applicability of those things to us, I think, depends on a lot of things that we don't really have a whole lot of knowledge about. So we don't know what those are or how they might apply to us, so we will obviously continue to monitor the situation. But we don't really have any comment on that now and certainly, don't have anything that would lead us to believe that we need to put a reserve on the books or do some of the other things that you're seeing in other organizations. Relative to other regulators, regulatory contact, we typically don't discuss kind of banking regulatory discussions, so we can't really comment any further relative to discussions beyond the fact that we haven't been involved in any discussions relative to the settlement with the various states. Paul J. Miller - FBR Capital Markets & Co., Research Division: And then on the loan growth, and we're seeing a lot of decent loan growth, not only by you but throughout the industry. Is it coming from -- are you seeing real economic growth even though it might be small? Or is it market share transfers from small institutions to the larger institutions like yourself?

Paul, this is Kevin. What I'd tell you is we are seeing loan growth, and we're seeing it really mostly in terms of our C&I buckets and larger, better credits. And so I certainly don't feel like it's coming from the smaller end of our business or our industry, but I do think we're seeing it in terms of the larger competitors that we've historically gone against from that standpoint because of the nature of the credits that we're seeing. So I would tend to see and steer you more toward the higher end than the lower end.

Your next question comes from Matt Burnell with Wells Fargo Securities.

Just following up on that question, if -- how much of the loan growth expectation in the first quarter is driven by continuing growth in the larger, better credits that, Kevin, you just mentioned? And if we end up getting in an environment that is a bit less volatile in the capital markets with a bit less overall fear, does that concern you in terms of many of those companies potentially moving away from banks for their lending and maybe potentially going into the capital markets? Just how sensitive are -- is your loan growth to that scenario?

I think, Matt, that for the most part, again, given kind of the base that we're talking about, strong, large international and national clients who really have weathered the storm very, very well and continue to weather the storm very well continue to look for opportunities to lower their costs, debt costs, lending costs, as well as continue to look for kind of strengthening the participations more broadly across their bank groups as well. I -- We don't see a lot of volatility or sensitivity relative to those issues because they're already baked into expectations, and it's still pulling through in terms of pipeline. So on a near-term basis, we don't see a great magnitude change, potential risk from that standpoint. Now obviously, Matt, dial your worst-case scenario up and we certainly think that would be something more concerning. But based on what we see today as most likely scenarios going forward in at least in the short term, we don't see that impacting us in that fashion.

Matt, I think one other thing is that I think we've seen more breadth in the last few months than maybe we were seeing earlier in the year.

True. Yes.

Yes, it is -- that's a really good point, Jeff. We are seeing it really even begin to come down in terms of smaller companies now surfacing a little bit, again, just being smart relative to how they position their balance sheets and P&Ls going forward as well. So we feel pretty confident, pretty good about where we stand right now.

Okay. And then if I could, a question on the putback request to Bruce. You mentioned that you're getting -- it appears you're getting some more requests for files on performing loans. I guess, I'm curious as to your guess as to why you're getting those requests if the -- because most other companies have mentioned that usually what drives putback requests are delinquencies. If these loans are performing, I guess, I'm a little curious as to why you're getting requests for documentation on performing loans.

Yes. I think that we're just seeing a different behavior from the GSEs, and as they have increased the number of their requests, it's increasing their statistical sample of our portfolio, and because of the percentage that is performing, that piece is an increasing percentage of the sampling that they're currently doing with us.

Yes, I think part of the difficulty in monitoring the levels of activity and interpreting the levels of activity is we have 2 different things going on from the GSEs that really have different purposes. One is related to kind of their managing their losses through kind of putbacks of loans that they're going to occur losses on. The other is just monitoring the ongoing quality of activity and the ongoing documentation, compliance with documentation standards. And requests that we get related to those 2 different activities that the GSEs engage in are difficult to pull apart sometimes.

The other thing that even though the sampling has increased, the requests were flat quarterly [ph].

And your next question comes from Steve Scinicariello with UBS Securities.

Just a couple quick ones for you, just in terms of kind of the whole CCAR and capital planning process, I mean, when we put you through our stress test, you guys performed extremely well. And I'm just kind of curious about the comments where you say in terms of minimizing the excess capital build. I mean, to mean, is it fair if I kind of translate that into equating to about a $1.4 billion type of amount of excess that you're kind of going to earn through the course of the year? Is that kind of a fair way read some of those comments?

I think before Dan answers, I will say we can't really respond to a question about how much we're going to earn for the year and how much we're going to distribute for the year. I'm going to turn it back to Dan just to kind of respond to his comments and what we're trying to do. I think conceptually, you can -- you're understanding what we're trying to do.

Yes, so within the -- in terms of the construction of our plan, we're obviously trying to balance a number of objectives. One of them being to manage our capital levels to our capital targets as closely as we can to return as much capital to our shareholders as possible but to stay within the lines, so to speak, with respect to the regulatory mandates, as well as regulatory guidance that might go above and beyond the things that are in writing in terms of the actual CCAR rules and regulations. So we think that the plan that we've put together is a good one and is a balanced plan in terms of making progress toward all of those objectives.

