2016-13. therefore , current period results and balances are not comparable to prior period amounts , particularly with regard to the provision and allowance for credit losses ( and their related subtotals ) . additional information for comparability to help investors understand our year-over-year performance , we are providing adjusted prior year allowance for credit losses and related allowance build figures using the cecl approach for comparative purposes . these adjusted prior year figures are non-gaap financial measures and should be viewed in addition to , not as a substitute for , our reported results . we believe that these adjusted figures are useful to investors since credit losses were estimated using the incurred loss approach prior to adoption of asu no . 2016-13 on january 1 , 2020. the adjusted allowance and related build figures provide investors with comparable amounts to understand our results . the following table provides a reconciliation of prior year allowance for credit losses figures as reported ( using the incurred loss approach ) to adjusted allowance for credit losses using the cecl approach , as well as related allowance build figures ( dollars in millions ) : replace_table_token_5_th ( 1 ) represents adjustment for recording reserves for expected losses , not simply those deemed to be already incurred , and extending the loss estimate period over the entire life of the loan . ( 2 ) calculated as the change in the allowance for credit losses as reported using the incurred loss approach . ( 3 ) calculated as the change in the allowance for credit losses as adjusted using the cecl approach . refer to `` — critical accounting estimates — allowance for credit losses on loan receivables `` for more details on our estimation process and key assumptions requiring significant judgment and to `` — loan quality — provision and allowance for credit losses `` for discussion of drivers of current period changes in the allowance for credit losses . covid-19 pandemic response and impact the covid-19 pandemic has continued to have a widespread and unprecedented impact on a global scale . the health crisis continues to have a severe effect on the economy and unemployment . the impact of covid-19 continues to evolve rapidly . its future effects are uncertain and it may be difficult to assess or predict the extent of the impacts of the pandemic on us as many factors are beyond our control and knowledge . for a discussion of the risks we face with respect to the covid-19 pandemic , the associated economic uncertainty , the steps taken to mitigate the pandemic and the resulting economic contraction , see `` item 1a — risk factors `` in part i of this annual report on form 10-k. this section includes a discussion of significant areas of potential impact on us of the covid-19 pandemic and certain actions we are taking or expect to take in this time of uncertainty caused by the covid-19 pandemic . outlook and financial results the pandemic has adversely impacted our financial results for the year ended december 31 , 2020. during the year we saw a decrease in sales volume and credit card loan growth as well as an increase in our estimate of life of loan expected credit losses . due to the economic environment and the resulting pressure on earnings in 2020 , we successfully executed our strategy and implemented approximately $ 400 million of cost reductions off of previously provided guidance from the fourth quarter 2019 earnings release , by targeting areas such as account acquisition costs and marketing expenses . offsetting these executed cost reductions were several non-recurring expense items in the fourth quarter of 2020 that were unrelated to the covid-19 pandemic . outbreaks of covid-19 have resulted in state and local governments implementing , or in some cases re-implementing , measures to try to contain the virus such as travel bans and restrictions , shutdowns and quarantines . we anticipate these measures as well as the related economic uncertainty will continue to negatively impact consumer and business spending habits and the consumer credit -51- environment , including the ability of consumers to repay their loans . while certain parts of the united states have lifted these measures , the resurgence of covid-19 has , and may continue to result in , governments re-imposing restrictions that may remain in place for a significant period of time . we expect the economic uncertainty associated with the covid-19 pandemic to continue in 2021. the level of impact on our business depends on the timing and shape of the economic recovery . we anticipate modest loan growth during 2021 , the size of which will be dependent on payment rate trends and the timing and pace of the broad economic recovery . regarding net interest margin , we expect to see continued benefit from lower deposit rates and the maturity of higher rate funding . in terms of credit performance , we expect losses to increase in the second half of 2021. the timing and magnitude of losses could be impacted by any additional government stimulus or material shifts in the economic environment . we remain committed to disciplined expense management and will continue to make investments for profitable long-term growth , including increased marketing as well as investments in core technology capabilities and efficiency improvements . regulatory and legislative federal , state and local governments , including the united