Bank of America Corp: Form 10-Q for the period ended Mar 31, 2026

Bank of America Corporation (the Corporation) and its management may make certain statements that constitute “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. These statements can be identified by the fact that they do not relate strictly to historical or current facts. Forward-looking statements often use words such as “anticipates,” “targets,” “expects,” “hopes,” “estimates,” “intends,” “plans,” “goals,” “outlook,” “believes,” “continue” and other similar expressions or future or conditional verbs such as “will,” “may,” “might,” “should,” “would” and “could.” Forward-looking statements represent the Corporation’s current expectations, plans or forecasts of its or its business segments’ future results, which may include, among other measures, revenue, liquidity, net interest income, other income, provision for credit losses, expenses, operating leverage, effective tax rate, efficiency ratio, capital measures, deposits and assets, as well as strategy, future business and economic conditions more generally, and other future matters. These statements are not guarantees of future results or performance and involve certain known and unknown risks, uncertainties and assumptions that are difficult to predict and are often beyond the Corporation’s control. Actual outcomes and results may differ materially from those expressed in, or implied by, any of these forward-looking statements.

You should not place undue reliance on any forward-looking statement and should consider the following uncertainties and risks, as well as the risks and uncertainties more fully discussed under Item 1A. Risk Factors of the Corporation’s 2025 Annual Report on Form 10-K and in any of the Corporation’s subsequent U.S. Securities and Exchange Commission (SEC) filings: the Corporation’s potential judgments, orders, settlements, penalties, fines and reputational damage, which are inherently difficult to predict, resulting from pending, threatened or future litigation and regulatory inquiries, demands, requests, investigations, proceedings and enforcement actions, which the Corporation is subject to in the ordinary course of business, including matters related to our processing of unemployment benefits for California and certain other states, the features of our automatic credit card payment service, the adequacy of the Corporation’s anti-money laundering and economic sanctions programs and the processing of electronic payments, including through the Zelle network, and related fraud, which are in various stages; in connection with ongoing litigation, the impact of certain changes to Visa’s and Mastercard’s respective card payment network rules and reductions in interchange fees for U.S.-based merchants; the possibility that the Corporation’s future liabilities may be in excess of its recorded liability and estimated range of possible loss for litigation, and regulatory and government actions; the impact of U.S. and global interest rates (including the potential for ongoing fluctuations in interest rates), inflation, currency exchange rates, economic conditions, trade policies and tensions, including changes in, or the imposition of, tariffs and/or trade barriers and the economic impacts, volatility and uncertainty resulting therefrom, which may have varying effects across

industries and geographies, and geopolitical instability; uncertainties about the financial stability and growth rates of non-U.S. jurisdictions, the risk that those jurisdictions may face difficulties servicing their sovereign debt, and related stresses on financial markets, currencies and trade, and the Corporation’s exposures to such risks, including direct, indirect and operational; the impact of the interest rate, inflationary, macroeconomic, banking and regulatory environment on the Corporation’s assets, business, financial condition and results of operations; the impact of adverse developments affecting the U.S. or global banking industry, including a deterioration in private credit markets, bank failures and liquidity concerns, resulting in worsening economic and market volatility, and regulatory responses thereto; the possibility that future credit losses may be higher than currently expected, including due to changes in economic assumptions, which may include unemployment rates, real estate prices, gross domestic product levels and corporate bond spreads, customer behavior, adverse developments with respect to U.S. or global economic conditions and other uncertainties, such as the impact of trade policies, supply chain disruptions, commodity prices, inflationary pressures and labor shortages on economic conditions and our business; potential losses related to the Corporation's concentration of credit risk; the Corporation’s ability to achieve its expense targets (including noninterest expense) and expectations regarding revenue, net interest income, operating leverage, other income, provision for credit losses, net charge-offs, effective tax rate, loan or deposit growth or other projections and targets; variances to the underlying assumptions and judgments used in estimating banking book net interest income sensitivity; adverse changes to the Corporation’s credit ratings from the major credit rating agencies; an inability to access capital markets or maintain deposits or borrowing costs; estimates of the fair value and other accounting values, subject to impairment assessments, of certain of the Corporation’s assets and liabilities; the estimated or actual impact of changes in accounting standards or assumptions in applying those standards; uncertainty regarding the content, timing and impact of regulatory capital and liquidity requirements; the impact of adverse changes to total loss-absorbing capacity requirements, stress capital buffer requirements and/or global systemically important bank surcharges; the potential impact of actions of the Board of Governors of the Federal Reserve System on the Corporation’s capital plans; the effect of changes in or interpretations of income tax laws and regulations, including impacts from the 2025 Budget Reconciliation Act; the impact of implementation and compliance with U.S. and international laws, regulations and regulatory interpretations, including recovery and resolution planning requirements, Federal Deposit Insurance Corporation assessments, fiduciary standards, derivatives regulations and potential changes to loss allocations between financial institutions and customers, including for losses incurred from the use of our products and services, including electronic payments and payment of checks, that were authorized by the customer but induced by fraud; the impact of failures or disruptions in or breaches of the Corporation’s operations or information systems, or those of various third parties, including regulators and federal and state governments, such as from cybersecurity incidents; the risks related to the development, implementation, use and management of emerging technologies, including artificial intelligence and the ability to achieve potential benefits, such as increased productivity and cost savings; the risks related to the transition and physical impacts of climate change; our ability to achieve environmental goals or the impact of any changes in the Corporation’s sustainability or human capital management strategy or goals; the impact of uncertain or changing political conditions, federal government shutdowns, including partial shutdowns, and uncertainty regarding the federal government’s debt limit or changes in fiscal, monetary, trade or regulatory policy; the emergence of widespread health emergencies or pandemics; the impact of natural disasters, extreme weather events, military conflicts (including the Russia/Ukraine conflict, the conflicts in the Middle East, the possible expansion of such conflicts and potential geopolitical and economic consequences), civil unrest, terrorism or other geopolitical events; and other matters.

Forward-looking statements speak only as of the date they are made, and the Corporation undertakes no obligation to update any forward-looking statement to reflect the impact of circumstances or events that arise after the date the forward-looking statement was made.

Notes to the Consolidated Financial Statements referred to in Management’s Discussion and Analysis of Financial Condition and Results of Operations (MD&A) are incorporated by reference into the MD&A. Throughout the MD&A, the Corporation uses certain acronyms and abbreviations that are defined in the Glossary.

Executive Summary

Business Overview

The Corporation is a Delaware corporation, a bank holding company (BHC) and a financial holding company. When used in this report, “Bank of America,” “the Corporation,” “we,” “us” and “our” may refer to Bank of America Corporation individually, Bank of America Corporation and its subsidiaries, or certain of Bank of America Corporation’s subsidiaries or affiliates. Our principal executive offices are located in Charlotte, North Carolina. Through our various bank and nonbank subsidiaries throughout the U.S. and in international markets, we provide a diversified range of banking and nonbank financial services and products through four business segments: Consumer Banking, Global Wealth & Investment Management (GWIM), Global Banking and Global Markets, with the remaining operations recorded in All Other. We operate our banking activities primarily under the Bank of America, National Association (Bank of America, N.A. or BANA) charter. At March 31, 2026, the Corporation had $3.5 trillion in assets and a headcount of approximately 212,000 employees. As of March 31, 2026, we served clients through operations across the U.S., its territories and more than 35 countries and/or jurisdictions. Our retail banking footprint covers all major markets in the U.S., and we serve approximately 69 million consumer and small business clients with approximately 3,500 retail financial centers, approximately 15,000 automated teller machines (ATMs), and leading digital banking platforms (www.bankofamerica.com (http://www.bankofamerica.com)) with approximately 50 million active users, including approximately 42 million active mobile users. We offer industry-leading support to approximately four million small business households. Our GWIM businesses, with client balances of $4.6 trillion, provide tailored solutions to meet client needs through a full set of

investment management, brokerage, banking, trust and retirement products. We are a global leader in corporate and investment banking and trading across a broad range of asset classes serving corporations, governments, institutions and individuals around the world.

The Corporation’s website is www.bankofamerica.com (http://www.bankofamerica.com), and the Investor Relations portion of our website is https://investor.bankofamerica.com. We use our website to distribute company information, including as a means of disclosing material, non-public information and for complying with our disclosure obligations under Regulation FD. We routinely post and make accessible financial and other information regarding the Corporation on our website. Investors should monitor our website, including the Investor Relations portion, in addition to our press releases, SEC filings, public conference calls and webcasts. Notwithstanding the foregoing, the information contained on our website as referenced in this paragraph is not incorporated by reference into this Quarterly Report on Form 10-Q.

Recent Developments

Capital Management

On April 23, 2026, the Corporation’s Board of Directors (Board) declared a quarterly common stock dividend of $0.28 per share, payable on June 26, 2026 to shareholders of record as of June 5, 2026.

For more information on our capital resources, see Capital Management beginning on page 16.

Financial Highlights

Summary Income Statement and Selected Financial Data

(Dollars in millions, except per share information)

(1) For definitions, see Key Metrics on page 94.

(2) Return on average tangible common shareholders’ equity is a non-GAAP financial measure. For more information and a corresponding reconciliation to the most directly comparable financial measures defined by accounting principles generally accepted in the United States of America (GAAP), see Non-GAAP Reconciliations on page 43.

Net income was $8.6 billion, or $1.11 per diluted share, for the three months ended March 31, 2026 compared to $7.4 billion, or $0.89 per diluted share, for the same period in 2025. The increase in net income was due to higher net interest income and noninterest income, as well as lower provision for credit losses, partially offset by higher noninterest expense.

Total assets increased $84.4 billion from December 31, 2025 to $3.5 trillion primarily driven by higher securities borrowed or purchased under agreements to resell and higher derivative assets to support Global Markets client activity, higher loans and leases due to growth in commercial loans, and higher cash and cash equivalents due to deposit inflows, partially offset by lower debt securities due to sales and maturities.

Total liabilities increased $87.0 billion from December 31, 2025 to $3.2 trillion primarily driven by higher trading account liabilities, customer trade payables and securities loaned or sold under agreements to repurchase to support Global Markets client activity, higher deposits in Consumer Banking and Global Banking, as well as higher short-term borrowings and long-term debt issuances for liquidity positioning.

Shareholders’ equity decreased $2.6 billion from December 31, 2025 primarily due to returns of capital to shareholders through common stock repurchases and common and preferred stock dividends, as well as a preferred stock redemption and a decrease in accumulated other comprehensive income (OCI), partially offset by net income.

Net Interest Income

Net interest income increased $1.3 billion to $15.7 billion for the three months ended March 31, 2026 compared to the same period in 2025. Net interest yield on a fully taxable-equivalent (FTE) basis increased eight basis points (bps) to 2.07 percent for the three months ended March 31, 2026. The increases were primarily driven by higher net interest income related to Global Markets activity, deposit and loan growth, and fixed-asset repricing, partially offset by the impact of lower interest rates. For more information on net interest yield and FTE basis, see Supplemental Financial Data on page 5, and for more information on interest rate risk management, see Interest Rate Risk Management for the Banking Book on page 40.

Noninterest Income

(Dollars in millions)

Noninterest income increased $723 million to $14.5 billion for the three months ended March 31, 2026 compared to the same period in 2025. The following highlights the significant changes.

• Service charges increased $113 million primarily due to higher treasury service charges.
• Investment and brokerage services increased $728 million primarily driven by higher asset management fees reflecting higher market valuations and the impact of strong assets under management (AUM) flows, as well as higher brokerage fees due to increased transactional volume, partially offset by the impact of lower AUM pricing.
• Investment banking fees increased $318 million driven by higher advisory fees, equity issuance and debt issuance fees.
• Market making and similar activities increased $53 million primarily driven by higher trading revenue in Equities, partially offset by lower income from foreign currency risk management activities.
• Other income decreased $464 million primarily due to gains recorded on leveraged finance activities in the prior-year period.

Provision for Credit Losses

The provision for credit losses decreased $143 million to $1.3 billion for the three months ended March 31, 2026 compared to the same period in 2025. For more information on the provision for credit losses, see Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses to the Consolidated Financial Statements.

Noninterest Expense

(Dollars in millions)

Noninterest expense increased $761 million to $18.5 billion for the three months ended March 31, 2026 compared to the same period in 2025. The increase was primarily driven by higher revenue-related expenses, as well as continued investments in the business, including people and technology.

Income Tax Expense

(Dollars in millions)

The effective tax rate decreased for the three months ended March 31, 2026 compared to the same period in 2025 primarily due to higher benefits related to the vesting of employee share-based awards in the current-year period.

