{ "ticker": "TFC", "company": "Truist Financial Corporation", "filing_type": "10-K", "year_current": "2026", "year_prior": "2025", "summary": { "added": 28, "removed": 7, "modified": 15, "unchanged": 4, "total_current": 47, "total_prior": 26 }, "source": "SEC EDGAR", "url": "https://riskdiff.com/tfc/2026-vs-2025/", "markdown_url": "https://riskdiff.com/tfc/2026-vs-2025/index.md", "json_url": "https://riskdiff.com/tfc/2026-vs-2025/index.json", "generated": "2026-05-22", "ai_summary": "Truist Financial Corporation substantially reorganized its risk factor disclosures by disaggregating broad categorical headings into 28 granular regulatory-specific risks, including dedicated sections for FHC regulation, capital requirements, liquidity standards, and various compliance regimes (BSA/AML, Volcker Rule, interchange fees). The company simultaneously consolidated operational and talent-related risks under streamlined headers such as \"Human Capital\" and \"Talent Practices,\" while removing seven overlapping or redundant risk categories including the standalone cybersecurity section. Fifteen existing risk categories underwent substantive modifications, with particular emphasis on clarifying liquidity, credit, operational, and technology risks alongside compliance and regulatory obligations.", "risks": [ { "status": "ADDED", "current_title": "FHC Regulation", "prior_title": null, "current_body": "Truist has elected to be treated as an FHC. As long as an FHC maintains its standing as an FHC, it may engage in a broader range of activities than would otherwise be permissible for a BHC, such as securities underwriting, merchant banking, and other activities that are financial in nature or incidental or complementary thereto. If certain conditions are met, FHCs may acquire shares of nonbank companies, with any acquisition of a nonbank company or voting shares of a nonbank company with total consolidated assets of $10 billion or more subject to the prior approval of the FRB. To maintain its standing as an FHC, an FHC and its IDI subsidiaries must be well-capitalized and well managed as defined by applicable law, and any IDI subsidiary must have at least a satisfactory CRA rating. If the FRB determines that an FHC is not well-capitalized or well managed, the FRB may impose corrective capital and managerial requirements on the FHC, which could affect resources and limit amounts otherwise available to creditors and shareholders. In such a situation, the FRB may also place limitations on the ability of an FHC to conduct certain business activities that FHCs are generally permitted to conduct as well as the FHC’s ability to make certain acquisitions. If the failure to meet these standards persists, an FHC may be required to divest its IDI subsidiaries or cease all activities other than those activities that may be conducted by BHCs that are not FHCs. Furthermore, if an IDI subsidiary of an FHC has not maintained a satisfactory CRA rating, the FHC would not be able to commence any new financial activities or acquire a company that engages in such activities, although the FHC would still be allowed to engage in activities that may be conducted by BHCs that are not FHCs. Federal law requires an FHC to act as a source of financial and managerial strength for its subsidiary IDIs. In times of severe financial stress, the obligation to serve as a source of strength could cause Truist to commit significant resources to supporting Truist Bank that otherwise would be available to Truist’s creditors and shareholders." }, { "status": "ADDED", "current_title": "Resolution Planning", "prior_title": null, "current_body": "As a Category III banking organization, Truist is required to submit a plan to the FRB and the FDIC periodically for Truist’s orderly resolution in the event of severe financial stress (a “165(d) Resolution Plan”). If the agencies were to determine that Truist’s 165(d) Resolution Plan is not credible, they would provide a joint notice identifying one or more deficiencies that could undermine the feasibility of the plan. If Truist were to receive such a notice and fail to timely submit a revised 165(d) Resolution Plan or adequately address the identified deficiencies, the agencies may subject Truist to formal or informal enforcement actions, including more stringent capital, leverage, or liquidity requirements or restrictions on growth, activities, or operations. Truist submitted its most recent 165(d) Resolution Plan on September 30, 2025. The next targeted plan is due July 1, 2028. In addition, as an IDI with over $50 billion in assets, Truist Bank is required to periodically submit to the FDIC a separate bank-level resolution plan (an “IDI Resolution Plan”). In 2024, the FDIC adopted a final rule that significantly modified the required frequency and informational content of IDI Resolution Plans. As a result of the rule, Truist Bank must submit a full IDI Resolution Plan to the FDIC every three years and an interim supplement in other years. The final rule introduced a new credibility standard for evaluating the adequacy of IDI Resolution Plan submissions, set expectations for capabilities testing, and contemplated increased engagement between IDIs and examiners. The application of the new credibility standard may require the exercise of a meaningful degree of judgment by the FDIC. If Truist Bank’s IDI Resolution Plan were not to satisfy the credibility standard or any other provision of the rule, the FDIC may require Truist Bank to revise portions of it. If Truist Bank were to fail to timely submit a revised IDI Resolution Plan or adequately address the identified deficiencies, the FDIC may subject Truist Bank to formal or informal enforcement actions. Truist Bank’s first interim supplement was submitted on July 1, 2025, and its full IDI Resolution Plan submission is due July 1, 2026." }, { "status": "ADDED", "current_title": "Enhanced Prudential Standards and Regulatory Tailoring Rules", "prior_title": null, "current_body": "U.S. BHCs, including Truist, are subject to a range of prudential standards and requirements based on their size and complexity. Under tailoring rules adopted by the U.S. banking agencies, Truist is subject to the standards and requirements applicable to Category III banking organizations, which generally include BHCs with greater than $250 billion, but less than $700 billion, in total consolidated assets and less than $75 billion in certain risk-related exposures. Truist Financial Corporation 7 Truist Financial Corporation 7 Truist Financial Corporation 7 Truist Financial Corporation 7 Truist Financial Corporation 7 Truist Financial Corporation 7 Truist is therefore subject to more stringent liquidity and capital requirements, leverage limits, internal and supervisory stress testing requirements, single-counterparty credit limits, resolution planning requirements, and enhanced risk management standards compared to smaller institutions, while certain larger banking organizations are subject to even more stringent prudential standards and requirements than Truist." }, { "status": "ADDED", "current_title": "Capital Requirements", "prior_title": null, "current_body": "Truist and Truist Bank are subject to risk-based and leverage regulatory capital requirements, which are established by the FRB for Truist and by the FDIC for Truist Bank. Failure of an FHC or an IDI to be well-capitalized as defined by applicable law or to meet minimum capital requirements can result in enforcement and other supervisory actions and have a significantly adverse impact on the institution’s business and operations. The U.S. risk-based regulatory capital rules are based on the Basel Framework developed by the BCBS for strengthening the regulation, supervision, and risk management of banks as well as certain provisions of the Dodd-Frank Act. These rules prescribe minimum capital levels and allow the FRB and the FDIC to impose incremental capital requirements on a banking organization based on its size, complexity, or risk profile to enhance its ability to operate in a safe and sound manner. Under the standardized approach of the regulatory capital rules that Truist and Truist Bank are required to use, risk weights are applied to their assets, exposures, and certain off-balance sheet items to determine their risk-weighted assets. These risk-weighted assets are the denominator in the following minimum capital ratios for Truist and Truist Bank: •CET1 Risk-Based Capital Ratio, equal to the ratio of CET1 capital to risk-weighted assets. CET1 capital primarily includes common shareholders’ equity and retained earnings, subject to certain regulatory adjustments and deductions, including with respect to goodwill, intangible assets, certain deferred tax assets, and AOCI. Truist must maintain a minimum CET1 capital ratio of 4.5% plus any additional CET1 mandated as a result of the SCB requirement. •Tier 1 Risk-Based Capital Ratio, equal to the ratio of Tier 1 capital to risk-weighted assets. Tier 1 capital is primarily composed of CET1 capital, perpetual preferred stock, and certain qualifying capital instruments. Truist must maintain a minimum Tier 1 capital ratio of 6.0%. •Total Risk-Based Capital Ratio, equal to the ratio of total capital, including CET1 capital, Tier 1 capital, and Tier 2 capital, to risk-weighted assets. Tier 2 capital primarily includes qualifying subordinated debt and qualifying ALLL. Tier 2 capital also includes certain trust preferred securities. Truist must maintain a minimum total capital ratio of 8.0%. Under the FRB’s capital framework for BHCs, Truist is subject to the SCB, an incremental risk-based capital requirement determined from supervisory stress test results. The SCB is equal to the greater of (i) the difference between Truist’s starting and minimum projected CET1 capital ratios under the severely adverse scenario in the supervisory stress test, plus the sum of the dollar amount of its planned common stock dividends for each of the fourth through seventh quarters of the planning horizon as a percentage of risk-weighted assets, or (ii) 2.5% of risk-weighted assets. Truist is required to describe its planned capital actions in its CCAR capital plan but is not required to seek prior approval for capital distributions in excess of those included in its CCAR capital plan. Instead, Truist is subject to automatic restrictions on capital distributions if its capital ratios fall below applicable minimum requirements, inclusive of the SCB. Refer to the section titled “Capital Planning and Stress Testing Requirements” for more information on the CCAR capital plan. The FRB has assigned Truist an SCB of 2.5%, which was effective from October 1, 2025 to September 30, 2026, when a revised SCB ordinarily would be provided to Truist. On February 4, 2026, the FRB notified Truist of a determination to extend until October 1, 2027, the deadlines for providing Truist with notice of its preliminary and final SCB requirements calculated in 2026. The FRB explained that its proposal from October 2025, seeking public comment on the models that the FRB planned to use for the 2026 supervisory stress test was still outstanding and was not expected to be finalized before conducting the 2026 supervisory stress test. As a result, absent further action from the FRB, Truist will continue to be subject to its current SCB requirement of 2.5% until 2027, when a new SCB based on updated models can be calculated. If Truist takes part in the supervisory stress test in 2027 as expected, Truist would receive a new final SCB requirement based on the results of a supervisory stress test conducted in 2027. If Truist continues to be subject to the capital plan rule but does not take part in the supervisory stress test in 2027, a final SCB requirement would be assigned that has been adjusted to account for Truist’s updated planned common stock dividends. The FRB reserved the authority to modify these deadlines based on a change in actual or expected economic conditions, a change in the financial condition of Truist or its risk profile, or other factors that could affect the safety and soundness of Truist. 8 Truist Financial Corporation 8 Truist Financial Corporation 8 Truist Financial Corporation 8 Truist Financial Corporation 8 Truist Financial Corporation 8 Truist Financial Corporation At the FRB’s discretion, certain large banking organizations, including Truist, may be subject to a CCyB of up to 2.5% of risk-weighted assets. This buffer is currently set at zero. An FRB policy statement establishes the framework and factors the FRB would use in setting and adjusting the CCyB. Covered banking organizations would generally have 12 months after the announcement of any increase in the CCyB to meet the increased buffer requirement, unless the FRB establishes an earlier effective date. Based on Truist’s current SCB, if the maximum CCyB amount is implemented, Truist would be required to maintain a CET1 capital ratio of at least 9.5%, a Tier 1 capital ratio of at least 11.0%, and a total capital ratio of at least 13.0% to avoid limitations on capital distributions and certain discretionary incentive compensation payments. Certain large banking organizations with significant trading assets and liabilities, including Truist, are subject to the Market Risk Rule and must adjust their risk-based capital ratios to reflect the market risk of their trading activities. Refer to the “Market Risk” section in MD&A for additional disclosures related to market risk management. Truist and Truist Bank are subject to a Tier 1 leverage ratio, equal to the ratio of Tier 1 capital to quarterly average assets, net of goodwill, certain other intangible assets, and certain other deductions. Category III banking organizations are also subject to a minimum 3.0% supplementary leverage ratio. The supplementary leverage ratio is calculated by dividing Tier 1 capital by total leverage exposure, which takes into account on-balance sheet assets as well as certain off-balance sheet items, including loan commitments and potential future exposure of derivative contracts. For purposes of certain FRB rules, including determining whether a BHC meets the requirements to be an FHC, the BHC must maintain a Tier 1 Risk-Based Capital Ratio of 6.0% or greater and a Total Risk-Based Capital Ratio of 10.0% or greater to be “well-capitalized.” The FRB may require a BHC to maintain capital ratios in excess of mandated minimum levels, depending upon general economic conditions and the BHC’s particular condition, risk profile, and growth plans. In July 2023, the U.S. banking agencies issued a proposal to revise the risk-based capital standards applicable to Truist and Truist Bank. The U.S. banking agencies have indicated their intent to re-propose the revised risk-based capital standards. The potential impacts on Truist and Truist Bank of a final rule remain uncertain. Refer to the “Capital” section in MD&A for additional information on minimum regulatory capital ratios and well-capitalized minimum ratios applicable to Category III banking organizations." }, { "status": "ADDED", "current_title": "Capital Planning and Stress Testing Requirements", "prior_title": null, "current_body": "Under the FRB’s CCAR process and related capital plan rule, Truist must submit an annual capital plan to the FRB that reflects its projected financial performance under hypothetical macro-economic scenarios, including stress scenarios designed by Truist and a supervisory severely adverse scenario provided by the FRB. The FRB’s CCAR framework and the Dodd-Frank Act stress testing framework require BHCs subject to Category III standards, such as Truist, to conduct company-run stress tests and submit to supervisory stress tests conducted by the FRB. Company-run stress tests employ stress scenarios provided by the FRB and incorporate Dodd-Frank Act capital actions intended to normalize capital distribution assumptions across large U.S. BHCs. Truist is required to conduct additional stress tests using internally-developed scenarios tailored to its unique risk profile. The FRB conducts CCAR and Dodd-Frank Act supervisory stress tests employing internal supervisory models and supervisory stress scenarios. As a Category III banking organization, Truist is subject to annual