10-K – 2026-02-24 – zions-20251231.htm

available. Furthermore, changes to FHLB or Federal Reserve funding programs could adversely affect our liquidity and the effectiveness of our risk management efforts.
Unfavorable rating actions by credit rating agencies could negatively impact our organization as well as the holders of our securities.
We access capital markets to supplement our funding sources, and our ability to do so is influenced by the credit ratings assigned to us by rating agencies. These ratings are based on various factors, including the Bank's financial strength and external conditions affecting the broader financial services industry. The interest rates applicable to our issued securities are also impacted by these credit ratings. Any downgrade of our ratings or those of our securities could result in higher funding costs and may negatively impact our liquidity position, financial condition, or the market valuation of our securities.
For more information on our approach to managing liquidity risk, including considerations related to rating agency actions, see “Liquidity Risk Management” in MD&A on page 75.
STRATEGIC AND BUSINESS RISK
Challenges experienced by other financial institutions could negatively impact the broader financial markets and, in turn, indirectly have an adverse effect on our operations.
The soundness and stability of many financial institutions are often closely interconnected through various credit, trading, clearing, or other operational relationships. As a result, concerns regarding—or an actual or threatened default by—any single institution could lead to widespread liquidity and credit problems, losses, or defaults across the broader financial system. This phenomenon, commonly referred to as “systemic risk,” may adversely affect financial intermediaries such as clearing agencies, clearing houses, banks, securities firms, and exchanges with which we regularly engage, and may therefore negatively impact our operations.
Events in the financial services industry during 2023 illustrated this dynamic. A number of regional and community banks experienced deposit outflows and heightened liquidity pressures, which in turn contributed to broad market concerns about the financial condition and creditworthiness of other institutions. These developments resulted in—and similar occurrences may again result in—significant and cascading disruptions across financial markets and the deposit environment, increased operating costs, reduced fee income, and increased volatility and downward pressure on the market value of our common stock.
We may face challenges in attracting and retaining qualified personnel or effectively fostering our corporate culture. Additionally, recruiting and compensation costs may increase as a result of evolving workplace dynamics, market conditions, economic factors, and regulatory changes.
Our ability to successfully execute strategic initiatives, deliver high-quality services, and remain competitive may be adversely affected if we are unable to recruit and retain qualified personnel, or if employee compensation and benefits expenses increase significantly. Regulatory guidance and rules issued by banking authorities impose restrictions on the structure and amount of compensation that financial institutions may offer, which can hinder our capacity to attract and retain key personnel. These constraints may place us at a disadvantage relative to competitors—particularly financial technology firms and other entities not subject to the same regulatory limitations—when competing for skilled professionals.
Additionally, broader economic conditions and evolving workforce dynamics, including shifting employee priorities, regulatory expectations, increased geographic mobility, and the adoption of remote work models, may further challenge our talent retention efforts and contribute to increased compensation demands, associated costs, or other operational challenges. Moreover, inflationary pressures have led to increased compensation costs, a trend that is expected to persist and may continue to impact our financial performance. If we experience such adverse effects with respect to our employees, our business, financial condition, and results of operations could be adversely or materially impacted.
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We have undertaken, and continue to implement, significant initiatives to improve operating efficiency and strengthen our internal control environment. The ultimate success, timely completion, and overall impact of these efforts may differ significantly from expectations, and any such deviation could have a material adverse effect on our organization.
We continue to invest in a variety of strategic initiatives designed to enhance our product and service offerings while simplifying business operations. These initiatives include organizational restructuring, efficiency enhancements, and the replacement or upgrading of technology systems. These initiatives, along with other significant changes, remain ongoing and are at varying stages of development. Due to the inherent complexity of such projects, estimates related to timelines, costs, anticipated savings, operational efficiencies, and other potential outcomes are subject to change and may vary significantly. Accordingly, there can be no assurance that the expected benefits or intended results of these initiatives will be realized.
Our ability to effectively develop, adopt, implement, and deliver technological innovations may significantly impact our financial performance and could adversely affect our business.
Our ability to remain competitive increasingly depends on maintaining robust technological capabilities and continuously identifying and developing innovative, value-added products for both current and prospective customers. Competitive pressures in technology arise from traditional banking and nontraditional sources. Larger banks often benefit from greater resources and economies of scale, enabling them to maintain advanced capabilities and accelerate the development or adoption of digital and emerging technologies.
In addition, fintechs and other technology-driven platforms are expanding their presence, offering a wide variety of products and services that challenge traditional banking models. The growing experimentation with and adoption of advanced technologies—such as AI, quantum computing, tokenized deposits, blockchain, stablecoins, and other digital currencies, including the potential issuance, acceptance, and integration of central bank digital currencies—has the potential to fundamentally reshape the financial services landscape. Regulatory developments related to these emerging technologies, including the recent enactment of the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (“GENIUS Act”) and the potential passage of the Digital Asset Market Clarity Act of 2025 (“CLARITY Act”), further underscore this shift. Failure to keep pace with technological advancements could adversely affect our competitive position, diminish customer satisfaction, and reduce the accessibility and relevance of our products and services.
We operate in a highly competitive environment, both in the range of products and services we provide and across the geographic markets in which we conduct business.
Consolidation in our industry—whether through smaller banks merging to create larger, more competitive institutions or through combinations of banks and non-bank entities—may intensify competitive pressures, particularly in affected regions or for specific products. To the extent we expand into new markets, we may encounter competitors with greater experience and established customer relationships, which could adversely impact our ability to compete effectively. Failure to adequately respond to these competitive dynamics could hinder our ability to attract and retain customers across our businesses.
OPERATIONAL RISK
Our operations may experience disruptions as a result of the implementation and impact of new and ongoing projects and initiatives.
We may face significant operational disruptions in connection with the execution of our various strategic projects and initiatives. Potential challenges include extended implementation timelines, budget overruns, loss of key personnel, technological issues, and processing errors. Additionally, disruptions may arise from capacity limitations, service level deficiencies, suboptimal performance, and costs associated with system replacements and upgrades.
Such issues could adversely affect our systems, operational processes, internal controls, procedures, workforce, and customer experience. In the event of a significant disruption, we could be subject to increased regulatory oversight, exposure to civil litigation, and potential financial liabilities or reputational risk. These outcomes could materially affect our control environment, operational efficiency, and overall financial performance.
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We could be adversely affected by failures in our internal controls.
Despite their design and implementation, our internal controls are subject to inherent limitations and may not fully prevent or detect operational failures or misstatements in our financial statements. Such issues may arise from inadequate or failed internal processes and systems, human error or misconduct, or adverse external events. A failure in our internal controls could materially and negatively affect our financial performance and earnings. Moreover, any perceived weakness in our internal controls may undermine stakeholder confidence—including that of customers, regulators, and investors—potentially resulting in reputational harm and adverse impacts on our business operations and stock price.
We could be adversely affected by internal and external fraud schemes.
We continue to face persistent and increasingly sophisticated attempts to defraud the Bank and our customers from a variety of sources. The frequency of these schemes may increase in an adverse economic environment. Our ability to identify and prevent fraud depends on the effectiveness of our systems, processes, and personnel; however, despite the safeguards we have implemented, some fraudulent activities may still go undetected. As a result, we may not be able to detect, prevent, or mitigate all future incidents, which could lead to material financial losses. Furthermore, even in cases where we are not financially responsible for reimbursing customers for fraudulent losses, such incidents can harm our reputation and impair our ability to attract and retain customers.
Climate-related and other catastrophic events may adversely impact our organization, our customers, the broader economy, financial and capital markets, and certain industries.
The occurrence of pandemics, natural disasters, and other climate-related or catastrophic events could materially and adversely affect our operations and financial performance. We maintain substantial operations and serve a significant customer base in regions such as Utah, Texas, California, and other regions—areas which are historically susceptible to natural and other environmental disasters. These include hurricanes, tornadoes, earthquakes, wildfires, floods, mudslides, prolonged droughts, and other weather-related events, many of which may be exacerbated by the effects of climate change and occur with increasing frequency and severity. Events, such as the 2025 wildfires in Southern California, have presented physical risks to our facilities, disrupted local economic activity, and adversely affected our business and customers—particularly through reduced access to insurance and essential services. Additionally, similar events occurring in other parts of the world may also have indirect impact on our operations and customers.
We utilize models to support the Bank’s management and decision-making processes. Inaccurate assumptions or non-representative training data within these models could lead to unreliable outputs or suboptimal decisions, which could adversely affect our operations.
We utilize various models in the management of the Bank, including those used to estimate the allowance for credit losses (“ACL”), manage interest rate and liquidity risk, project stress-related losses across segments of our loan and investment portfolios, and forecast net revenue under adverse conditions. However, models are inherently subject to limitations and cannot precisely predict future outcomes. Weaknesses in model design—such as inaccurate assumptions or reliance on historical data used to “train” or calibrate models that may not reflect current or expected conditions—could lead to inaccurate or misleading outputs. Consequently, decisions based on these models may occasionally be suboptimal. For more information about our deposit models, see “Interest Rate and Market Risk Management” in MD&A on page 72.
We outsource certain operations to third-party providers, which may pose risks that could adversely affect our business and operational performance.
We rely on various external suppliers to perform operational activities that support our business operations. While these partnerships offer strategic and operational advantages, they also present a range of risks. These risks vary based on factors including the nature and volume of data accessed or processed by suppliers, the concentration of services they deliver, their exposure to downstream service providers, and the geographic locations—both domestic and international— from which services are provided. Our internal control and third-party risk management frameworks may not always provide adequate oversight or mitigate all potential exposure. Substandard performance by third-party providers can adversely affect our ability to deliver products and services effectively, disrupt business
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continuity, and negatively impact customer experience. Moreover, replacing or identifying suitable alternatives for underperforming suppliers can be difficult and costly, particularly when swift transitions are required due to unforeseen circumstances.
Additionally, many of our suppliers have experienced operational challenges arising from inflationary pressures, wars and geopolitical conflicts, international trade policies, cyber threats, natural disasters, and other disruptive events. These external factors may, in turn, adversely affect our operations and service delivery.
For additional information about how we manage operational risk, see “Operational, Technology, and Cybersecurity Risk Management” in MD&A on page 78.
TECHNOLOGY RISK
Our operations and customer-facing services may be adversely affected by system vulnerabilities, failures, or outages.
We rely on various information technology systems to support both internal operations and customer-facing services. A vulnerability, failure, or outage affecting any of these systems could affect our ability to execute critical functions and deliver services to customers, such as online banking, mobile banking, remote deposit capture, treasury and payment services, and other services dependent on system processing. These risks are heightened as systems and software approach the end of their useful life or require increasingly frequent updates and modifications. Although we maintain well-established business continuity, disaster recovery, and crisis management protocols, these measures may not be sufficient to fully restore operations in the event of a significant system disruption. As such, we cannot ensure that such incidents will not result in significant operational or customer-facing impacts.
For risks related to technology system enhancements, see “Strategic and Business Risk” in Risk Factors on page 17.
The development and use of AI technologies present risks and challenges that could materially and adversely affect our business, financial condition, and results of operations.
We are in the early stages of integrating AI into certain aspects of our business operations with the objective of enhancing employee productivity and operational efficiency. At present, we have not implemented fully autonomous AI-driven systems in critical decision-making processes or client-facing activities. Instead, we utilize certain AI solutions to support, inform, or augment decision-making and client interactions, with all final actions subject to human oversight and review. We anticipate that AI technologies may become increasingly integrated into our operations over time. Additionally, some vendors or third-party service providers may incorporate AI within their products, services, or processes, which could indirectly impact our business.
AI models present unique risks, including the potential for “hallucinations”—instances where the system produces outputs that appear credible but are factually incorrect or misleading. Such errors may lead to inaccurate information being used in decision-making or communicated externally. AI models may also reflect biases inherent in their training data, which could lead to inaccurate outputs, inadvertent disclosure of confidential information, infringement of intellectual property rights, lack of transparency, or other adverse outcomes. The complexity of many AI models also makes them difficult to fully assess, potentially exposing us to financial liability, regulatory scrutiny, or reputational harm.
We are also exposed to risks arising from the use of AI by threat actors to commit fraud, misappropriate funds, and facilitate cyberattacks. If leveraged against us—or against other financial institutions, securities exchanges, or similar organizations—AI‑enabled threats could pose risks to our operational stability.
Any reliance on AI introduces a number of risks and challenges. The legal and regulatory environment governing AI remains uncertain and is evolving rapidly, both in the U.S. and internationally. Emerging frameworks include regulations specifically targeting AI technologies. Changes in applicable laws and regulations may require us to modify our approach to AI adoption, increase compliance costs, and heighten the risk of non-compliance. Additionally, challenges in monitoring and governing models over time—including changes in data inputs—may result in unintended deterioration in model accuracy.
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For more information about our approach to managing technology-related risks, see “Operational, Technology, and Cybersecurity Risk Management” in MD&A on page 78.
CYBERSECURITY RISK
We are exposed to risks related to information system failures and cybersecurity threats, which could adversely impact our business operations and financial performance.
We rely extensively on communications and information systems to support our business operations. These systems process and store confidential, proprietary, personal, or otherwise sensitive data, including financial and other confidential business information. Like other financial institutions, we and our customers are subject to persistent and increasingly sophisticated cyber threats from a range of threat actors, including organized cybercriminals, hackers, and state-sponsored organizations. The proliferation of advanced technologies—such as AI—alongside widespread internet connectivity and increased sophistication of the activities of threat actors has significantly heightened information security risks across the financial services industry.
Emerging technologies—including generative AI, mobile platforms, quantum computing, and cloud computing—continue to heighten operational and cybersecurity risks. The complexity and unpredictability of these technologies, as well as limited control over certain aspects of their security, present additional challenges. Threat actors employ a variety of tactics, including exploiting system vulnerabilities or misconfigurations, launching denial-of-service attacks, deploying ransomware, compromising business email systems, deceiving employees through email phishing and social engineering, and targeting our suppliers. These threats can be difficult to detect over extended periods and may be further exacerbated by the use of AI.
Third-party providers, including suppliers and their subcontractors, present operational and information security risks. These risks include potential security breaches or failures within their systems or those of their downstream partners. In such instances, we may not receive timely notification of incidents affecting our services or data, nor have the ability to participate in related investigations, disclosures, or remediation efforts. Additional risks may arise from human error, noncompliance with security protocols, or intentional misconduct by employees or third parties. Our ability to control and monitor the operational and cybersecurity measures implemented by third-party providers is limited, and under applicable laws, regulations, or contractual obligations, we may be held responsible for cyber incidents within third-party systems that impact us or our customers.
As cybersecurity threats continue to evolve, we remain committed to allocating the necessary resources in an effort to strengthen our defenses and address any information security vulnerabilities. While past cybersecurity incidents involving our systems and those of our third-party providers have not resulted in material impacts to our data, customers, or operations, we cannot guarantee that future incidents will not occur or that they will be effectively mitigated. The potential severity and consequences of such events are inherently uncertain.
Furthermore, system upgrades and enhancements may introduce risks related to implementation and integration with existing infrastructure. Given the complexity and interdependence of our technology environment, efforts to improve security can inadvertently lead to system disruptions or new vulnerabilities. Additional risks may arise if hardware and software vendors are unable to deliver timely patches or if we are unable to implement necessary updates promptly—particularly in cases where threat actors are actively exploiting known vulnerabilities.
Despite substantial investments in cybersecurity, our systems may remain susceptible to evolving threats, and our mitigation efforts may be deemed inadequate by regulatory authorities or courts. Any failure, disruption, or security incident—whether actual or perceived—affecting our communications and information technology systems or those of our third-party providers could impact our operations and services, damage our reputation, result in loss of customer business, increase regulatory scrutiny, expose us to civil litigation and financial liability, and lead to other material adverse consequences.
Furthermore, any insurance coverage we maintain may be insufficient to fully compensate for losses arising from the foregoing risks. We also cannot assure that such coverage will remain available on acceptable terms, or at all, or that insurers will not deny coverage for future claims.
For information about our cybersecurity risk management practices, see Part I, Item 1C. Cybersecurity on page 26.
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CAPITAL/FINANCIAL REPORTING RISK
Internal stress testing and capital management requirements, together with provisions of the National Bank Act and OCC regulations, may limit our ability to increase dividends, repurchase shares of our stock, or access capital markets.
We utilize stress testing as an important tool for informing decisions regarding the appropriate level of capital to maintain under adverse economic conditions. These tests are based on hypothetical scenarios that reflect a severity comparable to those published by the FRB. Compliance with stress testing and other applicable regulatory requirements may require actions such as increasing capital levels, limiting dividend payments or other capital distributions to shareholders, modifying business strategies, or reducing exposure to specific asset classes. Under the National Bank Act and OCC regulations, certain capital-related transactions, including share repurchases, require prior approval from the OCC. These regulatory constraints may limit our ability to respond to and take advantage of evolving market opportunities.
Regulatory requirements, prevailing economic conditions, and other factors may require us to raise capital under circumstances or in amounts that are unfavorable to us.
We are subject to risk-based and leverage capital ratio requirements established by our federal banking regulators. These ratios may fluctuate based on broader economic conditions, our specific risk profiles, and strategic growth plans. Compliance with these capital requirements may limit our ability to pursue expansion and has, at times, required the retention of earnings or the issuance of additional capital that might otherwise have been distributed to shareholders. Moreover, legislative and regulatory frameworks introduce additional uncertainty and risks. Recent regulatory proposals—such as those aimed at significantly revising capital standards and expanding long-term debt requirements for large banking organizations—may increase our cost of capital and other financing expenses. For more information about these regulatory proposals, see “Regulatory Developments” in Supervision and Regulation on page 9.
We may be adversely affected by risks related to accounting, financial reporting, and regulatory compliance.
We are subject to risks associated with accounting, financial reporting, and regulatory compliance. The accurate reporting of our financial condition and performance requires the application of significant estimates, judgments, and interpretations of complex and evolving accounting and regulatory standards. Modifications to accounting policies or changes in applicable accounting standards could materially impact the presentation of our financial results. The ongoing identification, interpretation, and implementation of complex and frequently changing accounting and regulatory requirements represent a persistent risk to our operations.
The value of our goodwill may decline in the future.
If the fair value of a reporting unit is determined to be lower than its carrying value, we would be required to recognize a goodwill impairment charge. Such a charge may arise due to various factors, including deterioration in the economic environment, a decline in the financial performance of the reporting unit, or the emergence of new legislative or regulatory developments that were not anticipated in management’s forecasts.
We may be unable to fully realize our DTAs, which could negatively impact our operating results and overall financial performance.
At December 31, 2025, we had a net deferred tax asset (“DTA”) of $714 million. The accounting treatment for the realization of DTAs involves complex considerations and requires significant management judgment. Our ability to fully realize the value of these assets may be adversely affected if future projections of taxable income, anticipated reversals of existing deferred tax liabilities (“DTLs”), or the effectiveness of tax planning strategies do not sufficiently support their recoverability. Additionally, changes in applicable tax laws and regulations, as well as shifts in macroeconomic or market conditions, may adversely impact our financial results. Accordingly, there can be no assurance that we will be able to fully realize our DTAs.
For information about our capital management approach, see “Capital Management” in MD&A on page 80.
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LEGAL/COMPLIANCE RISK
Laws and regulations applicable to us and the broader financial services industry impose significant restrictions on our business activities, subjecting us to heightened regulatory oversight and increased compliance costs.
We, along with the broader financial services industry, have incurred—and will continue to incur—significant personnel, systems, consulting, and other costs required to comply with evolving banking regulations. For additional information regarding the regulatory frameworks applicable to us and the financial services industry generally, see “Supervision and Regulation” on page 7.
Regulators, federal and state legislatures, the current administration, the U.S. Congress, and other governing or advisory bodies continue to implement rules, laws, and policies that affect financial institutions and public companies. These measures are often intended to promote, restrict, or penalize particular activities or industries, thereby influencing their access to financial services.
Additionally, initiatives such as the current administration's recent proposal to cap credit card interest rates at 10%, along with similar federal and state proposals to limit bank fees and interest rates, may negatively affect bank profitability and limit their ability to offer certain products and services. As a provider of financial products and services across multiple industries and geographic markets, we are subject to these regulatory frameworks and may be affected by future legislative developments. Because the scope and impact of these laws and regulations continue to change, their ultimate effect on our business operations and financial performance cannot be predicted.
Although the timing and likelihood of proposed regulatory changes remain uncertain, any resulting implementation could adversely affect our operations and financial results. Potential consequences include reduced revenues and after-tax returns for financial institutions, constraints on growth, increased FDIC insurance assessments, higher taxes or fees on funding and activities, limitations on the products and services we are able to offer, increased regulatory or legal compliance costs, and potential requirements to raise additional capital under unfavorable market conditions.
Political developments—including those resulting from administrative transitions and shifts in congressional control—can introduce volatility and uncertainty, potentially leading to significant changes in the size, scope, and effectiveness of government agencies and services.
Political developments may result in rapid changes to legislation, public policy, and governmental operations. Several initiatives under the current administration could heighten uncertainty and volatility in both U.S. and global financial markets, potentially affecting the government's capacity to deliver services at historical levels. These shifts may also affect our ability to obtain timely guidance and support from regulatory authorities in managing current and emerging risks, including those related to climate-related events, cybersecurity, privacy, AI, quantum computing, digital assets, and public safety. Many proposed measures remain subject to legal challenges or require additional legislative approval prior to implementation. Consequently, the timing, scope, and ultimate impact of these developments are uncertain and may produce either favorable or adverse effects on our business operations, financial performance, and customer relationships.
Legislative, administrative, and judicial changes to tax laws, regulations, or case law could adversely affect our business operations and financial performance.
We are subject to income tax laws in the U.S., its individual states, and other jurisdictions in which we operate. These laws are inherently complex and open to varying interpretations by both taxpayers and taxing authorities. In determining our income tax provision, management exercises judgments and relies on estimates to interpret applicable statutes, related regulations, and case law. While we strive to apply reasonable interpretations of the tax laws in preparing our tax filings, these positions may be challenged during audits or reassessed based on evolving legal precedents and factual developments. Changes in tax legislation, regulatory guidance, or judicial rulings may adversely affect our effective tax rate, overall tax liabilities, and financial results. For example, provisions of the recently enacted One Big Beautiful Bill Act relating to charitable giving have affected the timing, deductibility, and amount of our contributions. Additionally, adjustments resulting from tax authority audits could negatively impact our financial position.
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We may be adversely impacted by legal and governmental proceedings.
We are subject to risks arising from legal claims, litigation, and regulatory or governmental proceedings. Our exposure to such matters may increase due to a variety of factors, including economic pressures affecting customers and counterparties, a rise in claims and actions related to fraudulent schemes involving our customers, the implementation of new regulations under recently enacted legislation, changes in political leadership and priorities, and heightened enforcement and legal actions targeting financial institutions.
These proceedings may result in material adverse effects on our financial condition, operating results, or ability to conduct business. Potential consequences include unfavorable judgments, settlements, fines, civil money penalties, injunctions, operational restrictions, or other forms of relief. Although we maintain insurance coverage intended to mitigate financial exposure related to legal defense, settlements, and awards, such coverage is subject to deductibles and policy limits and may not fully offset all associated costs.
Participation in legal or regulatory matters—regardless of outcome—can also negatively impact our reputation and divert management attention from core business operations. Moreover, the financial services industry has experienced a notable increase in settlement amounts, which has adversely affected our ability to obtain insurance coverage for certain claims, raised deductible thresholds, and driven up premium costs. As a result, our financial performance is increasingly susceptible to adverse outcomes from legal proceedings.
Given the inherent uncertainty in forecasting the timing and financial impact of litigation and enforcement actions, adverse effects may occur sporadically and could be significant. Additionally, regulatory enforcement actions may influence our supervisory and CRA ratings, potentially limiting or restricting certain business activities.
The corporate and securities laws applicable to us are less developed than those governing state-chartered corporations, which may impact our ability to execute corporate transactions efficiently and effectively.
Our corporate affairs are governed by the National Bank Act, with related regulations administered by the OCC. In matters related to securities laws, the OCC enforces its own securities offering framework applicable to national banks and their securities issuances. Accordingly, our compliance with the Exchange Act is governed and enforced by the OCC.
State corporate statutes—such as those of Utah—are widely recognized, regularly updated through legislative processes, and often informed by model corporate law frameworks. Similarly, the federal securities law regime established under the Securities Act and the Exchange Act, along with the SEC’s comprehensive regulatory infrastructure, is broadly utilized by publicly traded companies.
The OCC’s statutory and regulatory frameworks, however, have been applied relatively infrequently to publicly traded banking institutions and remain less developed than the corporate and securities law regimes applicable to other public companies. While specific risks associated with operating under these frameworks are outlined below, the current lack of clarity and maturity in the OCC's approach may introduce uncertainty in the application of these rules to corporate or securities-related matters. This uncertainty could hinder our ability to execute transactions efficiently, optimally, or in some cases, at all.
Differences between the requirements of the National Bank Act and applicable state laws governing mergers could hinder our ability to execute acquisitions as efficiently or advantageously as bank holding companies and other financial institutions.
Unlike state corporate law, the National Bank Act requires shareholder approval for all mergers involving a national bank and another national or state-chartered bank, without providing exceptions for certain “minor” transactions—such as mergers between a parent company and its subsidiary, or transactions where an acquiring entity issues shares below a specified threshold to an unaffiliated party. Additionally, the National Bank Act and its implementing regulations may introduce complexities in structuring acquisitions involving nonbank entities.
These distinctions may adversely affect the ability of the Bank, and other institutions governed by the National Bank Act, to execute acquisition transactions efficiently. Furthermore, the requirement for shareholder approval in
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all merger scenarios may place us at a competitive disadvantage in certain circumstances, particularly when competing against institutions not subject to similar constraints, whose proposals may proceed without such conditions.
We are subject to restrictions on permissible activities, which limit the scope of business we can conduct and may complicate the acquisition of other financial institutions.
Under applicable laws and regulations, banks and bank holding companies are generally restricted to engaging in activities and making investments that are closely related to banking or are financial in nature. The scope of permissible financial activities is defined under the Gramm-Leach-Bliley Act, with banks subject to more limited authorities than bank holding companies. Notably, bank holding companies may engage in insurance underwriting and merchant banking activities, whereas banks are generally restricted from these lines of business, although insurance agency, broker-dealer, and investment advisory activities remain permissible.
Our structure as a standalone bank, without a bank holding company, may present challenges in pursuing future acquisitions of financial institutions that engage in activities permitted only for bank holding companies. This structural distinction could limit our strategic ability to expand into certain financial services sectors, potentially placing us at a competitive disadvantage.
REPUTATIONAL RISK
Operational, regulatory, compliance, and legal risks may harm our business and brands.
Any of the risks outlined in the Risk Factors section may result in harm to our business and brands, including negative publicity, unfavorable public perception, increased regulatory scrutiny, deterioration of stakeholder relationships, or other adverse effects.
OTHER RISKS
Wars, international trade policies and disputes, geopolitical conflicts, and retaliatory measures imposed by the U.S. and other countries—including the responses to such actions—may significantly disrupt both domestic and foreign economies and markets.
Recent geopolitical tensions—including wars, international trade disputes, and evolving global conflicts—have introduced heightened risks to global markets, trade dynamics, economic stability, and cybersecurity. These developments have affected, and may continue to affect, the availability and pricing of commodities and products, thereby disrupting supply chains and contributing to inflationary pressures. Additionally, they have affected currency valuations, interest rates, and other financial market indicators, while increasing the likelihood of cyberattacks that could result in significant costs and operational disruptions for governments and businesses alike. The impact of these conflicts and any retaliatory actions remains fluid and unpredictable. We expect that such geopolitical instability will continue to affect the global political landscape and exert influence over both international and domestic markets for the foreseeable future.
Although our operations have not been materially disrupted to date, future developments—such as cyberattacks targeting the U.S., the Bank, our customers, or our suppliers—could pose substantial challenges to our ability to conduct business effectively.
Diverging and evolving policy, legal, regulatory, and political developments—and differing stakeholder views—related to governance, environmental, social, and other sustainability matters may subject us to potentially conflicting requirements and expectations, which could negatively affect our business and harm our brands.
There has been increased focus among policymakers, investors, and other stakeholders on corporate practices related to environmental, social, and other sustainability matters. For example, recent executive orders issued by the current administration aim to restrict or prohibit certain corporate diversity initiatives and limit the consideration of environmental and social factors by financial institutions in customer‑related decisions.
Given the differing viewpoints among stakeholders on these issues, we face increased legal, regulatory, and operational risks. We may be unable to meet the conflicting expectations of all key stakeholders, which could
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adversely affect our business, operational results, and brands. Evolving policy, legal, regulatory, and political developments—as well as changing investor and regulatory expectations—may require adjustments to our business practices, strategies, or commitments and may increase compliance, operational, or other costs. Certain states have enacted or proposed laws addressing climate change and other sustainability issues, including climate‑related disclosure requirements. Other states have proposed or adopted laws or actions restricting the consideration of environmental and social factors in state investments and contracting.
In addition, in August 2025, President Trump signed Executive Order 14331, “Guaranteeing Fair Banking Access for All Americans,” which states that financial services should not be denied based on constitutionally or statutorily protected beliefs, affiliations, or political views. The Executive Order directs the Treasury Secretary and federal banking regulators to address politicized or unlawful debanking activities.
These and other laws, regulations, guidance, and expectations—many of which may have broad or extraterritorial application—have subjected, and may continue to subject, us to additional or conflicting requirements across the jurisdictions in which we operate. Such developments could negatively affect our business and brands, increase regulatory, compliance, credit, and operational risks, raise associated costs, or limit our ability to operate in certain jurisdictions.
For more information, see “Other Regulations and Proposals” in Supervision and Regulation on page 12.
Prolonged congressional negotiations in Washington, D.C. regarding government funding and related issues introduce additional volatility into the U.S. economy, particularly affecting capital and credit markets and the banking industry.
Legislative efforts to enact comprehensive, long-term appropriations have encountered significant challenges in recent years, thereby increasing the risk of a federal government shutdown. These fiscal uncertainties, along with the continued growth of the national debt and ongoing congressional deliberations over fiscal policy and budget discipline, may lead to adverse outcomes, including potential downgrades to the U.S. credit rating or even a default. Such developments could introduce additional volatility across the U.S. economy, with potential effects on capital and credit markets, the banking industry, financial markets, and the interest rate environment, among other unforeseen consequences.
In the event of a federal government shutdown or related fiscal disruption, the Bank could experience material adverse effects on its liquidity position, operating margins, overall financial condition, and results of operations. The recent government shutdown during the third quarter of 2025 did not have a significant impact on our operations or financial performance.