states congress , the executive branch and independent banking agencies have taken extraordinary measures to support the united states economy and mitigate the impacts of the covid-19 pandemic on the economy and on society at large . these policies have included regulatory relief and flexibility to financial institutions , liquidity to capital markets and financial support to businesses and consumers , including financial stimulus , payment forbearance , small business lending programs , increased unemployment payments and other forms of assistance . story_separator_special_tag the ccpa went into effect on january 1 , 2020 , and the final california attorney general regulations became effective on august 14 , 2020. california attorney general enforcement for ccpa began on july 1 , 2020. the california privacy rights act ( `` cpra `` ) , a ballot measure led by the original proponent of the ccpa , passed on november 3 , 2020 , and largely enters into force on january 1 , 2023. the cpra amends the ccpa to enhance consumer privacy protections and overall brings california 's privacy law closer to the gdpr . the cpra also creates a new california privacy protection agency . while the cpra retains an exemption for information collected , processed , sold , or disclosed subject to the gramm-leach-bliley act , we continue to evaluate the impact of the cpra on -55- our businesses and other providers of consumer financial services or networks that could adversely affect our businesses . results of operations the discussion below provides a summary of our results of operations and information about our loan receivables as of and for the year ended december 31 , 2020 , compared to the year ended december 31 , 2019. refer to our annual report on form 10-k for the year ended december 31 , 2019 , for discussion of our results of operations and loan receivables information as of and for the year ended december 31 , 2019 , compared to the year ended december 31 , 2018. segments we manage our business activities in two segments , digital banking and payment services , based on the products and services provided . for a detailed description of the operations of each segment , as well as the allocation conventions used in our business segment reporting , see note 22 : segment disclosures to our consolidated financial statements . the following table presents segment data ( dollars in millions ) : replace_table_token_6_th ( 1 ) prior to adoption of asu no . 2016-13 on january 1 , 2020 , credit losses were estimated using the incurred loss approach . -56- the following table presents information on transaction volume ( dollars in millions ) : replace_table_token_7_th ( 1 ) diners club volume is derived from data provided by licensees for diners club branded cards issued outside north america and is subject to subsequent revision or amendment . ( 2 ) represents gross discover card sales volume on the discover network . ( 3 ) represents discover card activity related to sales net of returns , balance transfers , cash advances and other activity . ( 4 ) represents discover card activity related to sales net of returns . digital banking our digital banking segment reported pretax income of $ 1.3 billion for the year ended december 31 , 2020 , as compared to $ 3.6 billion for the year ended december 31 , 2019. net interest income decreased for the year ended december 31 , 2020 , as compared to the year ended december 31 , 2019 , primarily driven by lower yields and lower volume on credit card loans , partially offset by lower funding costs . interest income decreased over the prior year primarily due to lower yields on credit cards loans , which was the result of lower market rates , and lower volume . interest expense decreased compared to the prior year due to lower average market rates and lower funding costs . for the year ended december 31 , 2020 , the provision for credit losses increased as compared to the year ended december 31 , 2019 , which primarily reflects the impact of life of loan reserving under cecl and a significant adverse change in the economic outlook due to the covid-19 pandemic . for a detailed discussion on provision for credit losses , see “ — loan quality — provision and allowance for credit losses . ” total other income for the digital banking segment decreased for the year ended december 31 , 2020 , as compared to the year ended december 31 , 2019 , primarily driven by a decrease in discount and interchange revenue , other income and loan fee income . net discount and interchange revenue decreased as a result of a decline in sales volume due to the impacts of the covid-19 pandemic . other income decreased due to a non-recurring write-down of certain real estate facilities . loan fee income decreased primarily due to lower late fees and cash advance fees . total other expense was relatively flat for the year ended december 31 , 2020 , as compared to the year ended december 31 , 2019. employee compensation and benefits increased as a result of higher average salaries , a larger headcount base , and a voluntary early retirement program which was initiated in the fourth quarter of 2020. information processing and communications increased due to non-recurring software write-offs and investments in infrastructure . this was offset by a decrease in marketing costs due to covid-19 related expense reductions in brand advertising for card . discover card sales volume was $ 142.8 billion