supervisory stress testing and biennial company-run stress testing requirements. Truist is required to submit its next capital plan and the results of its internal stress tests to the FRB by April 5, 2026. The FRB is expected to announce the results of its supervisory stress tests by June 30, 2026. In April 2025, the FRB issued a proposed rule that would result in the SCB being calculated based on an average of a banking organization’s stress test results over two consecutive years, which is intended to reduce volatility in banking organizations’ capital requirements. In October 2025, the FRB issued proposals to enhance the transparency and public accountability of its annual supervisory stress test. The proposals request comment on several elements of the stress test, including the models and scenarios used; an enhanced disclosure process for the scenarios and material model changes in future stress test cycles; modifications to reporting forms; and an adjusted timeline for the annual process to accommodate a comment period for scenarios and material model changes. Truist Financial Corporation 9 Truist Financial Corporation 9 Truist Financial Corporation 9 Truist Financial Corporation 9 Truist Financial Corporation 9 Truist Financial Corporation 9" }, { "status": "ADDED", "current_title": "Liquidity Requirements", "prior_title": null, "current_body": "Certain BHCs and their bank subsidiaries, including Truist and Truist Bank, are subject to a minimum LCR and NSFR. The LCR rule requires that banking organizations maintain an amount of eligible HQLA that is sufficient within the parameters of the rule to meet estimated total net cash outflows over a prospective 30 calendar-day period of stress. The NSFR rule defines a minimum amount of stable, long-term funding that banking organizations must maintain in relation to their asset composition and off-balance sheet activities. The NSFR, calculated as the ratio of available stable funding to required stable funding, must exceed 1.0x for banking organizations required to meet the full requirement. Available stable funding represents a weighted measure of a company’s funding sources over a one-year time horizon, calculated by applying standardized weightings to the company’s equity and liabilities based on their expected stability. Required Stable Funding is calculated by applying standardized weighting to assets, derivatives exposures, and certain other items based on their liquidity characteristics. As a Category III banking organization, Truist and Truist Bank are subject to LCR and NSFR requirements equal to 85% of the full requirement. Truist is also subject to FRB rules that require certain large BHCs to conduct internal liquidity stress tests over a range of time horizons, maintain a buffer of highly liquid assets sufficient to meet projected net outflows under the BHC’s 30-day liquidity stress test, and maintain a contingency funding plan." }, { "status": "ADDED", "current_title": "Long-Term Debt and Clean Holding Company Requirements", "prior_title": null, "current_body": "U.S. banking agencies issued a proposed rule that would require banking organizations with $100 billion or more in total assets to comply with long-term debt requirements and clean holding company requirements that currently apply only to GSIBs. This proposal would also impose a long-term debt requirement on certain categories of IDIs, including IDIs with $100 billion or more in total assets, such as Truist Bank. The clean holding company requirements would limit or prohibit banking organizations such as Truist from entering into certain transactions that could impede its orderly resolution, including transactions that could spread losses to subsidiaries and third parties or could limit the amount of Truist’s liabilities that are not eligible long-term debt. The timing and form of any final rule implementing the long-term debt requirements and clean holding company requirements remains uncertain." }, { "status": "ADDED", "current_title": "Payment of Dividends", "prior_title": null, "current_body": "The Parent Company is a legal entity separate and distinct from its subsidiaries. The Parent Company depends in part upon dividends received from its direct and indirect subsidiaries, including Truist Bank, to fund its activities, including capital distributions such as dividends and share repurchases. Federal law limits Truist Bank’s ability to declare and pay dividends to the Parent Company, including under regulatory capital requirements, safety-and-soundness requirements, and requirements relating to the payment of dividends out of net profits, surplus, and available earnings. Certain contractual restrictions also may limit the ability of Truist Bank to pay dividends to the Parent Company. No assurances can be given that Truist Bank will, in any circumstances, pay dividends to the Parent Company. The Parent Company’s ability to declare and pay dividends is similarly limited by federal banking law and FRB policies. The FRB has authority to prohibit a BHC from making capital distributions if determined to be an unsafe or unsound practice. The FRB has indicated generally that paying dividends may be an unsafe and unsound practice unless net income is sufficient to fund the dividends and the expected rate of earnings retention is consistent with the BHC’s capital needs, asset quality, and overall financial condition. In addition, a BHC’s ability to make capital distributions, including dividends and share repurchases, is subject to the FRB’s automatic restrictions on capital distributions if the BHC fails to maintain certain regulatory capital ratios. Truist’s risk-based capital and leverage ratio requirements are discussed above in the “Capital Requirements” section. North Carolina law provides that, as long as a bank does not make distributions that reduce its capital below its applicable required capital, the board of directors of a bank chartered under the laws of North Carolina may declare such distributions as the directors deem proper." }, { "status": "ADDED", "current_title": "Prompt Corrective Action", "prior_title": null, "current_body": "U.S. banking agencies are required to take “prompt corrective action” against IDIs that do not meet minimum capital requirements. There are five statutory categories that characterize an IDI’s capital position for this purpose: “well-capitalized,” “adequately capitalized,” “undercapitalized,” “significantly undercapitalized,” and “critically undercapitalized.” To be considered “well-capitalized,” an IDI must maintain minimum capital ratios and must not be subject to any order or written directive to meet and maintain a specific capital level for any capital measure. 10 Truist Financial Corporation 10 Truist Financial Corporation 10 Truist Financial Corporation 10 Truist Financial Corporation 10 Truist Financial Corporation 10 Truist Financial Corporation An IDI that fails to remain well-capitalized becomes subject to a series of restrictions that increase in severity as its capital condition weakens. These restrictions may include a prohibition on capital distributions, restrictions on asset growth, or the withholding of regulatory approval for applications. Additionally, the FRB is authorized to act against BHCs with undercapitalized IDI subsidiaries. In certain instances, a BHC acting as a source of strength would be required to guarantee the performance of the undercapitalized subsidiary’s capital restoration plan and could be liable for civil money damages for failing to fulfill those guarantees. If an IDI fails to meet applicable capital requirements, its supervisors may take a variety of formal and informal enforcement actions, including directing the IDI to raise additional capital, substantially restricting the IDI’s operations and activities, terminating the IDI’s deposit insurance, and in severe cases appointing a conservator or receiver for the IDI." }, { "status": "ADDED", "current_title": "Transactions with Affiliates", "prior_title": null, "current_body": "Transactions between Truist Bank and its nonbank affiliates, including the Parent Company, are subject to a number of legal restrictions. Under the Federal Reserve Act and FRB regulations, Truist Bank and its subsidiaries are subject to quantitative and qualitative limits on extensions of credit, purchases of assets, and certain other transactions with nonbank affiliates, including requirements that transactions be at arm’s length and consistent with safety and soundness." }, { "status": "ADDED", "current_title": "Acquisitions", "prior_title": null, "current_body": "Truist requires prior regulatory approval to engage in certain acquisitions. For example, under the BHCA, a BHC may not directly or indirectly acquire ownership or control of more than 5% of the voting shares or substantially all of the assets of any BHC or bank or merge or consolidate with another BHC without the prior approval of the FRB. The BHCA and other federal laws enumerate the factors the FRB must consider when reviewing the merger of BHCs, the acquisition of banks, or the acquisition of voting securities of a bank or BHC. These factors include the competitive effects of the transaction in the relevant geographic markets; the financial and managerial resources and future prospects of the companies and banks involved in the transaction; the effect of the transaction on the financial stability of the U.S.; the organizations’ compliance with anti-money laundering statutes and regulations; the convenience and needs of the communities to be served; and the records of performance under the CRA of the IDIs involved in the transaction. Federal law authorizes interstate acquisitions of banks and BHCs without geographic limitation, and a bank headquartered in one state is authorized to merge with a bank headquartered in another state, subject to market share limitations, regulatory approvals, and any state requirement that the target bank must have been in existence and operating for a minimum period of time. The FRB’s market share limitations impose conditions that the acquiring BHC, after and as a result of the acquisition, control no more than 10% of the total amount of deposits of IDIs in the U.S. and no more than 30%, subject to variation by state law, of such deposits in applicable states. FRB rules also prohibit an FHC from combining with another company if the resulting company’s liabilities would exceed 10% of the aggregate consolidated liabilities of all U.S. financial companies. After a bank has established branches in a state through an interstate merger transaction, the bank may establish and acquire additional branches at any location in the state where a bank headquartered in that state could have established or acquired branches under applicable federal or state law. The U.S. DOJ has withdrawn its 1995 Bank Merger Guidelines, which focused primarily on concentrations of deposits and branches, and clarified that it will assess competition considerations in connection with bank and BHC mergers using its 2023 Merger Guidelines and 2024 Banking Addendum. The 2023 Merger Guidelines are a general merger review framework used to evaluate transactions in all segments of the economy, and the 2024 Banking Addendum allows for consideration of theories of harm and relevant markets not considered in the 1995 Bank Merger Guidelines. It is still not entirely clear how the U.S. DOJ will apply this new merger review framework to bank and BHC mergers." }, { "status": "ADDED", "current_title": "Other Safety and Soundness Regulations", "prior_title": null, "current_body": "The FRB has authority to prohibit BHCs and their subsidiaries from conducting activities that constitute unsafe or unsound practices or violations of statute, rule, regulation, administrative order, or written agreement with a U.S. banking agency. These powers may be exercised through the issuance of confidential supervisory actions, cease and desist orders, civil money penalties, or other actions. In October 2025, the FDIC and the OCC issued a proposed rule that would define the term “unsafe or unsound practice” for purposes of their enforcement powers under the Federal Deposit Insurance Act. The proposed definition would focus on whether the practice is likely to materially harm, or already has materially harmed, the financial condition of an institution. Truist Financial Corporation 11 Truist Financial Corporation 11 Truist Financial Corporation 11 Truist Financial Corporation 11 Truist Financial Corporation 11 Truist Financial Corporation 11 Federal law and regulatory policy impose a number of obligations and restrictions on BHCs and their IDI subsidiaries that are designed to reduce potential loss exposure to depositors and the DIF in the event that the BHC or the IDI becomes or is in danger of becoming insolvent. In particular, a BHC must serve as a source of financial and managerial strength to its subsidiary IDI and commit financial resources to support that IDI during periods of severe stress. U.S. banking agencies have other broad powers over IDIs as well, including the power to impose confidential supervisory actions and civil penalties and to appoint a receiver or conservator over an IDI for the benefit of depositors and other creditors. The NCCOB also has the authority to take possession of a North Carolina state bank in certain circumstances, including when it appears that the bank has violated its charter or applicable law, is conducting its business in an unauthorized or unsafe manner, is in an unsafe or unsound condition to transact its business, or has an impairment of its capital stock." }, { "status": "ADDED", "current_title": "DIF Assessments", "prior_title": null, "current_body": "Truist Bank’s deposits are insured by the FDIC up to the maximum insurable amount, which is currently $250,000 per depositor per account ownership type. The FDIC imposes a risk-based deposit premium assessment system that determines assessment rates for each IDI using an assessment rate calculator, which incorporates measurements of the risk each IDI poses to the DIF. The assessment rate is applied to total average assets less tangible equity, as defined by the Dodd-Frank Act. The assessment rate schedule can change from time to time at the discretion of the FDIC, subject to certain limits. Under the current system, premiums are assessed quarterly. The FDIC implemented a special assessment to recoup losses to the DIF associated with the large bank failures in 2023. The special assessment is based on an IDI’s estimated uninsured deposits. Truist Bank’s special assessment may be adjusted for changes in the estimated relevant losses to the DIF reported by the FDIC. The special assessment will be paid by IDIs in eight quarterly installments, which began in the second quarter of 2024. In December 2025, the FDIC issued an interim final rule reducing the special assessment rate for the eighth collection quarter, with an invoice payment date of March 30, 2026, and outlining a process for (i) an offset to regular quarterly deposit insurance assessments for IDIs subject to the special assessment if the special assessment amount collected ultimately exceeds losses to the DIF or (ii) a one-time final shortfall special assessment if losses to the DIF exceed the special assessment amount collected." }, { "status": "ADDED", "current_title": "Consumer Protection Laws", "prior_title": null, "current_body": "In connection with its lending, leasing and deposit-taking activities, Truist Bank is subject to federal and state laws designed to protect consumers and borrowers and to promote financial services for various sectors of the economy and population. The CFPB examines Truist and Truist Bank for compliance with a broad range of federal consumer financial statutes and regulations, including those that relate to credit card, mortgage, automobile, student, and other consumer loans as well as deposit products and other consumer financial products and services. Laws that the CFPB is charged with enforcing include the Truth in Lending Act, Truth in Savings Act, Home Mortgage Disclosure Act, Fair Credit Reporting Act, Electronic Funds Transfer Act, Real Estate Settlement Procedures Act, Fair Debt Collection Practices Act, and Equal Credit