ITEM 1B. UNRESOLVED STAFF COMMENTS
There were no unresolved written comments from the staff of the SEC or the OCC issued 180 days or more before the end of our fiscal year that pertained to our periodic or current reports filed under the Exchange Act.

ITEM 1C. CYBERSECURITY
Cybersecurity risk is the potential for adverse impacts on the confidentiality, integrity, and availability of data that is owned, stored, or processed by the Bank and the associated communications and information technology systems. The frequency and sophistication of attempts to disrupt or gain unauthorized access to our systems and those of our suppliers—commonly referred to as hacking, cybersecurity fraud, or cyberattacks—continues to grow.
Oversight of cybersecurity risk is provided by the Board and managed through the Bank’s multiple lines of defense. This includes front-line bankers, operations teams, Enterprise Risk Management (“ERM”), and internal audit functions. Cybersecurity risk is governed under an established ERM framework, which incorporates key risk indicators, enterprise-wide standards, internal controls, and self-assessments aligned with established ERM policies. These elements are subject to ongoing evaluation and are systematically measured and reported to both Board-level and senior management-level risk committees. These committees are responsible for reviewing and responding to the findings to support effective risk mitigation and governance.
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The ROC is responsible for reviewing management reports concerning enterprise-wide risk management activities, including those related to cybersecurity. As part of its governance role, the ROC conducts an annual review and approval of the Bank's cybersecurity policies and programs. It also receives regular updates on key risk indicators, emerging threat trends, remediation efforts, and significant operational events.
The ROC provides ongoing reports to the Board regarding its oversight activities, including those pertaining to cybersecurity. To support these efforts, management utilizes a combination of real-time and periodic monitoring and reporting mechanisms designed to identify and respond to cybersecurity incidents. External third-party resources may also be engaged to enhance detection and response capabilities. Documented escalation procedures are routinely tested through tabletop exercises and other simulation activities. These procedures include timely notification to executive management in the event of qualifying cybersecurity incidents.
Responsibility for the direct assessment, measurement, and management of cybersecurity risks resides within the Bank's Information Security and Technology and Operations functions. These areas are led by the Chief Information Security Officer (“CISO”) and the Chief Technology and Operations Officer, who collectively bring extensive experience in cybersecurity, technology, operations, risk management, and audit, supported by experienced teams of cybersecurity, engineering, operations, and risk professionals. These teams participate in ongoing training, education, and industry certification programs to maintain the skills necessary to address evolving cybersecurity threats.
The Information Security function is responsible for establishing and maintaining the Bank’s cybersecurity framework, including threat monitoring, vulnerability management, incident response, and alignment with applicable regulatory and industry standards. The Technology and Operations function oversees the design, resilience, and control environment of the Bank’s technology infrastructure and operational processes, integrating cybersecurity considerations into enterprise systems, change management, and business continuity planning.
These functions operate within a structured governance framework that includes defined policies, independent risk oversight, internal audit review, and formal reporting routines. Cybersecurity risk assessments, key risk indicators, incident reporting, and control effectiveness metrics are regularly escalated to senior management and provided to the Board or its designated committees to support effective oversight.
To enhance the effectiveness of our cybersecurity program, we engage multiple independent third-party experts to evaluate our cybersecurity program and practices. These evaluations encompass a range of activities, including framework maturity assessments, blind penetration testing, technology health checks, cyber skill and staffing reviews, externally facilitated tabletop exercises, legal briefings from external cyber counsel, and strategic risk assessments. The results of these assessments are regularly reviewed with senior management and the ROC. Additionally, we actively participate in various cybersecurity industry forums and maintain access to law enforcement intelligence to stay informed of emerging threats and trends.
Our supply chain risk management framework incorporates cybersecurity-focused assessments of third-party vendors. We utilize commercially available services intended to continuously monitor suppliers, leveraging real-time security scoring of supplier technology services, threat intelligence, financial and geopolitical risk analysis, and other cybersecurity-related metrics. Regular reviews are conducted to assess changes in suppliers’ cybersecurity risk profiles. Additionally, ongoing threat intelligence monitoring is performed in an effort to detect potential cybersecurity incidents involving third parties. We also strive to include robust cybersecurity provisions in supplier contracts to mitigate associated risks.
In the event of a cybersecurity incident—whether identified internally or through third-party notifications—we conduct a structured assessment to determine the incident’s criticality, potential materiality, and disclosure requirements. This evaluation considers multiple factors, including service availability, operational disruption, reputational impact, regulatory and legal implications, sensitivity of affected data, and direct financial consequences.
The CISO continuously monitors these criteria to assess the potential impact of each incident, both individually and in aggregate. Established escalation protocols facilitate timely notification to senior and executive management, the Board or its relevant committees, and regulators, based on the severity and materiality of the incident.
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At December 31, 2025, cybersecurity threats— including those arising from prior incidents—did not have a material impact on our business strategy, results of operations, or financial condition. Management has applied formal, documented processes designed to evaluate known cybersecurity incidents for materiality and disclosure, and has concluded that no incidents to date have met the threshold for materiality, either individually or in aggregate.
Nonetheless, we acknowledge that future cybersecurity incidents may have a material adverse effect, despite ongoing efforts to prevent or mitigate such events. For additional information regarding cybersecurity risks, see “Cybersecurity Risk” in Risk Factors on page 21.

