Initial Letter Date

Form filed

Market Capitalization

09/26/2013

10-K

$ 7,530 M

You disclose in your business acquisition footnote on page [xx] that you expect the mortgage servicing rights and goodwill to be treated as intangible assets acquired in connection with the purchase of a trade or business to be amortized over 15 years for tax purposes. However, you do not appear to disclose any deferred tax liabilities related to tax-deductible goodwill in your purchase price allocations. Please tell us why have not recognized any deferred tax liabilities related to tax-deductible goodwill for any of your acquisitions.