Opportunity Act. The CFPB may take enforcement actions to prevent and remedy acts and practices relating to consumer financial products and services that it deems to be unfair, deceptive, or abusive. The CFPB also may impose new disclosure requirements for consumer financial products and services. CFPB regulations and supervisory actions may impact Truist or Truist Bank, including by reducing the fees that Truist and Truist Bank receive, altering the way products and services are provided, or increasing the risk of private litigation or regulatory enforcement action. In October 2024, the CFPB finalized a rule under the Dodd-Frank Act that requires certain entities, including Truist and Truist Bank, to make available to a consumer, upon request, information in the entity’s control or possession concerning the consumer financial product or service that the consumer obtained from that entity. The rule also requires data providers holding a consumer account, such as Truist Bank, to establish a developer interface satisfying certain data security specifications and other standards, through which the data provider can receive requests for and provide specific types of data covered by the rule in electronic, usable form to authorized third parties such as data aggregators. Data providers are prohibited from charging consumers or third parties fees for processing these consumer data requests. The rule further places certain data security, authorization, and other obligations on third parties accessing covered data from data providers, which could include Truist and Truist Bank when acting in certain capacities. In addition, the rule requires these third parties to limit their collection, use, and retention of the data received from the applicable data provider to only what is reasonably necessary to provide the applicable consumer’s requested product or service, including uses that are reasonably necessary to improve the product or service. After release of the final rule, banking industry participants sued to enjoin and invalidate the rule in the United States District Court for the Eastern District of Kentucky. The CFPB has indicated that it will significantly revise the final rule, which is expected to change Truist's and Truist Bank's obligations and the applicable compliance dates. On October 29, 2025, the court granted a preliminary injunction to pause the compliance dates and to enjoin the CFPB from enforcing the rule until after reconsideration. 12 Truist Financial Corporation 12 Truist Financial Corporation 12 Truist Financial Corporation 12 Truist Financial Corporation 12 Truist Financial Corporation 12 Truist Financial Corporation Truist and Truist Bank are subject to consumer protection laws that have been adopted by the states where they operate. State attorneys general and regulatory agencies have authority to enforce these state consumer protection laws as well as certain federal consumer protection laws. During 2025, the CFPB reduced its staff by over 80%. The reduction in force is the subject of litigation, and the staffing cuts are currently stayed pending the federal circuit court’s rehearing of the case. The impact of these developments on banking organizations subject to CFPB regulation and supervision, including Truist, is uncertain. States and state attorneys general may increase regulatory, investigative, and enforcement activity with respect to consumer protection in response to changes in regulation, supervision, and enforcement of consumer protection laws by the CFPB or other federal regulators." }, { "status": "ADDED", "current_title": "BSA/AML and Sanctions", "prior_title": null, "current_body": "The BSA, as amended by the Patriot Act, and its implementing regulations are designed to protect the U.S. financial system and those who rely on it from financial crimes, such as money laundering and terrorist financing. The BSA and its implementing regulations do this by requiring financial institutions, including IDIs such as Truist Bank, broker-dealers, and other financial institutions, to develop and implement BSA/AML compliance programs that detect and report financial crimes. The BSA and its implementing regulations also strengthen the ability of U.S. law enforcement agencies and the intelligence community to disrupt and prevent money laundering, the financing of terrorism, and related crimes. In addition, U.S. persons, including entities like Truist, must comply with sanctions programs administered by OFAC and the U.S. Department of State. These sanctions programs prohibit, among other things, financial transactions involving certain individuals, entities, countries, and territories that are the subject of U.S. economic sanctions and impose other restrictions on certain investments and dealings, including requirements to block assets. Federal law grants substantial enforcement powers to U.S. banking agencies, FinCEN, OFAC, the U.S. DOJ, and other government agencies with respect to BSA and OFAC compliance, including through examination and ongoing monitoring. This enforcement authority includes the ability to assess significant civil and criminal monetary penalties, fines, and restitution; to issue cease and desist or prohibition orders; to initiate injunctive actions against financial institutions and institution-affiliated parties; and to impose restrictions on business, including bank and BHC mergers and acquisitions. These enforcement actions may be initiated for violations of statutes and regulations or for unsafe and unsound practices and could result in substantial negative shareholder reaction and reputational damage." }, { "status": "ADDED", "current_title": "Privacy, Data Protection, and Cybersecurity", "prior_title": null, "current_body": "Various federal and state statutes and regulations contain data privacy, data protection, and cybersecurity provisions, and the regulatory framework for data privacy, data protection, and cybersecurity is rapidly evolving. The FRB, the FDIC, and other U.S. banking agencies have adopted guidelines for safeguarding confidential, personal customer information. These guidelines require each financial institution, under the supervision and ongoing oversight of its board of directors or an appropriate committee thereof, to create, implement, and maintain a comprehensive written information security program designed to support the security and confidentiality of customer information, protect against any anticipated threats or hazards to the security or integrity of such information, and protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to any customer. In addition, a number of government entities, including the FRB and the SEC, have increased their focus on cybersecurity through guidance, examinations, and regulations. At the federal level, the Gramm-Leach-Bliley Act requires financial institutions to, among other things, implement policies and procedures regarding the disclosure of nonpublic personal information about consumers to non-affiliated third parties. In general, the statute requires that financial institutions provide explanations to consumers on their policies and procedures regarding the disclosure of such nonpublic personal information and, except as otherwise required by law, prohibits disclosing such personal information except as provided in the financial institution’s policies and procedures. A joint regulation from the FRB, the OCC, and the FDIC requires a banking organization to notify its primary federal regulators as soon as possible and within 36 hours after identifying a “computer-security incident” that the banking organization believes in good faith has materially disrupted or degraded, or is reasonably likely to materially disrupt or degrade, its business or operations in a manner that would, among other things, jeopardize the viability of its operations, result in customers being unable to access their deposit and other accounts, result in a material loss of revenue, profit or stock price, or pose a threat to the financial stability of the U.S. Truist Financial Corporation 13 Truist Financial Corporation 13 Truist Financial Corporation 13 Truist Financial Corporation 13 Truist Financial Corporation 13 Truist Financial Corporation 13 In addition, once implementing regulations are finalized, the Cyber Incident Reporting for Critical Infrastructure Act (“CIRCIA”) will require, among other things, covered entities to report significant cyber incidents, including ransomware attacks, to the Cybersecurity and Infrastructure Security Agency (“CISA”) within 72 hours from the time the covered entity reasonably believes the incident occurred (and within 24 hours of making a ransom payment as a result of a ransomware attack). The CISA proposed a rule under the CIRCIA in April 2024 that would clarify the scope of cyber incidents to be reported and would further define covered entities subject to the CIRCIA to include banking organizations like Truist. Although the CIRCIA originally required the CISA to finalize its regulations by October 2025, the CISA has extended such deadline to May 2026. Truist’s nonbank subsidiaries are also subject to rules and regulations issued by the Federal Trade Commission, which regulates unfair or deceptive acts or practices, including with respect to data privacy, data protection, and cybersecurity. Moreover, the U.S. Congress has recently considered, and is expected to continue to consider, various proposals for more comprehensive data privacy, data protection, and cybersecurity legislation. Like other lenders, Truist Bank uses credit bureau data in its underwriting activities. The Fair Credit Reporting Act regulates use of such data, as well as reporting information to credit bureaus, prescreening individuals for credit offers, sharing of information between affiliates, and using affiliate data for marketing purposes. Similar state laws impose additional requirements on Truist Bank. States are also increasingly proposing or enacting legislation that relates to data privacy, data protection, and cybersecurity such as the California Consumer Privacy Act as amended by the California Privacy Rights Act. Truist may be subject to similar laws in other states where Truist does business or in states where Truist may collect personal information of residents. In addition, laws in all 50 U.S. states generally require businesses to provide notice under certain circumstances to individuals whose personal information has been disclosed as a result of a data breach. Moreover, the New York Department of Financial Services Cybersecurity Regulation is driving significant cybersecurity compliance activities for covered Truist entities. This regulation includes phased compliance periods as well as annual attestations of compliance by these Truist entities. Truist has undertaken compliance activities to address these statutes and regulations and continues to assess their requirements and applicability to Truist. These statutes and regulations, as well as proposed legislation and regulation regarding privacy, data protection, and cybersecurity, are subject to revision or formal guidance and may be interpreted or applied in a manner inconsistent with the Company’s understanding, which may result in further uncertainty and require Truist to incur additional costs to comply. Refer to “Item 1A. Risk Factors” for more information on the risks related to compliance with applicable privacy, data protection, and cybersecurity statutes and regulations. CRA The CRA requires that U.S. banking agencies assess the records of banks in meeting the credit needs of the communities where they are chartered to do business, including low- and moderate-income neighborhoods, consistent with safe and sound operations. Banks are assigned one of four ratings: “Outstanding,” “Satisfactory,” “Needs to Improve,” or “Substantial Noncompliance.” A bank’s assessment is considered in connection with its application to merge or consolidate with or acquire the assets or assume the liabilities of another bank or to open or relocate a branch office. The CRA record of each subsidiary bank of an FHC is assessed by the FRB in connection with any proposed acquisition or merger application. For its most recent CRA examination period, Truist Bank received the highest possible overall rating of “Outstanding” from the FDIC. In October 2023, the U.S. banking agencies issued a final rule to significantly amend their regulations implementing the CRA. This rule was subject to litigation, and a preliminary injunction was issued that prevented the rule from taking effect. In July 2025, the agencies issued a notice of proposed rulemaking to rescind the rule and reinstate the previous CRA regulations." }, { "status": "ADDED", "current_title": "Automated Overdraft Payment Regulation", "prior_title": null, "current_body": "Federal consumer protection laws govern automated overdraft payment programs offered by financial institutions. The CFPB prohibits financial institutions from charging consumers fees for paying overdrafts on ATM and one-time debit card transactions, unless a consumer opts in to the overdraft service. Financial institutions must provide consumers with a notice that explains the financial institution’s overdraft services, including associated fees and the consumer’s choices. In addition, FDIC-supervised institutions must monitor overdraft payment programs for “excessive or chronic” client use and undertake “meaningful and effective” follow-up action with clients that overdraw their accounts more than six times during a rolling 12-month period. Financial institutions must also impose daily limits on overdraft charges, review and modify check-clearing procedures, prominently distinguish account balances from available overdraft coverage amounts, and provide for board and management oversight regarding overdraft payment programs. Truist offers checking accounts that are not subject to overdraft fees. 14 Truist Financial Corporation 14 Truist Financial Corporation 14 Truist Financial Corporation 14 Truist Financial Corporation 14 Truist Financial Corporation 14 Truist Financial Corporation" }, { "status": "ADDED", "current_title": "Interchange Fees", "prior_title": null, "current_body": "The Dodd-Frank Act requires the FRB to establish standards for assessing whether debit interchange fees charged by large debit card issuers, including Truist Bank, are reasonable and proportional to the cost incurred by the issuers. These standards are set forth in the FRB’s Regulation II, which has been subject to extensive litigation that remains ongoing. In 2023, the FRB proposed but has not yet finalized revisions to Regulation II that would lower the interchange fee cap applicable to Truist Bank, which may result in reduced interchange fee revenue. States have taken steps as well to regulate interchange fees. The Illinois Interchange Fee Prohibition Act prohibits credit and debit card issuers, payment card networks, acquirer banks, and processors from receiving or charging an Illinois merchant any interchange fees on the gratuity and state and local tax portions of the transactions. This statute has an implementation date of July 1, 2026, and while subject to litigation, has not been enjoined. Other states are considering similar legislation, including some that is more expansive in its restrictions on interchange fees." }, { "status": "ADDED", "current_title": "Volcker Rule", "prior_title": null, "current_body": "Truist is prohibited under the Volcker Rule from (i) engaging in proprietary trading of certain securities and (ii) having certain ownership interests in and relationships with covered private funds. The Volcker Rule contains certain exemptions and exclusions, including for market-making, hedging, underwriting, and trading in U.S. government and agency obligations. Additionally, the Volcker Rule permits certain ownership interests in certain types of funds and permits the offering and sponsoring of funds under certain conditions. Truist maintains specific Volcker Rule compliance programs." }, { "status": "ADDED", "current_title": "Regulatory Regime for Swaps", "prior_title": null, "current_body": "The Dodd-Frank Act established a comprehensive regulatory regime for the OTC swaps market aimed at increasing