ITEM 2. PROPERTIES
At December 31, 2025, we operated a total of 407 branches, comprising 278 owned locations and 129 leased premises. Our corporate headquarters, located in Salt Lake City, Utah, is also leased. Annual rental obligations under long-term lease agreements are calculated based on various factors, including operating expenses, maintenance costs, and applicable taxes.
For additional information regarding lease arrangements and rental payments, see Note 8 of the Notes to Consolidated Financial Statements.

ITEM 3. LEGAL PROCEEDINGS
The information contained in Note 16 of the Notes to Consolidated Financial Statements is incorporated by reference herein.

ITEM 4. MINE SAFETY DISCLOSURES
None.

PART II

ITEM 5. MARKET FOR REGISTRANT’S COMMON EQUITY, RELATED STOCKHOLDER MATTERS, AND ISSUER PURCHASES OF EQUITY SECURITIES
PREFERRED STOCK
Our preferred stock is listed on the National Association of Securities Dealers Automated Quotations (“NASDAQ”) Global Select Market under the ticker symbol “ZIONP.” We have 4.4 million authorized shares of preferred stock, without par value, each carrying a liquidation preference of $1,000 per share. At December 31, 2025, 66,139 shares of Series A preferred stock were outstanding.
In December 2024, we completed the full redemption of all outstanding shares of Series G, I, and J preferred stock, resulting in a cash payment of approximately $374 million. The redemption resulted in a one-time reduction of approximately $6 million in net earnings applicable to common shareholders, reflecting the recognition of previously capitalized preferred stock issuance costs.
For more information regarding our preferred stock, see Note 14 of the Notes to Consolidated Financial Statements.
COMMON STOCK
Market Information
Our common stock is listed on NASDAQ under the ticker symbol “ZION.” On February 9, 2026, the closing price of our common stock on NASDAQ was $65.16 per share.
Equity Capital and Dividends
As of February 9, 2026, there were 3,313 registered shareholders of record of our common stock. This figure does not reflect the actual number of beneficial owners of the Bank's stock. In January 2026, the Board declared a
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quarterly dividend of $0.45 per common share, payable on February 19, 2026, to shareholders of record at the close of business on February 12, 2026.
Share Repurchases
In February 2025, we publicly announced a plan to repurchase up to $40 million of common shares outstanding during the fiscal year 2025, all of which were repurchased in the first quarter of 2025. We also acquired $1 million of shares during the first quarter in connection with our stock compensation plan. Repurchases in the third quarter of 2025 were limited to shares acquired solely in connection with our stock compensation plan.
The following schedule summarizes our share repurchases by quarter for the year ended December 31, 2025:
2025 SHARE REPURCHASES

Period Total number
of shares
purchased  1
Average
price paid
per share Shares purchased
as part of publicly
announced plans

First quarter 771,368  $ 53.62  747,268 
Second quarter —  —  — 
Third quarter 1,876  56.45  — 

Fourth quarter —  —  — 
Total 2025
773,244  $ 53.63  747,268 

1 Includes amounts related to common shares repurchased in connection with our stock compensation plan. These shares were acquired from employees to cover payroll tax obligations and stock option exercise costs incurred upon the exercise of stock options.
In January 2026, we publicly announced a plan to repurchase up to $75 million of common shares outstanding during the first quarter of 2026. For more information regarding our common stock activity, see the Consolidated Statement of Changes in Shareholders’ Equity on page 93.
Performance Graph
The following stock performance graph illustrates the five-year cumulative total return of our common stock, compared with the Standard and Poor’s (“S&P”) 500 Index, the S&P MidCap 400 Index, and the Keefe, Bruyette & Woods, Inc. (“KBW”) Regional Bank Index (“KRX”).
During the first quarter of 2024, we were removed from the S&P 500 Index and added to the S&P MidCap 400 Index. The KRX is a modified market capitalization-weighted index comprising geographically diverse regional bank and thrift stocks. It is developed and published by KBW, a nationally recognized brokerage and investment banking firm specializing in financial institutions.
The following performance graph is based on a $100 investment made on December 31, 2020, and assumes the reinvestment of all dividends.
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PERFORMANCE GRAPH FOR ZIONS BANCORPORATION, N.A.
INDEXED COMPARISON OF 5-YEAR CUMULATIVE TOTAL RETURN

2020 2021 2022 2023 2024 2025

Zions Bancorporation, N.A. 100.0  149.1  119.3  111.6  142.9  159.5 
KBW Regional Bank Index 100.0  136.7  127.2  126.7  143.4  152.7 
S&P 500 100.0  128.7  105.4  133.0  166.3  196.0 
S&P MidCap 400 100.0  124.6  108.3  126.0  143.5  154.3 

SECURITIES AUTHORIZED FOR ISSUANCE UNDER EQUITY COMPENSATION PLANS
The information contained in Item 12 of this Form 10-K is incorporated by reference herein.

ITEM 6. RESERVED

ITEM 7. MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS

Key Corporate Objectives
Our strategic objective is to achieve balanced growth in customers, pre‑tax net income, and shareholder returns. We provide a wide range of business products and related services to a broad customer base, which helps create balance, diversify risks, and support the communities we serve. While all business lines play an important role in generating long‑term value, our strategy is centered on five key growth areas: commercial banking, small business banking, capital markets, wealth management, and consumer banking.
These growth areas are supported by six strategic enablers that guide effective execution across the organization:
1. People and Empowerment — We prioritize employee development by investing in training programs and providing our teams with the tools and resources necessary to enhance their capabilities.
2. Technology — We invest in innovative technologies to improve operational efficiency and enable us to remain competitive.
3. Marketing — We implement targeted marketing strategies to strengthen our local brands, attract new clients, deepen existing relationships, and enhance overall customer engagement.
4. Operational Excellence — We invest in and support ongoing improvements to safely and securely deliver value to our customers.
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5. Risk Management — We apply disciplined risk management practices to promote prudent decision-making and maintain appropriate oversight.
6. Data and Analytics — We invest in relevant enterprise data and analytic tools to enable informed decision-making and support localized execution.
We allocate resources to achieve our growth and profitability objectives by delivering high‑quality products and services and by strengthening our customer relationships. Serving as a trusted advisor and supporting customers’ operational needs contributes to relatively stable deposits and ongoing relationship growth.
Key strategic initiatives focus on supporting commercial customer growth, expanding small business lending, enhancing capital markets capabilities, broadening access to wealth management services, and strengthening consumer deposit relationships. Collectively, these initiatives are critical to sustaining long-term growth and stability.
As previously described, we operate through seven separately managed affiliate banks supported by an enterprise‑level “Other” segment. This organizational model is central to achieving our strategic objectives by enabling local decision‑making and strong customer focus at the affiliate level, while maintaining disciplined governance, risk management, capital allocation, and shared technology and operations at the enterprise level.
RESULTS OF OPERATIONS
Our Financial Performance
This section, along with other sections of this report, presents information regarding our 2025 financial performance, compared with the prior year. For more information about our 2024 results compared with 2023, see the relevant sections of MD&A included in our 2024 Form 10-K. Growth rates equal to or exceeding 100% are designated as not meaningful (“NM”), as they typically result from a low base period.

Net Earnings Applicable to Common Shareholders
(in millions)
Diluted EPS Adjusted PPNR
(in millions) 1
Efficiency ratio 1

1 For information on non-GAAP financial measures, see page 84 .
Our financial performance in 2025 reflected solid growth compared with the prior year, with notable increases in net earnings applicable to common shareholders, diluted earnings per share (“EPS”), and adjusted pre-provision net revenue (“PPNR”). Diluted EPS increased to $6.01, up 21% from $4.95 in 2024, driven by higher net interest income and noninterest income, partially offset by increased noninterest expense. The efficiency ratio improved to 62.6%, compared with 64.2% in the prior year, reflecting positive operating leverage as adjusted taxable-equivalent revenue outpaced adjusted noninterest expense.
• Net interest income increased $197 million, or 8%, compared with the prior year period. This growth was primarily driven by lower funding costs and favorable shifts in the composition of average interest-earning assets. As a result, the net interest margin (“NIM”) improved to 3.21%, compared with 3.00%.
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◦ Average interest-earning assets increased $689 million, or 1%, primarily due to an increase in average loans and leases. This growth was partially offset by declines in average securities and average money market investments.
◦ Average interest-bearing liabilities increased $178 million, or less than 1%, due to an increase in both average borrowed funds and average interest-bearing deposits.
• The provision for credit losses remained flat at $72 million in both 2025 and 2024.
• Customer-related noninterest income increased $23 million, or 4%, primarily driven by higher retail and business banking fees, capital markets fees and income, and loan-related fees and income. Excluding the impact of net credit valuation adjustment (“CVA”), customer-related noninterest income increased $32 million , or 5% , benefiting from increased capital markets customer swap fee revenue and investment banking advisory fees.
• Noncustomer-related noninterest income increased $35 million, or 57%, mainly due to an increase in net securities gains, largely resulting from valuation adjustments within our Small Business Investment Company (“SBIC”) investment portfolio.
• Noninterest expense increased $92 million, or 4%. primarily due to higher salaries and employee benefits, along with increases in other noninterest expenses, marketing and business development costs, and technology, telecom, and information processing expenses. The increase in marketing and business development expense was largely due to a $15 million contribution to our charitable foundation, which will fund donations over the next three years that otherwise would have been nondeductible under recent tax law changes effective January 1, 2026. These increases were partially offset by lower deposit insurance and regulatory expenses.
• Total loans and leases increased $1.5 billion, or 3%, primarily due to growth in the commercial and industrial, term CRE, and consumer 1-4 family residential loan portfolios.
◦ Net loan and lease charge-offs totaled $89 million, or 0.15% of average loans and leases, compared with $60 million, or 0.10%, in 2024. The increase was primarily driven by a $50 million loss associated with two related commercial loans during the third quarter of 2025.
◦ Nonperforming assets totaled $320 million, or 0.52% of total loans and leases and other real estate owned (“OREO”), compared with $298 million, or 0.50% in 2024. Nonperforming assets remained primarily concentrated in the commercial and industrial, term CRE, and consumer 1-4 family residential loan portfolios. Classified loans totaled $2.4 billion, or 3.91% of total loans and leases, compared with $2.9 billion, or 4.83% in the prior year.
• Total deposits decreased $579 million, or 1%. Interest-bearing deposits declined primarily due to a reduction in brokered deposits. This decline was partially offset by an increase in noninterest-bearing demand deposits, largely resulting from the migration of a consumer interest-bearing product into a new noninterest-bearing offering. Customer deposits, excluding brokered deposits, totaled $71.8 billion, compared with $71.2 billion in the prior year.
• Total borrowed funds decreased $206 million, or 4%, compared with the prior year. This decline was primarily driven by a reduction in short-term advances from the FHLB, partially offset by the issuance of $500 million in 4.70% Fixed-to-Floating Senior Notes during the third quarter of 2025.
The following schedule presents additional selected financial highlights:
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SELECTED FINANCIAL HIGHLIGHTS

(Dollar amounts in millions, except per share amounts) 2025/2024
Change 2025 2024 2023
For the Year
Net interest income 8  % $ 2,627 $ 2,430 $ 2,438
Noninterest income 8  % 758 700 677
Total net revenue 8  % 3,385 3,130 3,115
Provision for credit losses —  % 72 72 132
Noninterest expense 4  % 2,138 2,046 2,097
Pre-provision net revenue 1
15  % 1,293 1,129 1,059
Adjusted pre-provision net revenue 1
12  % 1,266 1,131 1,170
Net income 15  % 899 784 680
Net earnings applicable to common shareholders 21  % 895 737 648
Per Common Share
Net earnings – diluted 21  % 6.01 4.95 4.35

Tangible book value at year-end 1
21  % 40.79 33.85 28.30
Market price – end 8  % 58.54 54.25 43.87
Market price – high (4) % 60.77 63.22 55.20
Market price – low 4  % 39.32 37.76 18.26
At Year-End
Assets —  % 88,990 88,775 87,203
Loans and leases, net of unearned income and fees 3  % 60,917 59,410 57,779
Deposits (1) % 75,644 76,223 74,961

Common equity 17  % 7,114 6,058 5,251

Performance Ratios
Return on average assets 1.00% 0.88% 0.77%
Return on average common equity 13.7% 13.1% 13.4%
Return on average tangible common equity 1
16.6% 16.2% 17.3%
Net interest margin 3.21% 3.00% 3.02%
Net charge-offs to average loans and leases 0.15% 0.10% 0.06%
Total allowance for credit losses to loans and leases outstanding 1.19% 1.25% 1.26%
Capital Ratios at Year-End

Common equity Tier 1 capital
11.5% 10.9% 10.3%
Tier 1 leverage
9.0% 8.3% 8.3%

Tangible common equity 1
6.9% 5.7% 4.9%

Other Selected Information
Weighted average diluted common shares outstanding
(in thousands)
—  % 147,157 147,215 147,756
Bank common shares repurchased (in thousands)
(16) % 747 890 947
Dividends declared 6  % $ 1.76 $ 1.66 $ 1.64
Common dividend payout ratio 2
29.4% 33.6% 37.8%
Capital distributed as a percentage of net earnings applicable to common shareholders 3
34% 38% 46%
Efficiency ratio 1, 4
62.6% 64.2% 62.9%

1 See “Non-GAAP Financial Measures” on page 84 for more information.
2 The common dividend payout ratio is calculated by dividing the total common dividends paid by the net earnings applicable to common shareholders.
3 This ratio is calculated by adding common dividends paid and share repurchases for the year, then dividing the total by net earnings applicable to common shareholders.
4 Excluding the $15 million charitable contribution, the efficiency ratio for 2025 would have been 62.2%.
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Net Interest Income and Net Interest Margin
Net interest income, which is the difference between interest earned on interest-earning assets and interest paid on interest-bearing liabilities, accounted for 78% of our net revenue (the sum of net interest income and noninterest income) in both 2025 and 2024. The NIM is calculated as net interest income as a percentage of average interest-earning assets.
NET INTEREST INCOME AND NET INTEREST MARGIN

Amount change Percent change Amount change Percent change
(Dollar amounts in millions) 2025 2024 2023

Interest and fees on loans 1
$ 3,501 $ (13) —  % $ 3,514 $ 318  10  % $ 3,196
Interest on money market investments 186 (44) (19) 230 42  22  188
Interest on securities 497 (52) (9) 549 (14) (2) 563
Total interest income 4,184 (109) (3) 4,293 346  9  3,947
Interest on deposits 1,250 (290) (19) 1,540 477  45  1,063
Interest on short- and long-term borrowings 307 (16) (5) 323 (123) (28) 446
Total interest expense 1,557 (306) (16) 1,863 354  23  1,509
Net interest income $ 2,627 $ 197  8  $ 2,430 $ (8) —  $ 2,438

Average interest-earning assets $ 83,153 $ 689  1  $ 82,464 $ 480  1  $ 81,984
Average interest-bearing liabilities 56,239 178  —  56,061 4,185  8  51,876
bps bps

Net interest margin 2
3.21  % 21  3.00  % (2) 3.02  %

1 Includes interest income recoveries of $10 million, $6 million, and $4 million for the respective years presented.
2 Taxable-equivalent rates used where applicable.
Net interest income increased $197 million, or 8%, relative to the same prior year period, primarily due to lower funding costs. The increase was further supported by a favorable shift in the composition of average interest-earning assets, reflecting growth in higher-yielding loans and a decline in lower-yielding securities and money market investments. As a result, the net interest margin improved to 3.21% in 2025, compared with 3.00% in 2024.
The following chart presents the changes in yields on average interest-earning assets:

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The yield on average interest-earning assets, net of hedging activity, declined 17 basis points (“bps”) in 2025, compared with the prior year, reflecting lower interest rates. The net yield on average loans and leases decreased 22 bps, while the net yield on average securities declined 11 bps. Additionally, the yield on average money market investments decreased 96 bps, as the short-term nature of these assets resulted in quicker repricing in the declining interest rate environment.
The following chart presents the changes in rates paid on average interest-bearing liabilities:

The total cost of deposits decreased 39 bps, and the rate paid on total deposits and interest-bearing liabilities decreased 36 bps in 2025, compared with the prior year, reflecting the lower interest rate environment. The rates paid on interest-bearing deposits and total borrowed funds decreased 59 bps and 34 bps, respectively.
Average interest-earning assets increased $689 million, or 1%, from the prior year, as an increase in average loans and leases was partially offset by decreases in average securities and average money market investments.
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Average loans and leases increased $1.9 billion, or 3%, to $60.4 billion, primarily due to growth in average consumer and commercial loans. Average securities decreased $1.2 billion, or 7%, to $18.4 billion, largely due to principal reductions, net of reinvestments. The continued paydown of lower-yielding securities—consistent with the portfolio runoff that began in 2023—has improved the overall asset mix and contributed to a higher net interest margin.
Average interest-bearing liabilities increased $178 million, or less than 1%, from the prior year. This increase was primarily driven by an increase in average borrowed funds, reflecting an increase in long-term debt, partially offset by declines in short-term borrowings and security repurchase agreements.