for the year ended december 31 , 2020 , which was a decrease of 2.3 % as compared to the year ended december 31 , 2019. this volume decline was primarily driven by lower consumer spending at the onset of the covid-19 pandemic . -57- payment services our payment services segment reported pretax income of $ 172 million for the year ended december 31 , 2020 , as compared to pretax income of $ 189 million for the year ended december 31 , 2019. the decrease in segment pretax income was primarily due to an increase in segment pretax expense driven by a covid-19 related non-cash impairment charge on the diners club business in the second quarter of 2020 , partially offset by gains on equity investment sales during the year . critical accounting estimates in preparing our consolidated financial statements in conformity

bank holding company liquidity the primary uses of funds at the unconsolidated dfs level include debt service obligations ( interest payments and return of principal ) and capital service and management activities , which include dividend payments on capital instruments and the periodic repurchase of shares of our common stock . our primary sources of funds at the bank holding company level include the proceeds from the issuance of unsecured debt and capital securities , as well as dividends from our subsidiaries , particularly discover bank . under periods of idiosyncratic or systemic stress , the bank holding company could lose or experience impaired access to the capital markets . in addition , our regulators have the discretion to restrict dividend payments from discover bank to the bank holding company . we utilize a measure referred to as number of months of pre-funding to determine the length of time discover financial services can meet upcoming funding obligations including common and preferred stock dividend payments and debt service obligations using existing cash resources . in prudently managing this metric , we structure our debt -77- maturity schedule to minimize the amount of debt maturing within a short period of time . see note 9 : long-term borrowings to our consolidated financial statements for further information regarding our debt . capital our primary sources of capital are the earnings generated by our businesses and the proceeds from issuances of capital securities . we seek to manage capital to a level and composition sufficient to support the growth and risks of our businesses and to meet regulatory requirements , rating agency targets and debt investor expectations . within these constraints , we are focused on deploying capital in a manner that provides attractive returns to our stockholders . the level , composition and utilization of capital are influenced by changes in the economic environment , strategic initiatives and legislative and regulatory developments . under regulatory capital requirements adopted by the federal reserve and the fdic , dfs , along with discover bank , must maintain minimum levels of capital .


 Write a concise suspicious activity report of the following text delimited by triple backquotes. Return your response as a formal report which covers the key points highlighting the location,dates,entity names and account holder information in chronological order of the text.
     ```bank holding company liquidity the primary uses of funds at the unconsolidated dfs level include debt service obligations ( interest payments and return of principal ) and capital service and management activities , which include dividend payments on capital instruments and the periodic repurchase of shares of our common stock . our primary sources of funds at the bank holding company level include the proceeds from the issuance of unsecured debt and capital securities , as well as dividends from our subsidiaries , particularly discover bank . under periods of idiosyncratic or systemic stress , the bank holding company could lose or experience impaired access to the capital markets . in addition , our regulators have the discretion to restrict dividend payments from discover bank to the bank holding company . we utilize a measure referred to as number of months of pre-funding to determine the length of time discover financial services can meet upcoming funding obligations including common and preferred stock dividend payments and debt service obligations using existing cash resources . in prudently managing this metric , we structure our debt -77- maturity schedule to minimize the amount of debt maturing within a short period of time . see note 9 : long-term borrowings to our consolidated financial statements for further information regarding our debt . capital our primary sources of capital are the earnings generated by our businesses and the proceeds from issuances of capital securities . we seek to manage capital to a level and composition sufficient to support the growth and risks of our businesses and to meet regulatory requirements , rating agency targets and debt investor expectations . within these constraints , we are focused on deploying capital in a manner that provides attractive returns to our stockholders . the level , composition and utilization of capital are influenced by changes in the economic environment , strategic initiatives and legislative and regulatory developments . under regulatory capital requirements adopted by the federal reserve and the fdic , dfs , along with discover bank , must maintain minimum levels of capital .