transparency and reducing systemic risk in the derivatives markets, including requirements for central clearing, exchange trading, capital adequacy, margin, reporting, and recordkeeping. The Dodd-Frank Act requires that certain swap dealers and security-based swap dealers register with one or both of the SEC and the CFTC, depending on the nature of the swaps business. Truist Bank is registered with the CFTC as a swap dealer and is registered with the SEC as a security-based swap dealer, subjecting Truist Bank to the CFTC’s and SEC’s regulatory regimes. This includes trade reporting and recordkeeping requirements, business conduct requirements (including daily valuations, disclosure of material risks associated with swaps and disclosure of material incentives and conflicts of interest), and mandatory clearing and exchange trading requirements for certain standardized swaps designated by the CFTC. The NFA is the primary self-regulatory organization for Truist’s swap dealer. Truist Bank’s uncleared swaps and security-based swaps are subject to variation margin and initial margin requirements." }, { "status": "ADDED", "current_title": "Broker-Dealer and Investment Adviser Regulation", "prior_title": null, "current_body": "Truist’s broker-dealer and investment adviser subsidiaries are subject to regulation by the SEC. FINRA is the primary self-regulatory organization for Truist’s registered broker-dealer subsidiaries. Truist’s broker-dealer and investment adviser subsidiaries are subject to additional regulation by states or local jurisdictions. The SEC and FINRA have enforcement powers over broker-dealers and investment advisers and can bring actions that result in fines, restitution, a limitation on permitted activities, disqualification to continue to conduct certain activities, and an inability to rely on certain favorable exemptions. Certain types of infractions and violations can affect Truist’s ability to issue new securities expeditiously. In addition, certain changes in the activities of a broker-dealer require approval from FINRA, which may base its approval on a variety of factors, such as internal controls, capital levels, management experience and quality, prior enforcement and disciplinary history, and supervisory concerns." }, { "status": "ADDED", "current_title": "Other Regulatory Matters", "prior_title": null, "current_body": "Truist is subject to examination by federal and state banking regulators as well as the SEC, the CFTC, FINRA, the MSRB, the NFA, various taxing authorities, and various state securities and other regulators. Truist periodically receives requests for information on business and accounting practices from regulatory authorities in various states, including state attorneys general, securities regulators, and other regulatory authorities. Such requests are part of our normal conduct of business." }, { "status": "ADDED", "current_title": "Human Capital", "prior_title": null, "current_body": "Truist works as One Team—unified by its purpose, mission, and values—to meet clients’ needs, uplift communities, empower teammates, and promote effective risk management and controls to drive performance. Truist recognizes that attracting the best talent, making investments in teammates, caring to better understand their backgrounds and experiences, and helping to bolster their career trajectories ultimately leads to more engaged and productive teammates, which can contribute to better client service and business outcomes for Truist overall. Truist Financial Corporation 15 Truist Financial Corporation 15 Truist Financial Corporation 15 Truist Financial Corporation 15 Truist Financial Corporation 15 Truist Financial Corporation 15 The Compensation and Human Capital Committee of the Board oversees the design and governance of Truist’s compensation and benefit programs consistent with its compensation philosophy. This committee also provides oversight of Truist’s human capital strategy that supports attracting, developing, and retaining qualified teammates. Truist strives to follow rigorous and dynamic talent practices, which develop teammates for success in a broad set of roles. Our talent practices include performance, succession, and progression planning. Truist’s Enterprise Ethics Office manages the standards for ethical conduct and monitors conduct risks and related teammate concerns. The Enterprise Ethics Office also facilitates the Board’s review and approval of the Code of Ethics. Through its risk monitoring and oversight routines, the Enterprise Ethics Office identifies trends and insights related to Truist’s organizational culture and control environment, which are reported to the Executive-level ERC and the Board. The following table presents a summary of teammates as of December 31, 2025: Table 2: Teammate Summary# of Teammates% of PopulationFull-Time37,08695.8 %Part-Time1,6254.2 Total38,711100.0 % Truist also leverages a contingent workforce, which is not reflected in the table, as an important part of the Company’s overall workforce strategy. Truist aspires to foster a performance-based culture that is reinforced with transparency and feedback. Through transparency, we further our teammate mission of creating an inclusive and energizing environment that empowers teammates to learn, grow, and have meaningful careers. Promoting feedback allows for business settings where every teammate is respected, everyone matters and has a voice, and everyone feels welcome and empowered to make meaningful contributions. Collectively, this approach helps us to be competitive in meeting the needs of our clients and communities." }, { "status": "ADDED", "current_title": "Talent Practices", "prior_title": null, "current_body": "Truist utilizes a suite of talent practices providing insight into the state of our talent. Talent practices are designed to underpin and strengthen executive leaders’ decisions, which are informed by data and insights. These practices include: •Performance management - goal planning, feedback, check-ins, and performance evaluation. •Succession planning - tools that identify potential interim, near- and longer-term internal successors designed to allow for optionality and business continuity. •Talent assessment - manager evaluation of the forward-looking potential of eligible teammates through the lens of their performance, ability, agility, and aspiration as well as consideration of retention risk. •Progression planning - helps teammates and managers chart a path for teammates to learn, grow, and have meaningful careers. •Enterprise strategic workforce planning and skill assessments – a practice enabling the business to plan for the appropriate workforce capability and capacity in target job profiles." }, { "status": "ADDED", "current_title": "Talent Development", "prior_title": null, "current_body": "Truist teammates have access to programs and benefits for career advancement. Teammates can partner with a certified coach to help them identify and focus on potential career paths, create clear goals, and remain accountable in achieving those goals. For teammates who qualify, Truist also provides tuition assistance so teammates can continue formal education by seeking degrees that align with career goals or develop needed emerging skills through our Future Skills program. Truist offers career and job transparency through a set of resources including career discovery and career planning online services. Truist seeks to achieve a career destination culture through career mobility and pipeline strategies and programs, including Truist’s Leadership Institute, which leverages developmental experiences, team optimization, executive coaching, and leadership development. 16 Truist Financial Corporation 16 Truist Financial Corporation 16 Truist Financial Corporation 16 Truist Financial Corporation 16 Truist Financial Corporation 16 Truist Financial Corporation In addition to career development opportunities, Truist provides learning experiences to new and existing teammates to help build the skills needed now and in the future, including role skill preparedness, upskilling for advancements, including the responsible use of emerging technologies such as AI, and access to skill building content for teammate-led learning. Truist Learning and Development also prioritizes and integrates regulatory-related training to mitigate risk across the organization. Truist has invested in innovative talent marketplace and learning technologies and believes that skill development leads to healthy and robust career mobility, which furthers our teammate value proposition and retention efforts." }, { "status": "ADDED", "current_title": "Compensation and Total Rewards", "prior_title": null, "current_body": "Truist’s Compensation and Total Rewards enable its purpose, mission, and values, specifically Truist’s mission to create an inclusive and energizing environment that empowers teammates. Truist aims to provide market competitive total rewards to attract and retain talent while enabling Truist’s short- and long-term performance. Truist provides compensation and rewards that are designed to achieve positive business results, are based on market and internal assessments, and are aligned with risk management principles. Truist’s benefits program for qualified teammates includes a company-funded defined benefit pension plan, a 401(k) plan, an employee stock purchase plan, Truist Momentum financial well-being education, healthcare coverage, and other insurance benefits. Truist also provides access to a Lifeforce physical well-being program, mental well-being support, paid time off, teammate and family resources such as access to backup child-care centers and family care resources, and on-site services such as health centers and fitness centers." }, { "status": "ADDED", "current_title": "Website Access to Truist’s Filings with the SEC", "prior_title": null, "current_body": "Truist’s electronic filings with the SEC, including the Annual Report on Form 10-K, Quarterly Reports on Form 10-Q, Current Reports on Form 8-K, and amendments to these reports filed or furnished pursuant to Sections 13(a) or 15(d) of the Exchange Act are made available at no cost on the Company’s Investor Relations website, https://ir.truist.com, as soon as reasonably practicable after Truist files such material with, or furnishes it to, the SEC. Truist’s SEC filings are also available through the SEC’s website at https://www.sec.gov. Truist may use its website to distribute Company information, including as a means of disclosing material, non-public information and for complying with its disclosure obligations under Regulation FD. Truist routinely posts and makes accessible financial and other information, including corporate responsibility and sustainability information, regarding Truist on its website. Investors should monitor Truist’s website, including the Investor Relations portion, in addition to its press releases, SEC filings, public conference calls, and webcasts. The information on our website is not incorporated by reference into this report." }, { "status": "ADDED", "current_title": "Corporate Governance", "prior_title": null, "current_body": "Information with respect to the Board, Executive Officers, and corporate governance policies and principles is presented on Truist’s Investor Relations website, https://ir.truist.com. Specifically, the Company makes available on its Investor Relations website, under the heading “Governance & Responsibility” (i) its Code of Ethics for the Board, senior financial officers, and teammates, (ii) its Corporate Governance Guidelines, and (iii) the charters of the Company’s standing Board committees. If the Company makes changes in, or provides waivers from, the provisions of its Code of Ethics that the SEC requires it to disclose, the Company intends to disclose these events in the “Governance & Responsibility” section of its Investor Relations website. Truist Financial Corporation 17 Truist Financial Corporation 17 Truist Financial Corporation 17 Truist Financial Corporation 17 Truist Financial Corporation 17 Truist Financial Corporation 17 Table 3: Information about our Executive OfficersExecutive OfficerRecent Work ExperienceYears of ServiceAgeWilliam H. Rogers, Jr.Chairman and Chief Executive OfficerChairman since March 2022. Chief Executive Officer since September 2021. President and Chief Operating Officer from December 2019 to September 2021.4568Michael B. MaguireSenior Executive Vice President and Chief Financial OfficerChief Financial Officer since September 2022. Chief National Consumer Finance Services and Payments Officer from September 2021 to September 2022. Head of National Consumer Finance and Payments from December 2019 to August 2021.2347Brad BenderSenior Executive Vice President and Chief Risk OfficerChief Risk Officer since November 2024. Interim Chief Information Officer from April 2024 to November 2024. Head of Enterprise Operational Services from November 2023 to April 2024. Head of Consumer Finance Solutions and Enterprise Operations and Global Services from May 2023 to November 2023. Head of Consumer Finance Solutions from September 2022 to May 2023. Head of Home Improvement Lending from August 2021 to September 2022. Head of Consumer Credit Risk and Policy Management from December 2019 to August 2021.2145Scott A. StengelSenior Executive Vice President, Chief Legal Officer, Head of Government Affairs, and Corporate SecretaryChief Legal Officer, Head of Government Affairs, and Corporate Secretary since December 2023. General Counsel at Ally Financial Inc. from May 2016 to December 2023.254Kristin LesherSenior Executive Vice President and Chief Wholesale Banking OfficerChief Wholesale Banking Officer since February 2024. Executive Vice President and Head of Commercial Banking Coverage at Wells Fargo from October 2021 to November 2023. Head of East Region Commercial Banking Coverage at Wells Fargo from November 2018 to October 2021.253Dontá L. WilsonSenior Executive Vice President and Chief Consumer and Small Business Banking OfficerChief Consumer and Small Business Banking Officer since November 2023. Chief Retail & Small Business Banking Officer from March 2022 to November 2023. Chief Digital and Client Experience Officer from November 2018 to March 2022.2749 William H. Rogers, Jr. Chairman and Chief Executive Officer Chairman since March 2022. Chief Executive Officer since September 2021. President and Chief Operating Officer from December 2019 to September 2021. Michael B. Maguire Senior Executive Vice President and Chief Financial Officer Brad Bender Senior Executive Vice President and Chief Risk Officer Chief Risk Officer since November 2024. Interim Chief Information Officer from April 2024 to November 2024. Head of Enterprise Operational Services from November 2023 to April 2024. Head of Consumer Finance Solutions and Enterprise Operations and Global Services from May 2023 to November 2023. Head of Consumer Finance Solutions from September 2022 to May 2023. Head of Home Improvement Lending from August 2021 to September 2022. Head of Consumer Credit Risk and Policy Management from December 2019 to August 2021. Scott A. Stengel Senior Executive Vice President, Chief Legal Officer, Head of Government Affairs, and Corporate Secretary Chief Legal Officer, Head of Government Affairs, and Corporate Secretary since December 2023. General Counsel at Ally Financial Inc. from May 2016 to December 2023. Kristin Lesher Senior Executive Vice President and Chief Wholesale Banking Officer Chief Wholesale Banking Officer since February 2024. Executive Vice President and Head of Commercial Banking Coverage at Wells Fargo from October 2021 to November 2023. Head of East Region Commercial Banking Coverage at Wells Fargo from November 2018 to October 2021. Dontá L. Wilson Senior Executive Vice President and Chief Consumer and Small Business Banking Officer Chief Consumer and Small Business Banking Officer since November 2023. Chief Retail & Small Business Banking Officer from March 2022 to November 2023. Chief Digital and Client Experience Officer from November 2018 to March 2022. William H. Rogers, Jr. Chairman and Chief Executive Officer Chairman since March 2022. Chief Executive Officer since September 2021. President and Chief Operating Officer from December 2019 to September 2021. Michael B. Maguire Senior Executive Vice President and Chief Financial Officer Brad Bender Senior Executive Vice President and Chief Risk Officer Chief Risk Officer since November 2024. Interim Chief Information Officer from April 2024 to November 2024. Head of Enterprise Operational Services from November 2023 to April 2024. Head of Consumer Finance Solutions and Enterprise Operations and Global Services from May 2023 to November 2023. Head of Consumer Finance Solutions from September 2022 to May 2023. Head of Home Improvement Lending from August 2021 to September 2022. Head of Consumer Credit Risk and Policy Management from December 2019 to August 2021. Scott A. Stengel Senior Executive Vice President, Chief Legal Officer, Head of Government Affairs, and Corporate Secretary Chief Legal Officer, Head of Government Affairs, and Corporate Secretary since December 2023. General Counsel at Ally Financial Inc. from May 2016 to December 2023. Kristin Lesher Senior Executive Vice President and Chief Wholesale Banking Officer Chief Wholesale Banking Officer since February 2024. Executive Vice President and Head of Commercial Banking Coverage at Wells Fargo from October 2021 to November 2023. Head of East Region Commercial Banking Coverage at Wells Fargo from November 2018 to October 2021. Dontá L. Wilson Senior Executive Vice President and Chief Consumer and Small Business Banking Officer Chief Consumer and Small Business Banking Officer since November 2023. Chief Retail & Small Business Banking Officer from March 2022 to November 2023. Chief Digital and Client Experience Officer from November 2018 to March 2022. 