Average deposits increased $113 million, or less than 1%, to $74.9 billion. Average interest-bearing deposits increased $52 million, while average noninterest-bearing deposits increased $61 million, representing 34% of total deposits in both 2025 and 2024.
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Average borrowed funds, primarily composed of secured borrowings, increased $126 million, or 2%, to $6.5 billion. This growth was driven by an increase in long-term debt, partially offset by declines in short-term advances from the FRB and security repurchase agreements. The increase in long-term debt reflects the issuance of $500 million in 4.70% Fixed-to-Floating Senior Notes in August 2025.
For more information on our investment securities portfolio and borrowed funds, and how we manage liquidity risk, refer to the “Investment Securities Portfolio” section on page 50 and the “Liquidity Risk Management” section on page 75. For further discussion of the effects of market rates on net interest income and how we manage interest rate risk, refer to the “Interest Rate and Market Risk Management” section on page 72.
The following schedule summarizes the average balances, the amount of interest earned or paid, and the applicable yields for interest-earning assets, as well as the cost of interest-bearing liabilities:
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CONSOLIDATED AVERAGE BALANCE SHEETS, YIELDS, AND RATES

Year Ended December 31,
2025 2024 2023
(Dollar amounts in millions) Average balance Interest Yield/
Rate 1
Average balance Interest Yield/
Rate 1
Average balance Interest Yield/
Rate 1

ASSETS
Money market investments:
Interest-bearing deposits $ 1,671  $ 73  4.37  % $ 1,970  $ 106  5.40  % $ 2,163  $ 112  5.18  %
Federal funds sold and securities purchased under agreements to resell 2,420  113  4.70  2,203  124  5.62  1,358  76  5.57 
Total money market investments 4,091  186  4.56  4,173  230  5.52  3,521  188  5.33 
Trading securities 114  5  4.62  36  2  4.41  53  1  2.86 
Investment securities:
Available-for-sale 9,109  295  3.24  9,621  332  3.46  10,900  331  3.03 
Held-to-maturity 9,250  204  2.21  10,017  224  2.23  10,731  240  2.24 
Total investment securities 18,359  499  2.72  19,638  556  2.83  21,631  571  2.64 
Loans held for sale 168  10  NM 70  4  NM 39  2  NM
Loans and leases: 2

Commercial 31,389  1,846  5.88  30,671  1,842  6.01  30,519  1,679  5.50 
Commercial real estate 13,562  890  6.55  13,532  967  7.14  13,023  908  6.98 
Consumer 15,470  794  5.14  14,344  737  5.14  13,198  639  4.84 
Total loans and leases 60,421  3,530  5.84  58,547  3,546  6.06  56,740  3,226  5.69 
Total interest-earning assets 83,153  4,230  5.09  82,464  4,338  5.26  81,984  3,988  4.86 
Cash and due from banks 715  714  662 
Allowance for credit losses on loans and debt securities (687) (689) (632)
Goodwill and intangibles 1,084  1,055  1,062 
Other assets 5,289  5,279  5,579 
Total assets $ 89,554  $ 88,823  $ 88,655 
LIABILITIES AND SHAREHOLDERS’ EQUITY
Interest-bearing deposits:
Savings and money market $ 39,253  $ 842  2.14  $ 38,796  $ 1,022  2.63  $ 34,135  $ 650  1.90 
Time 10,493  408  3.89  10,898  518  4.75  9,028  413  4.58 

Total interest-bearing deposits 49,746  1,250  2.51  49,694  1,540  3.10  43,163  1,063  2.46 
Borrowed funds:
Federal funds purchased and security repurchase agreements 1,117  47  4.28  1,309  68  5.19  3,380  169  4.98 
Other short-term borrowings 4,223  188  4.46  4,458  218  4.90  4,741  241  5.08 
Long-term debt 1,153  72  6.16  600  37  6.07  592  36  6.09 
Total borrowed funds 6,493  307  4.73  6,367  323  5.07  8,713  446  5.11 
Total interest-bearing liabilities 56,239  1,557  2.77  56,061  1,863  3.32  51,876  1,509  2.91 
Noninterest-bearing demand deposits 25,127  25,066  29,703 

Other liabilities 1,592  1,643  1,797 
Total liabilities 82,958  82,770  83,376 
Shareholders’ equity:
Preferred equity 66  423  440 
Common equity 6,530  5,630  4,839 

Total shareholders’ equity 6,596  6,053  5,279 
Total liabilities and shareholders’ equity $ 89,554  $ 88,823  $ 88,655 
Spread on average interest-bearing funds 2.32  % 1.94  % 1.95  %
Impact of net noninterest-bearing sources of funds 0.89  % 1.06  % 1.07  %
Net interest margin $ 2,673  3.21  % $ 2,475  3.00  % $ 2,479  3.02  %
Memo: total cost of deposits $ 74,873  1,250  1.67  % $ 74,760  1,540  2.06  % $ 72,866  1,063  1.46  %
Memo: total deposits and interest-bearing liabilities $ 81,366  1,557  1.92  % $ 81,127  1,863  2.28  % $ 81,579  1,509  1.87  %

1 Taxable-equivalent rates used where applicable.
2 Net of unamortized purchase premiums, discounts, and deferred loan fees and costs.
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The following schedule summarizes year-over-year changes in net interest income on a fully taxable-equivalent basis for the periods presented. For yield calculations, average loan balances include the principal amounts of nonaccrual and restructured loans. Interest payments received on nonaccrual loans are not recognized as interest income; instead, they are applied as reductions to the outstanding principal. Additionally, interest on modified loans is generally accrued at the modified rates.
In analyzing changes in taxable-equivalent net interest income attributable to volume and rate, variances are primarily allocated to volume, with the following exceptions: (1) when both volume and rate increase, the variance is allocated proportionately between the two factors, and (2) when the rate increases and volume decreases, the variance is allocated to rate.
ANALYSIS OF CHANGES IN TAXABLE-EQUIVALENT NET INTEREST INCOME

2025 over 2024 2024 over 2023
Changes due to Total changes Changes due to Total changes
(In millions) Volume Rate 1
Volume Rate 1

INTEREST-EARNING ASSETS
Money market investments:
Interest-bearing deposits $ (13) $ (20) $ (33) $ (10) $ 4  $ (6)
Federal funds sold and securities purchased under agreements to resell 9  (20) (11) 48  —  48 
Total money market investments (4) (40) (44) 38  4  42 
Trading securities 3  —  3  —  1  1 
Securities:
Available-for-sale (17) (20) (37) (39) 40  1 
Held-to-maturity (17) (3) (20) (15) (1) (16)
Total securities (34) (23) (57) (54) 39  (15)
Loans held for sale 10  (4) 6  2  —  2 
Loans and leases 2

Commercial 43  (39) 4  8  155  163 
Commercial real estate 4  (81) (77) 37  22  59 
Consumer 57  —  57  57  41  98 
Total loans and leases 104  (120) (16) 102  218  320 
Total interest-earning assets 79  (187) (108) 88  262  350 
INTEREST-BEARING LIABILITIES
Interest-bearing deposits:
Saving and money market 12  (192) (180) 97  275  372 
Time (16) (94) (110) 89  16  105 

Total interest-bearing deposits (4) (286) (290) 186  291  477 
Borrowed funds:
Federal funds purchased and security repurchase agreements (9) (12) (21) (104) 3  (101)
Other short-term borrowings (11) (19) (30) (14) (9) (23)
Long-term debt 35  —  35  1  —  1 
Total borrowed funds 15  (31) (16) (117) (6) (123)
Total interest-bearing liabilities 11  (317) (306) 69  285  354 
Change in taxable-equivalent net interest income $ 68  $ 130  $ 198  $ 19  $ (23) $ (4)

1 Taxable-equivalent rates used where applicable.
2 Net of unearned income and fees, net of related costs. Loans include nonaccrual and modified loans.
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The Allowance and Provision for Credit Losses
The allowance for credit losses (“ACL”) comprises both the allowance for loan and lease losses (“ALLL”) and the reserve for unfunded lending commitments (“RULC”). The ALLL represents the estimated current expected credit losses related to the loan and lease portfolio as of the balance sheet date. The RULC represents the estimated reserve for current expected credit losses associated with off-balance sheet commitments. Changes in the ALLL and RULC, net of charge-offs and recoveries, are recognized as the provision for loan and lease losses and the provision for unfunded lending commitments, respectively, on the consolidated statement of income. The ACL for debt securities is estimated separately from loans and is included in “Investment securities” on the consolidated balance sheet.

The ACL was $724 million at December 31, 2025, compared with $741 million at December 31, 2024. The decrease in the ACL primarily reflects lower reserves associated with CRE portfolio-specific risks, partially offset by more adverse economic scenarios and increased growth in loans and commitments. The ratio of ACL to total loans and leases was 1.19% at December 31, 2025, compared with 1.25% at December 31, 2024. The following schedule illustrates the primary drivers of changes in the ACL compared with the prior year.

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Our ACL estimate is derived using econometric loss models that incorporate multiple economic scenarios, including optimistic, baseline, and stressed conditions. These scenarios are weighted to determine the overall credit loss estimate, and management may adjust the weightings based on its assessment of current economic conditions and reasonable and supportable forecasts. The schedule above summarizes the key drivers of the year-over-year change in the ACL, reflecting the combined effect of economic forecasts, credit quality trends and portfolio-specific risks, and portfolio composition.
The second bar reflects the impact of changes in economic forecasts and current economic conditions, incorporating management’s judgment in determining the scenario weightings for the current period. These changes resulted in a $58 million increase in the ACL compared with the prior year, primarily driven by the increased weighting assigned to more adverse economic scenarios.
The third bar captures changes in credit quality factors, including risk grade migration, portfolio-specific risks, and specific reserves on loans. Collectively, these factors contributed to a $78 million decrease in the ACL, largely driven by reduced CRE portfolio-specific risks.
The fourth bar represents the effect of changes in the composition of the loan portfolio, including shifts in loan balances and mix, the aging of the portfolio, and other qualitative risk factors. These changes resulted in a $3 million increase in the ACL, primarily driven by $1.5 billion in period-end loan growth, partially offset by changes in the loan portfolio mix.
The provision for credit losses, which includes both the provision for loan and lease losses and the provision for unfunded lending commitments, was $72 million in both 2025 and 2024. The provision for securities losses was less than $1 million during each of those years.
For more information regarding the methodology used to determine the appropriate levels of the ALLL and RULC, see Note 6 of the Notes to Consolidated Financial Statements.

Noninterest Income
Noninterest income is comprised of revenue generated from products and services that typically do not bear an associated interest rate or yield. It is categorized as either customer-related or noncustomer-related. Customer-related noninterest income excludes items such as securities gains and losses, dividends, and insurance-related income.
Noninterest income accounted for 22% of total net revenue (the sum of net interest income and noninterest income) in both 2025 and 2024. In 2025, noninterest income increased $58 million, or 8%, relative to the prior year. The following schedule presents a comparison of the major components of noninterest income:
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NONINTEREST INCOME

(Dollar amounts in millions) 2025 Amount change Percent change 2024 Amount change Percent change 2023

Commercial account fees $ 185  $ 3  2  % $ 182  $ 8  5  % $ 174 
Card fees 95  (1) (1) 96  (5) (5) 101 
Retail and business banking fees 75  8  12  67  1  2  66 
Loan-related fees and income 75  5  7  70  (9) (11) 79 
Capital markets fees and income 1
116  6  5  110  33  43  77 
Wealth management fees 57  (1) (2) 58  —  —  58 
Other customer-related fees 59  3  5  56  (5) (8) 61 
Customer-related noninterest income 662  23  4  639  23  4  616 
Dividends and other income 44  2  5  42  (15) (26) 57 
Securities gains (losses), net 52  33  NM 19  15  NM 4 
Noncustomer-related noninterest income 96  35  57  61  —  NM 61 
Total noninterest income $ 758  $ 58  8  $ 700  $ 23  3  $ 677 
Adjusted customer-related noninterest income 2
$ 671  $ 32  5  $ 639  $ 19  3  $ 620 

1 Effective the first quarter of 2025, capital markets fees and income include the net CVA, which was previously disclosed under noncustomer-related noninterest income as fair value and nonhedge derivative income.
2 Net of CVA. For information on non-GAAP financial measures, see page 84.
Customer-related Noninterest Income
Consistent with our key corporate objectives, we prioritize strengthening and expanding both new and existing relationships by delivering high-quality products and services to commercial, small business, and consumer customers, thereby benefiting noninterest income through enhanced service offerings.
Customer-related noninterest income increased $23 million, or 4%, in 2025, compared with the prior year. Key drivers of this growth included:
• Retail and business banking fees increased $8 million, or 12%, mainly due to an increase in overdraft and deposit service fees.
• Capital markets fees increased $6 million, or 5%. Excluding the impact of net CVA, capital markets fees and income increased $15 million, or 14%, benefiting from higher customer swap fee revenue and increased investment banking advisory fees.
• Loan-related fees and income increased $5 million, or 7%, primarily due to increased loan sales activity.
• Commercial account fees increased $3 million or 2%, largely due to an increase in account analysis fees, partially offset by a decrease in merchant fees.
Noncustomer-related Noninterest Income
Noncustomer-related noninterest income increased $35 million, or 57%, in 2025, relative to the prior year. Net securities gains increased $33 million, largely attributable to valuation adjustments within our SBIC investment portfolio.
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Noninterest Expense
The following schedule presents a comparison of the major components of noninterest expense:
NONINTEREST EXPENSE

(Dollar amounts in millions) 2025 Amount change Percent change 2024 Amount change Percent change 2023

Salaries and employee benefits $ 1,350  $ 63  5  % $ 1,287  $ 12  1  % $ 1,275 
Technology, telecom, and information processing 276  16  6  260  20  8  240 
Occupancy and equipment, net 166  5  3  161  1  1  160 
Professional and legal services 61  (3) (5) 64  2  3  62 
Marketing and business development 64  19  42  45  (1) (2) 46 
Deposit insurance and regulatory expense 64  (27) (30) 91  (78) (46) 169 
Credit-related expense 25  —  —  25  (1) (4) 26 
Other real estate expense, net (2) (1) NM (1) (1) NM — 
Other 134  20  18  114  (5) (4) 119 
Total noninterest expense $ 2,138  $ 92  4  $ 2,046  $ (51) (2) $ 2,097 
Adjusted noninterest expense (non-GAAP) $ 2,122  $ 97  5  $ 2,025  $ 39  2  $ 1,986 

Noninterest expense increased $92 million, or 4%, in 2025. Salaries and benefits expense accounted for approximately 63% of total noninterest expense in both 2025 and 2024. The following schedule presents the major components of salaries and employee benefits expense:
SALARIES AND EMPLOYEE BENEFITS

(Dollar amounts in millions) 2025 Amount change Percent change 2024 Amount change Percent change 2023

Salaries and bonuses $ 1,120  $ 59  6  % $ 1,061  $ 4  —  % $ 1,057 
Employee benefits:
Employee health and insurance 104  (1) (1) 105  5  5  100 
Retirement and profit sharing 52  3  6  49  (2) (4) 51 
Payroll taxes and other fringe benefits 74  2  3  72  5  7  67 
Total employee benefits 230  4  2  226  8  4  218 
Total salaries and employee benefits $ 1,350  $ 63  5  $ 1,287  $ 12  1  $ 1,275 
Full-time equivalent employees at December 31 9,195  (211) (2) 9,406  (273) (3) 9,679 

Salaries and employee benefits expense increased $63 million, or 5%, primarily due to increased incentive compensation accruals reflecting improved profitability, along with higher base salaries and severance costs. At December 31, 2025, we had 9,195 full-time equivalent employees, representing a decrease of approximately 2% compared with the prior year.
Other drivers impacting total noninterest expense included:
• Other noninterest expense increased $20 million, primarily due to higher subscription costs, success fee accrual adjustments related to SBIC investments, impairment of certain long-lived assets, and legal settlement reserves.
• Marketing and business development expense increased $19 million, largely attributable to a $15 million donation to our charitable foundation, which will be used over the next three years to make charitable donations that otherwise would have been nondeductible as a result of recent tax law changes that became effective on January 1, 2026.
• Technology, telecom, and information processing expense increased $16 million, primarily driven by higher costs associated with application software, licensing, and maintenance.
These increases were partially offset by a $27 million reduction in deposit insurance and regulatory expense, primarily due to updated FDIC special assessment estimates.
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Adjusted noninterest expense increased $97 million, or 5%, primarily due to the same factors noted above. The efficiency ratio improved to 62.6%, compared with 64.2%, reflecting positive operating leverage as adjusted taxable-equivalent revenue outpaced adjusted noninterest expense. Excluding the $15 million charitable contribution, adjusted noninterest expense for 2025 would have been $2.11 billion, resulting in an efficiency ratio of 62.2%. For information on non-GAAP financial measures, see page 84.