Supplemental Financial Data

Non-GAAP Financial Measures

In this Quarterly Report on Form 10-Q, we present certain non-GAAP financial measures. Non-GAAP financial measures exclude certain items or otherwise include components that differ from the most directly comparable measures calculated in accordance with GAAP. Non-GAAP financial measures are provided as additional useful information to assess our financial condition, results of operations (including period-to-period operating performance) or compliance with prospective regulatory requirements. These non-GAAP financial measures are not intended as a substitute for GAAP financial measures and may not be defined or calculated the same way as non-GAAP financial measures used by other companies.

When presented on a consolidated basis, we view net interest income on an FTE basis as a non-GAAP financial measure. To derive the FTE basis, net interest income is adjusted to reflect tax-exempt income on an equivalent before-tax basis with a corresponding increase in income tax expense. For purposes of this calculation, we use the federal statutory tax rate of 21 percent and a representative state tax rate. Net interest yield, which measures the basis points we earn over the cost of funds, utilizes net interest income on an FTE basis. We believe that presentation of these items on an FTE basis allows for comparison of amounts from both taxable and tax-exempt sources and is consistent with industry practices.

We may present certain key performance indicators and ratios excluding certain items (e.g., debit valuation adjustment (DVA) gains (losses)), which result in non-GAAP financial measures. We believe that the presentation of measures that exclude these items is useful because such measures provide additional information to assess the underlying operational performance and trends of our businesses and to allow better comparison of period-to-period operating performance.

We also evaluate our business based on certain ratios that utilize tangible equity, a non-GAAP financial measure. Tangible equity represents shareholders’ equity or common shareholders’ equity reduced by goodwill and intangible assets (excluding mortgage servicing rights (MSRs)), net of related deferred tax liabilities (“adjusted” shareholders’ equity or common shareholders’ equity). These measures are used to evaluate our use of equity. In addition, profitability, relationship and investment models use both return on average tangible common shareholders’ equity and return on average tangible

shareholders’ equity as key measures to support our overall growth objectives. These ratios are:

• Return on average tangible common shareholders’ equity measures our net income applicable to common shareholders as a percentage of adjusted average common shareholders’ equity. The tangible common equity ratio represents adjusted ending common shareholders’ equity divided by total tangible assets.
• Return on average tangible shareholders’ equity measures our net income as a percentage of adjusted average total shareholders’ equity. The tangible equity ratio represents adjusted ending shareholders’ equity divided by total tangible assets.
• Tangible book value per common share represents adjusted ending common shareholders’ equity divided by ending common shares outstanding.

We believe ratios utilizing tangible equity provide additional useful information because they present measures of those assets that can generate income. Tangible book value per common share provides additional useful information about the level of tangible assets in relation to outstanding shares of common stock.

The aforementioned supplemental data and performance measures are presented in Table 5 on page 6.

For more information on the reconciliation of these non-GAAP financial measures to the corresponding GAAP financial measures, see Non-GAAP Reconciliations on page 43.

Key Performance Indicators

We present certain key financial and nonfinancial performance indicators (key performance indicators) that management uses when assessing our consolidated and/or segment results. We believe they are useful to investors because they provide additional information about our underlying operational performance and trends. These key performance indicators (KPIs) may not be defined or calculated in the same way as similar KPIs used by other companies. For information on how these metrics are defined, see Key Metrics on page 94.

Our consolidated key performance indicators, which include various equity and credit metrics, are presented in Table 1 on page 3, and Table 5 on page 6.

For information on key segment performance metrics, see Business Segment Operations on page 8.

(In millions, except per share information)

(1) For definitions, see Key Metrics on page 94.

(2) Calculated as total net income for four consecutive quarters divided by annualized average assets for four consecutive quarters.

(3) Tangible equity ratios and tangible book value per share of common stock are non-GAAP financial measures. For more information on these ratios and corresponding reconciliations to GAAP financial measures, see Supplemental Financial Data on page 5 and Non-GAAP Reconciliations on page 43.

(4) Includes the allowance for loan and lease losses and the reserve for unfunded lending commitments.

(5) Balances and ratios do not include loans accounted for under the fair value option. For additional exclusions from nonperforming loans, leases and foreclosed properties, see Consumer Portfolio Credit Risk Management – Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity on page 29 and corresponding Table 24 and Commercial Portfolio Credit Risk Management – Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 33 and corresponding Table 30.

(6) For more information, including which approach is used to assess capital adequacy, see Capital Management on page 16.

(Dollars in millions)

(1) Includes the impact of interest rate risk management contracts. For more information, see Interest Rate Risk Management for the Banking Book on page 40.

(2) Nonperforming loans are included in the respective average loan balances. Income on these nonperforming loans is generally recognized on a cost recovery basis.

(3) Includes U.S. commercial real estate loans of $63.1 billion and $59.8 billion, and non-U.S. commercial real estate loans of $5.8 billion and $5.9 billion for the first quarter of 2026 and 2025.

(4) Includes $77.3 billion and $53.7 billion of structured notes and liabilities for the first quarter of 2026 and 2025.

(5) Net interest income includes FTE adjustments of $162 million and $145 million for the first quarter of 2026 and 2025.

Business Segment Operations

Segment Description and Basis of Presentation

We report our results of operations through four business segments: Consumer Banking, GWIM, Global Banking and Global Markets, with the remaining operations recorded in All Other. We manage our segments and report their results on an FTE basis. For more information, see Business Segment Operations in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

We periodically review capital allocated to our businesses and allocate capital annually during the strategic and capital planning processes. We utilize a methodology that considers the effect of regulatory capital requirements in addition to internal risk-based capital models. The capital allocated to the business segments is referred to as allocated capital. Allocated equity in the reporting units is comprised of allocated capital plus capital

for the portion of goodwill and intangibles specifically assigned to the reporting unit. For more information, including the definition of a reporting unit, see Note 7 – Goodwill and Intangible Assets to the Consolidated Financial Statements.

For more information on our presentation of financial information on an FTE basis, see Supplemental Financial Data on page 5, and for reconciliations to consolidated total revenue, net income and period--end total assets, see Note 17 – Business Segment Information to the Consolidated Financial Statements.

Key Performance Indicators

We present certain key financial and nonfinancial performance indicators that management uses when evaluating segment results. We believe they are useful to investors because they provide additional information about our segments’ operational performance, client trends and business growth.

Consumer Banking

(Dollars in millions)

Consumer Banking offers a diversified range of lending, deposit and investment products and services to consumers and small businesses. For more information about Consumer Banking, see Business Segment Operations in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

Consumer Banking Results

Net income for Consumer Banking increased $529 million to $3.1 billion compared to the same period in 2025 primarily due to higher revenue and lower provision for credit losses. Net interest income increased $488 million to $9.0 billion primarily

driven by higher deposit spreads, as well as loan and deposit balances. Noninterest income increased $68 million to $2.1 billion, primarily due to results from the allocation of asset and liability management (ALM) activities.

The provision for credit losses decreased $160 million to $1.1 billion primarily due to improved asset quality in credit card. Noninterest expense remained relatively unchanged at $5.8 billion.

The return on average allocated capital was 27 percent, up from 23 percent, due to higher net income, partially offset by an increase in allocated capital. For information on capital allocated to the business segments, see Business Segment Operations on page 8.

Average loans and leases increased $7.1 billion to $322.2 billion due to growth across all products.

Average deposits increased $3.3 billion to $950.8 billion primarily due to net inflows of $9.1 billion in checking and $7.9 billion in time deposits, partially offset by net outflows of $13.8 billion in money market and other savings.

Consumer investment assets increased $75.6 billion to $573.3 billion driven by higher market valuations and positive net client flows.

Key Statistics

The table below provides key performance indicators for deposit spreads, other period-end information, credit and debit card and loan production activities.

(Dollars in millions)

(1) Includes client brokerage assets, deposit sweep balances, brokered CDs and AUM in Consumer Banking.

(2) Represents mobile and/or online active users over the past 90 days.

(3) Represents mobile active users over the past 90 days.

(4) Includes consumer credit card portfolios in Consumer Banking and GWIM.

(5) Calculated as the effective annual percentage rate divided by average loans.

(6) Calculated as the difference between total revenue, net of interest expense, and net charge-offs divided by average loans.

(7) The loan production amounts represent the unpaid principal balance of loans and, in the case of home equity, the principal amount of the total line of credit.

(8) In addition to loan production in Consumer Banking, there is also first mortgage and home equity loan production in GWIM.

Active mobile banking users increased by more than one million, reflecting client growth and continuing changes in our clients’ banking preferences. We had a net decrease of 141 financial centers and an increase of 36 ATMs as we continued to optimize our consumer banking network.

During the three months ended March 31, 2026, the total risk-adjusted margin increased one basis point primarily driven by lower net charge-offs, largely offset by lower card-related fee income and lower net interest margin due to loan balance mix. Total credit card purchase volumes increased $4.8 billion to $93.0 billion, and debit card purchase volumes increased $11.7 billion to $151.9 billion, reflecting higher levels of consumer spending.

During the three months ended March 31, 2026, first mortgage loan originations for Consumer Banking and the total Corporation increased $1.2 billion and $1.9 billion compared to the same period in 2025 primarily driven by higher demand.

During the three months ended March 31, 2026, home equity production in Consumer Banking and the total Corporation increased $166 million and $248 million compared to the same period in 2025 primarily driven by higher demand.

Global Wealth & Investment Management

(Dollars in millions)

GWIM consists of two primary businesses: Merrill Wealth Management and Bank of America Private Bank. For more information on GWIM, see Business Segment Operations in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

Net income for GWIM increased $322 million to $1.3 billion for the three months ended March 31, 2026 compared to the same period in 2025 primarily due to higher revenue, partially offset by higher noninterest expense. The operating margin was 26 percent compared to 22 percent a year ago.

Net interest income increased $97 million to $1.9 billion primarily driven by loan growth.

Noninterest income, which primarily includes investment and brokerage services income, increased $599 million to $4.9 billion. The increase was primarily driven by higher asset management fees, which increased 15 percent to $4.2 billion, reflecting higher market valuations and the impact of strong AUM flows, as well as higher brokerage fees due to increased transactional volume, partially offset by the impact of lower AUM pricing.

Noninterest expense increased $279 million to $4.9 billion primarily due to higher revenue-related incentives.

The return on average allocated capital was 24 percent, up from 21 percent, due to higher net income, partially offset by an increase in allocated capital. For information on capital allocated to the business segments, see Business Segment Operations on page 8.

Average loans and leases increased $29.8 billion to $262.2 billion primarily driven by custom lending, securities-based lending and residential mortgage. Average deposits increased $179 million to $286.6 billion, with growth in banking balances largely offset by a decline in brokerage deposits due to clients moving balances to higher yielding cash alternatives.

Merrill Wealth Management revenue of $5.6 billion increased 11 percent primarily driven by higher asset management fees reflecting higher market valuations and the impact of strong AUM flows, as well as higher brokerage fees due to increased transactional volume, partially offset by the impact of lower AUM pricing.

Bank of America Private Bank revenue of $1.1 billion increased 14 percent primarily driven by higher net interest income from loan and deposit growth, as well as higher asset management fees reflecting higher market valuations and the impact of strong AUM flows.

(Dollars in millions)

(1) Includes margin receivables, which are classified in customer and other receivables on the Consolidated Balance Sheet.

Client Balances

Client balances increased $415.2 billion, or 10 percent, to $4.6 trillion at March 31, 2026 compared to March 31, 2025. The increase in client balances was driven by higher market valuations and positive net client flows.

Global Banking

(Dollars in millions)

Global Banking, which includes Global Corporate Banking, Global Commercial Banking, Business Banking and Global Investment Banking, provides a wide range of lending-related products and services, integrated working capital management and treasury solutions, and underwriting and advisory services through our network of global offices and client relationship teams. For more information about Global Banking, see Business Segment Operations in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

Net income for Global Banking increased $163 million to $2.1 billion for the three months ended March 31, 2026 compared to the same period in 2025 driven by higher revenue, partially offset by higher noninterest expense and higher provision for credit losses.

Net interest income increased $79 million to $3.2 billion primarily due to the benefit of higher average deposit and loan balances, partially offset by the impact of lower interest rates.

Noninterest income increased $216 million to $3.1 billion primarily due to higher investment banking fees, revenue from tax-related equity investment activity and higher treasury service charges, partially offset by gains related to sales of certain leveraged finance positions in the prior-year period.

The provision for credit losses increased $31 million to $185 million primarily driven by loan growth in the commercial and industrial portfolio and a qualitative reserve build related to uncertainties associated with the ongoing conflicts in the Middle East, partially offset by improved asset quality within the commercial real estate portfolio.

Noninterest expense was $3.2 billion, relatively unchanged from the same period a year ago.

The return on average allocated capital was 16 percent, up from 15 percent, due to higher net income, partially offset by an increase in allocated capital. For information on capital allocated to the business segments, see Business Segment Operations on page 8.