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 Suspicious Activity Report : 2016-13. therefore , current period results and balances are not comparable to prior period amounts , particularly with regard to the provision and allowance for credit losses ( and their related subtotals ) . additional information for comparability to help investors understand our year-over-year performance , we are providing adjusted prior year allowance for credit losses and related allowance build figures using the cecl approach for comparative purposes . these adjusted prior year figures are non-gaap financial measures and should be viewed in addition to , not as a substitute for , our reported results . we believe that these adjusted figures are useful to investors since credit losses were estimated using the incurred loss approach prior to adoption of asu no . 2016-13 on january 1 , 2020. the adjusted allowance and related build figures provide investors with comparable amounts to understand our results . the following table provides a reconciliation of prior year allowance for credit losses figures as reported ( using the incurred loss approach ) to adjusted allowance for credit losses using the cecl approach , as well as related allowance build figures ( dollars in millions ) : replace_table_token_5_th ( 1 ) represents adjustment for recording reserves for expected losses , not simply those deemed to be already incurred , and extending the loss estimate period over the entire life of the loan . ( 2 ) calculated as the change in the allowance for credit losses as reported using the incurred loss approach . ( 3 ) calculated as the change in the allowance for credit losses as adjusted using the cecl approach . refer to `` — critical accounting estimates — allowance for credit losses on loan receivables `` for more details on our estimation process and key assumptions requiring significant judgment and to `` — loan quality — provision and allowance for credit losses `` for discussion of drivers of current period changes in the allowance for credit losses . covid-19 pandemic response and impact the covid-19 pandemic has continued to have a widespread and unprecedented impact on a global scale . the health crisis continues to have a severe effect on the economy and unemployment . the impact of covid-19 continues to evolve rapidly . its future effects are uncertain and it may be difficult to assess or predict the extent of the impacts of the pandemic on us as many factors are beyond our control and knowledge . for a discussion of the risks we face with respect to the covid-19 pandemic , the associated economic uncertainty , the steps taken to mitigate the pandemic and the resulting economic contraction , see `` item 1a — risk factors `` in part i of this annual report on form 10-k. this section includes a discussion of significant areas of potential impact on us of the covid-19 pandemic and certain actions we are taking or expect to take in this time of uncertainty caused by the covid-19 pandemic . outlook and financial results the pandemic has adversely impacted our financial results for the year ended december 31 , 2020. during the year we saw a decrease in sales volume and credit card loan growth as well as an increase in our estimate of life of loan expected credit losses . due to the economic environment and the resulting pressure on earnings in 2020 , we successfully executed our strategy and implemented approximately $ 400 million of cost reductions off of previously provided guidance from the fourth quarter 2019 earnings release , by targeting areas such as account acquisition costs and marketing expenses . offsetting these executed cost reductions were several non-recurring expense items in the fourth quarter of 2020 that were unrelated to the covid-19 pandemic . outbreaks of covid-19 have resulted in state and local governments implementing , or in some cases re-implementing , measures to try to contain the virus such as travel bans and restrictions , shutdowns and quarantines . we anticipate these measures as well as the related economic uncertainty will continue to negatively impact consumer and business spending habits and the consumer credit -51- environment , including the ability of consumers to repay their loans . while certain parts of the united states have lifted these measures , the resurgence of covid-19 has , and may continue to result in , governments re-imposing restrictions that may remain in place for a significant period of time . we expect the economic uncertainty associated with the covid-19 pandemic to continue in 2021. the level of impact on our business depends on the timing and shape of the economic recovery . we anticipate modest loan growth during 2021 , the size of which will be dependent on payment rate trends and the timing and pace of the broad economic recovery . regarding net interest margin , we expect to see continued benefit from lower deposit rates and the maturity of higher rate funding . in terms of credit performance , we expect losses to increase in the second half of 2021. the timing and magnitude of losses could be impacted by any additional government stimulus or material shifts in the economic environment . we remain committed to disciplined expense management and will continue to make investments for profitable long-term growth , including increased marketing as well as investments in core technology capabilities and efficiency improvements . regulatory and legislative federal , state and local governments , including the united states congress , the executive branch and independent banking agencies have taken extraordinary measures to support the united states economy and mitigate the impacts of the covid-19 pandemic on the economy and on society at large . these policies have included regulatory relief and flexibility to financial institutions , liquidity to capital markets and financial