Technology Spend
We invest in technology initiatives designed to improve our products and services, increase our operational efficiency, and enable us to remain competitive. We report these investments as technology spend, which includes the following:
• Technology, telecom, and information processing expense — includes current period expenses presented on the consolidated statement of income related to application software licensing and maintenance, telecommunications, and data processing, less related amortization and depreciation of capitalized technology investments;
• Other technology-related expense — includes related noncapitalized salaries and employee benefits, occupancy and equipment, and professional and legal services; and
• Technology investments — includes capitalized technology infrastructure equipment, hardware, and software (both purchased and internally developed).
The following schedule presents the composition of our technology spend:
TECHNOLOGY SPEND

(Dollar amounts in millions) 2025 Amount change Percent change 2024 Amount change Percent change 2023

Technology, telecom, and information processing expense $ 276  $ 16  6  % $ 260  $ 20  8  % $ 240 
Less: related non-cash amortization and depreciation (78) 1  (1) (79) (8) 11  (71)
Other technology-related expense 253  2  1  251  19  8  232 
Capitalized technology investments 59  25  74  34  (48) (59) 82 
Total technology spend
$ 510  $ 44  9  $ 466  $ (17) (4) $ 483 

Total technology spend increased $44 million, or 9%, compared with the prior year. This increase was driven by higher capitalized technology investments associated with lending and customer-focused technology initiatives. In addition, technology, telecom, and information processing expense increased, largely reflecting the previously noted increases in application software, licensing, and maintenance costs.

Income Taxes
The following schedule summarizes the income tax expense and effective tax rates for the periods presented:
INCOME TAXES

(Dollar amounts in millions) 2025 2024 2023

Income before income taxes $ 1,175  $ 1,012  $ 886 
Income tax expense 276  228  206 
Effective tax rate 23.5  % 22.5  % 23.3  %

The effective tax rate was 23.5%, 22.5%, and 23.3%, for the years ended 2025, 2024, and 2023, respectively. For more information about the factors affecting our effective tax rate, the significant components of our DTAs and DTLs, and unrecognized tax benefits related to uncertain tax positions, see Note 20 of the Notes to Consolidated Financial Statements.
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Preferred Stock Dividends
Preferred stock dividends totaled $4 million in 2025, $41 million in 2024, and $32 million in 2023. The decrease from the prior year was due to the redemption of the outstanding shares of our Series G, I, and J preferred stock during the fourth quarter of 2024. For further details, see Note 14 of the Notes to Consolidated Financial Statements.

Operating Segment Results
As described under Item 1. Business on page 5, we manage our operations through seven affiliate banks—Zions Bank, CB&T, Amegy, NBAZ, NSB, Vectra, and TCBW—which constitute our primary operating segments. Each affiliate operates in distinct geographic markets under its own local brand and management team. The affiliate banks are supported by an enterprise‑level “Other” segment, which provides governance and risk oversight, capital allocation, strategic objectives, centralized technology infrastructure, back‑office operations, and certain business lines that are not managed through the affiliate structure.
Centrally provided services are allocated to the operating segments based on estimated or actual usage of those services. Capital is allocated according to the risk-weighted assets held by each segment. We utilize an internal funds transfer pricing process to measure segment performance. This methodology is subject to ongoing refinement. For more information regarding operating segment performance, see Note 22 of the Notes to Consolidated Financial Statements.
Selected financial information for each operating segment is presented below. Ratios are calculated using amounts in thousands. All references to domestic deposits by state are based on FDIC deposit market share data for full-service institutions with at least three branches as of June 30, 2025.
Zions Bank
Zions Bank, headquartered in Salt Lake City, Utah, operated 92 branches in Utah, 25 branches in Idaho, and one branch in Wyoming at December 31, 2025. Based on domestic deposit market share in these states, Zions Bank ranked as the second largest full-service commercial bank in Utah and the fifth largest in Idaho. FDIC deposit market share data for Wyoming at June 30, 2025 was not considered meaningful.
ZIONS BANK SELECTED FINANCIAL INFORMATION

(Dollar amounts in millions) 2025 Amount change Percent change 2024 Amount change Percent change 2023
SELECTED INCOME STATEMENT DATA
Net interest income $ 738 $ 46  7  % $ 692 $ (6) (1) % $ 698
Provision for credit losses 14 22  NM (8) (28) NM 20
Noninterest income 190 3  2  187 (5) (3) 192
Noninterest expense 570 (1) —  571 (11) (2) 582
Income (loss) before income taxes 344 28  9  316 28  10  288
SELECTED BALANCE SHEET DATA (at year end)
Loans:
Commercial 8,093 (162) (2) 8,255 (269) (3) 8,524
Commercial real estate 2,961 178  6  2,783 62  2  2,721
Consumer 3,990 170  4  3,820 278  8  3,542
Total loans 15,044 186  1  14,858 71  —  14,787
Total deposits 21,155 (169) (1) 21,324 632  3  20,692
CREDIT QUALITY
Net loan and lease charge-offs (recoveries) $ 8  11  NM $ (3) (22) NM $ 19 
Ratio of net charge-offs (recoveries) to average loans and leases 0.05  % (0.02) % 0.13  %
Allowance for credit losses $ 161  7  5  $ 154  (3) (2) $ 157 
Ratio of allowance for credit losses to net loans and leases, at year end 1.07  % 1.04  % 1.10  %
Nonperforming assets $ 58  29  NM $ 29  3  12  $ 26 
Ratio of nonperforming assets to net loans and leases and other real estate owned 0.39  % 0.20  % 0.18  %

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California Bank & Trust
California Bank & Trust, headquartered in San Diego, California, operated 77 branches across California at December 31, 2025. Based on domestic deposit market share in the state, CB&T ranked as the 13 th largest full-service commercial bank in California.
In January 2025, Southern California experienced devastating wildfires. Our credit losses were insignificant, primarily due to adequate insurance coverage and our limited residential credit exposure in the affected areas.
In late March 2025, we purchased four FirstBank Coachella Valley, California branches and their associated deposit and loan accounts. In addition to the four branches, the purchase included approximately $630 million in deposits and $420 million in consumer and commercial loans.
CALIFORNIA BANK AND TRUST SELECTED FINANCIAL INFORMATION

(Dollar amounts in millions) 2025 Amount change Percent change 2024 Amount change Percent change 2023
SELECTED INCOME STATEMENT DATA
Net interest income $ 647 $ 63  11  % $ 584 $ (18) (3) % $ 602
Provision for credit losses 53 11  26  42 (2) (5) 44
Noninterest income 126 5  4  121 5  4  116
Noninterest expense 433 30  7  403 (8) (2) 411
Income (loss) before income taxes 287 27  10  260 (3) (1) 263
SELECTED BALANCE SHEET DATA (at year end)
Loans:
Commercial 7,572 277  4  7,295 (30) —  7,325
Commercial real estate 4,228 (16) —  4,244 (98) (2) 4,342
Consumer 3,641 601  20  3,040 530  21  2,510
Total loans 15,441 862  6  14,579 402  3  14,177
Total deposits 15,868 1,339  9  14,529 (505) (3) 15,034
CREDIT QUALITY
Net loan and lease charge-offs (recoveries) $ 58  15  35  $ 43  33  NM $ 10 
Ratio of net charge-offs (recoveries) to average loans and leases 0.38  % 0.30  % 0.07  %
Allowance for credit losses $ 153  (14) (8) $ 167  5  3  $ 162 
Ratio of allowance for credit losses to net loans and leases, at year end 1.01  % 1.17  % 1.15  %
Nonperforming assets $ 105  4  4  $ 101  19  23  $ 82 
Ratio of nonperforming assets to net loans and leases and other real estate owned 0.68  % 0.69  % 0.58  %

Amegy Bank
Amegy Bank, headquartered in Houston, Texas, operated 76 branches across Texas at December 31, 2025. Based on domestic deposit market share in the state, Amegy ranked as the eighth largest full-service commercial bank in Texas.
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AMEGY BANK SELECTED FINANCIAL INFORMATION

(Dollar amounts in millions) 2025 Amount change Percent change 2024 Amount change Percent change 2023
SELECTED INCOME STATEMENT DATA
Net interest income $ 565 $ 69  14  % $ 496 $ 39  9  % $ 457
Provision for credit losses 8 (14) (64) 22 7  47  15
Noninterest income 189 14  8  175 (9) (5) 184
Noninterest expense 465 9  2  456 3  1  453
Income (loss) before income taxes 281 88  46  193 20  12  173
SELECTED BALANCE SHEET DATA (at year end)
Loans:
Commercial 8,458 607  8  7,851 589  8  7,262
Commercial real estate 2,462 24  1  2,438 290  14  2,148
Consumer 3,545 (40) (1) 3,585 (2) —  3,587
Total loans 14,465 591  4  13,874 877  7  12,997
Total deposits 15,319 (30) —  15,349 (42) —  15,391
CREDIT QUALITY
Net loan and lease charge-offs (recoveries) $ 5  1  25  $ 4  (1) (20) $ 5 
Ratio of net charge-offs (recoveries) to average loans and leases 0.04  % 0.03  % 0.04  %
Allowance for credit losses $ 159  18  13  $ 141  2  1  $ 139 
Ratio of allowance for credit losses to net loans and leases, at year end 1.12  % 1.05  % 1.08  %
Nonperforming assets $ 58  (18) (24) $ 76  41  NM $ 35 
Ratio of nonperforming assets to net loans and leases and other real estate owned 0.40  % 0.55  % 0.27  %

National Bank of Arizona
National Bank of Arizona, headquartered in Phoenix, Arizona, operated 56 branches across Arizona at December 31, 2025. Based on domestic deposit market share in the state, NBAZ ranked as the fifth largest full-service commercial bank in Arizona.
NATIONAL BANK OF ARIZONA SELECTED FINANCIAL INFORMATION

(Dollar amounts in millions) 2025 Amount change Percent change 2024 Amount change Percent change 2023
SELECTED INCOME STATEMENT DATA
Net interest income $ 262 $ 17  7  % $ 245 $ (4) (2) % $ 249
Provision for credit losses (14) (31) NM 17 13  NM 4
Noninterest income 44 1  2  43 3  8  40
Noninterest expense 195 (1) (1) 196 2  1  194
Income (loss) before income taxes 125 50  67  75 (16) (18) 91
SELECTED BALANCE SHEET DATA (at year end)
Loans:
Commercial 2,530 34  1  2,496 (101) (4) 2,597
Commercial real estate 1,560 (172) (10) 1,732 (39) (2) 1,771
Consumer 1,501 85  6  1,416 157  12  1,259
Total loans 5,591 (53) (1) 5,644 17  —  5,627
Total deposits 6,968 84  1  6,884 39  1  6,845
CREDIT QUALITY
Net loan and lease charge-offs (recoveries) $ 3  2  NM $ 1  —  —  $ 1 
Ratio of net charge-offs (recoveries) to average loans and leases 0.05  % 0.02  % 0.02  %
Allowance for credit losses $ 49  (24) (33) $ 73  19  35  $ 54 
Ratio of allowance for credit losses to net loans and leases, at year end 0.88  % 1.28  % 1.02  %
Nonperforming assets $ 14  4  40  $ 10  (2) (17) $ 12 
Ratio of nonperforming assets to net loans and leases and other real estate owned 0.25  % 0.18  % 0.21  %

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Nevada State Bank
Nevada State Bank, headquartered in Las Vegas, Nevada, operated 43 branches across Nevada at December 31, 2025. Based on domestic deposit market share in the state, NSB ranked as the fifth largest full-service commercial bank in Nevada.
NEVADA STATE BANK SELECTED FINANCIAL INFORMATION

(Dollar amounts in millions) 2025 Amount change Percent change 2024 Amount change Percent change 2023
SELECTED INCOME STATEMENT DATA
Net interest income $ 213 $ 16  8  % $ 197 $ 5  3  % $ 192
Provision for credit losses (2) 9  82  (11) (53) NM 42
Noninterest income 52 —  —  52 7  16  45
Noninterest expense 174 (3) (2) 177 3  2  174
Income (loss) before income taxes 93 10  12  83 62  NM 21
SELECTED BALANCE SHEET DATA (at year end)
Loans:
Commercial 1,620 94  6  1,526 180  13  1,346
Commercial real estate 770 (51) (6) 821 (30) (4) 851
Consumer 1,340 7  1  1,333 99  8  1,234
Total loans 3,730 50  1  3,680 249  7  3,431
Total deposits 7,236 157  2  7,079 (60) (1) 7,139
CREDIT QUALITY
Net loan and lease charge-offs (recoveries) $ 3  (4) (57) $ 7  4  NM $ 3 
Ratio of net charge-offs (recoveries) to average loans and leases 0.08  % 0.20  % 0.09  %
Allowance for credit losses $ 46  (7) (13) $ 53  (13) (20) $ 66 
Ratio of allowance for credit losses to net loans and leases, at year end 1.24  % 1.49  % 1.95  %
Nonperforming assets $ 34  (8) (19) $ 42  (4) (9) $ 46 
Ratio of nonperforming assets to net loans and leases and other real estate owned 0.91  % 1.14  % 1.34  %

Vectra Bank Colorado
Vectra Bank Colorado, headquartered in Denver, Colorado, operated 33 branches in Colorado and one branch in New Mexico at December 31, 2025. Based on domestic deposit market share in the state, Vectra ranked as the 15 th largest full-service commercial bank in Colorado. FDIC deposit market share data for Vectra in New Mexico at June 30, 2025 was not considered meaningful.
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VECTRA BANK COLORADO SELECTED FINANCIAL INFORMATION

(Dollar amounts in millions) 2025 Amount change Percent change 2024 Amount change Percent change 2023
SELECTED INCOME STATEMENT DATA
Net interest income $ 143 $ (5) (3) % $ 148 $ (3) (2) % $ 151
Provision for credit losses 9 6  NM 3 (4) (57) 7
Noninterest income 36 7  24  29 1  4  28
Noninterest expense 137 —  —  137 (4) (3) 141
Income (loss) before income taxes 33 (4) (11) 37 6  19  31
SELECTED BALANCE SHEET DATA (at year end)
Loans:
Commercial 1,527 (175) (10) 1,702 (62) (4) 1,764
Commercial real estate 692 (100) (13) 792 (150) (16) 942
Consumer 1,433 24  2  1,409 78  6  1,331
Total loans 3,652 (251) (6) 3,903 (134) (3) 4,037
Total deposits 3,490 (102) (3) 3,592 97  3  3,495
CREDIT QUALITY
Net loan and lease charge-offs (recoveries) $ 9  —  —  $ 9  7  NM $ 2 
Ratio of net charge-offs (recoveries) to average loans and leases 0.23  % 0.22  % 0.05  %
Allowance for credit losses $ 40  (1) (2) $ 41  (4) (9) $ 45 
Ratio of allowance for credit losses to net loans and leases, at year end 1.04  % 1.01  % 1.12  %
Nonperforming assets $ 17  (12) (41) $ 29  13  81  $ 16 
Ratio of nonperforming assets to net loans and leases and other real estate owned 0.47  % 0.74  % 0.40  %

The Commerce Bank of Washington
The Commerce Bank of Washington, headquartered in Seattle, Washington, operates under the name “The Commerce Bank of Washington” within Washington and as “The Commerce Bank of Oregon” in Portland, Oregon. At December 31, 2025, TCBW operated two branches in Washington and one branch in Oregon. FDIC deposit market share data for TCBW in Washington and Oregon at June 30, 2025 was not considered meaningful.
THE COMMERCE BANK OF WASHINGTON SELECTED FINANCIAL INFORMATION

(Dollar amounts in millions) 2025 Amount change Percent change 2024 Amount change Percent change 2023
SELECTED INCOME STATEMENT DATA
Net interest income $ 71 $ 8  13  % $ 63 $ 2  3  % $ 61
Provision for credit losses 3 (6) (67) 9 7  NM 2
Noninterest income 8 —  —  8 1  14  7
Noninterest expense 36 3  9  33 (2) (6) 35
Income (loss) before income taxes 40 11  38  29 (2) (6) 31
SELECTED BALANCE SHEET DATA (at year end)
Loans:
Commercial 1,307 88  7  1,219 151  14  1,068
Commercial real estate 724 56  8  668 71  12  597
Consumer 67 3  5  64 (5) (7) 69
Total loans 2,098 147  8  1,951 217  13  1,734
Total deposits 1,042 (132) (11) 1,174 69  6  1,105
CREDIT QUALITY
Net loan and lease charge-offs (recoveries) $ 3  2  NM $ 1  1  NM $ — 
Ratio of net charge-offs (recoveries) to average loans and leases 0.15  % 0.06  % —  %
Allowance for credit losses $ 19  —  —  $ 19  8  73  $ 11 
Ratio of allowance for credit losses to net loans and leases, at year end 0.95  % 1.05  % 0.65  %
Nonperforming assets $ 30  24  NM $ 6  (2) (25) $ 8 
Ratio of nonperforming assets to net loans and leases and other real estate owned 1.43  % 0.31  % 0.46  %