Great. Now that's very helpful. Just it definitely seems just the amount of excess capital is pretty significant there. And then just the only other follow-up I had, just sort of point of clarification, just going back to the salary and compensation expense line, I know we have the uptick this quarter for a lot of the areas that you mentioned, about $24 million. And I was just curious. How much of that increase is related to kind of the incentive compensation? If I take the $24 million increase back out onto the $6 million in FICA is -- how much of that $18 million incremental jump would be to like mortgage banking incentive comp?

I'm not sure if we have that number here. While perhaps some of the folks here see if we have that detail with us, I would just point out that we mentioned several other items that impact salary and benefits expense during the quarter. There was $6 million or $8 million related to pension settlements that hit during the quarter because we triggered the accounting threshold that requires those charges to be taken. There was $10 million related to revaluing long-term equity grants as a result of the performance of our stock during the quarter, which was up $2.60, I think, from end of third quarter, the end of the fourth. So there's -- that's about $16 million, $18 million there. Of the rest of the increase in salary and benefits, I would expect that a fair amount of it relates to the mortgage activity either from incentives paid to mortgage originators or expense related to personnel to process the higher level of loan activity.

I think our mortgage expenses in total for the quarter were up about $13 million, $15 million. And about $8 million, $10 million of that was due to incentives being paid on production.

Your next question comes from Mike Mayo with CLSA.

I'm just referring to Slide 9, where you look at PPNR. On one hand, you're showing growth in commercial loans, growth in deposits, growth in spread revenues, growth in service charges. On the other hand, PPNR is down quite a bit, and you said expect around $530 million or so in the first quarter and maybe a little higher after that. But you're still only recapturing about half of the decline from the prior couple quarters. And just looking to see what you think is the root cause for decline in PPNR. Or is it simply factors out of your control or things that you can control?

Mike, it's Jeff. I mean, I think if you're looking at the current quarter versus the last several, mortgage banking and the effect of the Durbin Amendment are going your 2 big drivers, and then the sort of unusually higher level of our expenses this quarter would be the out [ph].

And in terms of getting back to a more normalized rate -- because you said later this year it should trend back higher. Have you given any guidance where you think it settles out at?

No, I don't think or we have not given guidance, PPNR guidance. I think if you look at the components of that, we have given a bit of guidance relative to the future NII. I think we gave some guidance with respect to NIM and NII going forward for 2011 that talked about stronger levels in the latter half of the year due to continued asset growth, as well as day count benefit in the second half of the year. Expenses, we gave guidance with respect to the $25 million seasonality impact on the first quarter going away, as well as other continued expense improvements as we go forward in the year. And relative to fees, while we haven't given a lot of specifics relative to fees for the whole year, clearly, one of the things we've talked about is the fact that right now we are being impacted by the implementation of the Durbin Amendment in the fourth quarter. And we've talked about the fact that while we were optimistic relative to our ability to mitigate most, if not all of that, that, that was going to take time. And I think we will see the continuing impact of our mitigation initiatives with respect to Durbin become more and more prevalent in our earnings as we move through 2012.

Okay. And then just separately, it seems like you're going back toward more normal levels in terms of credit, you said, by the end of this year. But on the other hand, 60% efficiency ratio by year end is a far cry from where the company was many years ago. And what's the key -- if you don't get the revenue growth coming back, what's the key to getting that efficiency ratio lower?

This is Jeff. A couple things. I think we indicated we expected charge-offs to about go below 100 basis points in the second half of the year, but that is not something considered to be normal. Obviously, that's not part of the efficiency ratio, but we do expect further improvement in credit than that. More broadly speaking, our efficiency ratio in the low-60s is not where we expect to be, not where we intend to be. But we are in an environment where interest rates are very, very low, and we are earning next to nothing on our deposits, which is the large source of value for a bank, a banking company. And that is a very important part of the long-term revenue capability of the company, and we are going to invest in the company in order to realize that benefit, which we will realize. It's just probably not going to be this year.

And last follow-up, it's a hard question. I mean, what if rates stay low for longer? At what point do you say, "We're going to pull back on a number branches"? You had some banks building a lot of branches. Some of them are closing. At what point do you say, "You know what, this rate environment's going to stay around for longer than many expect. Maybe we should pull back"?

Mike, I think -- this is Kevin. What I would have to believe is that it was a more permanent adjustment in the environment as opposed to our being able to realize the value of that longer term. So we will manage that. We'll continue to move and make progress from that perspective. But we're managing this for long-term total return for our shareholders, and I'd have to believe that there were some permanent structure and change to valuation or the ability to create value out of our franchise in order to really kind of, in my mind, cut bone. We've always been good at making sure that we were lean and we run hard and run fast from that perspective. That culture hasn't changed. But we're going to make sure that as long as we're focused on creating long-term value, those are the things that we'll balance against types of decisions you talked about.