18 Truist Financial Corporation 18 Truist Financial Corporation 18 Truist Financial Corporation 18 Truist Financial Corporation 18 Truist Financial Corporation 18 Truist Financial Corporation" }, { "status": "REMOVED", "current_title": null, "prior_title": "Compliance Risks", "prior_body": "•Truist is subject to extensive and evolving government regulation and supervision, which could adversely affect our business, financial condition, results of operations, and prospects. •Regulatory capital and liquidity standards and future revisions to them may negatively impact our business and financial results. •Truist is subject to risks related to originating and selling loans, including repurchase and indemnification obligations. •Truist faces risks as a servicer of loans. •Truist faces substantial risks in safeguarding personal and other sensitive information. •Differences in regulation and supervision can affect the Company’s ability to compete effectively." }, { "status": "REMOVED", "current_title": null, "prior_title": "Reputational Risks", "prior_body": "•Negative public opinion, whether real or perceived, or our failure to successfully manage it could damage the Company’s reputation and adversely impact our business, financial condition, results of operations, and prospects." }, { "status": "REMOVED", "current_title": null, "prior_title": "Talent Management Risks", "prior_body": "•We could be harmed by an inability to attract, develop, retain, and motivate qualified teammates while effectively managing recruiting and compensation costs amid highly competitive and rapidly changing market conditions. •The Company’s operations rely on its ability, and the ability of key external parties, to maintain appropriately staffed workforces and on the competence, trustworthiness, health, and safety of teammates." }, { "status": "REMOVED", "current_title": null, "prior_title": "Regulatory and Legal Risks", "prior_body": "•The Company may incur damages, fines, penalties, and other negative consequences from past, current, or future supervisory actions and regulatory or other legal violations, including inadvertent or unintentional violations. •Pending or threatened legal proceedings and other matters may adversely affect the Company’s business, financial condition, results of operations, and reputation." }, { "status": "REMOVED", "current_title": null, "prior_title": "Reputational Risks", "prior_body": "•Negative public opinion, whether real or perceived, or our failure to successfully manage it could damage the Company’s reputation and adversely impact our business, financial condition, results of operations, and prospects." }, { "status": "REMOVED", "current_title": null, "prior_title": "Talent Management Risks", "prior_body": "•We could be harmed by an inability to attract, develop, retain, and motivate qualified teammates while effectively managing recruiting and compensation costs amid highly competitive and rapidly changing market conditions. •The Company’s operations rely on its ability, and the ability of key external parties, to maintain appropriately staffed workforces and on the competence, trustworthiness, health, and safety of teammates." }, { "status": "REMOVED", "current_title": null, "prior_title": "ITEM 1C. CYBERSECURITY", "prior_body": "The following is a discussion of Truist’s cybersecurity risk management strategy and governance. Refer to the “Risk Management” section of Part II, Item 7 for additional discussion. Cybersecurity risk management and strategy Like other financial services firms, Truist faces an increasingly complex and evolving cybersecurity threat environment. See Item 1A, “Risk Factors” for information on risks from cybersecurity threats. We maintain a risk-based cybersecurity framework that is part of our ERM Framework. It is implemented through people, processes, and technology, whereby we assess, identify, and manage material risks from cybersecurity threats, and seek to adapt our risk mitigation activities accordingly. Foundationally, our cybersecurity framework is based upon the National Institute of Standards and Technology for Improving Critical Infrastructure Cybersecurity and is also designed to incorporate elements from additional industry standards, such as those of the Federal Financial Institutions Examination Council, to better suit the Company’s cyber risk profile. In addition, our cybersecurity framework incorporates internal and third-party capabilities that drive the development and implementation of our data security strategy, which is designed to reduce cybersecurity risk while enabling Truist’s corporate business objectives. Processes for assessing, identifying, and managing material risks from cybersecurity threats We maintain an Information Security Program that specifies how we execute our cybersecurity framework. The Information Security Program is designed to assess, identify, and manage risks arising from the cybersecurity threats facing Truist. Truist maintains cybersecurity and information security policies, procedures, and technologies that are intended to protect our clients’, teammates’ and our own data against unauthorized disclosure, modification, and misuse. These policies, procedures, and technologies cover a broad range of areas, including identification of internal and external threats, access control, data security, protective controls, detection of malicious or unauthorized activity, incident response, and recovery planning. For example, to further mitigate the risks presented by an evolving cyber threat landscape, Truist: •provides data protection guidance to clients; •promotes data protection awareness and accountability through mandatory teammate training; and •conducts scenario-driven test exercises simulating impacts and consequences developed through analysis of real-world incidents as well as known and anticipated cyber threats. These exercises are designed to assess the viability of Truist’s crisis response and management programs and provide the basis for improvement. In addition, as a key part of the Company’s Information Security Program, Truist participates in the federally recognized Financial Services Information Sharing and Analysis Center, as well as other industry organizations and initiatives that promote industry best practices, such as harmonized cybersecurity standards, cyber readiness, and secure consumer financial data sharing. Our Cyber Incident Response Team is responsible for identifying, triaging, and containing cybersecurity threats and incidents, including, to the extent possible, those experienced by third-party service providers. Incidents with potential for higher impacts are routed to an enterprise response function that coordinates the response activities across impacted resource groups and business stakeholders. Through this structure, Truist manages its cyber, business, and legal obligations, including escalation to executive management and the Board, as appropriate, client and regulatory notifications, and remediation activities. Our Information Security Program is also designed to help oversee, identify, and mitigate cybersecurity risks associated with our use of third-party service providers. Following an initial assessment of the level of enterprise risk potentially posed by use of the third party, the service provider is then subject to further risk-based assessments on its operational resilience and cybersecurity practices, including disaster recovery and business continuity plans that specify the time frame to resume activities and recover data. In its agreements with third-party service providers, Truist requires service providers to adhere to Truist’s relevant cybersecurity and operational resilience standards, subject to certain exceptions that are managed on a case-by-case basis. Our Information Security Program is assessed periodically to test the effectiveness of key controls through cybersecurity maturity measurements, technology risk oversight, compliance risk management testing and monitoring, internal audit review, and regulatory oversight. In addition, Truist maintains disaster recovery plans that are reviewed, modified, and approved annually. Truist Financial Corporation 41 Truist Financial Corporation 41 Truist Financial Corporation 41 Truist Financial Corporation 41 Truist Financial Corporation 41 Truist Financial Corporation 41 Management’s role in assessing and managing material risks from cybersecurity threats Truist’s Information Security Program is operated and maintained by management, including the CIO, interim CISO, and CRO. These senior officers are responsible for assessing and managing Truist’s cybersecurity risks. Our Information Security Program also includes processes for escalating and considering the materiality of incidents that impact Truist, including escalation to executive management and the Board, which are periodically tested through tabletop exercises to assess Truist’s preparedness. Our cybersecurity framework strategy, which is overseen by the interim CISO, is informed by various risk and control assessments, control testing, external assessments, threat intelligence, and public and private information sharing. In addition, various management committees assess and manage Truist’s cybersecurity risks. These committees promote visibility and awareness of cybersecurity risks and drive action and escalation as needed. The primary management committees involved in Truist’s Information Security Program are the Enterprise Technology Risk Committee and the Technology Risk Oversight Committee, each of which is a sub-committee of the ERC. Truist’s cybersecurity teams that implement the Information Security Program and the risk partners who oversee the program leverage these committees to report on and escalate current or emerging cybersecurity risks or other changes in the business environment which could affect Truist’s risk profile or control environment. As discussed in more detail in the “Risk Management” section of Part II, Item 7, the ERC is a cross-functional executive forum to promote awareness and dialogue on risk matters across the enterprise, including cybersecurity risks, oversee the execution of risk program requirements and sound risk management activities, and enact delegated decision-making authority and oversight routines from the BRC. Our CRO and CIO are members of the ERC. The interim CISO provides updates at every ERC meeting on cybersecurity and information security risk. The Enterprise Technology Risk Committee provides business unit oversight of key management activities, including the Company’s Information Security Program. The Technology Risk Oversight Committee provides oversight of key risk management activities to identify, assess, monitor, mitigate, and report on technology (including core technology, data and cybersecurity) risk across the enterprise. These sub-committees serve as governing forums for monitoring and escalating significant cybersecurity as well as other technology risk matters to the ERC. The members of management that lead our Information Security Program and strategy have extensive experience in technology, cybersecurity, and information security. Our CRO previously served as our interim CIO and has more than 20 years of banking experience spanning a variety of roles in both the commercial and consumer segments, including credit risk, portfolio risk management, model management, acquisition integrations, technology, and vertically integrated operations for revenue producing businesses, including leading operational services across Truist for deposits, payments, credit card, capital markets, consumer and wholesale lending, fraud, and care centers across all products. Our CIO has over 25 years of experience leading technology teams at financial institutions, including in the areas of application development, infrastructure, information technology strategy, risk management, and information security. Following the departure of our CISO in November 2024, the CIO is serving as our interim CISO while our search for a permanent CISO continues. The CIO’s direct reports have on average over 20 years of experience with technology management and information security at financial institutions, including in the areas of governance, operations, application and data protection, access management, and business information security. Board of Directors’ oversight of risks from cybersecurity threats Our Board has primary responsibility for the oversight of our enterprise risk management and exercises its oversight function in respect of cybersecurity risk through the BRC. The BRC is responsible for overseeing Truist’s risk management function, including approving and reviewing Truist’s risk management framework and policies, and overseeing management’s implementation of such framework and policies. The oversight responsibility of our Board and the BRC is facilitated through management-reporting processes designed to provide visibility to the Board on cybersecurity matters. For example, members of the BRC receive regular reports from our CRO and interim CISO related to information technology and cybersecurity risks to Truist. The BRC meets periodically with risk management advisors and discusses with executive management any cybersecurity recommendations received. Management also discusses urgent cybersecurity developments with the Chairs of the BRC and BTC between Board and committee meetings, as appropriate. The Board annually reviews and approves our Information Security Program and Information Security Policy. Additionally, the BTC provides oversight of Truist’s technology strategy, including elements of it that involve cybersecurity. Truist provides ongoing development and education to its directors with respect to cybersecurity, including presentations at Board meetings on special topics, such as updates on cybersecurity legislation and regulation. The Board also conducts a cybersecurity tabletop exercise at least every other year to simulate Truist’s analysis and response to hypothetical cybersecurity incidents. In addition, Truist provides directors with a Board Cybersecurity Handbook that provides details on key Truist practices, resources, and protocols relating to cybersecurity protection, response, and preparedness. Finally, as required by the Gramm-Leach-Bliley Act, the Board receives an update at least annually on Truist’s Information Security Program. 