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BALANCE SHEET ANALYSIS
Interest-earning Assets
Interest-earning assets—which include loans and leases, investment securities, and money market investments—carry associated interest rates or yields. We strive to maintain a high level of interest-earning assets relative to total assets. For more information regarding average balances, the associated revenue generated, and the corresponding yields of these assets, see the Average Balance Sheet on page 39.
AVERAGE LOANS AND LEASES, INVESTMENT SECURITIES, AND
MONEY MARKET INVESTMENTS (at December 31)

Investment Securities Portfolio
Investment securities are classified as either available-for-sale (“AFS”) or held-to-maturity (“HTM”), and are primarily used to provide balance sheet liquidity. The portfolio largely consists of securities that can be readily converted to cash or used to generate liquidity through secured borrowing agreements, without the need to sell the securities. Our investment securities portfolio also helps to balance the inherent interest rate mismatch between loans and deposits, thereby helping to preserve the economic value of shareholders’ equity. The estimated deposit duration at December 31, 2025 was assumed to be longer than the loan duration (including swaps). At December 31, 2025, the estimated duration of the investment securities portfolio, which measures price sensitivity to interest rate changes, was 3.8 years, compared with 3.4 years at December 31, 2024, reflecting slower realized prepayment assumptions than previously modeled.
For more information about our borrowing capacity associated with the investment securities portfolio and our approach to managing liquidity risk, refer to the “Liquidity Risk Management” section on page 75.
For more information on fair value measurements and the accounting for our investment securities portfolio, refer to Note 3 and Note 5 of the Notes to Consolidated Financial Statements.
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INVESTMENT SECURITIES PORTFOLIO

December 31, 2025 December 31, 2024
(In millions) Par Value Amortized
cost Fair
value Par Value Amortized
cost Fair
value
Available-for-sale
U.S. Treasury securities $ 1,500  $ 1,500  $ 1,411  $ 780  $ 781  $ 662 
U.S. Government agencies and corporations:
Agency securities 317  313  298  446  441  415 
Agency guaranteed mortgage-backed securities 7,213  7,207  6,223  7,656  7,713  6,451 
Small Business Administration loan-backed securities 334  355  341  427  455  434 
Municipal securities 884  953  909  1,096  1,186  1,108 
Other debt securities 25  25  25  25  25  25 
Total available-for-sale 10,273  10,353  9,207  10,430  10,601  9,095 
Held-to-maturity
U.S. Government agencies and corporations:
Agency securities $ 137  $ 137  $ 134  $ 148  $ 148  $ 140 
Agency guaranteed mortgage-backed securities 10,008  8,459  8,545  10,983  9,202  8,941 
Municipal securities 271  271  261  319  319  301 
Total held-to-maturity 10,416  8,867  8,940  11,450  9,669  9,382 

Total investment securities $ 20,689  $ 19,220  $ 18,147  $ 21,880  $ 20,270  $ 18,477 

The amortized cost of total investment securities decreased $1.1 billion, or 5%, during 2025, primarily due to principal reductions net of reinvestments. At December 31, 2025, approximately 6% of the portfolio consisted of floating-rate instruments, compared with 7% at December 31, 2024. Additionally, at December 31, 2025, we had active pay-fixed interest rate swaps with an aggregate notional amount of $6.7 billion. These swaps are designated as fair value hedges of fixed-rate AFS securities and effectively convert the fixed interest income on the hedged portion of the securities to a floating rate.
At December 31, 2025, the AFS investment securities portfolio included approximately $80 million in net premium, distributed across various security categories. Taxable-equivalent premium amortization for these investment securities totaled $46 million in 2025, compared with $57 million in 2024.
For more information regarding our investment securities portfolio, swaps, and related unrealized gains and losses, refer to the “Interest Rate Risk Management” section on page 72, the “Capital Management” section on page 80, and Note 5 of the Notes to Consolidated Financial Statements.

Municipal Investments and Extensions of Credit
We support our communities by offering a range of financial products and services to state and local governments (“municipalities”), including deposit services, lending solutions, and investment banking services. Additionally, we invest in securities issued by municipal entities.
Our municipal lending portfolio generally includes obligations that are repaid from, or secured by, the general funds or pledged revenues of municipalities, as well as by real estate or equipment. We also extend credit to private commercial and 501(c)(3) not-for-profit organizations that utilize a pass-through municipal structure to benefit from favorable tax treatment.
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The following schedule presents our total investments and extensions of credit to municipalities:
MUNICIPAL INVESTMENTS AND EXTENSIONS OF CREDIT

December 31,
(In millions) 2025 2024

Loans and leases $ 4,294  $ 4,364 
Unfunded lending commitments 384  524 
Available-for-sale – municipal securities 909  1,108 
Held-to-maturity – municipal securities 271  319 
Trading – municipal securities 64  35 
Total $ 5,922  $ 6,350 

Our municipal loans and securities are primarily concentrated within our geographic footprint. At December 31, 2025, approximately $2 million of municipal loans and leases were on nonaccrual, compared with $11 million at December 31, 2024. These nonaccrual loans were extended to private commercial entities that utilize a pass-through municipal structure to benefit from favorable tax treatment.
Municipal securities are internally risk-graded, using methodologies aligned with those applied to loans, with grading frameworks tailored to the size and nature of the credit exposure. These internal risk grades—Pass, Special Mention, and Substandard—are consistent with published regulatory risk classifications. At December 31, 2025, all municipal securities were rated as Pass. For additional information about the credit quality of our municipal loans and securities, see Notes 5 and 6 of the Notes to Consolidated Financial Statements.
Loan and Lease Portfolio
We offer a wide range of lending products to commercial customers, primarily small- and medium-sized businesses, as well as other products secured by CRE. Additionally, we provide various retail banking products and services to consumers and small businesses.
The following schedule presents the composition of our loan and lease portfolio:
LOAN AND LEASE PORTFOLIO

  December 31, 2025 December 31, 2024
(Dollar amounts in millions) Amount % of
total loans Amount % of
total loans
Commercial:
Commercial and industrial $ 17,761  29.2  % $ 16,891  28.4  %
Owner-occupied 9,274  15.2  9,333  15.7 
Municipal 4,294  7.0  4,364  7.4 
Leasing 367  0.6  377  0.6 
Total commercial 31,696  52.0  30,965  52.1 
Commercial real estate:
Term 11,234  18.4  10,703  18.0 
Construction and land development 2,162  3.6  2,774  4.7 
Total commercial real estate 13,396  22.0  13,477  22.7 
Consumer:
1-4 family residential 10,462  17.2  9,939  16.7 
Home equity credit line 3,950  6.5  3,641  6.1 
Construction and other consumer real estate 782  1.3  810  1.4 
Bankcard and other revolving plans 515  0.8  457  0.8 
Other 116  0.2  121  0.2 
Total consumer 15,825  26.0  14,968  25.2 
Total loans and leases $ 60,917  100.0  % $ 59,410  100.0  %

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During 2025, the loan and lease portfolio increased $1.5 billion, or 3%, to $60.9 billion. This growth was primarily driven by increases in the commercial and industrial, term CRE, and consumer 1-4 family residential mortgage loan portfolios. The ratio of loans and leases to total assets was 68% at December 31, 2025, compared with 67% at December 31, 2024. Commercial and industrial loans remained the largest loan segment, representing 29% and 28% of total loans for the same respective periods.
The following schedule presents the contractual maturity distribution of our loan and lease portfolio:
LOAN AND LEASE PORTFOLIO BY CONTRACTUAL MATURITY

December 31, 2025
(In millions) One year or less One year through five years Five years through fifteen years Over fifteen years Total
Commercial:
Commercial and industrial $ 3,706  $ 12,026  $ 1,977  $ 52  $ 17,761 
Owner-occupied 510  2,080  5,307  1,377  9,274 
Municipal 417  673  2,269  935  4,294 
Leasing 34  225  108  —  367 
Total commercial 4,667  15,004  9,661  2,364  31,696 
Commercial real estate:
Term 3,690  5,493  1,900  151  11,234 
Construction and land development
700  1,396  38  28  2,162 
Total commercial real estate 4,390  6,889  1,938  179  13,396 
Consumer:
1-4 family residential 6  20  167  10,269  10,462 
Home equity credit line 1  5  46  3,898  3,950 
Construction and other consumer real estate
1  1  22  758  782 
Bankcard and other revolving plans
318  197  —  —  515 
Other 9  79  28  —  116 
Total consumer 335  302  263  14,925  15,825 
Total loans and leases $ 9,392  $ 22,195  $ 11,862  $ 17,468  $ 60,917 

Our loans and leases have either predetermined (fixed) or variable interest rates. The following schedule presents the interest rate composition of our loan and lease portfolio with contractual maturities greater than one year, excluding the impact of any interest rate swaps associated with the portfolio. For more information about our interest rate risk management, see “Interest Rate Risk Management” section on page 72.
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LOAN AND LEASE PORTFOLIO WITH CONTRACTUAL MATURITIES OVER ONE YEAR BY INTEREST RATE TYPE

December 31, 2025
Loans with contractual maturities over one year
(In millions) Predetermined (fixed) interest rates Variable interest rates Total
Commercial:
Commercial and industrial $ 2,006  $ 12,049  $ 14,055 
Owner-occupied 2,814  5,950  8,764 
Municipal 2,662  1,215  3,877 
Leasing 333  —  333 
Total commercial 7,815  19,214  27,029 
Commercial real estate:
Term 1,493  6,051  7,544 
Construction and land development
13  1,449  1,462 
Total commercial real estate 1,506  7,500  9,006 
Consumer:
1-4 family residential 1,174  9,282  10,456 
Home equity credit line 182  3,767  3,949 
Construction and other consumer real estate
—  781  781 
Bankcard and other revolving plans
1  196  197 
Other 106  1  107 
Total consumer 1,463  14,027  15,490 
Total loans and leases $ 10,784  $ 40,741  $ 51,525 

Other Noninterest-bearing Investments
Other noninterest-bearing investments consist of equity investments held primarily for capital appreciation, dividends, or to meet certain regulatory requirements. The following schedule presents our related investments.
OTHER NONINTEREST-BEARING INVESTMENTS

December 31, Amount change Percent change
(Dollar amounts in millions) 2025 2024

Bank-owned life insurance $ 573  $ 562  $ 11  2  %
Federal Home Loan Bank stock 100  124  (24) (19)
Federal Reserve stock 54  65  (11) (17)
Farmer Mac stock 31  28  3  11 
SBIC investments 271  204  67  33 
Other 47  37  10  27 
Total other noninterest-bearing investments $ 1,076  $ 1,020  $ 56  5 

Other noninterest-bearing investments increased $56 million, or 5%, during 2025, This growth was primarily attributable to higher balances within our SBIC investment portfolio, partially offset by reductions in holdings of FHLB and Federal Reserve stock.
The SBIC investment portfolio increased $67 million, largely driven by new investments and valuation adjustments on related investments. The reduction in FHLB stock resulted from lower FHLB borrowings. To maintain borrowing capacity, we are required to hold FHLB stock equal to approximately 4-5% of our outstanding FHLB borrowings.
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Premises, Equipment, and Software
In July 2024, we successfully completed the final phase of a multi-year project to replace our core loan and deposit banking systems. As a result, we transitioned substantially all commercial, CRE, and non-mortgage consumer loans, as well as deposit accounts, to a modern, integrated core platform.
We continue to invest in additional lending, deposit, and other customer-focused technology initiatives aimed at further modernizing our systems, improving customer experiences, and enhancing operational performance. For additional information about our premises, equipment, and software, see Note 9 of the Notes to Consolidated Financial Statements.
The following schedule summarizes the capitalized costs associated with the core system replacement project, which are amortized using a useful life of ten years:
CAPITALIZED COSTS ASSOCIATED WITH THE CORE SYSTEM REPLACEMENT PROJECT

December 31, 2025
(In millions) Phase 1 Phase 2 Phase 3 Total

Total amount of capitalized costs, less accumulated amortization $ 8  $ 27  $ 186  $ 221 
End of scheduled amortization period Q2 2027 Q1 2029 Q2 2033

Deposits
Deposits are our primary funding source. The following schedule presents the composition of our deposit portfolio:
DEPOSIT PORTFOLIO

December 31, 2025 December 31, 2024
(Dollar amounts in millions) Amount % of
total
deposits Amount % of
total
deposits
Deposits by type
Noninterest-bearing demand $ 25,823  34.1  % $ 24,704  32.4  %
Interest-bearing:
Savings and money market 39,914  52.8  40,037  52.5 
Time 6,070  8.0  6,448  8.5 
Brokered 3,837  5.1  5,034  6.6 
Total interest-bearing 49,821  65.9  % 51,519  67.6  %
Total deposits $ 75,644  100.0  % $ 76,223  100.0  %
Deposit-related metrics
Estimated amount of insured deposits $ 41,228  55  % $ 41,836  55  %
Estimated amount of uninsured deposits 34,416  45  % 34,387  45  %
Estimated amount of collateralized deposits 1
$ 3,212  4  % $ 3,199  4  %
Loan-to-deposit ratio 81% 78%

1 Includes both insured and uninsured deposits.
Total deposits declined $579 million, or 1%, in 2025. Interest-bearing deposits decreased $1.7 billion, primarily due to a reduction in brokered deposits. This decline was partially offset by a $1.1 billion increase in noninterest-bearing demand deposits, mainly driven by the migration of a consumer interest-bearing product into a new noninterest-bearing offering. At December 31, 2025, customer deposits (excluding brokered deposits) totaled $71.8 billion, compared with $71.2 billion at December 31, 2024. These balances included approximately $6.8 billion and $7.0 billion of reciprocal deposits, respectively.
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At December 31, 2025, the total estimated amount of uninsured deposits was $34.4 billion, or 45% of total deposits, compared with $34.4 billion, or 45%, at December 31, 2024. Our loan-to-deposit ratio was 81%, compared with 78% for the same respective periods. For more information on liquidity, including the ratio of available liquidity to uninsured deposits, see “Liquidity Risk Management” on page 75.

RISK MANAGEMENT
As outlined in Item 1A. Risk Factors on page 14, we are exposed to a broad range of risks. Oversight of these risks is allocated across various management committees, with the Enterprise Risk Management Committee serving as the primary coordinating body. To address these risks, we employ comprehensive risk management practices designed to promote prudent risk-taking and effective oversight. Risk management is embedded in our operations and functions as a critical driver of overall performance, closely aligned with our key strategic objectives.
Our Risk Management Framework is structured around a three-lines-of-defense model, with clearly defined responsibilities for each line:
1. The first line of defense represents business units and functions engaged in revenue generation, expense management, operational support, and technology services. These groups are directly accountable for identifying, owning, and managing the risks inherent in their activities.
2. The second line of defense represents independent risk management and compliance functions responsible for assessing and overseeing risk-related activities across the organization.
3. The third line of defense is the internal audit function, which provides an independent assessment of the effectiveness of both the first and second lines of defense.
To support management’s efforts, the Board has established specialized committees responsible for overseeing the Bank's risk management processes:
• The Audit Committee assists the Board in monitoring the quality and integrity of the Bank's accounting, auditing, and financial reporting practices, while also ensuring compliance with applicable laws, regulations, and standards.
• The ROC provides governance over ERM activities. In accordance with its charter, the ROC meets regularly to review ERM processes, monitor risk exposures, and approve ERM policies and initiatives.
Credit Risk Management
Credit risk represents the potential for loss resulting from the failure of a borrower, guarantor, or other obligor to perform in accordance with the terms of a credit-related agreement. This risk arises primarily from our lending activities and from off-balance sheet credit instruments.
The Board, through the ROC, approves key credit policies, monitors adherence to those policies, and oversees alignment with the credit risk appetite established in the Risk Management Framework. The Board has delegated responsibility for credit risk management and for approving changes to credit policies to the Chief Credit Officer, who chairs the Credit Risk Committee.
Our approach to credit risk management is supported by formal credit policies and standards, risk management practices, and independent credit examination functions that together establish a consistent framework for sound underwriting and credit decision-making across our local banking affiliates. We emphasize strong underwriting standards and the early identification of potential problem credits to facilitate timely corrective actions and mitigate potential losses.
Our credit policies and practices are designed to mitigate key risks inherent in our lending activities, including risks related to borrower creditworthiness, cash flow volatility, collateral protection and valuation, concentrations of credit exposure, and external factors that may affect borrower performance or collateral values. Key elements of these policies include requirements for sensitivity and scenario analysis to assess borrower resilience—particularly the capacity to meet repayment obligations under adverse economic conditions, such as rising interest rates—as well
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as requirements for borrowers to maintain insurance coverage on collateralized properties at levels appropriate to the nature and extent of the credit exposure.
To strengthen oversight and objectivity, our credit risk management function operates independently from the lending function and is responsible for establishing credit risk standards, monitoring portfolio quality, and providing independent assessment of credit activities. We maintain well-defined standards for evaluating our loan portfolio and employ a comprehensive loan risk-grading system to assess and monitor potential credit risk exposure.
In addition, our internal credit examination department, which is independent of lending operations, conducts periodic reviews of lending departments and credit activities. These examinations assess credit quality, documentation adequacy, administration of loan risk grades, and compliance with established credit policies. Examinations related to the ACL are reported to both the Audit Committee and the ROC.
Our business activities are conducted primarily within the geographic footprint of our banking affiliates. To manage and limit undue concentrations of credit risk, we adhere to established concentration limits by industry, collateral type, geographic location, and individual customer or counterparty. These limits apply to certain commercial industries and portfolios, including leveraged lending, municipal lending, oil and gas-related lending, and various types of CRE lending—particularly construction and land development, multifamily, industrial, and office properties. Concentration limits are actively monitored and adjusted as conditions warrant.
U.S. Government Agency Guaranteed Loans
We participate in several guaranteed lending programs sponsored by U.S. government agencies, including the U.S. Small Business Administration (“SBA”), Federal Housing Authority, U.S. Department of Veterans Affairs, Export-Import Bank of the U.S., and the U.S. Department of Agriculture. At December 31, 2025, approximately $617 million in loans were guaranteed, primarily by the SBA. The following schedule presents the composition of our U.S. government agency-guaranteed loan portfolio:
U.S. GOVERNMENT AGENCY GUARANTEED LOANS