Global Corporate, Global Commercial and Business Banking

The following table and discussion present a summary of results, which exclude certain investment banking and other activities in Global Banking.

(Dollars in millions)

Business Lending revenue increased $165 million for the three months ended March 31, 2026 compared to the same period in 2025 primarily driven by tax-related equity investment activity in affordable housing and renewable energy.

Global Transaction Services revenue increased $205 million for the three months ended March 31, 2026 compared to the same period in 2025 primarily driven by the benefit of higher average deposit balances and higher treasury service charges, partially offset by the impact of lower interest rates.

Average loans and leases of $396.9 billion increased five percent for the three months ended March 31, 2026 compared to the same period in 2025 due to client demand. Average deposits of $647.6 billion increased 13 percent due to growth in deposit balances from existing clients and the addition of new clients.

Global Investment Banking

Client teams and product specialists underwrite and distribute debt, equity and loan products, and provide advisory services and tailored risk management solutions. The economics of certain investment banking and underwriting activities are shared primarily between Global Banking and Global Markets under an internal revenue-sharing arrangement. Global Banking originates certain deal-related transactions with our corporate and commercial clients that are executed and distributed by

Global Markets. To provide a complete discussion of our consolidated investment banking fees, the table below presents total Corporation investment banking fees and the portion attributable to Global Banking.

(Dollars in millions)

Total Corporation investment banking fees, which exclude self-led deals and are primarily included within Global Banking and Global Markets, increased 21 percent to $1.8 billion for the three months ended March 31, 2026 compared to the same period in 2025 primarily due to higher advisory fees, equity issuance and debt issuance fees.

Global Markets

(Dollars in millions)

Global Markets offers sales and trading services and research services to institutional clients across fixed-income, credit, currency, commodity and equity businesses. Global Markets product coverage includes securities and derivative products in both the primary and secondary markets. For more information about Global Markets, see Business Segment Operations in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

The following explanations for period-over-period changes in results for Global Markets, including those disclosed under Sales and Trading Revenue, are the same for amounts including and excluding net DVA. Amounts excluding net DVA are non-GAAP financial measures. For more information on net DVA, see Supplemental Financial Data on page 5.

Net income for Global Markets increased $57 million to $2.0 billion for the three months ended March 31, 2026 compared to the same period in 2025. Net DVA gains were $63 million compared to $19 million in 2025. Excluding net DVA, net income increased $23 million to $2.0 billion.

Revenue increased $524 million to $7.1 billion primarily due to higher sales and trading revenue, partially offset by gains related to sales of certain leveraged finance positions in the prior-year period. Sales and trading revenue increased $722 million, and excluding net DVA, increased $678 million. These increases were primarily driven by higher revenue in Equities.

Noninterest expense increased $559 million to $4.4 billion primarily driven by higher revenue-related expenses and continued investments in the business, including people and technology.

Average total assets increased $132.3 billion to $1.1 trillion for the three months ended March 31, 2026 compared to the same period in 2025 driven by loan growth, higher levels of inventory and increased financing activity. Period-end total assets increased $58.9 billion from December 31, 2025 to $1.1 trillion driven by the same factors as average total assets.

The return on average allocated capital was 15 percent, down from 16 percent, primarily due to an increase in allocated capital. For information on capital allocated to the business segments, see Business Segment Operations on page 8.

Sales and Trading Revenue

For a description of sales and trading revenue, see Business Segment Operations in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K. The following table and related discussion present sales and trading revenue, substantially all

of which is in Global Markets, with the remainder in Global Banking. In addition, the following table and related discussion also present sales and trading revenue, excluding net DVA, which is a non-GAAP financial measure. For more information on net DVA, see Supplemental Financial Data on page 5.

Sales and Trading Revenue (1, 2, 3)

(Dollars in millions)

(1) For more information on sales and trading revenue, see Note 3 – Derivatives to the Consolidated Financial Statements.

(2) Includes FTE adjustments of $174 million and $78 million for the three months ended March 31, 2026 and 2025.

(3) Includes Global Banking sales and trading revenue of $242 million and $(37) million for the three months ended March 31, 2026 and 2025.

(4) Fixed-income, Currencies and Commodities (FICC) and Equities sales and trading revenue, excluding net DVA, is a non-GAAP financial measure. FICC net DVA gains were $49 million and $15 million for the three months ended March 31, 2026 and 2025. Equities net DVA gains were $14 million and $4 million for the three months ended March 31, 2026 and 2025.

Including and excluding net DVA, FICC revenue increased $66 million and $32 million for the three months ended March 31, 2026 compared to the same period in 2025 driven by improved trading performance in macro and credit products. Including and excluding net DVA, Equities revenue increased $656 million and $646 million driven by increased client activity and improved trading performance in derivatives.

All Other

(Dollars in millions)

(1) In segments where the total of liabilities and equity exceeds assets, which are generally deposit-taking segments, we allocate assets from All Other to those segments to match liabilities (i.e., deposits) and allocated shareholders’ equity. Average allocated assets were $1.0 trillion and $976.7 billion for the three months ended March 31, 2026 and 2025, and period-end allocated assets were $1.0 trillion at both March 31, 2026 and December 31, 2025.

n/m = not meaningful

All Other primarily consists of ALM activities, liquidating businesses and certain expenses not otherwise allocated to a business segment, and adjustments to allocate income tax benefits from tax-related equity investments to noninterest income to present Global Banking and Global Markets on an FTE basis. ALM activities encompass interest rate and foreign currency risk management activities for which substantially all of the results are allocated to our business segments. For more information on our ALM activities, see Note 17 – Business Segment Information to the Consolidated Financial Statements.

Results in All Other improved $153 million to net income of $101 million primarily due to lower noninterest expense.

Noninterest expense decreased $127 million to $163 million primarily due to lower expenses related to a liquidating business activity.

The income tax benefit increased $54 million to $978 million.

Managing Risk

Risk is inherent in all our business activities. The seven key types of risk faced by the Corporation are strategic, credit, market, liquidity, compliance, operational and reputational. Sound risk management enables us to serve our customers and deliver for our shareholders. If not managed well, risk can result in financial loss, regulatory sanctions and penalties, litigation and damage to our reputation, each of which may adversely impact our ability to execute our business strategies. We take a comprehensive approach to risk management with a defined Risk Framework and an articulated Risk Appetite Statement, which are approved annually by the Board’s Enterprise Risk Committee (ERC) and the Board.

Our Risk Framework serves as the foundation for the consistent and effective management of risks facing the Corporation. The Risk Framework sets forth roles and responsibilities for the management of risk and provides a blueprint for how the Board, through delegation of authority to committees and executive officers, establishes risk appetite and associated limits for our activities.

Our risk appetite provides a common framework that includes a set of measures to assist senior management and the Board in assessing the Corporation’s risk profile across all risk types against our risk appetite and risk capacity. Our risk appetite is formally articulated in the Risk Appetite Statement, which includes both qualitative statements and quantitative limits.

For more information on the Corporation’s risks, see Item 1A. Risk Factors of the Corporation’s 2025 Annual Report on Form 10-K. These risks are being managed within our Risk Framework and supporting risk management programs. For more information on our Risk Framework, risk management activities and the key types of risk faced by the Corporation, see the Managing Risk section in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

Capital Management

The Corporation manages its capital position so that its capital is more than adequate to support its business activities and aligns with risk, risk appetite and strategic planning. For more information, see Capital Management in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

CCAR and Capital Planning

The Federal Reserve requires BHCs with average total consolidated assets of $100 billion or more to submit a capital plan and planned capital actions on an annual basis, consistent with the rules governing the Comprehensive Capital Analysis and Review (CCAR) capital plan and associated stress capital buffer (SCB) requirements, which include supervisory stress testing by the Federal Reserve. Based on the results of our 2025 CCAR stress test under the current regulatory framework, our SCB is 2.5 percent, resulting in a Common equity tier 1 (CET1) minimum requirement of 10.0 percent, effective October 1, 2025. At March 31, 2026, the Corporation’s CET1 ratio was 11.2 percent under the Standardized approach.

In February 2026, the Federal Reserve announced that SCB requirements for large banks, including the Corporation, will not change until 2027. As a result, the Corporation’s SCB will remain at 2.5 percent through September 30, 2027. In April 2026, we submitted our 2026 CCAR capital plan and related supervisory stress tests. The Federal Reserve has indicated that it will disclose CCAR capital plan supervisory stress test results by June 30, 2026.

The Board authorized a $40 billion common stock repurchase program, effective August 1, 2025. Pursuant to this Board authorization, during the three months ended March 31, 2026, the Corporation repurchased $7.2 billion of common stock. For more information, see Part II, Item 2. Unregistered Sales of Equity Securities and Use of Proceeds on page 96 and Capital Management – CCAR and Capital Planning in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

The timing and amount of common stock repurchases are subject to various factors, including the Corporation’s capital position, liquidity, financial performance and alternative uses of capital, stock trading price, regulatory requirements and general market conditions, and may be suspended or discontinued at any time. Such repurchases may be effected through open market purchases or privately negotiated transactions, including repurchase plans that satisfy the conditions of Rule 10b5-1 of the Securities Exchange Act of 1934, as amended (Exchange Act).

Further, as part of our planned capital actions, during the three months ended March 31, 2026, the Corporation paid common stock dividends of $2.0 billion.

Regulatory Capital

As a BHC, we are subject to regulatory capital rules, including Basel 3, issued by U.S. banking regulators. Basel 3 established minimum capital ratios and buffer requirements and outlined two methods of calculating risk-weighted assets (RWA), the Standardized approach and the Advanced approaches. The Standardized approach relies primarily on supervisory risk weights based on exposure type, and the Advanced approaches determine risk weights based on internal models.

The Corporation's depository institution subsidiaries are also subject to the Prompt Corrective Action (PCA) framework. The Corporation and its primary affiliated banking entity, BANA, are Advanced approaches institutions under Basel 3 and are required to report regulatory risk-based capital ratios and RWA under both the Standardized and Advanced approaches. The lower of the capital ratios under Standardized or Advanced approaches compared to their respective regulatory capital ratio requirements is used to assess capital adequacy, including under the PCA framework. As of March 31, 2026, the Corporation’s binding ratio was the Total capital ratio under the Standardized approach.

Minimum Capital Requirements

In order to avoid restrictions on capital distributions and discretionary bonus payments to executive officers, the Corporation must meet risk-based capital ratio requirements that include a capital conservation buffer of 2.5 percent (under the Advanced approaches only), an SCB (under the Standardized approach only), plus any applicable countercyclical capital buffer and a global systemically important bank (G-SIB) surcharge. The buffers and surcharge must be comprised solely of CET1 capital. At March 31, 2026 and December 31, 2025, the Corporation’s minimum CET1 requirement was 10.0 percent under both the Standardized approach and the Advanced approaches.

The Corporation is required to calculate its G-SIB surcharge on an annual basis under two methods and is subject to the higher of the resulting two surcharges. Method 1 is consistent with the approach prescribed by the Basel Committee on Banking Supervision’s assessment methodology and is calculated using specified indicators of systemic importance. Method 2 modifies the Method 1 approach for various factors. The Corporation’s Method 1 G-SIB surcharge is 1.5 percent, and its Method 2 G-SIB surcharge is 3.0 percent. Under the current regulatory framework, on January 1, 2027, the Corporation’s G-SIB surcharge will increase by 50 bps to 2.0 percent under Method 1 and to 3.5 percent under Method 2, which will increase the Corporation’s minimum capital ratio requirements.

The Corporation and its insured depository institution subsidiaries are also required to maintain a minimum supplementary leverage ratio (SLR) plus a leverage buffer to avoid certain restrictions on capital distributions and discretionary bonus payments to executive officers. Prior to January 1, 2026, the minimum SLR requirement was 5.0 percent for the Corporation and 6.0 percent for its insured depository institutions. Effective January 1, 2026, the Corporation and its insured depository institutions early adopted a final rule on modified enhanced SLR requirements, resulting in a minimum SLR requirement of 3.75 percent, which includes

the leverage buffer, for both the Corporation and its insured depository institutions. At March 31, 2026, the Corporation’s SLR was 5.5 percent and BANA’s SLR was 5.9 percent, which both exceeded their minimum SLR requirement of 3.75 percent. For more information, see Capital Management – Regulatory Developments in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

Capital Composition and Ratios

Table 7 presents Bank of America Corporation’s capital ratios and related information in accordance with Basel 3 Standardized and Advanced approaches as measured at March 31, 2026 and December 31, 2025. For the periods presented herein, the Corporation met the definition of well capitalized under current regulatory requirements.

(Dollars in millions, except as noted)

(1) The CET1 capital regulatory minimum is the sum of the CET1 capital ratio minimum of 4.5 percent, our G-SIB surcharge of 3.0 percent, and SCB (under the Standardized approach) of 2.5 percent at March 31, 2026 and December 31, 2025. The countercyclical capital buffer was zero for both periods. The SLR regulatory minimum at March 31, 2026 and December 31, 2025 includes a leverage buffer of 0.75 percent and 2.0 percent.

