( a ) pursuant to regulatory guidance issued in the third quarter of 2012 , additional troubled debt restructurings related to changes in treatment of certain loans of $ 366 million in 2012 , net of charge-offs , resulting from bankruptcy where no formal reaffirmation was provided by the borrower and therefore a concession has been granted based upon discharge from personal liability were added to the consumer lending population . the additional tdr population increased nonperforming loans by $ 288 million