(Dollar amounts in millions) December 31,
2025 Percent
guaranteed December 31,
2024 Percent
guaranteed

Commercial $ 766  77  % $ 687  78  %
Commercial real estate 31  71  25  76 
Consumer 4  100  4  100 
Total loans $ 801  77  $ 716  78 

Commercial Lending
The following schedule presents the composition of our commercial lending portfolio:
COMMERCIAL LENDING PORTFOLIO

December 31, 2025 December 31, 2024
(Dollar amounts in millions) Amount % of total 
commercial loans Amount % of total 
commercial loans Amount change Percent change
Commercial:
Commercial and industrial $ 17,761  56.0  % $ 16,891  54.6  % $ 870  5.2  %
Owner-occupied 9,274  29.3  9,333  30.1  (59) (0.6)
Municipal 4,294  13.5  4,364  14.1  (70) (1.6)
Leasing 367  1.2  377  1.2  (10) (2.7)
Total commercial $ 31,696  100.0  % $ 30,965  100.0  % $ 731  2.4 

Our commercial loan portfolio spans a broad range of industries and generally carries maturities of one to five years, with amortization schedules determined by the nature of the underlying collateral and guarantees. These loans are typically structured to meet diverse financing needs and may take the form of seasonal, term, working capital, or
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bridge loans, offered as revolving and non-revolving lines of credit, amortizing term loans, guidance facilities, or single-payment loans. Loan agreements typically include covenants requiring borrowers to provide periodic financial statements, enabling ongoing monitoring of business performance, leverage, debt service coverage, and liquidity.
The underwriting process for commercial loans primarily focuses on a comprehensive evaluation of management quality, financial performance, industry dynamics, sponsorship (where applicable), and transaction structure. Credit enhancements are generally secured through collateral and guarantees from the owners or sponsors. Prospective cash flows are stress-tested under various downside scenarios, including revenue decline, margin compression, and interest rate volatility.
The following schedule presents the geographic distribution of our commercial lending portfolio, based on the location of the primary borrower.
COMMERCIAL LENDING BY GEOGRAPHY

December 31, 2025 December 31, 2024
(Dollar amounts in millions) Amount % of
total Nonaccrual loans Amount % of
total Nonaccrual loans

Commercial
Arizona $ 2,338  7.4  % $ 7  $ 2,202  7.1  % $ 5 
California 6,351  20.0  68  6,190  20.0  58 
Colorado 1,710  5.4  4  1,892  6.1  17 
Nevada 1,384  4.4  2  1,336  4.3  11 
Texas 7,978  25.2  32  7,367  23.8  47 
Utah/Idaho 6,479  20.4  23  6,309  20.4  6 
Washington/Oregon 1,425  4.5  8  1,338  4.3  10 
Other 1
4,031  12.7  2  4,331  14.0  4 
Total commercial $ 31,696  100.0  % $ 146  $ 30,965  100.0  % $ 158 

1 No other geography exceeds 2.1% and 2.6% for December 31, 2025 and December 31, 2024, respectively.
The following schedule presents the industry distribution of our commercial lending portfolio, classified based on the North American Industry Classification System.
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COMMERCIAL LENDING BY INDUSTRY

December 31, 2025 December 31, 2024
(Dollar amounts in millions) Amount % of
total Nonaccrual loans Amount % of
total Nonaccrual loans

Real estate, rental, and leasing $ 3,321  10.5  % $ 32  $ 3,083  10.0  % $ 7 
Retail trade 2,810  8.9  6  2,873  9.3  7 
Manufacturing 2,591  8.2  20  2,322  7.5  7 
Healthcare and social assistance 2,342  7.4  7  2,541  8.2  34 
Finance and insurance 2,306  7.3  10  2,762  8.9  1 
Public Administration 2,226  7.0  —  2,106  6.8  — 
Wholesale trade 1,870  5.9  1  1,909  6.2  2 
Utilities 1
1,591  5.0  —  1,389  4.5  2 
Transportation and warehousing 1,567  4.9  6  1,589  5.1  7 
Construction 1,529  4.8  13  1,335  4.3  26 
Hospitality and food services 1,423  4.5  2  1,352  4.4  2 
Mining, quarrying, and oil and gas extraction 1,284  4.1  —  1,178  3.8  — 
Educational services 1,187  3.7  —  1,292  4.2  — 
Other Services (except Public Administration) 1,098  3.5  2  1,069  3.4  3 
Professional, scientific, and technical services 1,071  3.4  3  1,057  3.4  25 
Other 2
3,480  10.9  44  3,108  10.0  35 
Total $ 31,696  100.0  % $ 146  $ 30,965  100.0  % $ 158 

1 Includes primarily utilities, power, and renewable energy.
2 No other industry group exceeds 3.2% and 3.4% for December 31, 2025 and December 31, 2024, respectively.
As previously noted, our commercial lending portfolio is well-diversified across both geographic regions and industry sectors. In light of increased investor interest in loans extended to NDFIs, we provide the following information regarding these exposures within our commercial lending portfolio.
Loans to Nondepository Financial Institutions
NDFIs encompass a wide range of financial entities that provide services similar to those of traditional banking institutions, but do not accept public deposits and are not generally subject to oversight by federal banking regulators. We provide financing to NDFIs, including mortgage intermediaries, business development companies (“BDCs”), private equity funds, consumer credit platforms, and other financial entities.
We regularly monitor NDFI exposures through borrower-level hold limits, perform stress testing of underlying portfolios, verify compliance with applicable regulatory requirements, review portfolio quality, and assess liquidity and capital adequacy.
Our NDFI portfolio is diversified across various lending segments and asset classes, including:
• Mortgage credit intermediaries — Loans to mortgage companies engaged in residential or commercial mortgage origination and servicing; special purpose entities supporting mortgage-related securitization activities, such as real estate investment trusts (“REITs”) and collateralized debt obligations.
• Business credit intermediaries — Loans to finance companies, direct lenders, private debt funds, equipment leasing companies, BDCs, SBICs, senior loan funds, and other nonbank business lenders.
• Private equity funds — Capital call commitment and subscription-based facilities extended to private equity, venture capital, and other general partnership funds.
• Consumer credit intermediaries — Loans to nonbank consumer secured and unsecured lending platforms, as well as special purposes entities, finance companies, direct lenders, private debt funds, equipment leasing companies, or other financial intermediaries whose underlying assets primarily consist of consumer loans.
• Other — Loans to insurance companies, investment banks, broker-dealers, publicly listed investment funds, hedge funds, family offices, and other investment firms and financial vehicles.
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At December 31, 2025, loans to NDFIs totaled approximately $2.0 billion, representing 6.3% of total commercial loans and 3.3% of total loans, a decrease from $2.4 billion, or 7.6% of total commercial loans and 4.0% of total loans, at December 31, 2024.
The following schedule presents the composition of our NDFI lending portfolio:
NDFI LENDING PORTFOLIO

December 31, 2025 December 31, 2024
(Dollar amounts in millions) Amount % of
total Nonaccrual loans Amount % of
total Nonaccrual loans

Mortgage credit intermediaries $ 352  17.6  % $ 9  $ 559  23.8  % $ — 
Business credit intermediaries 1
968  48.4  —  489  20.8  1 
Private equity funds 121  6.1  —  189  8.0  — 
Consumer credit intermediaries 303  15.2  —  349  14.8  — 
Other financial institutions 1
253  12.7  1  767  32.6  — 
Total NDFI portfolio $ 1,997  100.0  % $ 10  $ 2,353  100.0  % $ 1 

1 Balances as of December 31, 2025 reflect an updated categorization of NDFI loans based on industry and purpose, compared with balances at December 31, 2024. This resulted in the reclassification of certain loans primarily from “Other financial institutions” to “Business credit intermediaries.”
The following schedule presents NDFI loan credit quality metrics:
NDFI LOAN CREDIT QUALITY

(Dollar amounts in millions) December 31, 2025 December 31, 2024

Credit quality metrics
Criticized loan ratio 0.8  % 5.5  %
Classified loan ratio 0.8  % 5.5  %
Nonaccrual loan ratio 0.5  % —  %
Delinquency ratio —  % —  %
Ratio of NDFI net charge-offs 1 (recoveries) to average loans
2.7  % —  %
Ratio of allowance for credit losses to NDFI loans, at period end 1.03  % 0.64  %

1 Total NDFI net charge-offs primarily included a $50 million charge-off recorded in the third quarter of 2025 associated with revolving lines of credit extended to two related commercial borrowers to finance the origination and purchase of commercial and residential mortgages. This resulted from a review of the borrowers, guarantors, and associated collateral, which identified apparent irregularities and misrepresentations. As a result, legal action has been initiated to pursue recovery of the outstanding amounts owed from the guarantors of the credits.

Commercial Real Estate Lending
The following schedule presents the composition of our CRE lending portfolio:
COMMERCIAL REAL ESTATE LENDING PORTFOLIO

December 31, 2025 December 31, 2024
(Dollar amounts in millions) Amount % of total 
CRE loans Amount % of total 
CRE loans Amount change Percent change
Commercial real estate:
Term $ 11,234  83.9  % $ 10,703  79.4  % $ 531  5.0  %
Construction and land development 2,162  16.1  2,774  20.6  (612) (22.1)
Total commercial real estate $ 13,396  100.0  % $ 13,477  100.0  % $ (81) (0.6)

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Term CRE loans typically have maturities ranging from three to seven years and may incorporate full, partial, or non-recourse guarantee structures. Standard term CRE loan arrangements generally include annually tested operating covenants, requiring loan rebalancing based on minimum debt service coverage, debt yield, or loan-to-value (“LTV”) ratios.
Construction and land development loans generally mature within 18 to 36 months and may involve full or partial recourse guarantees. These loans often include one- to five-year extension options or roll-to-permanent features, which commonly convert into term loans upon completion.
Underwriting for commercial properties primarily emphasizes the economic viability of the project, while also giving considerable weight to the sponsor's creditworthiness and experience. Owners are generally required to contribute their equity prior to any loan advances. Loan agreements frequently include remargining provisions—requiring additional equity infusions if the collateral's value or cash flow declines—as well as sponsor guarantees.
Underwriting for residential construction and development loans incorporates many of the same requirements applied to commercial projects, including the developer's creditworthiness and experience, up-front equity contributions, principal curtailment provisions, and overall project viability. Additional considerations include anticipated market acceptance of the product, location quality, the developer's financial strength, and their ability to maintain budget discipline.
Routine progress inspections by qualified independent inspectors are conducted prior to each loan disbursement. Advance rates are determined based on the collateral quality, project viability, and sponsor creditworthiness, with exceptions granted on a case-by-case basis.
Appraisals are performed in compliance with applicable regulatory standards. In certain cases, automated valuation reports or internal evaluations may be utilized. An appraisal is ordered and reviewed prior to loan closing, and a new appraisal or evaluation is typically obtained when market conditions indicate a potential decline in collateral value, or when a loan is modified, renewed, or exhibits signs of credit deterioration.
For CRE loans, the LTV ratio is calculated by dividing the outstanding loan balance by the most recent appraised collateral value. At December 31, 2025, the weighted average LTV ratio for our term CRE portfolio was below 60%.
Loan agreements require regular submission of financial information related to both the project and the sponsor. This includes lease schedules, rent rolls, and, for construction projects, independent progress inspection reports. We actively monitor this financial information to verify compliance with the covenants outlined in the loan agreement.
The presence of a guarantee that improves repayment likelihood is factored into the assessment of expected losses on CRE loans. When guarantor support is measurable and properly documented, it is incorporated into projected cash flows and liquidity available for debt service. Our expected loss methodology accounts for these additional repayment sources.
As part of our credit extension process, we typically obtain and review updated financial information for the guarantor. The scope and frequency of financial reporting collected and analyzed vary based on contractual requirements, transaction size, and the guarantor's financial strength.
In the event of default, we pursue all available sources of repayment, including collateral and guarantors. Several factors influence the decision to enforce a guarantor obligation, such as the value and liquidity of other repayment sources (e.g., collateral), the guarantor's financial strength and liquidity, applicable statutory limitations, and the cost-benefit analysis of pursuing the guarantee relative to the potential recovery amount.
The following schedule presents the geographic distribution of our CRE lending portfolio, based on the location of the primary collateral:
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COMMERCIAL REAL ESTATE LENDING BY GEOGRAPHY

December 31, 2025 December 31, 2024
(Dollar amounts in millions) Amount % of
total Nonaccrual loans Amount % of
total Nonaccrual loans

Commercial real estate
Arizona $ 1,709  12.8  % $ —  $ 1,801  13.4  % $ — 
California 3,549  26.5  22  3,569  26.5  50 
Colorado 726  5.4  16  666  4.9  — 
Nevada 1,016  7.6  —  1,104  8.2  — 
Texas 2,566  19.2  5  2,596  19.2  8 
Utah/Idaho 2,376  17.7  —  2,170  16.1  — 
Washington/Oregon 1,122  8.4  30  1,090  8.1  — 
Other 332  2.4  —  481  3.6  1 
Total commercial real estate $ 13,396  100.0  % $ 73  $ 13,477  100.0  % $ 59 

The following schedule presents our CRE lending portfolio, categorized by the type of collateral:
COMMERCIAL REAL ESTATE LENDING BY COLLATERAL TYPE

December 31, 2025 December 31, 2024
(Dollar amounts in millions) Amount % of
total Nonaccrual loans Amount % of
total Nonaccrual loans
Commercial property
Multifamily $ 3,994  29.8  % $ —  $ 4,007  29.7  % $ 1 
Industrial 3,045  22.7  —  2,954  21.9  — 
Office 1,675  12.5  67  1,812  13.5  50 
Retail 1,586  11.8  —  1,533  11.4  — 
Hospitality 678  5.1  5  625  4.6  8 
Land 286  2.1  —  261  1.9  — 
Other 1
1,436  10.8  —  1,644  12.2  — 
Residential property 2

Single family 398  3.0  1  330  2.5  — 
Land 111  0.8  —  110  0.8  — 
Condo/Townhome 29  0.2  —  17  0.1  — 
Other 1
158  1.2  —  184  1.4  — 
Total $ 13,396  100.0  % $ 73  $ 13,477  100.0  % $ 59 

1 Included in the total amount of the “Other” commercial and residential categories was approximately $232 million and $342 million of unsecured loans at December 31, 2025 and 2024, respectively.
2 Residential property consists primarily of loans provided to commercial homebuilders for land, lot, and single-family housing developments.
As previously noted, our CRE lending portfolio is diversified by both geography and collateral type, with the largest concentration in multifamily properties. Given the recent investor interest in multifamily, industrial, and office collateral types, we have provided additional analysis of these segments within our CRE portfolio below.
Multifamily CRE
At both December 31, 2025 and 2024, our multifamily CRE loan portfolio totaled $4.0 billion, representing 30% of the total CRE loan portfolio. Approximately 47% of the multifamily CRE loan portfolio is scheduled to mature within the next 12 months. We anticipate that most of these borrowers will successfully refinance at maturity—either through the Bank or other lenders—supported by strong property cash flows, appropriate LTVs, sufficient equity positions, and guarantor backing. The following schedule presents the composition of our multifamily CRE loan portfolio, along with related credit quality metrics:
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MULTIFAMILY CRE LOAN PORTFOLIO

(Dollar amounts in millions) December 31, 2025 December 31, 2024
Multifamily CRE
Term $ 3,203  $ 2,918 
Construction and land development 791  1,089 
Total multifamily CRE $ 3,994  $ 4,007 
Credit quality metrics
Criticized loan ratio 17.5  % 21.5  %
Classified loan ratio 15.0  % 18.8  %
Nonaccrual loan ratio —  % —  %
Delinquency ratio —  % —  %
Ratio of multifamily CRE net charge-offs (recoveries) to average loans —  % —  %
Ratio of allowance for credit losses to multifamily CRE loans, at period end 1.50  % 2.55  %
Weighted average LTV for multifamily term CRE loans 59  % 57  %