(2) Total capital under the Advanced approaches differs from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.

(3) Reflects total average assets adjusted for certain Tier 1 capital deductions.

At March 31, 2026, CET1 capital was $199.7 billion, a decrease of $1.7 billion from December 31, 2025, primarily due to capital distributions and an increase in net unrealized losses on available-for-sale debt securities included in accumulated OCI, largely offset by earnings. Tier 1 capital decreased $2.7 billion driven by the same factors as CET1 capital and a preferred stock redemption. Total capital under the Standardized approach decreased $2.9 billion driven by the

same factors as Tier 1 capital, as well as a decrease in subordinated debt and in the adjusted allowance for credit losses included in Tier 2 capital. RWA under the Standardized approach, which drove the lower CET1 capital ratio at March 31, 2026, increased $5.2 billion during the first quarter of 2026 to $1,778 billion primarily driven by growth in Global Banking and Global Markets, partially offset by GWIM. Supplementary leverage exposure at March 31, 2026 increased $100.7 billion primarily driven by increased activity in Global Markets.

Table 8 shows the capital composition at March 31, 2026 and December 31, 2025.

(Dollars in millions)

(1) Includes amounts in accumulated OCI related to the hedging of items that are not recognized at fair value on the Consolidated Balance Sheet.

Table 9 shows the components of RWA as measured under Basel 3 at March 31, 2026 and December 31, 2025.

(Dollars in billions)

n/a = not applicable

Bank of America, N.A. Regulatory Capital

Table 10 presents regulatory capital information for BANA in accordance with Basel 3 Standardized and Advanced approaches as measured at March 31, 2026 and December 31, 2025. BANA met the definition of well capitalized under the PCA framework for both periods.

(Dollars in millions, except as noted)

(1) Risk-based capital regulatory minimums at both March 31, 2026 and December 31, 2025 are the minimum ratios under Basel 3 including a capital conservation buffer of 2.5 percent. The regulatory minimums for the Tier 1 leverage ratios as of both period ends, and the SLR as of December 31, 2025, are the percent required to be considered well capitalized under the PCA framework.

(2) Total capital under the Advanced approaches differs from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.

(3) Reflects total average assets adjusted for certain Tier 1 capital deductions.

Total Loss-Absorbing Capacity Requirements

Total loss-absorbing capacity (TLAC) consists of the Corporation’s Tier 1 capital and eligible long-term debt issued directly by the Corporation. Eligible long-term debt for TLAC ratios is comprised of unsecured debt that has a remaining maturity of at least one year and satisfies additional requirements as prescribed in the TLAC final rule. As with the

risk-based capital ratios and SLR, the Corporation is required to maintain TLAC ratios in excess of minimum requirements plus applicable buffers to avoid restrictions on capital distributions and discretionary bonus payments to executive officers. Table 11 presents the Corporation's TLAC and long-term debt ratios and related information as of March 31, 2026 and December 31, 2025.

Bank of America Corporation Total Loss-Absorbing Capacity and Long-Term Debt

(Dollars in millions)

(1) The TLAC RWA regulatory minimum consists of 18.0 percent plus a TLAC RWA buffer comprised of 2.5 percent plus the Method 1 G-SIB surcharge of 1.5 percent. The countercyclical buffer is zero for both periods. The TLAC supplementary leverage exposure regulatory minimum consists of 7.5 percent plus a 0.75 percent TLAC leverage buffer. The TLAC RWA and leverage buffers must be comprised solely of CET1 capital and Tier 1 capital, respectively.

(2) The long-term debt RWA regulatory minimum is comprised of 6.0 percent plus the Corporation’s Method 2 G-SIB surcharge of 3.0 percent. The long-term debt leverage exposure regulatory minimum is 3.25 percent, consisting of 2.5 percent plus a 0.75 percent long-term debt leverage buffer.

(3) The approach that yields the higher RWA is used to calculate TLAC and long-term debt ratios, which was the Standardized approach as of March 31, 2026 and December 31, 2025.

Regulatory Developments

The following supplements the disclosure in Capital Management – Regulatory Developments in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

On March 19, 2026, the Federal Reserve, Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation issued a notice of proposed rulemaking (NPR) regarding risk-based capital requirements for large banking organizations. Separately, the Federal Reserve issued an NPR that would revise the calculation of the G-SIB surcharge. Any final rules issued are subject to change from the current proposals. The Corporation is evaluating the potential impact of the proposed rules on its regulatory capital requirements.

Regulatory Capital and Securities Regulation

The Corporation’s principal U.S. broker-dealer subsidiaries are BofA Securities, Inc. (BofAS) and Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S). The Corporation's principal European subsidiaries undertaking broker-dealer activities are Merrill Lynch International (MLI) and BofA Securities Europe SA (BofASE).

The U.S. broker-dealer subsidiaries are subject to the net capital requirements of Rule 15c3-1 under the Exchange Act. BofAS computes its capital requirements as an alternative net capital broker-dealer under Rule 15c3-1(a)(7) and Rule 15c3-1e, which permit the use of SEC-approved models, and MLPF&S computes its capital requirements in accordance with the alternative standard under Rule 15c3-1. BofAS is registered as a futures commission merchant and is subject to Commodity Futures Trading Commission (CFTC) Regulation 1.17. The U.S. broker-dealer subsidiaries are also registered with the Financial Industry Regulatory Authority, Inc. (FINRA). Pursuant to FINRA Rule 4110, FINRA may impose higher net capital requirements than Rule 15c3-1 under the Exchange Act with respect to each of the broker-dealers.

BofAS provides institutional services, and in accordance with the SEC alternative net capital requirements, is required to regularly maintain tentative net capital in excess of $5.0 billion and net capital in excess of the greater of $1.0 billion or a certain percentage of its reserve requirement in addition to a certain percentage of securities-based swap risk margin. BofAS must also notify the SEC in the event its tentative net capital is less than $6.0 billion. In accordance with CFTC net capital requirements, BofAS is required to hold a certain percentage of its customers' and affiliates' risk-based margin if greater than the SEC’s minimum net capital requirement. At March 31, 2026, BofAS had tentative net capital of $24.9 billion. BofAS

also had regulatory net capital of $20.4 billion, which exceeded the minimum requirement of $4.8 billion.

MLPF&S provides retail services and is required to maintain net capital that is the greater of $250,000 or two percent of a certain component of its reserve calculation. At March 31, 2026, MLPF&S' regulatory net capital was $11.3 billion, which exceeded the minimum requirement of 190 million.

Our European broker-dealers are subject to requirements from U.S. and non-U.S. regulators. MLI, a U.K. investment firm, is regulated by the Prudential Regulation Authority and the Financial Conduct Authority and is subject to certain regulatory capital requirements. At March 31, 2026, MLI’s capital resources were $34.1 billion, which exceeded the minimum Pillar 1 requirement of $13.3 billion.

BofASE, an authorized credit institution with its head office located in France, is regulated by the Autorité de Contrôle Prudentiel et de Résolution and the Autorité des Marchés Financiers, and supervised under the Single Supervisory Mechanism by the European Central Bank. At March 31, 2026, BofASE's capital resources were $11.7 billion, which exceeded the minimum Pillar 1 requirement of $4.1 billion.

In addition, MLI and BofASE remained conditionally registered with the SEC as security-based swap dealers, and maintained net liquid assets at March 31, 2026 that exceeded the applicable minimum requirements under the Exchange Act. The entities are also registered as swap dealers with the CFTC and met applicable capital requirements at March 31, 2026.

Liquidity Risk

Funding and Liquidity Risk Management

Our primary liquidity risk management objective is to meet expected or unexpected cash flow and collateral requirements, including payments under long-term debt agreements, commitments to extend credit and customer deposit withdrawals, while continuing to support our businesses and customers under a range of economic conditions. To achieve that objective, we analyze and monitor our liquidity risk under expected and stressed conditions, maintain liquidity and access to diverse funding sources, including our stable deposit base, and seek to align liquidity-related incentives and risks. These liquidity risk management practices have helped enable us to effectively navigate market volatility arising from the interest rate environment, inflationary pressures and broader macroeconomic changes.

We define liquidity as readily available assets, limited to cash and high-quality, liquid, unencumbered securities that we can use to meet our contractual and contingent financial obligations as they arise. We manage our liquidity position through line of business and ALM activities, as well as through our legal entity funding strategy, on both a forward and current (including intraday) basis under both expected and stressed conditions. We believe that a centralized approach to funding and liquidity management enhances our ability to monitor liquidity requirements, maximizes access to funding sources, minimizes borrowing costs and facilitates timely responses to liquidity events.

We provide centralized funding and liquidity management through a variety of activities, including monitoring of established limits, assessing exposures under both normal and stressed conditions and reviewing liquidity risk management processes and controls. Global Risk Management (GRM) provides oversight of liquidity management across the Corporation, including front line units and legal entities. GRM oversees the liquidity risk management governance structure, establishes liquidity risk policies, and provides independent review and challenge of the Corporation's liquidity risk management processes.

For more information on the Corporation’s liquidity risks, see the Liquidity section within Item 1A. Risk Factors of the Corporation’s 2025 Annual Report on Form 10-K. For more information regarding global funding and liquidity risk management, as well as liquidity sources, liquidity arrangements, contingency planning and credit ratings discussed below, see Liquidity Risk in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

NB Holdings Corporation

Bank of America Corporation, as the parent company (the Parent), which is a separate and distinct legal entity from our bank and nonbank subsidiaries, has an intercompany arrangement with our wholly-owned holding company subsidiary, NB Holdings Corporation (NB Holdings). We have transferred, and agreed to transfer, additional Parent assets not required to satisfy anticipated near-term expenditures to NB Holdings. The Parent is expected to continue to have access to the same flow of dividends, interest and other amounts of cash necessary to service its debt, pay dividends and perform other obligations as it would have had it not entered into these arrangements and transferred any assets. These arrangements support our preferred single point of entry resolution strategy, under which only the Parent would be resolved under the U.S. Bankruptcy Code.

Global Liquidity Sources and Other Unencumbered Assets

We maintain liquidity available to the Corporation, including the Parent and selected subsidiaries, in the form of cash and high- quality, liquid, unencumbered securities. Our liquidity buffer, referred to as Global Liquidity Sources (GLS), is comprised of assets that are readily available to the Parent and selected subsidiaries, including holding company, bank and broker-dealer subsidiaries, even during stressed market conditions. Our cash is primarily on deposit with the Federal Reserve Bank and, to a lesser extent, central banks outside of the U.S. We limit the composition of high-quality, liquid, unencumbered securities to U.S. government securities, U.S. agency securities, U.S. agency mortgage-backed securities and other investment-grade securities, and a select group of non-U.S. government securities. We can obtain cash for these securities, even in stressed conditions, through repurchase agreements or outright sales. We hold our GLS in legal entities that allow us to meet the liquidity requirements of our global businesses, and we consider the impact of potential regulatory, tax, legal and other

restrictions that could limit the transferability of funds among entities.

Table 12 presents average GLS for the three months ended March 31, 2026 and December 31, 2025.

Average Global Liquidity Sources

(Dollars in billions)

(1) Nonbank includes Parent, NB Holdings and other regulated entities.

Our bank subsidiaries’ liquidity is primarily driven by deposit and lending activity, as well as securities valuation and net debt activity. Bank subsidiaries can also generate incremental liquidity by pledging a range of unencumbered loans and securities to certain Federal Home Loan Banks (FHLBs) and the Federal Reserve Discount Window. The cash we could have obtained by borrowing against this pool of specifically-identified eligible assets was $342 billion and $343 billion at March 31, 2026 and December 31, 2025. We have established operational procedures to enable us to borrow against these assets, including regularly monitoring our total pool of eligible loans and securities collateral. Eligibility is defined in guidelines from the FHLBs and the Federal Reserve and is subject to change at their discretion. Due to regulatory restrictions, liquidity generated by the bank subsidiaries can generally be used only to fund obligations within the bank subsidiaries, and transfers to the Parent or nonbank subsidiaries may be subject to prior regulatory approval.

Liquidity is also held in nonbank entities, including the Parent, NB Holdings and other regulated entities. The Parent and NB Holdings liquidity is typically in the form of cash deposited at BANA, which is excluded from the liquidity at bank subsidiaries, and high-quality, liquid, unencumbered securities. Liquidity held in other regulated entities, comprised primarily of broker-dealer subsidiaries, is primarily available to meet the obligations of that entity, and transfers to the Parent or to any other subsidiary may be subject to prior regulatory approval due to regulatory restrictions and minimum requirements. Our other regulated entities also hold unencumbered investment-grade securities and equities that we believe could be used to generate additional liquidity.