support to businesses and consumers , including financial stimulus , payment forbearance , small business lending programs , increased unemployment payments and other forms of assistance . story_separator_special_tag the ccpa went into effect on january 1 , 2020 , and the final california attorney general regulations became effective on august 14 , 2020. california attorney general enforcement for ccpa began on july 1 , 2020. the california privacy rights act ( `` cpra `` ) , a ballot measure led by the original proponent of the ccpa , passed on november 3 , 2020 , and largely enters into force on january 1 , 2023. the cpra amends the ccpa to enhance consumer privacy protections and overall brings california 's privacy law closer to the gdpr . the cpra also creates a new california privacy protection agency . while the cpra retains an exemption for information collected , processed , sold , or disclosed subject to the gramm-leach-bliley act , we continue to evaluate the impact of the cpra on -55- our businesses and other providers of consumer financial services or networks that could adversely affect our businesses . results of operations the discussion below provides a summary of our results of operations and information about our loan receivables as of and for the year ended december 31 , 2020 , compared to the year ended december 31 , 2019. refer to our annual report on form 10-k for the year ended december 31 , 2019 , for discussion of our results of operations and loan receivables information as of and for the year ended december 31 , 2019 , compared to the year ended december 31 , 2018. segments we manage our business activities in two segments , digital banking and payment services , based on the products and services provided . for a detailed description of the operations of each segment , as well as the allocation conventions used in our business segment reporting , see note 22 : segment disclosures to our consolidated financial statements . the following table presents segment data ( dollars in millions ) : replace_table_token_6_th ( 1 ) prior to adoption of asu no . 2016-13 on january 1 , 2020 , credit losses were estimated using the incurred loss approach . -56- the following table presents information on transaction volume ( dollars in millions ) : replace_table_token_7_th ( 1 ) diners club volume is derived from data provided by licensees for diners club branded cards issued outside north america and is subject to subsequent revision or amendment . ( 2 ) represents gross discover card sales volume on the discover network . ( 3 ) represents discover card activity related to sales net of returns , balance transfers , cash advances and other activity . ( 4 ) represents discover card activity related to sales net of returns . digital banking our digital banking segment reported pretax income of $ 1.3 billion for the year ended december 31 , 2020 , as compared to $ 3.6 billion for the year ended december 31 , 2019. net interest income decreased for the year ended december 31 , 2020 , as compared to the year ended december 31 , 2019 , primarily driven by lower yields and lower volume on credit card loans , partially offset by lower funding costs . interest income decreased over the prior year primarily due to lower yields on credit cards loans , which was the result of lower market rates , and lower volume . interest expense decreased compared to the prior year due to lower average market rates and lower funding costs . for the year ended december 31 , 2020 , the provision for credit losses increased as compared to the year ended december 31 , 2019 , which primarily reflects the impact of life of loan reserving under cecl and a significant adverse change in the economic outlook due to the covid-19 pandemic . for a detailed discussion on provision for credit losses , see “ — loan quality — provision and allowance for credit losses . ” total other income for the digital banking segment decreased for the year ended december 31 , 2020 , as compared to the year ended december 31 , 2019 , primarily driven by a decrease in discount and interchange revenue , other income and loan fee income . net discount and interchange revenue decreased as a result of a decline in sales volume due to the impacts of the covid-19 pandemic . other income decreased due to a non-recurring write-down of certain real estate facilities . loan fee income decreased primarily due to lower late fees and cash advance fees . total other expense was relatively flat for the year ended december 31 , 2020 , as compared to the year ended december 31 , 2019. employee compensation and benefits increased as a result of higher average salaries , a larger headcount base , and a voluntary early retirement program which was initiated in the fourth quarter of 2020. information processing and communications increased due to non-recurring software write-offs and investments in infrastructure . this was offset by a decrease in marketing costs due to covid-19 related expense reductions in brand advertising for card . discover card sales volume was $ 142.8 billion for the year ended december 31 , 2020 , which was a decrease of 2.3 % as compared to the year ended december 31 , 2019. this volume decline was primarily driven by lower consumer spending at the onset of the covid-19 pandemic . -57- payment services our payment services segment reported pretax income of $ 172 million for the year ended december 31 , 2020 , as compared to pretax income of $ 189 million for the year ended december 31 , 2019. the decrease in segment pretax income was primarily due to an increase in segment pretax expense driven by a covid-19 related non-cash impairment charge on the diners club business in the second quarter of 2020 , partially offset by gains on equity investment sales during the year . critical accounting estimates in preparing our consolidated financial statements in conformity