42 Truist Financial Corporation 42 Truist Financial Corporation 42 Truist Financial Corporation 42 Truist Financial Corporation 42 Truist Financial Corporation 42 Truist Financial Corporation" }, { "status": "MODIFIED", "current_title": "Liquidity Risks", "prior_title": "Liquidity Risks", "similarity_score": 0.92, "confidence": "high", "key_changes": [ "Reworded sentence: \"Truist competes for deposit funding with banks and other financial institutions and with money market funds and other providers of deposit equivalents.\"", "Reworded sentence: \"For example, in 2025, maintaining and growing client deposits continued to be challenging as the Federal Reserve System reduced the size of its balance sheet through quantitative tightening.\"", "Reworded sentence: \"In addition, idiosyncratic factors affecting the Company, including realization of other risks described herein, as well as other factors outside of the Company’s control, such as a general market disruption or an operational problem that affects service providers or intermediaries, could impair the Company’s ability to access short-term or contingent funding sources or create an unforeseen outflow of cash due to, among other factors, draws on unfunded commitments or attrition of non-FDIC-insured and other deposits.\"", "Reworded sentence: \"The GSEs could limit their purchases of conforming loans due to capital constraints or other changes in their eligibility criteria for conforming loans, such as maximum loan amounts or borrower eligibility.\"", "Reworded sentence: \"Credit ratings may also be influenced by other factors, some of which are outside the Company’s control, such as recent and anticipated economic trends, geopolitical risk, legislative and regulatory developments, perceptions of the banking industry and U.S.\"" ], "current_body": "•Our inability to retain and grow deposits or a change in deposit costs or mix could negatively impact our funding strategy and financial results. •Truist’s liquidity could be impaired by an inability to access short-term funding, an unforeseen outflow of cash, or an inability to monetize liquid assets. •A disruption in our access to the mortgage secondary market and GSEs for liquidity could negatively affect us. •The Company’s cost of funding or access to the banking and capital markets could be adversely affected if our credit ratings are downgraded or otherwise fail to meet investor expectations. •The Parent Company relies on dividends from Truist Bank for its liquidity needs, the payment of which is limited by statutes and regulations, and the Parent Company could have less access to funding sources and its liquidity could be constrained if Truist Bank becomes unable to pay dividends. •The financial system is highly interrelated, and financial or systemic shocks or the failure of even a single financial institution or other participant in the financial system could adversely impact us.", "prior_body": "•Our inability to retain and grow deposits or a change in deposit costs or mix could negatively impact our funding strategy and financial results. •Truist’s liquidity could be impaired by an inability to access short-term funding, an unforeseen outflow of cash, or an inability to monetize liquid assets. •A disruption in our access to the mortgage secondary market and GSEs for liquidity could negatively affect us. •The Company’s cost of funding or access to the banking and capital markets could be adversely affected if our credit ratings are downgraded or otherwise fail to meet investor expectations. •The Parent Company could have less access to funding sources and its liquidity could be constrained if the Bank becomes unable to pay dividends. •The financial system is highly interrelated, and financial or systemic shocks or the failure of even a single financial institution or other participant in the financial system could adversely impact us." }, { "status": "MODIFIED", "current_title": "Strategic Risks", "prior_title": "Strategic Risks", "similarity_score": 0.892, "confidence": "high", "key_changes": [ "Reworded sentence: \"Ineffective execution of strategic initiatives could adversely affect investor sentiment and the Company’s business, financial condition, results of operations, prospects, and reputation.\"", "Reworded sentence: \"In addition, the execution of our strategies may be impacted by our response to external factors, including geopolitical, macroeconomic, social, cultural, competitive, and regulatory factors.\"", "Reworded sentence: \"36 Truist Financial Corporation 36 Truist Financial Corporation 36 Truist Financial Corporation 36 Truist Financial Corporation 36 Truist Financial Corporation 36 Truist Financial Corporation Truist also competes with nonbank companies and, in some cases, with companies other than those traditionally considered financial sector participants.\"", "Reworded sentence: \"The adoption of new technologies by competitors, including internet banking services, mobile applications, advanced ATM functionality, digital assets, tokenization, stablecoins and cryptocurrencies, and similar products, services, and technologies that enable financial services and transactions without or with less intermediation by commercial banks, is likely to require the Company to make substantial investments to modify or adapt the Company’s existing products and services or even radically alter the way Truist conducts business.\"", "Reworded sentence: \"If we are unable to successfully adopt and implement new technologies in a way that meets customer and industry demand, we may lose market share or deposits, including as a result of financial disintermediation.\"" ], "current_body": "•Ineffective execution of strategic initiatives could adversely affect investor sentiment and the Company’s business, financial condition, results of operations, prospects, and reputation. •Competition may reduce Truist’s client base or cause Truist to modify the pricing or other terms for products and services, or require significant investments to maintain competitiveness, which could have an adverse impact on our business and financial results. •Acquisitions, mergers, and divestitures introduce a broad range of anticipated and unanticipated risks, including unforeseen or negative consequences from supervisory or regulatory action that may limit Truist’s ability to pursue and complete them, which may impair the Company’s ability to expand or grow its client base, or execute on its strategic initiatives and compete effectively. •Truist has businesses other than banking that are subject to a variety of risks that may affect our financial condition and results of operations.", "prior_body": "•Ineffective execution of strategic initiatives could adversely affect investor sentiment and our business and financial results. •Competition may reduce Truist’s client base or cause Truist to modify the pricing or other terms for products and services, which could have an adverse impact on our business and financial results. •Acquisitions, mergers, and divestitures introduce a broad range of anticipated and unanticipated risks, including unforeseen or negative consequences from supervisory or regulatory action that may limit Truist’s ability to pursue and complete them. •Truist has businesses other than banking that are subject to a variety of risks." }, { "status": "MODIFIED", "current_title": "Credit Risks", "prior_title": "Credit Risks", "similarity_score": 0.878, "confidence": "high", "key_changes": [ "Reworded sentence: \"Truist incurs credit risk, which is the risk to current or anticipated earnings or capital arising when a borrower, obligor, issuer, or counterparty has a decline in creditworthiness or does not meet its financial obligations to us.\"", "Added sentence: \"The Company may have higher credit risk, or experience higher credit losses, to the extent its loan exposures increase or are concentrated by loan type, industry segment, borrower type, or location of the borrower or collateral, including with respect to any increase in its nonbank financial institution lending activities.\"", "Reworded sentence: \"Credit losses may exceed the amount of the Company’s reserves due to changing economic conditions, falling collateral values, falling commodity prices, higher unemployment, losses on a client or sector where Truist has an outsized exposure, or other factors such as changes in borrower behavior or borrower composition.\"", "Reworded sentence: \"Truist Financial Corporation 23 Truist Financial Corporation 23 Truist Financial Corporation 23 Truist Financial Corporation 23 Truist Financial Corporation 23 Truist Financial Corporation 23 The Company could have more credit risk and higher credit losses if our underwriting standards and practices are inadequate, we adopt more liberal underwriting standards for competitive or other reasons, information provided to us by clients and counterparties is inaccurate, or our concentration and other risk limits are not well-calibrated.\"", "Added sentence: \"Additionally, in deciding whether to extend credit or enter into other transactions with clients and counterparties, the Company relies on the completeness and accuracy of representations made by and information furnished by or on behalf of clients and counterparties, including financial statements and other financial information.\"" ], "current_body": "•The Company is subject to credit risk, and the Company’s allowance for credit losses may not be adequate to cover realized and future losses. •The Company could have more credit risk and higher credit losses if our underwriting standards and practices are inadequate, we adopt more liberal underwriting standards for competitive or other reasons, information provided to us by clients and counterparties is inaccurate, or our concentration and other risk limits are not well-calibrated. •The Company may suffer losses if the value of collateral declines in weak, deteriorating, or stressed economic or market conditions.", "prior_body": "•The Company is subject to credit risk, and the Company’s allowance for credit losses may not be adequate to cover realized and future losses. •The Company could have more credit risk and higher credit losses if our underwriting standards and practices are inadequate, we adopt more liberal underwriting standards for competitive or other reasons, or our concentration and other risk limits are not well calibrated. •The Company may suffer losses if the value of collateral declines in weak, deteriorating, or stressed economic or market conditions." }, { "status": "MODIFIED", "current_title": "Technology and Data Risks", "prior_title": "Technology Risks", "similarity_score": 0.868, "confidence": "high", "key_changes": [ "Reworded sentence: \"The Company’s applications, operating systems, and infrastructure, as well as operational capabilities managed or supplied by third parties on whom we rely, could fail or be interrupted, which could adversely impact the Company’s business, operations, financial condition, prospects, and reputation and cause significant legal and financial exposure.\"", "Reworded sentence: \"The Company’s ability to conduct its business and operations may be adversely affected by these kinds of disruptions to third parties whom the Company interacts with or relies upon.\"", "Reworded sentence: \"The Company and its clients, suppliers, service providers, and other third parties face a wide array of cybersecurity risks, which could result in the loss, alteration, or disclosure of confidential, proprietary, personal, and other sensitive information; adversely impact the Company’s business, operations, financial condition, results of operations, prospects, and reputation; and cause significant legal and financial exposure.\"", "Reworded sentence: \"28 Truist Financial Corporation 28 Truist Financial Corporation 28 Truist Financial Corporation 28 Truist Financial Corporation 28 Truist Financial Corporation 28 Truist Financial Corporation A successful penetration or circumvention of the security for our applications, operating systems, or infrastructure or those of third parties could cause serious negative consequences, including loss of clients and business opportunities; costs associated with maintaining client and business relationships after a cyber-attack or security breach; a loss of investor confidence; significant disruption to the Company’s operations and business; misappropriation, exposure, or destruction of the Company’s confidential, proprietary, and other sensitive information, including personal information, and the funds of the Company and its clients; damage to the Company’s or third-parties’ computers, systems, or networks; and a violation of applicable statutes and regulations, including those related to data privacy, data protection, and cybersecurity.\"", "Reworded sentence: \"The Company faces risks associated with the privacy, quality, availability, and retention of key data for operational, strategic, regulatory, and compliance purposes.\"" ], "current_body": "•The Company’s applications, operating systems, and infrastructure, as well as operational capabilities managed or supplied by third parties on whom we rely, could fail or be interrupted, which could adversely impact the Company’s business, operations, financial condition, prospects, and reputation and cause significant legal and financial exposure. •Truist is heavily reliant on technology, and a failure to effectively anticipate, develop, and implement new or enhanced technology could negatively impact our financial results, business, operations, security, or ability to compete effectively. •The Company and its clients, suppliers, service providers, and other third parties face a wide array of cybersecurity risks, which could result in the loss, alteration, or disclosure of confidential, proprietary, personal, and other sensitive information; adversely impact the Company’s business, operations, financial condition, results of operations, prospects, and reputation; and cause significant legal and financial exposure. •The Company faces risks associated with the privacy, quality, availability, and retention of key data for operational, strategic, regulatory, and compliance purposes. •Truist faces substantial risks in safeguarding personal and other sensitive information, which may negatively impact the Company’s business, financial condition, results of operations, prospects, or reputation. •The use of AI in our products and services, as well as our business and the industry more broadly, may negatively impact our business, operations, financial condition, results of operations, prospects, and reputation. Truist Financial Corporation 19 Truist Financial Corporation 19 Truist Financial Corporation 19 Truist Financial Corporation 19 Truist Financial Corporation 19 Truist Financial Corporation 19", "prior_body": "•The Company’s operating systems and infrastructure, as well as operational capabilities managed or supplied by third parties on whom we rely, could fail or be interrupted, which could disrupt the Company’s business and adversely impact the Company’s operations, financial condition, prospects, and reputation, and cause significant legal and financial exposure. •Truist is heavily reliant on technology, and a failure to effectively anticipate, develop, and implement new technology could negatively impact our financial results, business, operations, or security. •The Company faces risks associated with the quality, availability, and retention of key data for operational, strategic, regulatory, and compliance purposes. •The Company and its suppliers and service providers face a wide array of cybersecurity risks, which could result in the loss, alteration, or disclosure of confidential, proprietary, personal, and other sensitive information; adversely impact the Company’s operations, financial condition, prospects, and reputation; and cause significant legal and financial exposure." }, { "status": "MODIFIED", "current_title": "Strategic Risks", "prior_title": "Strategic Risks", "similarity_score": 0.835, "confidence": "high", "key_changes": [ "Reworded sentence: \"•Ineffective execution of strategic initiatives could adversely affect investor sentiment and the Company’s business, financial condition, results of operations, prospects, and reputation.