Table 13 presents the composition of average GLS for the three months ended March 31, 2026 and December 31, 2025.

Average Global Liquidity Sources Composition

(Dollars in billions)

Our GLS are substantially the same in composition to what qualifies as High Quality Liquid Assets (HQLA) under the final U.S. Liquidity Coverage Ratio (LCR) rules. However, HQLA for purposes of calculating LCR is not reported at market value, but at a lower value that incorporates regulatory deductions and the exclusion of excess liquidity held at certain subsidiaries. The LCR is calculated as the amount of a financial institution’s unencumbered HQLA relative to the estimated net cash outflows the institution could encounter over a 30-day period of significant liquidity stress, expressed as a percentage. Our average consolidated HQLA, on a net basis, was $673 billion and $667 billion for the three months ended March 31, 2026 and December 31, 2025. For both periods, the average consolidated LCR was 112 percent. Our LCR may fluctuate due to normal business flows from customer activity.

Liquidity Stress Analysis

We utilize liquidity stress analysis to assist us in determining the appropriate amounts of liquidity to maintain at the Parent and our subsidiaries to meet contractual and contingent cash outflows under a range of scenarios. For more information on liquidity stress analysis, see Liquidity Risk – Liquidity Stress Analysis in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

Net Stable Funding Ratio

The Net Stable Funding Ratio (NSFR) is a liquidity requirement for large banks to maintain a minimum level of stable funding over a one-year period. The requirement is intended to support the ability of banks to lend to households and businesses in both normal and adverse economic conditions and is complementary to the LCR, which focuses on short-term liquidity risks. The U.S. NSFR applies to the Corporation on a consolidated basis and to our insured depository institutions. At March 31, 2026, the Corporation and its insured depository institutions were in compliance with the U.S. NSFR. For more information, see the Pillar 3 U.S. NSFR Disclosure report for the quarters ended December 31, 2025 and September 30, 2025 on the Corporation’s website, the contents of which are not incorporated by reference into this Quarterly Report on Form 10-Q.

Diversified Funding Sources

We fund our assets primarily with a mix of deposits, and secured and unsecured liabilities through a centralized, globally coordinated funding approach diversified across products, programs, markets, currencies and investor groups. We fund a substantial portion of our lending activities through our

deposits, which were $2.04 trillion and $2.02 trillion at March 31, 2026 and December 31, 2025. Our trading activities in other regulated entities are primarily funded on a secured basis through securities lending and repurchase agreements, and these amounts will vary based on customer activity and market conditions.

Deposits

Our deposit base is well-diversified by clients, geography and product type across our business segments. At March 31, 2026, 48 percent of our deposits were in Consumer Banking, 14 percent in GWIM and 32 percent in Global Banking. We consider a substantial portion of our deposit base to be a stable, low-cost and consistent source of liquidity. At March 31, 2026, approximately 70 percent of consumer and small business deposits and 83 percent of U.S. deposits in Global Banking were held by clients who have had accounts with us for 10 or more years. In addition, at March 31, 2026 and December 31, 2025, 27 percent and 26 percent of our deposits were noninterest bearing and were primarily operating accounts of our consumer and commercial clients. Deposits at March 31, 2026 increased $18.9 billion from December 31, 2025 primarily due to deposit growth in Consumer Banking and Global Banking.

During the three months ended March 31, 2026 and 2025, rates paid on deposits were 51 bps and 61 bps in Consumer Banking, 204 bps and 250 bps in GWIM, and 221 bps and 273 bps in Global Banking. For information on rates paid on consolidated deposit balances, see Table 6 on page 7.

Long-term Debt

During the three months ended March 31, 2026, we issued $33.1 billion of long-term debt consisting of $9.7 billion of notes issued by Bank of America Corporation, substantially all of which were TLAC compliant, $10.3 billion of notes issued by Bank of America, N.A. and $13.1 billion of other debt.

During the three months ended March 31, 2026, we had total long-term debt maturities and redemptions in the aggregate of $24.4 billion consisting of $11.8 billion for Bank of America Corporation, $5.5 billion for Bank of America, N.A. and $7.1 billion of other debt. Table 14 presents the carrying value of aggregate annual contractual maturities of long-term debt at March 31, 2026.

Long-term Debt by Maturity

(Dollars in millions)

(1) Total includes $175.7 billion of outstanding senior notes that are both TLAC eligible and callable one year before their stated maturities, including $16.4 billion during the remainder of 2026, and $27.3 billion, $27.8 billion, $8.4 billion and $21.5 billion during each year of 2027 through 2030, respectively, and $74.3 billion thereafter. For more information on our TLAC eligible and callable outstanding notes, see Liquidity Risk – Diversified Funding Sources in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

(2) Represents liabilities of consolidated variable interest entities (VIEs) included in long-term debt on the Consolidated Balance Sheet.

Total long-term debt increased $8.1 billion to $326.0 billion during the three months ended March 31, 2026 primarily due to debt issuances, partially offset by maturities and valuation adjustments. We may, from time to time, repurchase outstanding debt instruments in various transactions, depending on market conditions, liquidity and other factors. Our other regulated entities may also make markets in our debt instruments to provide liquidity for investors.

During the three months ended March 31, 2026, we issued $15.8 billion of structured notes, which are debt obligations that pay investors returns linked to other debt or equity securities, indices, currencies or commodities. These structured notes are typically issued to meet client demand, and notes with certain attributes may also be TLAC eligible. We typically use derivatives and/or investments to economically hedge the variable returns due on the structured notes so that the net cost, which is recognized in market making and similar activities, is similar to unsecured long-term debt. We could be required to settle certain structured note obligations for cash or other securities prior to maturity under certain circumstances, which we consider for liquidity planning purposes. We believe, however, that a portion of such borrowings will remain outstanding beyond the earliest put or redemption date.

Substantially all of our senior and subordinated debt obligations contain no provisions that could trigger a requirement for an early repayment, require additional collateral support, result in changes to terms, accelerate maturity or create additional financial obligations upon an adverse change in our credit ratings, financial ratios, earnings, cash flows or stock price. For more information on long-term debt funding,

including issuances and maturities and redemptions, see Note 11 – Long-term Debt to the Consolidated Financial Statements of the Corporation’s 2025 Annual Report on Form 10-K.

We use derivative transactions to manage the duration, interest rate and currency risks of our borrowings, considering the characteristics of the assets they are funding. For more information on our ALM activities, see Interest Rate Risk Management for the Banking Book on page 40.

Credit Ratings

Credit ratings and outlooks are opinions expressed by rating agencies on our creditworthiness and that of our obligations or securities, including long-term debt, short-term borrowings, preferred stock and other securities, including asset securitizations. Table 15 presents the Corporation’s current long-term/short-term senior debt ratings and outlooks expressed by the rating agencies.

The ratings and outlooks from Moody's Investors Service, Standard & Poor’s Global Ratings and Fitch Ratings for the Corporation and its subsidiaries have not changed from those disclosed in the Corporation's 2025 Annual Report on Form 10-K.

For more information on additional collateral and termination payments that could be required in connection with certain over-the-counter derivative contracts and other trading agreements in the event of a credit rating downgrade, see Note 3 – Derivatives to the Consolidated Financial Statements herein and Item 1A. Risk Factors of the Corporation’s 2025 Annual Report on Form 10-K.

Senior Debt Ratings

NR = not rated

Finance Subsidiary Issuers and Parent Guarantor

BofA Finance LLC, a Delaware limited liability company (BofA Finance), is a consolidated finance subsidiary of the Corporation that has issued and sold, and is expected to continue to issue and sell, its senior unsecured debt securities (Guaranteed Notes) that are fully and unconditionally guaranteed by the Corporation. The Corporation guarantees the due and punctual payment, on demand, of amounts payable on the Guaranteed Notes if not paid by BofA Finance. In addition, each of BAC Capital Trust XIII, BAC Capital Trust XIV and BAC Capital Trust XV, Delaware statutory trusts (collectively, the Trusts) is a 100 percent owned finance subsidiary of the Corporation that has issued and sold trust preferred securities (the Trust Preferred Securities) or capital securities (the Capital Securities and, together with the Guaranteed Notes and the Trust Preferred Securities, the Guaranteed Securities), as applicable, that remained outstanding at March 31, 2026. The Corporation has fully and unconditionally guaranteed (or effectively provided for the full and unconditional guarantee of) all such securities issued by such finance subsidiaries. For more information regarding such guarantees by the Corporation, see Liquidity Risk – Finance Subsidiary Issuers and Parent Guarantor in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

Representations and Warranties Obligations

For information on representations and warranties obligations in connection with the sale of mortgage loans, see Note 12 – Commitments and Contingencies to the Consolidated Financial Statements of the Corporation’s 2025 Annual Report on Form 10-K.

Credit Risk Management

For information on our credit risk management activities, see the following: Consumer Portfolio Credit Risk Management on page 24, Commercial Portfolio Credit Risk Management on page 29, Non-U.S. Portfolio on page 35, Allowance for Credit Losses on page 36, Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses to the Consolidated Financial Statements, and Credit Risk Management in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K. For more information on the Corporation’s credit risks, see the Credit section within Item 1A. Risk Factors of the Corporation’s 2025 Annual Report on Form 10-K. For more information on the Corporation’s economic and geopolitical risks, see the Geopolitical section within Item 1A. Risk Factors of the Corporation’s 2025 Annual Report on Form 10-K.

During the three months ended March 31, 2026, our net charge-off ratio decreased compared to the same period in

2025 primarily driven by lower credit card and commercial real estate office charge-offs. Commercial reservable criticized exposure decreased $409 million compared to December 31, 2025 driven by the commercial real estate portfolio, and nonperforming loans remained relatively unchanged at $5.8 billion. Uncertainties surrounding geopolitical tensions, particularly related to the ongoing conflicts in the Middle East, and persistent inflationary pressures continue to weigh on the broader economic outlook. These factors have been assessed for any impacts to the portfolio and may contribute to future deterioration in credit quality metrics as they evolve.

Consumer Portfolio Credit Risk Management

Credit risk management for the consumer portfolio begins with initial underwriting and continues throughout a borrower’s credit cycle. Statistical techniques in conjunction with experiential judgment are used in all aspects of portfolio management including underwriting, product pricing, risk appetite, setting credit limits, and establishing operating processes and metrics to quantify and balance risks and returns. Statistical models are built using detailed behavioral information from external sources, such as credit bureaus, and/or internal historical experience and are a component of our consumer credit risk management process. These models are used in part to assist in making both new and ongoing credit decisions as well as portfolio management strategies, including authorizations and line management, collection practices and strategies, and determination of the allowance for loan and lease losses and allocated capital for credit risk.

Consumer Credit Portfolio

During the three months ended March 31, 2026, the U.S. unemployment rate and home prices remained relatively stable. During the three months ended March 31, 2026, net charge-offs decreased $60 million to $1.1 billion compared to the same period in 2025, primarily driven by improvement in the credit card portfolio.

The consumer allowance for loan and lease losses decreased $109 million to $8.3 billion from December 31, 2025. For more information, see Allowance for Credit Losses on page 36.

For more information on our accounting policies regarding delinquencies, nonperforming status, charge-offs and loan modifications for the consumer portfolio, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements of the Corporation’s 2025 Annual Report on Form 10-K and Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses to the Consolidated Financial Statements.

Table 16 presents our outstanding consumer loans and leases, consumer nonperforming loans and accruing consumer loans past due 90 days or more.

(Dollars in millions)

(1) Residential mortgage loans accruing past due 90 days or more are fully-insured loans. At March 31, 2026 and December 31, 2025, residential mortgage included $115 million and $104 million of loans on which interest had been curtailed by the Federal Housing Administration (FHA), and therefore were no longer accruing interest, although principal was still insured, and $125 million and $103 million of loans on which interest was still accruing.

(2) Outstandings primarily includes auto and specialty lending loans and leases of $53.9 billion and $55.3 billion, U.S. securities-based lending loans of $56.2 billion and $55.0 billion at March 31, 2026 and December 31, 2025, and non-U.S. consumer loans of $3.1 billion and $3.0 billion at March 31, 2026 and December 31, 2025.

(3) For more information on the fair value option, see Note 15 – Fair Value Option to the Consolidated Financial Statements.

(4) Excludes consumer loans accounted for under the fair value option. At March 31, 2026 and December 31, 2025, loans accounted for under the fair value option that were past due 90 days or more and not accruing interest were insignificant.

n/a = not applicable

Table 17 presents net charge-offs and related ratios for consumer loans and leases.