[Operator Instructions] And your next question comes from David Long with Raymond James. David J. Long - Raymond James & Associates, Inc., Research Division: Back to the expenses, speaking about the guidance that you gave in October after your third quarter call, how much, if any, of what we're looking now as your guidance is a result of additional investment in the business due to maybe your outlook on the economy improving?

Well, the only thing that I would tell you is part of the investment that we're making does continue in terms of us picking up some teams out -- lifting out some folks that we believe that will help contribute even in a difficult environment like today. We've been successful in hiring some commercial teams in different parts of our markets. We'll continue to look for those opportunities. And where we see the opportunities to find folks that contribute to our folks -- to our bottom line in this type of environment, that makes sense for us to continue to look at as contributing to expenses. I don't know if there's anything else, Dan, that you'd add to that. But that'd be our orientation, Dave. David J. Long - Raymond James & Associates, Inc., Research Division: Okay. And then secondly, thinking about your loan growth, your guidance seems to be that your pipeline's still pretty good. We should still expect to see decent loan growth here in the first quarter in the commercial side. And is there any seasonality or maybe some of your customers taking advantage of accelerated depreciation opportunities here on that we need to consider when thinking about loan growth, commercial loan growth specifically for the first quarter?

Yes, this is Bruce. I would say that there's been very little seasonality and people taking advantage of that right now, and so we don't -- the only difference is if we do see an uptick in utilization, which has been at really almost historical low levels and we even saw another downtick of 1% in the last quarter.

This is Jeff. I mean, there is some seasonality that does exist. It is more in the consumer side than the commercial side. Fourth quarter growth was very strong. We've given guidance for the first quarter, which I think with continued solid growth or something along those lines. So we feel very good about where we are heading into the year, and we expect good, solid loan growth.

And your next question comes from Andrew Marquardt with Evercore Partners.

Just back on PPNR, off of the -- so it seems like off the first quarter $530 million range, we should think about incrementally improving, but it seems like it's largely expense driven and then maybe even more so in the back half of the year. I guess the question is can you get -- magnitude-wise, can you get up to the kind of the higher 5s, if you will, maybe even without a better rate environment just driven by expenses and maybe some loan growth driving NII? Or is that really going to be a challenge?

Well, we haven't given specific PPNR guidance for the second half of the year. But I think we do expect that we will see contribution to higher PPNR levels on all fronts, not just from expenses. Clearly, expenses will be a significant factor in terms of improving on that $530 million. But we also expect NII in the second half to be stronger than the first because of the continued asset growth, as well as day count benefit that kick in, in the second half of the year. And as I mentioned earlier, I think we would expect the PPNR contribution from Durbin mitigation activities to be stronger in the second half of the year than first. So while without commenting on specific levels of PPNR, I think we would expect contributions from all of those things to allow us to move north of that $530 million.

And just core improvement and our results, bearing fruit. Corporate banking has good, solid momentum behind it, the brokerage business. So I think there -- as Dan said, on all fronts, we expect improvement from the first quarter, and I think our guidance suggests that.

Okay. And then just back on capital deployment, an earlier question, can you just remind us what your internal capital targets are? I believe you've said in the past maybe 8%, 8.5%. And I think you said you're at 9.7%. Is that 8%, 8.5%, you think, still valid given everything that's been going on in terms of how the regulators view things?

Yes, I think what we said in the past is in the 8% range for Tier 1 common. That was a level or that is a targeted level that is without the benefit of finalization of the U.S. rules around Basel III and so forth. So to the extent that there are some things in there that we don't anticipate, that number might be adjusted slightly. But in general, we think that's an appropriate target and will continue to be an appropriate target as we move forward. So I think your question commented on our current Basel III level of 9.7%. I think that's kind of where we would expect it to be based on what we know about the rules now. So that would represent a fairly sizable amount of excess capital that, over time, we would seek to deploy and/or return to shareholders.

I would just add that, that does include an assumption which we don't know, that the current Basel proposals would include unrealized gains in Tier 1 common. And we do have a fairly sizable amount. It's 300, 400 -- 30 or 40 basis points in our capital ratios, and we don't know whether that will ultimately be included. So as we look at our excess capital versus our target, we don't know whether that's excess capital or not. We certainly wouldn't treat it as excess capital because it can go away with changes in the interest rates.

Yes. That's helpful And then just a couple ticky tack questions. On page -- Slide 19 rather, you had mentioned in terms of mortgage putback litigation section, quarterly repurchase costs $20 million to $25 million, I believe. Is that what we should think about as a current or as an ongoing cost?

I think we indicated in our remarks that we expected credit-related expenses in the first quarter to be similar to the fourth. And I think that has been the range of experience over the last 5, 6, 7 quarters. So absent a change in GSE behavior, that's where we're running.

Okay, got it. And then the last ticky tack is just -- or do you guys have any update on the prior kind of outstanding SEC investigation around legacy accounting reporting issues? Any update on that? Where does that stand?

No, we don't really have anything new to report on that front.

And there are no further questions at this time. I would like to thank everyone for participating in today's call. You may now disconnect.