\"" ], "current_body": "•Ineffective execution of strategic initiatives could adversely affect investor sentiment and the Company’s business, financial condition, results of operations, prospects, and reputation. •Competition may reduce Truist’s client base or cause Truist to modify the pricing or other terms for products and services, or require significant investments to maintain competitiveness, which could have an adverse impact on our business and financial results. •Acquisitions, mergers, and divestitures introduce a broad range of anticipated and unanticipated risks, including unforeseen or negative consequences from supervisory or regulatory action that may limit Truist’s ability to pursue and complete them, which may impair the Company’s ability to expand or grow its client base, or execute on its strategic initiatives and compete effectively. •Truist has businesses other than banking that are subject to a variety of risks that may affect our financial condition and results of operations.", "prior_body": "•Ineffective execution of strategic initiatives could adversely affect investor sentiment and our business and financial results. •Competition may reduce Truist’s client base or cause Truist to modify the pricing or other terms for products and services, which could have an adverse impact on our business and financial results. •Acquisitions, mergers, and divestitures introduce a broad range of anticipated and unanticipated risks, including unforeseen or negative consequences from supervisory or regulatory action that may limit Truist’s ability to pursue and complete them. •Truist has businesses other than banking that are subject to a variety of risks." }, { "status": "MODIFIED", "current_title": "Market Risks", "prior_title": "Market Risks", "similarity_score": 0.834, "confidence": "high", "key_changes": [ "Removed sentence: \"•The levels of or changes in interest rates could adversely affect our results of operations and financial condition.\"", "Removed sentence: \"•The Company’s hedging strategies may not be successful in mitigating our interest rate, foreign exchange, and market risks, which could adversely affect our financial results.\"", "Reworded sentence: \"•Our financial results, the value of loans and debt securities we hold, and lending and other business activities have in the past, and may in the future, be adversely affected by weak or deteriorating economic conditions.\"", "Added sentence: \"•Changes in interest rates have affected our net interest income and other financial results in the past and could in the future adversely affect us.\"", "Added sentence: \"•The Company’s hedging strategies may not be successful in mitigating our interest rate, foreign exchange, and market risks, which could adversely affect our results of operations and financial condition.\"" ], "current_body": "•Changes in monetary, fiscal, and other policies, and changes in the U.S. political environment, could adversely affect us. •Our financial results, the value of loans and debt securities we hold, and lending and other business activities have in the past, and may in the future, be adversely affected by weak or deteriorating economic conditions. •Geopolitical conditions, the outbreak or escalation of hostilities, acts or threats of terrorism, and related volatility and instability in global economic and market conditions could adversely affect us. •Changes in interest rates have affected our net interest income and other financial results in the past and could in the future adversely affect us. •The Company’s hedging strategies may not be successful in mitigating our interest rate, foreign exchange, and market risks, which could adversely affect our results of operations and financial condition.", "prior_body": "•The levels of or changes in interest rates could adversely affect our results of operations and financial condition. •The Company’s hedging strategies may not be successful in mitigating our interest rate, foreign exchange, and market risks, which could adversely affect our financial results. •Changes in monetary, fiscal, and other policies, and changes in the U.S. political environment, could adversely affect us. •Financial results, lending, and other business activities could be adversely affected by weak or deteriorating economic conditions. •Geopolitical conditions, the outbreak or escalation of hostilities, acts or threats of terrorism, and related volatility and instability in global economic and market conditions could adversely affect us." }, { "status": "MODIFIED", "current_title": "Risks Related to Estimates and Assumptions", "prior_title": "Risks Related to Estimates and Assumptions", "similarity_score": 0.828, "confidence": "high", "key_changes": [ "Reworded sentence: \"•Truist’s business and operations rely significantly on the use of models, and any deficiencies in the design, implementation, or use of models could adversely affect our business, results of operations, and financial condition.\"" ], "current_body": "•Truist’s business and operations rely significantly on the use of models, and any deficiencies in the design, implementation, or use of models could adversely affect our business, results of operations, and financial condition. •Truist employs estimates and assumptions to determine the value or amount of many of our assets and liabilities, and if these estimates or assumptions prove inaccurate, our business, financial condition, results of operations, and prospects could be adversely affected. •Depressed market values for the Company’s stock and adverse economic conditions sustained over a period of time may require the Company to write down all or some portion of the Company’s goodwill.", "prior_body": "•Our business and operations make extensive use of models, and we could be adversely affected if our design, implementation, or use of models is flawed. •We use estimates and assumptions in determining the value or amount of many of our assets and liabilities, and our business, financial condition, results of operations, and prospects could be adversely affected if these prove to be incorrect. •Depressed market values for the Company’s stock and adverse economic conditions sustained over a period of time may require the Company to write down all or some portion of the Company’s goodwill." }, { "status": "MODIFIED", "current_title": "Compliance, Regulatory, and Legal Risks", "prior_title": "Compliance Risks", "similarity_score": 0.795, "confidence": "high", "key_changes": [ "Reworded sentence: \"Truist is subject to supervision, regulation, and examination by the FRB, the FDIC, the NCCOB, the SEC, the CFTC, the CFPB, FINRA, the MSRB, the NFA, and various other federal and state regulatory agencies.\"", "Reworded sentence: \"In addition to banking statutes and regulations, Truist is subject to various other laws that directly or indirectly affect its business and operations, including the products and services it may offer and the manner in which it may offer them and its ability to make distributions to shareholders.\"", "Reworded sentence: \"Statutes and regulations that are applicable to us, and Truist’s inability to act in certain instances without receiving prior regulatory approval, affect Truist’s lending and deposit practices, capital structure, investment practices, dividend policy, ability to repurchase common stock, ability to pursue strategic acquisitions, and other activities.\"", "Removed sentence: \"Any potential new regulations or modifications to existing regulations would likely necessitate changes to Truist’s existing regulatory compliance and risk management infrastructure and could result in increased compliance costs.\"", "Reworded sentence: \"No assurance can be given that applicable laws and policies will not be amended or construed differently, that new laws and policies will not be adopted, or that any of these laws and policies will not be enforced more aggressively, including as a result of changes to control of branches of the U.S.\"" ], "current_body": "•Truist is subject to extensive and evolving government regulation and supervision, which could adversely affect our business, financial condition, results of operations, and prospects. •The Company may incur damages, fines, and penalties and face other negative consequences from supervisory actions and regulatory or other legal violations, including inadvertent or unintentional violations. •Pending or threatened legal proceedings and other matters may adversely affect the Company’s business, financial condition, results of operations, prospects, and reputation. •Regulatory capital and liquidity standards applicable to large banking organizations and future revisions to existing standards may negatively impact our business, financial results, financial condition, growth, profitability, or our ability to return capital to shareholders. •Differences in, or changes to, regulation and supervision and industry disruption can affect the Company’s ability to compete effectively, which may adversely affect our business, financial condition, financial results, or growth. •Truist faces risks of non-compliance and may incur additional operational and compliance costs under laws relating to anti-money laundering, economic sanctions, embargo programs, anti-bribery, and anti-corruption.", "prior_body": "•Truist is subject to extensive and evolving government regulation and supervision, which could adversely affect our business, financial condition, results of operations, and prospects. •Regulatory capital and liquidity standards and future revisions to them may negatively impact our business and financial results. •Truist is subject to risks related to originating and selling loans, including repurchase and indemnification obligations. •Truist faces risks as a servicer of loans. •Truist faces substantial risks in safeguarding personal and other sensitive information. •Differences in regulation and supervision can affect the Company’s ability to compete effectively." }, { "status": "MODIFIED", "current_title": "Additional Risks", "prior_title": "Other External Risks", "similarity_score": 0.764, "confidence": "high", "key_changes": [ "Reworded sentence: \"Negative public opinion, whether or not warranted, could damage the Company’s brand in the market and relationships with stakeholders, and adversely impact our business, financial condition, results of operations, and prospects.\"", "Reworded sentence: \"Transition risks, including changes in consumer preferences, longer-term shifts in market dynamics, changes in or additional regulatory requirements or taxes, and additional counterparty or client requirements, could have an adverse impact on asset values and the financial performance of Truist’s businesses, and those of its clients, and could be exacerbated in specific industries that may be more sensitive or vulnerable to a transition to a lower-carbon economy.\"", "Reworded sentence: \"While material impact from climate change is expected to occur over a longer time horizon, the acceleration of a transition to a lower-carbon economy could present idiosyncratic risks for individual companies.\"", "Reworded sentence: \"Additionally, the Company faces potential brand and stakeholder risks as a result of its practices related to climate change, including as a result of the Company’s direct or indirect involvement, or lack of involvement, in certain industries, in particular those involved in fossil fuels, as well as any decisions management makes in response to managing climate risk, especially as views on climate-related matters become subject to increased polarization.\"", "Reworded sentence: \"Truist may incur additional costs and require additional resources as it evolves its strategy, practices, and related disclosures with respect to these matters.\"" ], "current_body": "•Negative public opinion, whether or not warranted, could damage the Company’s brand in the market and relationships with stakeholders, and adversely impact our business, financial condition, results of operations, and prospects. •We could be harmed by an inability to attract, develop, retain, and motivate qualified teammates while effectively managing recruiting and compensation costs amid highly competitive and rapidly changing market conditions. •The Company relies on its ability, and the ability of key external parties, to maintain appropriately staffed workforces and on the competence, trustworthiness, health, and safety of teammates. •The Company is at risk of losses from fraud which could result in financial loss and reputational harm. •Physical, transition, and other risks associated with climate change, together with governmental responses to such risks, may negatively impact our business, financial condition, operations, reputation, and clients. •Natural disasters, pandemics, extreme weather events, and other catastrophic events could adversely affect our financial condition and results of operations. 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation", "prior_body": "•Physical, transition, and other risks associated with climate change, together with governmental responses to them, may negatively impact our business, operations, reputation, and clients. •The Company is at risk of increased losses from fraud. •Natural disasters, pandemics, and other catastrophic events could adversely impact us. 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation" }, { "status": "MODIFIED", "current_title": "Additional Risks", "prior_title": "Other External Risks", "similarity_score": 0.678, "confidence": "medium", "key_changes": [ "Reworded sentence: \"•Negative public opinion, whether or not warranted, could damage the Company’s brand in the market and relationships with stakeholders, and adversely impact our business, financial condition, results of operations, and prospects.\"" ], "current_body": "•Negative public opinion, whether or not warranted, could damage the Company’s brand in the market and relationships with stakeholders, and adversely impact our business, financial condition, results of operations, and prospects. •We could be harmed by an inability to attract, develop, retain, and motivate qualified teammates while effectively managing recruiting and compensation costs amid highly competitive and rapidly changing market conditions. •The Company relies on its ability, and the ability of key external parties, to maintain appropriately staffed workforces and on the competence, trustworthiness, health, and safety of teammates. •The Company is at risk of losses from fraud which could result in financial loss and reputational harm. •Physical, transition, and other risks associated with climate change, together with governmental responses to such risks, may negatively impact our business, financial condition, operations, reputation, and clients. •Natural disasters, pandemics, extreme weather events, and other catastrophic events could adversely affect our financial condition and results of operations. 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation", "prior_body": "•Physical, transition, and other risks associated with climate change, together with governmental responses to them, may negatively impact our business, operations, reputation, and clients. •The Company is at risk of increased losses from fraud. •Natural disasters, pandemics, and other catastrophic events could adversely impact us. 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation 20 Truist Financial Corporation" }, { "status": "MODIFIED", "current_title": "Operational Risks", "prior_title": "Operational Risks", "similarity_score": 0.667, "confidence": "medium", "key_changes": [ "Reworded sentence: \"Truist relies on third parties to support key components of the Company’s business and operational infrastructure, and their failure to perform to our standards or our failure to appropriately assess and manage these relationships could adversely affect us.\"", "Reworded sentence: \"Our use of third-party service providers exposes us to the risk that such third parties may not comply with their contractual obligations to us and to the risk that we may not satisfy applicable regulatory responsibilities regarding the management and oversight of third parties.