TFCTruist Financial

Truist has elected to be treated as an FHC, which permits us to engage in a number of financial and related activities beyond banking, including securities, advisory, banking such as securities underwriting and merchant banking activities. Truist banking. FHCs and Truist Bank their IDI subsidiaries are subject to ongoing requirements for Truist to continue to qualify as an FHC. If a BHC an FHC or any of its insured depository institutions IDIs were found not to be well capitalized well-capitalized or well managed, managed as defined under by applicable law, the BHC can be restricted from engaging in FRB may impose corrective capital and managerial requirements on the broader range of financial FHC, which could impact resources and related activities permitted for FHCs, including limit amounts otherwise available to creditors and shareholders. In such a situation, the ability to acquire companies engaged in those activities, and can be required to discontinue these activities or even divest any of its insured depository institutions. In addition, if an insured-depository-institution subsidiary of a BHC were to fail to achieve a satisfactory or better rating under the CRA, FRB may also place limitations on the ability of the BHC FHC to expand 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, the 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 and related activities or acquire a company that engages in such activities, although the FHC would still be allowed to engage in activities closely related to banking and make acquisitions could be restricted. investments in the ordinary course of conducting banking activities.

Operational risk is the risk of loss associated with external events or inadequate or failed internal processes, people, systems, or from external events. systems. It includes legal risk, which is the risk of loss arising from defective transactions, litigation or claims made, litigation, claims, or the failure to adequately protect company-owned Company-owned assets. An operational loss occurs when an event results in a loss or reserve originating from operational risk. The Company executes business activities in diverse markets and relies on the ability of its teammates and systems to process a high number of transactions. Operational risk is inherent in all business activities, and the management of this risk is important to the achievement of the Company’s objectives. Business units and enterprise functions have primary responsibility and accountability for identifying, mitigating, and monitoring operational risks embedded in their business activities, including additional or increased risks created by economic and financial disruptions. Business continuity and disaster recovery planning are critical to effectively managing operational risks. Each business unit and enterprise function is required to develop, maintain, and test these plans at least annually to identify recovery activities that, if needed, can support mission critical functions, including technology, networks and data centers supporting client applications and business operations. While the Company strives to design processes to minimize operational risks, there is no absolute assurance that business disruptions or operational losses will not occur as a result of an external event or internal control breakdown. On an ongoing basis, management makes process changes and investments to enhance Truist’s systems of internal controls and business continuity and disaster recovery plans.

This class action case was filed in Fulton County State Court on July 12, 2010, and an amended complaint was filed on August 9, 2010. Plaintiff alleges that all overdraft fees charged to his account which related to debit card and ATM transactions are actually interest charges and therefore subject to the usury laws of Georgia. The amended complaint asserts claims for violations of civil and criminal usury laws, conversion, and money had and received, and seeks damages on a class-wide basis, including refunds of challenged overdraft fees and pre-judgment interest. On October 6, 2017, the trial court granted plaintiff’s motion for class certification and defined the class as “Every Georgia citizen who had or has one or more accounts with SunTrust Bank and who, from July 12, 2006, to October 6, 2017 (i) had at least one overdraft of $500.00 or less resulting from an ATM or debit card transaction (the “Transaction”); (ii) paid any Overdraft Fees as a result of the Transaction; and (iii) did not receive a refund of those Fees,” and the granting of a certified class was affirmed on appeal. The class seeks sought a return of up to $ 452 million in paid overdraft fees from the 2006 to 2017 period above, plus prejudgment interest which, interest, which based on the this amount of claimed fees, was fees would have been estimated to be at approximately $ 431 463 million as of December 31, 2024. A court-ordered mediation was held on February 28, 2024, but no resolution was reached. On March 4, 2024, the trial court issued an order granting in part and denying in part Truist’s motions to amend the class definition to narrow the scope of the class, to compel arbitration against certain class members, and for summary judgment. Truist and the class separately appealed the trial court’s order to the Georgia Court of Appeals. On February 20, 2025, the Georgia Court of Appeals ruled on the appeals and affirmed in part and reversed in part the trial court’s March 4, 2024 order. Truist continues to assess the court’s rulings. 2025.

December 31, 2024 Standards Not Yet Adopted Improvements 2027 Expense Disaggregation Disclosures / Introduces new requirements to Income Tax Disclosures Improves the transparency disclose more detailed information about certain types of income tax disclosures by requiring (1) consistent categories and greater disaggregation of information expenses not already presented in separate expense captions in the rate reconciliation Consolidated Statements of Income, including employee compensation, depreciation, intangible asset amortization, and (2) income taxes paid disaggregated by jurisdiction. It also includes certain other amendments selling expenses. Banks that present a caption for salaries and benefits under SEC rules would be permitted to improve the effectiveness of income tax disclosures. retain their current definition. Permits either a prospective or retrospective transition approach. Truist is evaluating the impact of this standard on its disclosures. This standard relates to footnote disclosures only.