(Dollars in millions)

(1) Negative numbers represent net recoveries. Net charge-off ratios are calculated as annualized net charge-offs divided by average outstanding loans and leases, excluding loans accounted for under the fair value option.

n/m = not meaningful

We believe that the presentation of information adjusted to exclude the impact of the fully-insured loan portfolio and loans accounted for under the fair value option is more representative of the ongoing operations and credit quality of the business. As a result, in the following tables and discussions of the residential mortgage and home equity portfolios, we exclude loans accounted for under the fair value option and provide information that excludes the impact of the fully-insured loan portfolio in certain credit quality statistics.

Residential Mortgage

The residential mortgage portfolio made up the largest percentage of our consumer loan portfolio at 49 percent of consumer loans and leases at March 31, 2026. Approximately 49 percent of the residential mortgage portfolio was in Consumer Banking, 47 percent was in GWIM and the remaining portion was in Global Markets and All Other.

Outstanding balances in the residential mortgage portfolio were relatively unchanged during the three months ended March 31, 2026.

At March 31, 2026 and December 31, 2025, the residential mortgage portfolio included $8.9 billion and $9.1 billion of outstanding fully-insured loans, of which $1.8 billion and $1.9 billion had FHA insurance, with the remainder protected by Fannie Mae long-term standby agreements.

Table 18 presents certain residential mortgage key credit statistics on both a reported basis and excluding the fully-insured loan portfolio. The following discussion presents the residential mortgage portfolio excluding the fully-insured loan portfolio.

(Dollars in millions)

(1) Outstandings, accruing past due, nonperforming loans and percentages of portfolio exclude loans accounted for under the fair value option.

(2) Includes loans that are contractually current that have not yet demonstrated a sustained period of payment performance following a modification.

Nonperforming outstanding balances in the residential mortgage portfolio increased $95 million to $2.1 billion during the three months ended March 31, 2026 driven by extended relief provided to borrowers for their residential rebuilding efforts after the 2025 California wildfires. Of the nonperforming residential mortgage loans at March 31, 2026, $1.2 billion, or 58 percent, were current on contractual payments. Excluding fully-insured loans, loans accruing past due 30 days or more decreased $21 million to $1.1 billion during the three months ended March 31, 2026.

Of the $227.3 billion in total residential mortgage loans outstanding at March 31, 2026, $65.9 billion, or 29 percent, of loans were originated as interest-only. The outstanding balance of interest-only residential mortgage loans that had entered the amortization period was $3.7 billion, or six percent, at March 31, 2026. Residential mortgage loans that have entered the amortization period generally experience a higher rate of early stage delinquencies and nonperforming status compared to the residential mortgage portfolio as a whole. At March 31, 2026, $51 million, or one percent, of outstanding interest-only residential mortgages that had entered the amortization period were accruing past due 30 days or more compared to $1.1

billion, or less than one percent, for the entire residential mortgage portfolio. In addition, at March 31, 2026, $153 million, or four percent, of outstanding interest-only residential mortgage loans that had entered the amortization period were nonperforming, of which $50 million were contractually current. Loans that have yet to enter the amortization period in our interest-only residential mortgage portfolio are primarily well-collateralized loans to our wealth management clients and have an interest-only period of three years to 10 years. Substantially all of these loans that have yet to enter the amortization period will not be required to make a fully-amortizing payment until 2028 or later.

Table 19 presents outstandings, nonperforming loans and net charge-offs by certain state concentrations for the residential mortgage portfolio. In the New York area, the New York-Northern New Jersey-Long Island Metropolitan Statistical Area (MSA) made up 15 percent of outstandings at both March 31, 2026 and December 31, 2025. The Los Angeles-Long Beach-Santa Ana MSA within California represented 14 percent of outstandings at both March 31, 2026 and December 31, 2025.

Residential Mortgage State Concentrations

(Dollars in millions)

(1) Outstandings and nonperforming loans exclude loans accounted for under the fair value option.

Home Equity

At March 31, 2026, the home equity portfolio made up six percent of the consumer portfolio and was comprised of home equity lines of credit (HELOCs), home equity loans and reverse mortgages. HELOCs generally have an initial draw period of 10 years, and after the initial draw period ends, the loans generally convert to 15- or 20-year amortizing loans. We no longer originate home equity loans or reverse mortgages.

At March 31, 2026, 85 percent of the home equity portfolio was in Consumer Banking, 11 percent was in GWIM and the remainder of the portfolio was in All Other. Outstanding balances in the home equity portfolio were relatively unchanged during the

three months ended March 31, 2026. Of the total home equity portfolio at March 31, 2026 and December 31, 2025, $8.8 billion and $8.9 billion, or 33 percent as of the end of both periods, were in first-lien positions. At March 31, 2026, outstanding balances in the home equity portfolio that were in a second-lien or more junior-lien position and where we also held the first-lien loan totaled $4.7 billion, or 18 percent, of our total home equity portfolio.

Unused HELOCs totaled $43.0 billion and $43.1 billion at March 31, 2026 and December 31, 2025. The HELOC utilization rate was 38 percent at both March 31, 2026 and December 31, 2025.

Table 20 presents certain home equity portfolio key credit statistics.

Home Equity – Key Credit Statistics (1)

(Dollars in millions)

(1) Outstandings, accruing past due, nonperforming loans and percentages of the portfolio exclude loans accounted for under the fair value option.

(2) Includes loans that are contractually current that have not yet demonstrated a sustained period of payment performance following a modification.

Nonperforming outstanding balances in the home equity portfolio were relatively unchanged during the three months ended March 31, 2026. Of the nonperforming home equity loans at March 31, 2026, $237 million, or 61 percent, were current on contractual payments. In addition, $84 million, or 21 percent, were 180 days or more past due and had been written down to the estimated fair value of the collateral, less costs to sell. Accruing loans that were 30 days or more past due remained relatively unchanged during the three months ended March 31, 2026.

Of the $26.8 billion in total home equity portfolio outstandings at March 31, 2026, as shown in Table 20, eight percent require interest-only payments. The outstanding balance of HELOCs that had reached the end of their draw period and entered the amortization period was $3.1 billion at March 31, 2026. The HELOCs that have entered the amortization period have experienced a higher percentage of early stage delinquencies and nonperforming status when compared to the HELOC portfolio as a whole. At March 31, 2026, $26 million, or one percent, of outstanding HELOCs that had entered the

amortization period were accruing past due 30 days or more. In addition, at March 31, 2026, $211 million, or seven percent, were nonperforming.

For our interest-only HELOC portfolio, we can infer how many of our home equity customers pay only the minimum amount due on their home equity loans and lines through a review of our HELOC portfolio that we service and is still in its revolving period. During the three months ended March 31, 2026, 21 percent of these customers with an outstanding balance did not pay any principal on their HELOCs.

Table 21 presents outstandings, nonperforming balances and net recoveries by certain state concentrations for the home equity portfolio. In the New York area, the New York-Northern New Jersey-Long Island MSA made up 10 percent of the outstanding home equity portfolio at both March 31, 2026 and December 31, 2025. The Los Angeles-Long Beach-Santa Ana MSA within California made up 10 percent of the outstanding home equity portfolio at both March 31, 2026 and December 31, 2025.

Home Equity State Concentrations

(Dollars in millions)

(1) Outstandings and nonperforming loans exclude loans accounted for under the fair value option.

(2) Negative numbers represent net recoveries.

Credit Card

At March 31, 2026, 97 percent of the credit card portfolio was managed in Consumer Banking with the remainder in GWIM. Outstandings in the credit card portfolio decreased $3.2 billion during the three months ended March 31, 2026 to $102.8 billion primarily driven by a seasonal decline in purchase volume. Net charge-offs decreased $77 million to $924 million

during the three months ended March 31, 2026 compared to the same period in 2025 as the portfolio continued to improve. Credit card loans 30 days or more past due decreased $92 million, and 90 days or more past due decreased $10 million during the three months ended March 31, 2026.

Unused lines of credit for credit card increased to $426.7 billion at March 31, 2026 from $417.6 billion at December 31, 2025.

Table 22 presents certain state concentrations for the credit card portfolio.

Credit Card State Concentrations

(Dollars in millions)

Direct/Indirect Consumer

At March 31, 2026, 47 percent of the direct/indirect portfolio was included in Consumer Banking (consumer auto and recreational vehicle lending) and 53 percent was included in GWIM (principally securities-based lending loans). Outstandings

in the direct/indirect portfolio were relatively unchanged during the three months ended March 31, 2026.

Table 23 presents certain state concentrations for the direct/indirect consumer loan portfolio.

(Dollars in millions)

Other Consumer

Other consumer primarily consists of deposit overdraft balances. Net charge-offs during the three months ended March 31, 2026 totaled $63 million, relatively unchanged compared to the same period in 2025.

Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity

Table 24 presents nonperforming consumer loans, leases and foreclosed properties activity for the three months ended March 31, 2026. During the three months ended March 31, 2026, nonperforming consumer loans increased $104 million to $2.7 billion driven by extended residential mortgage relief provided to borrowers for their home rebuilding efforts following the 2025 California wildfires.

At March 31, 2026, $550 million, or 21 percent, of nonperforming loans were 180 days or more past due and had been written down to their estimated property value less costs to sell. In addition, at March 31, 2026, $1.5 billion, or 57 percent, of nonperforming consumer loans were current and classified as nonperforming loans in accordance with applicable policies.

During the three months ended March 31, 2026, foreclosed properties remained relatively unchanged.

Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity

(Dollars in millions)

(1) Consumer loans may be returned to performing status when all principal and interest is current and full repayment of the remaining contractual principal and interest is expected, or when the loan otherwise becomes well-secured and is in the process of collection.

(2) Outstanding consumer loans and leases exclude loans accounted for under the fair value option.

Commercial Portfolio Credit Risk Management

Commercial credit risk is evaluated and managed with the goal that concentrations of credit exposure continue to be aligned with our risk appetite. We review, measure and manage concentrations of credit exposure by industry, product, geography, customer relationship and loan size. We also review, measure and manage commercial real estate loans by geographic location and property type. In addition, within our non-U.S. portfolio, we evaluate exposures by region and by country. Tables 29, 31 and 34 summarize our concentrations. We also utilize syndications of exposure to third parties, loan sales, hedging and other risk mitigation techniques to manage the size and risk profile of the commercial credit portfolio. For more information on our industry concentrations, see Table 31 and Commercial Portfolio Credit Risk Management – Industry Concentrations on page 33.

For more information on our accounting policies regarding delinquencies, nonperforming status and net charge-offs, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements of the Corporation’s 2025 Annual Report on Form 10-K and Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses to the Consolidated Financial Statements.

Commercial Credit Portfolio

Outstanding commercial loans and leases increased $22.9 billion during the three months ended March 31, 2026 due to growth in U.S. and Non-U.S. commercial, primarily in Global Banking and Global Markets. During the three months ended March 31, 2026, commercial credit quality improved, as the reservable criticized utilized exposure rate improved to 3.21 percent from 3.37 percent as of December 31, 2025.

Nonperforming commercial loans decreased $77 million during the three months ended March 31, 2026, primarily due to commercial real estate. Commercial net charge-offs increased $17 million compared to the same period in 2025 primarily due to higher U.S. commercial charge-offs, partially offset by continued improvement in the commercial real estate office portfolio.

We are closely monitoring emerging trends, including the ongoing conflicts in the Middle East and higher energy prices, as well as borrower performance in the current environment.

The commercial allowance for loan and lease losses increased $54 million during the three months ended March 31, 2026 to $4.9 billion. For more information, see Allowance for Credit Losses on page 36.

Total commercial utilized credit exposure increased $34.7 billion during the three months ended March 31, 2026 to $843.1 billion primarily driven by higher loans and leases, as well as derivative assets. The utilization rate for loans and leases, standby letters of credit (SBLCs) and financial guarantees, and commercial letters of credit, in the aggregate, was 56 percent and 55 percent at March 31, 2026 and December 31, 2025.

Table 25 presents commercial credit exposure by type for utilized, unfunded and total binding committed credit exposure. Commercial utilized credit exposure includes SBLCs and financial guarantees and commercial letters of credit that have been issued and for which we are legally bound to advance funds under prescribed conditions during a specified time period, and excludes exposure related to trading account assets. Although funds have not yet been advanced, these exposure types are considered utilized for credit risk management purposes.

Commercial Credit Exposure by Type

(Dollars in millions)

(1) Commercial utilized exposure includes loans of $3.6 billion and $3.3 billion accounted for under the fair value option at March 31, 2026 and December 31, 2025.

(2) Commercial unfunded exposure includes commitments accounted for under the fair value option with a notional amount of $2.4 billion and $2.3 billion at March 31, 2026 and December 31, 2025.

(3) Excludes unused business card lines, which are not legally binding.

(4) Includes the notional amount of unfunded legally binding lending commitments, net of amounts distributed (i.e., syndicated or participated) to other financial institutions. The distributed amounts were $10.5 billion and $10.6 billion at March 31, 2026 and December 31, 2025.