\"", "Reworded sentence: \"In addition, a failure to appropriately assess and manage our relationships with third parties, especially those supporting significant banking functions, shared services, or other critical activities, could adversely affect Truist by resulting in potential harm to clients and any liability associated with that harm; supervisory actions, regulatory fines, penalties, or other sanctions; lower revenues and the opportunity cost from lost revenues; increased operational costs; or harm to Truist’s reputation.\"", "Reworded sentence: \"Moreover, as the risks we face continue to evolve, despite our ongoing efforts to improve the design and implementation of our risk framework, those efforts may not be adequate or effective.\"" ], "current_body": "•Truist relies on third parties to support key components of the Company’s business and operational infrastructure, and their failure to perform to our standards or our failure to appropriately assess and manage these relationships could adversely affect us. •The Company’s risk and control framework may fail to identify, assess, monitor, and mitigate the risks we face and cause us to suffer unexpected losses that could adversely affect our business, financial condition, results of operations, prospects, and reputation. •Truist can be negatively affected if it fails to identify and address operational and compliance risks associated with the introduction of or changes to products, services, and delivery platforms. •Truist is subject to risks related to originating and selling loans, including repurchase and indemnification obligations, which may adversely affect our business, results of operations, and financial condition. •Truist faces loan servicing risks that could adversely impact the Company’s business, operations, liquidity, and results of operations.", "prior_body": "•Truist relies extensively on third parties to provide key components of the Company’s business infrastructure, and their failure to perform to our standards or our failure to appropriately assess and manage these relationships could adversely affect us. •The Company’s risk management framework may fail to identify and manage the risks that we face. •In deciding whether to extend credit or enter into other transactions with clients and counterparties, Truist depends on the accuracy and completeness of information about clients and counterparties, and Truist could be negatively impacted if the information is not accurate or complete. •Truist can be negatively affected if it fails to identify and address operational risks associated with the introduction of or changes to products, services, and delivery platforms. Truist Financial Corporation 21 Truist Financial Corporation 21 Truist Financial Corporation 21 Truist Financial Corporation 21 Truist Financial Corporation 21 Truist Financial Corporation 21" }, { "status": "MODIFIED", "current_title": "Technology and Data Risks", "prior_title": "Technology Risks", "similarity_score": 0.666, "confidence": "medium", "key_changes": [ "Reworded sentence: \"•The Company’s applications, operating systems, and infrastructure, as well as operational capabilities managed or supplied by third parties on whom we rely, could fail or be interrupted, which could adversely impact the Company’s business, operations, financial condition, prospects, and reputation and cause significant legal and financial exposure.\"" ], "current_body": "•The Company’s applications, operating systems, and infrastructure, as well as operational capabilities managed or supplied by third parties on whom we rely, could fail or be interrupted, which could adversely impact the Company’s business, operations, financial condition, prospects, and reputation and cause significant legal and financial exposure. •Truist is heavily reliant on technology, and a failure to effectively anticipate, develop, and implement new or enhanced technology could negatively impact our financial results, business, operations, security, or ability to compete effectively. •The Company and its clients, suppliers, service providers, and other third parties face a wide array of cybersecurity risks, which could result in the loss, alteration, or disclosure of confidential, proprietary, personal, and other sensitive information; adversely impact the Company’s business, operations, financial condition, results of operations, prospects, and reputation; and cause significant legal and financial exposure. •The Company faces risks associated with the privacy, quality, availability, and retention of key data for operational, strategic, regulatory, and compliance purposes. •Truist faces substantial risks in safeguarding personal and other sensitive information, which may negatively impact the Company’s business, financial condition, results of operations, prospects, or reputation. •The use of AI in our products and services, as well as our business and the industry more broadly, may negatively impact our business, operations, financial condition, results of operations, prospects, and reputation. Truist Financial Corporation 19 Truist Financial Corporation 19 Truist Financial Corporation 19 Truist Financial Corporation 19 Truist Financial Corporation 19 Truist Financial Corporation 19", "prior_body": "•The Company’s operating systems and infrastructure, as well as operational capabilities managed or supplied by third parties on whom we rely, could fail or be interrupted, which could disrupt the Company’s business and adversely impact the Company’s operations, financial condition, prospects, and reputation, and cause significant legal and financial exposure. •Truist is heavily reliant on technology, and a failure to effectively anticipate, develop, and implement new technology could negatively impact our financial results, business, operations, or security. •The Company faces risks associated with the quality, availability, and retention of key data for operational, strategic, regulatory, and compliance purposes. •The Company and its suppliers and service providers face a wide array of cybersecurity risks, which could result in the loss, alteration, or disclosure of confidential, proprietary, personal, and other sensitive information; adversely impact the Company’s operations, financial condition, prospects, and reputation; and cause significant legal and financial exposure." }, { "status": "MODIFIED", "current_title": "Risk Factors", "prior_title": "Risk Factors", "similarity_score": 0.647, "confidence": "medium", "key_changes": [ "Reworded sentence: \"The following discussion sets forth material risk factors that could affect Truist’s financial condition, results of operations, business, or prospects.\"" ], "current_body": "The following discussion sets forth material risk factors that could affect Truist’s financial condition, results of operations, business, or prospects. When a risk factor spans more than one risk category, the risk factor has been listed by its primary risk category. Any of the risk factors discussed below, either by itself or together with other risk factors, could materially and adversely affect Truist’s financial condition, results of operations, business, prospects, or reputation. These risk factors do not identify all risks that we face; additional risks that are not presently known to us or risks that we currently deem immaterial may have an adverse effect on Truist’s financial condition, results of operations, business, prospects, or reputation.", "prior_body": "The following discussion sets forth some of the more important risk factors that could materially affect Truist’s financial condition and operations. When a risk factor spans several risk categories, the risks have been listed by their primary risk category. The risks described are not all inclusive. Additional risks that are not presently known or risks deemed immaterial may have an adverse effect on Truist’s financial condition, results of operations, business, and prospects." }, { "status": "MODIFIED", "current_title": "Compliance, Regulatory, and Legal Risks", "prior_title": "Regulatory and Legal Risks", "similarity_score": 0.571, "confidence": "low", "key_changes": [ "Reworded sentence: \"•Truist is subject to extensive and evolving government regulation and supervision, which could adversely affect our business, financial condition, results of operations, and prospects.\"" ], "current_body": "•Truist is subject to extensive and evolving government regulation and supervision, which could adversely affect our business, financial condition, results of operations, and prospects. •The Company may incur damages, fines, and penalties and face other negative consequences from supervisory actions and regulatory or other legal violations, including inadvertent or unintentional violations. •Pending or threatened legal proceedings and other matters may adversely affect the Company’s business, financial condition, results of operations, prospects, and reputation. •Regulatory capital and liquidity standards applicable to large banking organizations and future revisions to existing standards may negatively impact our business, financial results, financial condition, growth, profitability, or our ability to return capital to shareholders. •Differences in, or changes to, regulation and supervision and industry disruption can affect the Company’s ability to compete effectively, which may adversely affect our business, financial condition, financial results, or growth. •Truist faces risks of non-compliance and may incur additional operational and compliance costs under laws relating to anti-money laundering, economic sanctions, embargo programs, anti-bribery, and anti-corruption.", "prior_body": "•The Company may incur damages, fines, penalties, and other negative consequences from past, current, or future supervisory actions and regulatory or other legal violations, including inadvertent or unintentional violations. •Pending or threatened legal proceedings and other matters may adversely affect the Company’s business, financial condition, results of operations, and reputation." }, { "status": "MODIFIED", "current_title": "Operational Risks", "prior_title": "Operational Risks", "similarity_score": 0.468, "confidence": "low", "key_changes": [ "Reworded sentence: \"•Truist relies on third parties to support key components of the Company’s business and operational infrastructure, and their failure to perform to our standards or our failure to appropriately assess and manage these relationships could adversely affect us.\"" ], "current_body": "•Truist relies on third parties to support key components of the Company’s business and operational infrastructure, and their failure to perform to our standards or our failure to appropriately assess and manage these relationships could adversely affect us. •The Company’s risk and control framework may fail to identify, assess, monitor, and mitigate the risks we face and cause us to suffer unexpected losses that could adversely affect our business, financial condition, results of operations, prospects, and reputation. •Truist can be negatively affected if it fails to identify and address operational and compliance risks associated with the introduction of or changes to products, services, and delivery platforms. •Truist is subject to risks related to originating and selling loans, including repurchase and indemnification obligations, which may adversely affect our business, results of operations, and financial condition. •Truist faces loan servicing risks that could adversely impact the Company’s business, operations, liquidity, and results of operations.", "prior_body": "•Truist relies extensively on third parties to provide key components of the Company’s business infrastructure, and their failure to perform to our standards or our failure to appropriately assess and manage these relationships could adversely affect us. •The Company’s risk management framework may fail to identify and manage the risks that we face. •In deciding whether to extend credit or enter into other transactions with clients and counterparties, Truist depends on the accuracy and completeness of information about clients and counterparties, and Truist could be negatively impacted if the information is not accurate or complete. •Truist can be negatively affected if it fails to identify and address operational risks associated with the introduction of or changes to products, services, and delivery platforms. Truist Financial Corporation 21 Truist Financial Corporation 21 Truist Financial Corporation 21 Truist Financial Corporation 21 Truist Financial Corporation 21 Truist Financial Corporation 21" }, { "status": "UNCHANGED", "current_title": "Risks Related to Estimates and Assumptions", "prior_title": "Risks Related to Estimates and Assumptions", "current_body": "•Truist’s business and operations rely significantly on the use of models, and any deficiencies in the design, implementation, or use of models could adversely affect our business, results of operations, and financial condition. •Truist employs estimates and assumptions to determine the value or amount of many of our assets and liabilities, and if these estimates or assumptions prove inaccurate, our business, financial condition, results of operations, and prospects could be adversely affected. •Depressed market values for the Company’s stock and adverse economic conditions sustained over a period of time may require the Company to write down all or some portion of the Company’s goodwill." }, { "status": "UNCHANGED", "current_title": "Credit Risks", "prior_title": "Credit Risks", "current_body": "•The Company is subject to credit risk, and the Company’s allowance for credit losses may not be adequate to cover realized and future losses. •The Company could have more credit risk and higher credit losses if our underwriting standards and practices are inadequate, we adopt more liberal underwriting standards for competitive or other reasons, information provided to us by clients and counterparties is inaccurate, or our concentration and other risk limits are not well-calibrated. •The Company may suffer losses if the value of collateral declines in weak, deteriorating, or stressed economic or market conditions." }, { "status": "UNCHANGED", "current_title": "Liquidity Risks", "prior_title": "Liquidity Risks", "current_body": "•Our inability to retain and grow deposits or a change in deposit costs or mix could negatively impact our funding strategy and financial results. •Truist’s liquidity could be impaired by an inability to access short-term funding, an unforeseen outflow of cash, or an inability to monetize liquid assets. •A disruption in our access to the mortgage secondary market and GSEs for liquidity could negatively affect us. •The Company’s cost of funding or access to the banking and capital markets could be adversely affected if our credit ratings are downgraded or otherwise fail to meet investor expectations. •The Parent Company relies on dividends from Truist Bank for its liquidity needs, the payment of which is limited by statutes and regulations, and the Parent Company could have less access to funding sources and its liquidity could be constrained if Truist Bank becomes unable to pay dividends. •The financial system is highly interrelated, and financial or systemic shocks or the failure of even a single financial institution or other participant in the financial system could adversely impact us." }, { "status": "UNCHANGED", "current_title": "Market Risks", "prior_title": "Market Risks", "current_body": "•Changes in monetary, fiscal, and other policies, and changes in the U.S. political environment, could adversely affect us. •Our financial results, the value of loans and debt securities we hold, and lending and other business activities have in the past, and may in the future, be adversely affected by weak or deteriorating economic conditions. •Geopolitical conditions, the outbreak or escalation of hostilities, acts or threats of terrorism, and related volatility and instability in global economic and market conditions could adversely affect us. •Changes in interest rates have affected our net interest income and other financial results in the past and could in the future adversely affect us. •The Company’s hedging strategies may not be successful in mitigating our interest rate, foreign exchange, and market risks, which could adversely affect our results of operations and financial condition." } ] }