BNYBNY Mellon

We note that your non-GAAP reconciliations include presentation of a single adjustment to exclude the impact of notable items, which appears to be comprised of multiple individual components such as those described in footnote (a) to the table on page 105.

Rest of the question

In future filings, please revise your disclosure to disaggregate the notable items into separate adjustment lines and / or quantify each individual component within the reconciliation footnote for all periods presented.

In our future filings, we will disaggregate the impact of notable items in our presentation of non-GAAP reconciliations for all periods presented, beginning with our earnings release for the third quarter of 2023. Read in the reply ↗

We note the reference on page 53 to "multiple cyber and digital initiatives within the Company." We also note Risk Factor disclosure indicating potential risk exposures from the initiative announced in 2021 to develop a digital custody and administration platform designed to simultaneously support both traditional and digital assets, including cryptocurrencies.

Rest of the question

You state on page 97 that you have started to provide custody services for a limited number of cryptocurrencies for select U.S. institutional clients. We also note statement that the initiative is a "decades-long journey for blockchain and tokenization." Please revise Business or where appropriate in future filings to further clarify the nature and extent of the Digital Asset Custody platform and the status of the related initiative.

We will provide additional disclosure in our Annual Report on Form 10-K for the year ending December 31, 2023 to further clarify the nature and extent of BNY Mellon’s Digital Asset Custody Platform and related initiative. In particular, we will include in our Annual Report and incorporate by reference in Part I, Item 1 (Business) of the Form 10-K disclosure in substantially the form set forth below, though the actual language used may not be precisely the language set forth below as the disclosure will be based on the prevailing facts and circumstances, which are subject to change.

Our

Rest of the answer

Digital Asset Custody platform offers custody and administration services for Bitcoin and Ether for select U.S. institutional clients. Our Digital Assets Funds Services provides accounting and administration, transfer agency and ETF services to digital asset funds. We expect to continue developing our digital asset capabilities and to work closely with clients to address their evolving digital asset needs. As of and for the year ended Dec. 31, 2023, our Digital Asset Custody platform and related initiative had a de minimis impact on our assets, liabilities, revenues and expenses.

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On behalf of

BNY Mellon, I hereby acknowledge that:

•

BNY Mellon is responsible for the adequacy and accuracy of the disclosure in the filing;

Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

BNY Mellon may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Read in the reply ↗