(5) Derivative assets are carried at fair value, reflect the effects of legally enforceable master netting agreements and have been reduced by cash collateral of $30.8 billion and $27.2 billion at March 31, 2026 and December 31, 2025. Not reflected in utilized and committed exposure is additional non-cash derivative collateral held of $72.1 billion and $71.4 billion at March 31, 2026 and December 31, 2025, which consists primarily of other marketable securities.

Nonperforming commercial loans decreased $77 million during the three months ended March 31, 2026, driven by commercial real estate. Table 26 presents our commercial loans and leases portfolio and related credit quality information at March 31, 2026 and December 31, 2025.

Commercial Credit Quality

(Dollars in millions)

(1) Includes card-related products.

(2) Commercial loans accounted for under the fair value option includes U.S. commercial of $2.5 billion and $2.1 billion and non-U.S. commercial of $1.1 billion and $1.2 billion at March 31, 2026 and December 31, 2025 For more information on the fair value option, see Note 15 – Fair Value Option to the Consolidated Financial Statements.

Table 27 presents net charge-offs and related ratios for the three months ended March 31, 2026 and 2025.

Commercial Net Charge-offs and Related Ratios

(Dollars in millions)

(1) Net charge-off ratios are calculated as annualized net charge-offs divided by average outstanding loans and leases, excluding loans accounted for under the fair value option.

Table 28 presents commercial reservable criticized utilized exposure by loan type. Criticized exposure corresponds to the Special Mention, Substandard and Doubtful asset categories as defined by regulatory authorities. Total commercial reservable criticized utilized exposure of $24.3 billion decreased $409

million, or two percent, during the three months ended March 31, 2026 primarily driven by commercial real estate and non-U.S. commercial. At both March 31, 2026 and December 31, 2025, 87 percent of commercial reservable criticized utilized exposure was secured.

Commercial Reservable Criticized Utilized Exposure (1, 2)

(Dollars in millions)

Commercial and industrial:

(1) Total commercial reservable criticized utilized exposure includes loans and leases of $23.5 billion and $23.9 billion and commercial letters of credit of $844 million and $869 million at March 31, 2026 and December 31, 2025.

(2) Percentages are calculated as commercial reservable criticized utilized exposure divided by total commercial reservable utilized exposure for each exposure category.

Commercial and Industrial

Commercial and industrial loans include U.S. commercial and non-U.S. commercial portfolios.

U.S. Commercial

At March 31, 2026, 57 percent of the U.S. commercial loan portfolio, excluding small business, was managed in Global Banking, 25 percent in Global Markets, 17 percent in GWIM (loans that provide financing for asset purchases, business investments and other liquidity needs for high net worth clients) and the remainder primarily in Consumer Banking. U.S. commercial loans increased $15.7 billion, or four percent, during the three months ended March 31, 2026 primarily driven by Global Banking. Reservable criticized utilized exposure increased $431 million, or four percent, driven by a broad range of industries.

Non-U.S. Commercial

At March 31, 2026, 51 percent of the non-U.S. commercial loan portfolio was managed in Global Banking and 48 percent in Global Markets. Non-U.S. commercial loans increased $5.7 billion, or four percent, during the three months ended March 31, 2026 primarily driven by Global Banking. Reservable criticized utilized exposure decreased $231 million, or eight percent. For more information on the non-U.S. commercial portfolio, see Non-U.S. Portfolio on page 35.

Commercial Real Estate

Commercial real estate primarily includes commercial loans secured by non-owner-occupied real estate and is dependent on the sale or lease of the real estate as the primary source of repayment. Outstanding loans increased $867 million or one

percent during the three months ended March 31, 2026 to $69.6 billion, driven by growth across multiple property types. The commercial real estate portfolio is primarily managed in Global Banking and consists of loans made primarily to public and private developers, and commercial real estate firms. The portfolio remains diversified across property types and geographic regions. California represented the largest state concentration at 20 percent of commercial real estate at both March 31, 2026 and December 31, 2025. Industrial/Warehouse loans represented the largest property type concentration at 18 percent and 19 percent of commercial real estate at March 31, 2026 and December 31, 2025. Office loans decreased $617 million, or five percent, from December 31, 2025 and represented less than one percent of total loans for the Corporation.

Reservable criticized utilized exposure for commercial real estate decreased $699 million, or eight percent, during the three months ended March 31, 2026. Reservable criticized exposure for the office property type was $3.1 billion at March 31, 2026, representing a decrease of $360 million, or 10 percent, from December 31, 2025. Approximately $4.4 billion of office loans are scheduled to mature by the end of 2026.

During the three months ended March 31, 2026, net charge-offs decreased $67 million to $56 million compared to the same period in 2025 driven by office loans. We use a number of proactive risk mitigation initiatives designed to reduce adversely rated exposure in the commercial real estate portfolio, including transfers of deteriorating exposures for management by independent special asset officers and the pursuit of loan restructurings or asset sales to achieve the best results for our customers and the Corporation.

Table 29 presents outstanding commercial real estate loans by geographic region, based on the geographic location of the collateral, and by property type.

Outstanding Commercial Real Estate Loans

(Dollars in millions)

U.S. Small Business Commercial

The U.S. small business commercial loan portfolio is comprised of small business card loans and small business loans primarily managed in Consumer Banking. Credit card-related products were 51 percent of the U.S. small business commercial portfolio at both March 31, 2026 and December 31, 2025, and represented 97 percent and 98 percent of net charge-offs for the three months ended March 31, 2026 and 2025. Accruing loans that were past due 90 days or more remained relatively unchanged during the three months ended March 31, 2026.

Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity

Table 30 presents the nonperforming commercial loans, leases and foreclosed properties activity during the three months ended March 31, 2026 and 2025. Nonperforming loans do not include loans accounted for under the fair value option. During the three months ended March 31, 2026, nonperforming commercial loans and leases decreased $77 million to $3.2 billion. At March 31, 2026, 96 percent of commercial nonperforming loans, leases and foreclosed properties were secured, and 46 percent were contractually current. Commercial nonperforming loans were carried at 82 percent of their unpaid principal balance, as the carrying value of these loans has been reduced to the estimated collateral value less costs to sell.

Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity (1, 2)

(Dollars in millions)

(1) Balances do not include nonperforming loans held-for-sale of $500 million and $583 million at March 31, 2026 and 2025.

(2) Includes U.S. small business commercial activity. Small business card loans are excluded as they are not classified as nonperforming.

(3) Commercial loans and leases may be returned to performing status when all principal and interest is current and full repayment of the remaining contractual principal and interest is expected, when the loan otherwise becomes well-secured and is in the process of collection, or when a modified loan demonstrates a sustained period of payment performance.

(4) Outstanding commercial loans exclude loans accounted for under the fair value option.

Industry Concentrations

Table 31 presents commercial committed and utilized credit exposure by industry. For information on net notional credit protection purchased to hedge funded and unfunded exposures for which we elected the fair value option, as well as certain other credit exposures, see Commercial Portfolio Credit Risk Management – Risk Mitigation.

Commercial credit exposure is diversified across a broad range of industries. Total commercial committed exposure increased $29.1 billion during the three months ended March 31, 2026 to $1.5 trillion. The increase in commercial committed exposure was concentrated in Asset managers and funds, Capital goods and Energy.

For information on industry limits, see Commercial Portfolio Credit Risk Management – Risk Mitigation in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

Asset managers and funds, our largest industry concentration with committed exposure of $242.8 billion, increased $8.4 billion, or four percent, during the three months ended March 31, 2026, which was primarily driven by investment-grade exposures.

Finance companies, our second largest industry concentration with committed exposure of $130.8 billion, increased $1.1 billion, or one percent, during the three months ended March 31, 2026. The increase in committed exposure was primarily driven by increases in Diversified financials and Thrifts and mortgage finance.

Capital goods, our third largest industry concentration with committed exposure of $112.7 billion, increased $4.0 billion, or four percent, during the three months ended March 31, 2026. The increase in committed exposure was driven by increases in Industrial conglomerates, Aerospace and defense and Trading companies and distributors, partially offset by a decrease in Electrical equipment.

Geopolitical tensions, particularly related to the ongoing conflicts in the Middle East, and higher costs associated with persistent inflationary pressures have led to increased uncertainty in the U.S. and global economies and have adversely impacted, and may continue to adversely impact, a number of industries. We continue to monitor these risks.

(Dollars in millions)

(1) Includes U.S. small business commercial exposure.

(2) Includes the notional amount of unfunded legally binding lending commitments, net of amounts distributed (i.e., syndicated or participated) to other financial institutions. The distributed amounts were $10.5 billion and $10.6 billion at March 31, 2026 and December 31, 2025.

(3) Industries are viewed from a variety of perspectives to best isolate the perceived risks. For purposes of this table, the real estate industry is defined based on the primary business activity of the borrowers or counterparties using operating cash flows and primary source of repayment as key factors.

Risk Mitigation

We purchase credit protection to cover the funded portion as well as the unfunded portion of certain credit exposures. To lower the cost of obtaining our desired credit protection levels, we may add credit exposure within an industry, borrower or counterparty group by selling protection.

At both March 31, 2026 and December 31, 2025, net notional credit default protection purchased in our credit derivatives portfolio to hedge our funded and unfunded exposures for which we elected the fair value option, as well as certain other credit exposures, was $14.5 billion. We recorded net gains of $12 million for the three months ended March 31, 2026 compared to net gains of $3 million for the three months ended March 31, 2025. The net gains on these instruments were largely offset by net losses on the related exposures. The Value-at-Risk (VaR) results for these exposures are included in the fair value option portfolio information in Table 37. For more information, see Trading Risk Management on page 38.

Tables 32 and 33 present the maturity profiles and the credit exposure debt ratings of the net credit default protection portfolio at March 31, 2026 and December 31, 2025.

Net Credit Default Protection by Maturity

Bank of America 34

Net Credit Default Protection by Credit Exposure Debt Rating

(Dollars in millions)

(1) Represents net credit default protection purchased.

(2) Ratings are refreshed on a quarterly basis.

(3) Ratings of BBB- or higher are considered to meet the definition of investment grade.

(4) NR is comprised of index positions held and any names that have not been rated.

For more information on credit derivatives and counterparty credit risk valuation adjustments, see Note 3 – Derivatives to the Consolidated Financial Statements of the Corporation’s 2025 Annual Report on Form 10-K.

Non-U.S. Portfolio

Our non-U.S. credit and trading portfolios are subject to country risk. We define country risk as the risk of loss from unfavorable economic and political conditions, currency fluctuations, social instability and changes in government policies. A risk management framework is in place to measure, monitor and manage non-U.S. risk and exposures. In addition to the direct risk of doing business in a country, we also are exposed to indirect country risks (e.g., related to the collateral received on secured financing transactions or related to client clearing activities). These indirect exposures are managed in the normal course of business through credit, market and operational risk governance rather than through country risk governance. For more information on our non-U.S. credit and trading portfolios, see Non-U.S. Portfolio in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K. For more information on risks related to our non-U.S. portfolio, see the Geopolitical section within Item 1A. Risk Factors of the Corporation’s 2025 Annual Report on Form 10-K.

Table 34 presents our 20 largest non-U.S. country exposures at March 31, 2026. These exposures accounted for 89 percent of our total non-U.S. exposure at March 31, 2026 and 88 percent at December 31, 2025. Net country exposure for these 20 countries increased $15.4 billion from December 31, 2025 primarily driven by increases in France, Germany, the United Kingdom and India.

Top 20 Non-U.S. Countries Exposure

(Dollars in millions)

Our largest non-U.S. country exposure at March 31, 2026 was the United Kingdom with net exposure of $67.4 billion, which increased $2.8 billion from December 31, 2025 primarily due to increased exposure to financial institutions. Our second largest non-U.S. country exposure was Germany with net exposure of $42.5 billion at March 31, 2026, which increased

$3.4 billion from December 31, 2025 primarily due to increased corporate exposure. We continue to closely monitor the ongoing conflicts in the Middle East and potential impacts on our portfolio and borrowers, including through higher energy prices, increased market volatility, supply chain disruptions and related macroeconomic effects.

Allowance for Credit Losses

The allowance for credit losses decreased $71 million from December 31, 2025 to $14.3 billion at March 31, 2026, which included a $96 million reserve decrease and $25 million reserve increase related to the consumer and commercial portfolios, respectively. Table 35 presents an allocation of the allowance for credit losses by product type at March 31, 2026 and December 31, 2025.

(Dollars in millions)

(1) Ratios are calculated as allowance for loan and lease losses as a percentage of loans and leases outstanding excluding loans accounted for under the fair value option.

(2) Includes allowance for loan and lease losses for U.S. small business commercial loans of $1.4 billion at both March 31, 2026 and December 31, 2025.

n/m = not meaningful

Table 36 presents a rollforward of the allowance for credit losses, including certain loan and allowance ratios for the three months ended March 31, 2026 and 2025. For more information on the Corporation’s credit loss accounting policies and activity related to the allowance for credit losses, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements of the Corporation’s 2025 Annual Report on Form 10-K and Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses to the Consolidated Financial Statements.

(Dollars in millions)

(1) Includes U.S. small business commercial charge-offs of $155 million and $147 million for the three months ended March 31, 2026 and 2025.

(2) Includes U.S. small business commercial recoveries of $12 million and $14 million for the three months ended March 31, 2026 and 2025.

(3) Ratios are calculated as allowance for loan and lease losses as a percentage of loans and leases outstanding excluding loans accounted for under the fair value option.

(4) Primarily includes amounts related to credit card and unsecured consumer lending portfolios in Consumer Banking.

Market Risk Management

For more information on our market risk management process, see Market Risk Management in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K. For more information on market risks, see the Market section within Item 1A. Risk Factors of the Corporation’s 2025 Annual Report on Form 10-K.

Market risk is the risk that changes in market conditions may adversely impact the value of assets or liabilities, or otherwise negatively impact earnings. This risk is inherent in the financial instruments associated with our operations, primarily within our Global Markets segment. We are also exposed to these risks in other areas of the Corporation (e.g., our ALM activities). In the event of market stress, these risks could have a material impact on our results.

Trading Risk Management

To evaluate risks in our trading activities, we focus on the actual and potential volatility of revenues generated by individual positions as well as portfolios of positions. VaR is a common statistic used to measure market risk. Our primary VaR statistic is equivalent to a 99 percent confidence level, which means that for a VaR with a one-day holding period, there should not be

losses in excess of VaR, on average, 99 out of 100 trading days.

Table 37 presents the total market-based portfolio VaR, which is the combination of the total trading positions portfolio and the fair value option portfolio. The VaR amounts for all periods presented in Table 37 and Table 38 include the financial instruments used in the Corporation’s market risk management of its trading portfolios. For more information on the market risk VaR for trading activities, see Trading Risk Management in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

The total market-based portfolio VaR results in Table 37 include market risk to which we are exposed from all business segments’ trading activities, which exclude credit valuation adjustment (CVA), DVA and the related hedges of these items. The majority of this portfolio is within the Global Markets segment.

Table 37 presents period-end, average, high and low daily trading VaR for the three months ended March 31, 2026, December 31, 2025 and March 31, 2025 using a 99 percent confidence level.

(Dollars in millions)

(1) The high and low for each portfolio may have occurred on different trading days than the high and low for the components. Therefore, the amount of portfolio diversification, which is the difference between the total portfolio and the sum of the individual components, is not relevant.

n/a = not applicable

The following graph presents the trading positions portfolio VaR for the previous five quarters, corresponding to the data in Table 37.

Additional VaR statistics produced within our single VaR model are provided in Table 38 at the same level of detail as in Table 37. Evaluating VaR with additional statistics allows for an increased understanding of the risks in the portfolio, as the historical market data used in the VaR calculation does not necessarily follow a predefined statistical distribution. Table 38 presents average trading VaR statistics at 99 percent and 95 percent confidence levels for the three months ended March 31, 2026, December 31, 2025 and March 31, 2025.

Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics

(Dollars in millions)

Backtesting

The accuracy of the VaR methodology is evaluated by backtesting, which compares the daily VaR results, utilizing a one-day holding period, against a comparable subset of trading revenue. For more information on our backtesting process, see Trading Risk Management – Backtesting in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

During the three months ended March 31, 2026, there were two days where this subset of trading revenue had losses that exceeded our total covered portfolio VaR, utilizing a one-day holding period.

Total Trading-related Revenue

Total trading-related revenue, excluding brokerage fees, and CVA, DVA and funding valuation adjustment gains (losses), represents the total amount earned from trading positions, including net interest income associated with Global Markets trading activities, which are taken in a diverse range of financial instruments and markets. For more information, see Trading Risk Management – Total Trading-related Revenue in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

The following histogram is a graphic depiction of trading volatility and illustrates the daily level of trading-related revenue

for the three months ended March 31, 2026 compared to the three months ended December 31, 2025. During the three months ended March 31, 2026, positive trading-related revenue was recorded for 100 percent of the trading days, of which 97 percent were daily trading gains of over $25 million. This compares to the three months ended December 31, 2025 where positive trading-related revenue was recorded for 98 percent of the trading days, of which 89 percent were daily trading gains of over $25 million, and the largest loss was $2 million.

Trading Portfolio Stress Testing

Because the very nature of a VaR model suggests results can exceed our estimates and it is dependent on a limited historical window, we also stress test our portfolio using scenario analysis. This analysis estimates the change in the value of our trading portfolio that may result from abnormal market movements. For more information, see Trading Risk Management – Trading Portfolio Stress Testing in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

Interest Rate Risk Management for the Banking Book

The following discussion presents net interest income for banking book activities. For more information, see Interest Rate Risk Management for the Banking Book in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

Table 39 presents the spot and 12-month forward rates used in developing the forward curve used in our baseline forecasts at March 31, 2026 and December 31, 2025.

Forward Rates

Table 40 shows the potential pretax impact to forecasted net interest income over the next 12 months from March 31, 2026 and December 31, 2025 resulting from instantaneous parallel and non-parallel shocks to the market-based forward curve. Periodically, we evaluate the scenarios presented so that they are meaningful in the context of the current rate environment. Amounts presented reflect dynamic deposit sensitivities, which incorporate behavioral customer deposit balance changes that could occur under various scenarios. For more information, see Interest Rate Risk Management for the Banking Book in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

Estimated Banking Book Net Interest Income Sensitivity to Curve Changes

(Dollars in billions)

We continue to be asset sensitive to a parallel move in interest rates, with the majority of that impact coming from the short end of the yield curve. Additionally, higher interest rates negatively impact the fair value of our debt securities classified as available for sale and adversely affect accumulated OCI, and thus capital levels under the Basel 3 capital rules. Under instantaneous upward parallel shifts, the near-term adverse impact to Basel 3 capital would be reduced over time by offsetting positive impacts to net interest income generated from banking book activities. For more information on Basel 3, see Capital Management – Regulatory Capital on page 16.

As part of our ALM activities, we use securities, certain residential mortgages, and interest rate and foreign exchange derivatives in managing interest rate sensitivity. The sensitivity analysis in Table 40 assumes that we take no action in response to these rate shocks and does not assume any change in other macroeconomic variables normally correlated with changes in interest rates. In higher rate scenarios, the analysis assumes that a portion of low-cost or noninterest-bearing deposits is replaced with higher yielding deposits or market-based funding. Conversely, in lower rate scenarios, the analysis assumes that a portion of higher yielding deposits or market-based funding is replaced with low-cost or noninterest-bearing deposits.

For larger interest rate shift scenarios, the interest rate sensitivity may behave in a non-linear manner as there are numerous estimates and assumptions, which require a high

degree of judgment and are often interrelated, that could impact the outcome. Pertaining to the mortgage-backed securities and residential mortgage portfolio, if long-end interest rates were to significantly decrease over the next twelve months, for example over 200 bps, there would generally be an increase in customer prepayment behaviors with an incremental reduction to net interest income, noting that the extent of changes in customer prepayment activity can be impacted by multiple factors and is not necessarily limited to long-end interest rates. Conversely, if long-end interest rates were to significantly increase over the next twelve months, for example, over 200 bps, customer prepayments would likely modestly decrease and result in an incremental increase to net interest income. In addition, deposit pricing is rate sensitive in nature. This sensitivity is assumed to have non-linear impacts to larger short-end rate movements. In decreasing interest rate scenarios, and particularly where interest rates have decreased to small amounts, the ability to further reduce rates paid is reduced as customer rates near zero. In higher short-end rate scenarios, deposit pricing will likely increase at a faster rate, leading to incremental interest expense and reducing asset sensitivity. While the impact related to the above assumptions used in the asset sensitivity analysis can provide directional analysis on how net interest income will be impacted in changing environments, the ultimate impact is dependent upon the interrelationship of the assumptions and factors, which vary in different macroeconomic scenarios.

Economic Value of Equity

In addition to interest rate sensitivity described above, the Corporation’s management of its interest rate exposures in the banking book also considers a long-term view of interest rate sensitivity through the measurement of Economic Value of Equity (EVE). EVE captures changes in the net present value of banking book assets and liabilities under various interest rate scenarios and its impact to Tier 1 capital. Similar to net interest income, the Corporation establishes limits for EVE. EVE is largely driven by the Corporation’s longer duration fixed-rate products, such as investment securities, residential mortgages and deposits. For assets or liabilities that have no stated maturity, such as deposits, the Corporation estimates the duration for measurement purposes.

Interest Rate and Foreign Exchange Derivative Contracts

We use interest rate and foreign exchange derivative contracts in our ALM activities to manage our interest rate and foreign exchange risks. Specifically, we use those derivatives to manage both the variability in cash flows and changes in fair value of various assets and liabilities arising from those risks. Our interest rate derivative contracts are generally non-leveraged swaps tied to various benchmark interest rates and foreign exchange basis swaps, options, futures and forwards, and our foreign exchange contracts include cross-currency interest rate swaps, foreign currency futures contracts, foreign currency forward contracts and options.

The derivatives used in our ALM activities can be split into two broad categories: designated accounting hedges and other risk management derivatives. Designated accounting hedges are primarily used to manage our exposure to interest rates as described in the Interest Rate Risk Management for the Banking Book section and are included in the sensitivities presented in Table 40. The Corporation also uses foreign currency derivatives in accounting hedges to manage substantially all of the foreign exchange risk of our foreign operations. By hedging the foreign exchange risk of our foreign operations, the Corporation's market risk exposure in this area is not significant.

Risk management derivatives are predominantly used to hedge foreign exchange risks related to various foreign currency-denominated assets and liabilities and eliminate substantially all foreign currency exposures in the cash flows of the Corporation’s non-trading foreign currency-denominated financial instruments. These foreign exchange derivatives are sensitive to other market risk exposures such as cross-currency basis spreads and interest rate risk. However, as these features are not a significant component of these foreign exchange derivatives, the market risk related to this exposure is not significant. For more information on the accounting for derivatives, see Note 3 – Derivatives to the Consolidated Financial Statements.

Mortgage Banking Risk Management

We originate, fund and service mortgage loans, which subject us to credit, liquidity and interest rate risks, among others. We determine whether loans will be held for investment or held for sale at the time of commitment and manage credit and liquidity risks by selling or securitizing a portion of the loans we originate.

Changes in interest rates impact the value of interest rate lock commitments (IRLCs) and the related residential first mortgage loans held-for-sale (LHFS), as well as the value of the MSRs. Because the interest rate risks of these hedged items offset, we combine them into one overall hedged item with one combined economic hedge portfolio consisting of derivative contracts and securities. For more information on IRLCs and the related residential mortgage LHFS, see Mortgage Banking Risk Management in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K.

Critical Accounting Estimates

Our significant accounting principles are essential in understanding the MD&A. Many of our significant accounting principles require complex judgments to estimate the values of assets and liabilities. We have procedures and processes in place to facilitate making these judgments. For more information, see Critical Accounting Estimates in the MD&A of the Corporation’s 2025 Annual Report on Form 10-K and Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements of the Corporation’s 2025 Annual Report on Form 10-K.

Non-GAAP Reconciliations

Table 41 provides reconciliations of certain non-GAAP financial measures to the most directly comparable GAAP financial measures.

Average and Period-end Supplemental Financial Data and Reconciliations to GAAP Financial Measures (1)

(Dollars in millions)

(1) For more information on non-GAAP financial measures and ratios we use in assessing the results of the Corporation, see Supplemental Financial Data on page 5.

See Market Risk Management on page 38 in the MD&A and the sections referenced therein for Quantitative and Qualitative Disclosures about Market Risk.

Disclosure Controls and Procedures

As of the end of the period covered by this report, the Corporation’s management, including the Chief Executive Officer and Chief Financial Officer, conducted an evaluation of the effectiveness and design of the Corporation’s disclosure controls and procedures (as that term is defined in Rule 13a-15(e) of the Exchange Act). Based upon that evaluation, the Corporation’s Chief Executive Officer and Chief Financial Officer concluded that the Corporation’s disclosure controls and procedures were effective, as of the end of the period covered by this report.

Changes in Internal Control Over Financial Reporting

There have been no changes in the Corporation’s internal control over financial reporting (as defined in Rule 13a-15(f) of the Exchange Act) during the three months ended March 31, 2026, that have materially affected, or are reasonably likely to materially affect, the Corporation’s internal control over financial reporting.

There are no material changes from the risk factors set forth under Part 1, Item 1A. Risk Factors of the Corporation’s 2025 Annual Report on Form 10-K.