The following schedules present our multifamily CRE loan portfolio, categorized by collateral location for the periods presented:
MULTIFAMILY CRE LOAN PORTFOLIO BY COLLATERAL LOCATION

December 31, 2025
Loan Type
(Dollar amounts in millions) Term Construction and land development Total % of
total Nonaccrual loans
Multifamily CRE
Arizona $ 301  $ 52  $ 353  8.8  % $ — 
California 898  134  1,032  25.9  — 
Colorado 158  74  232  5.8  — 
Nevada 206  7  213  5.3  — 
Texas 931  191  1,122  28.1  — 
Utah/Idaho 420  232  652  16.3  — 
Washington/Oregon 228  101  329  8.3  — 
Other 61  —  61  1.5  — 
Total multifamily CRE $ 3,203  $ 791  $ 3,994  100.0  % $ — 

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December 31, 2024
Loan Type
(Dollar amounts in millions) Term Construction and land development Total % of
total Nonaccrual loans
Multifamily CRE
Arizona $ 364  $ 142  $ 506  12.6  % $ — 
California 850  172  1,022  25.5  1 
Colorado 91  101  192  4.8  — 
Nevada 188  99  287  7.2  — 
Texas 808  310  1,118  27.9  — 
Utah/Idaho 320  134  454  11.3  — 
Washington/Oregon 234  130  364  9.1  — 
Other 63  1  64  1.6  — 
Total multifamily CRE $ 2,918  $ 1,089  $ 4,007  100.0  % $ 1 

Industrial CRE
At December 31, 2025 and 2024, our industrial CRE loan portfolio totaled $3.0 billion, representing 23% and 22% of the total CRE loan portfolio, respectively. Approximately 34% of the industrial CRE loan portfolio is scheduled to mature within the next 12 months. We anticipate that most of these borrowers will successfully refinance at maturity—either through the Bank or other lenders—supported by strong property cash flows, appropriate LTVs, sufficient equity positions, and guarantor backing.
The following schedule presents the composition of our industrial CRE loan portfolio and other related credit quality metrics:
INDUSTRIAL CRE LOAN PORTFOLIO

(Dollar amounts in millions) December 31, 2025 December 31, 2024
Industrial CRE
Term $ 2,720  $ 2,462 
Construction and land development 325  492 
Total industrial CRE $ 3,045  $ 2,954 
Credit quality metrics
Criticized loan ratio 11.3  % 14.6  %
Classified loan ratio 10.3  % 12.8  %
Nonaccrual loan ratio —  % —  %
Delinquency ratio —  % —  %
Ratio of industrial CRE net charge-offs (recoveries) to average loans —  % —  %
Ratio of allowance for credit losses to industrial CRE loans, at period end 1.48  % 2.30  %
Weighted average LTV for industrial term CRE loans 63  % 53  %

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The following schedules present our industrial CRE loan portfolio, categorized by collateral location for the periods presented:
INDUSTRIAL CRE LOAN PORTFOLIO BY COLLATERAL LOCATION

December 31, 2025
Loan Type
(Dollar amounts in millions) Term Construction and land development Total % of
total Nonaccrual loans
Industrial CRE

Arizona $ 464  $ 19  $ 483  15.9  % $ — 
California 861  23  884  29.0  — 
Colorado 79  15  94  3.1  — 
Nevada 224  64  288  9.5  — 
Texas 438  40  478  15.7  — 
Utah/Idaho 385  134  519  17.0  — 
Washington/Oregon 218  30  248  8.1  — 
Other 51  —  51  1.7  — 
Total industrial CRE $ 2,720  $ 325  $ 3,045  100.0  % $ — 

December 31, 2024
Loan Type
(Dollar amounts in millions) Term Construction and land development Total % of
total Nonaccrual loans
Industrial CRE

Arizona $ 374  $ 33  $ 407  13.8  % $ — 
California 730  189  919  31.1  — 
Colorado 58  1  59  2.0  — 
Nevada 241  108  349  11.8  — 
Texas 453  42  495  16.8  — 
Utah/Idaho 350  83  433  14.7  — 
Washington/Oregon 201  36  237  8.0  — 
Other 55  —  55  1.8  — 
Total industrial CRE $ 2,462  $ 492  $ 2,954  100.0  % $ — 

Office CRE
At December 31, 2025 and 2024, our office CRE loan portfolio totaled $1.7 billion and $1.8 billion, respectively, representing 13% of the total CRE loan portfolio in both periods. Approximately 26% of the office CRE loan portfolio is scheduled to mature within the next 12 months. We anticipate that most of these borrowers will successfully refinance at maturity—either through the Bank or other lenders—supported by strong property cash flows, appropriate LTVs, sufficient equity positions, and guarantor backing.
The following schedule presents the composition of our office CRE loan portfolio and other related credit quality metrics:
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OFFICE CRE LOAN PORTFOLIO

(Dollar amounts in millions) December 31, 2025 December 31, 2024
Office CRE
Term $ 1,655  $ 1,697 
Construction and land development 20  115 
Total office CRE $ 1,675  $ 1,812 
Credit quality metrics
Criticized loan ratio 9.4  % 14.5  %
Classified loan ratio 9.3  % 12.8  %
Nonaccrual loan ratio 4.0  % 2.8  %
Delinquency ratio 1.1  % 1.4  %
Ratio of office CRE net charge-offs (recoveries) to average loans 0.1  % 0.3  %

Ratio of allowance for credit losses to office CRE loans, at period end 2.93  % 3.92  %
Weighted average LTV for office term CRE loans 57  % 56  %

The following schedules present our office CRE loan portfolio, categorized by collateral location for the periods presented:
OFFICE CRE LOAN PORTFOLIO BY COLLATERAL LOCATION

December 31, 2025
Loan Type
(Dollar amounts in millions) Term Construction and land development Total % of
total Nonaccrual loans
Office CRE
Arizona $ 225  $ —  $ 225  13.4  % $ — 
California 304  5  309  18.5  21 
Colorado 59  —  59  3.5  16 
Nevada 87  —  87  5.2  — 
Texas 170  —  170  10.2  1 
Utah/Idaho 473  15  488  29.1  — 
Washington/Oregon 328  —  328  19.6  29 
Other 9  —  9  0.5  — 
Total office CRE $ 1,655  $ 20  $ 1,675  100.0  % $ 67 

December 31, 2024
Loan Type
(Dollar amounts in millions) Term Construction and land development Total % of
total Nonaccrual loans
Office CRE
Arizona $ 255  $ —  $ 255  14.1  % $ — 
California 328  38  366  20.2  49 
Colorado 58  —  58  3.2  — 
Nevada 77  11  88  4.9  — 
Texas 186  7  193  10.6  1 
Utah/Idaho 482  34  516  28.5  — 
Washington/Oregon 283  25  308  17.0  — 
Other 28  —  28  1.5  — 
Total office CRE $ 1,697  $ 115  $ 1,812  100.0  % $ 50 

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Consumer Lending
The following schedule presents the composition of our consumer lending portfolio:
CONSUMER LENDING PORTFOLIO

December 31, 2025 December 31, 2024
(Dollar amounts in millions) Amount % of total 
consumer loans Amount % of total 
consumer loans Amount change Percent change
Consumer:
1-4 family residential $ 10,462  66.1  % $ 9,939  66.4  % $ 523  5.3  %
Home equity credit line 3,950  25.0  3,641  24.3  309  8.5 
Construction and other consumer real estate 782  4.9  810  5.4  (28) (3.5)
Bankcard and other revolving plans 515  3.3  457  3.1  58  12.7 
Other 116  0.7  121  0.8  (5) (4.1)
Total consumer $ 15,825  100.0  % $ 14,968  100.0  % $ 857  5.7 

1-4 Family Residential Mortgages
We originate first-lien residential home mortgage loans that are considered prime quality. At December 31, 2025, our 1-4 family residential mortgage loan portfolio totaled $10.5 billion, or 66%, of our total consumer loan portfolio, compared with $9.9 billion, or 66%, at December 31, 2024.
At December 31, 2025 and December 31, 2024, approximately 89% and 90%, respectively, of our 1-4 family residential mortgage loan portfolio consisted of variable-rate loans. We generally retain variable-rate loans in our loan portfolio and sell conforming fixed-rate loans to third parties, including the Federal National Mortgage Association and the Federal Home Loan Mortgage Corporation. In connection with these sales, we provide customary representations and warranties affirming that the loans satisfy specified underwriting standards and collateral documentation requirements.
Home Equity Credit Lines
We also originate home equity credit lines (“HECLs”). At December 31, 2025 and December 31, 2024, our HECL portfolio totaled $4.0 billion, and $3.6 billion, respectively. Approximately 34% and 37% of these HECLs were secured by first liens for the respective periods.
At December 31, 2025, loans representing less than 1% of the outstanding HECL portfolio balance were estimated to have combined loan-to-value (“CLTV”) ratios exceeding 100%. The estimated CLTV ratio is calculated by dividing the sum of our loan and any prior lien amounts divided by the estimated current collateral value. At origination, underwriting standards for the HECL portfolio generally require a maximum CLTV of 80% and a Fair Isaac Corporation (“FICO”) credit score above 700.
At December 31, 2025, approximately 93% of our HECL portfolio remained in the draw period, with about 22% of those loans scheduled to begin amortizing within the next five years. We believe the risk of loss or borrower default upon full amortization, as well as the impact of significant interest rate changes, is low due to the rate shock analysis performed at origination.
The ratio of HECL net charge-offs (recoveries) for the trailing twelve months to average balances was 0.01% at December 31, 2025, compared with 0.00% at December 31, 2024. For additional information regarding the credit quality of the HECL portfolio, see Note 6 of the Notes to Consolidated Financial Statements.
The following schedule presents the geographic distribution of our consumer lending portfolio, based on the location of the primary borrower:
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CONSUMER LENDING BY GEOGRAPHY

December 31, 2025 December 31, 2024
(Dollar amounts in millions) Amount % of
total Nonaccrual loans Amount % of
total Nonaccrual loans
Consumer
Arizona $ 1,439  9.1  % $ 7  $ 1,365  9.1  % $ 5 
California 3,683  23.3  15  3,159  21.1  14 
Colorado 1,396  8.8  12  1,353  9.1  7 
Nevada 1,344  8.5  12  1,328  8.9  10 
Texas 3,658  23.1  25  3,657  24.4  25 
Utah/Idaho 3,521  22.3  19  3,430  22.9  14 
Washington/Oregon 320  2.0  3  237  1.6  — 
Other 464  2.9  3  439  2.9  5 
Total consumer $ 15,825  100.0  % $ 96  $ 14,968  100.0  % $ 80 

Credit Quality
We monitor credit quality by assessing multiple factors, including nonperforming status, internal risk grades, and net charge-offs. These metrics are integral to our overall evaluation of the adequacy of the ACL. For more information on these factors and the ACL, see Note 6 of the Notes to Consolidated Financial Statements.
Nonperforming Assets
Nonperforming assets include nonaccrual loans and OREO, or foreclosed properties. The following schedule presents the composition of our nonperforming assets:
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NONPERFORMING ASSETS

(Dollar amounts in millions) December 31,
2025 2024
Nonaccrual loans:

Commercial:
Commercial and industrial $ 90  $ 114 
Owner-occupied 51  31 
Municipal 2  11 
Leasing 3  2 
Commercial real estate:
Term 72  59 
Construction and land development 1  — 
Consumer:
Real estate 95  79 
Other 1  1 
Total nonaccrual loans 315  297 
Other real estate owned 1 :

Commercial:
Commercial properties 3  1 
Developed land —  — 
Land —  — 
Residential:
1-4 family 2  — 

Total other real estate owned 5  1 
Total nonperforming assets $ 320  $ 298 
Accruing loans past due 90 days or more:
Commercial $ 3  $ 14 
Commercial real estate 1  3 
Consumer 1  1 
Total accruing loans past due 90 days or more $ 5  $ 18 
Nonaccrual loans current as to principal and interest payments:
Commercial $ 92  $ 126 
Commercial real estate 50  28 
Consumer 37  29 
Total nonaccrual loans current as to principal and interest payments $ 179  $ 183 

Ratio of nonperforming assets to net loans and leases 2 and other real estate owned
0.52  % 0.50  %
Ratio of accruing loans past due 90 days or more to net loans and leases 2
0.01  % 0.03  %
Ratio of nonperforming assets 2 and accruing loans past due 90 days or more to loans and leases 2 and other real estate owned 1
0.53  % 0.53  %
Ratio of nonaccrual loans 1 current as to principal and interest payments
56.8  % 61.6  %

1 Does not include banking premises held for sale.
2 Includes loans held for sale.
Nonperforming assets totaled $320 million, or 0.52%, of total loans and leases and other real estate owned at December 31, 2025, compared with $298 million, or 0.50%, at December 31, 2024. Nonperforming assets increased primarily within the commercial owner-occupied, term CRE, and consumer 1-4 family residential loan portfolios, partially offset by a decline in the commercial and industrial portfolio. For more information on nonaccrual loans, see Note 6 of the Notes to Consolidated Financial Statements.
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Classified Loans
Classified loans are considered loans with well-defined weaknesses and are assigned using our internal risk grade definitions of substandard and doubtful, which are consistent with regulatory risk classifications. The following schedule presents our classified loans by loan segment:
CLASSIFIED LOANS

(Dollar amounts in millions) December 31,
2025 December 31,
2024

Commercial
$ 1,063  $ 1,130 
Commercial real estate 1,205  1,651 
Consumer 112  89 
Total classified loans $ 2,380  $ 2,870 
Ratio of classified loans to total loans and leases 3.91  % 4.83  %

Classified loans totaled $2.4 billion, or 3.91% of total loans and leases, at December 31, 2025, compared with $2.9 billion, or 4.83%, at December 31, 2024. The year-over-year decline was primarily driven by reductions in classified CRE exposures, largely attributable to loan payoffs. The loss content of our CRE loan portfolio continues to be mitigated by strong underwriting, supported by significant borrower equity and guarantor support. As a result, our CRE nonperforming assets and net charge-offs have remained relatively low.
Allowance for Credit Losses
The ACL comprises both the ALLL and the RULC and represents our estimate of current expected credit losses related to the loan and lease portfolio and unfunded lending commitments as of the balance sheet date.
We estimate current expected credit losses using econometric loss models that incorporate historical credit loss experience, prevailing economic conditions, and multiple forward-looking economic scenarios. These scenarios—including optimistic, baseline, and stressed conditions—are weighted to produce the quantitative component of the ACL, and management may adjust the weightings based on its assessment of current economic conditions and reasonable and supportable forecasts. Because economic forecasts may not always align with observed credit quality trends, changes in the ACL may not necessarily correspond directionally with changes in credit quality.
Additionally, we consider qualitative and environmental factors that may indicate actual losses could differ from amounts estimated by the quantitative models. The influence of these factors on the ACL may vary from quarter to quarter. During 2025, the qualitative portion of the ACL decreased primarily due to reduced CRE portfolio-specific risks, leading us to assign lesser weight to stressed economic assumptions for that portfolio.
The following schedules present the changes in, and allocation of, the ACL:
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CHANGES IN THE ALLOWANCE FOR CREDIT LOSSES

Year Ended December 31,
(Dollar amounts in millions) 2025 2024 2023

Loans and leases outstanding, $ 60,917 $ 59,410 $ 57,779
Average loans and leases outstanding:
Commercial 31,389 30,671 30,519
Commercial real estate 13,562 13,532 13,023
Consumer 15,470 14,344 13,198
Total average loans and leases outstanding $ 60,421 $ 58,547 $ 56,740
Allowance for loan and lease losses:
Balance at beginning of year $ 696  $ 684  $ 572 
Provision for loan losses 71  72  148 
Charge-offs:
Commercial 103  68  45 
Commercial real estate 4  11  3 
Consumer 15  12  14 
Total 122  91  62 
Recoveries:
Commercial 24  23  20 
Commercial real estate 4  3  — 
Consumer 5  5  6 
Total 33  31  26 
Net loan and lease charge-offs 89  60  36 
Balance at end of year $ 678  $ 696  $ 684 
Reserve for unfunded lending commitments:
Balance at beginning of year $ 45  $ 45  $ 61 
Provision for unfunded lending commitments 1  —  (16)
Balance at end of year $ 46  $ 45  $ 45 
Total allowance for credit losses:
Allowance for loan and lease losses $ 678  $ 696  $ 684 
Reserve for unfunded lending commitments 46  45  45 
Total allowance for credit losses $ 724  $ 741  $ 729 

Ratio of allowance for credit losses to net loans and leases 1.19  % 1.25  % 1.26  %
Ratio of allowance for credit losses to nonaccrual loans 230  % 249  % 328  %
Ratio of allowance for credit losses to nonaccrual loans and accruing loans past due 90 days or more 226  % 235  % 324  %
Ratio of total net charge-offs to average total loans and leases 0.15  % 0.10  % 0.06  %
Ratio of commercial net charge-offs to average commercial loans 0.25  % 0.15  % 0.08  %
Ratio of commercial real estate net charge-offs to average commercial real estate loans —  % 0.06  % 0.02  %
Ratio of consumer net charge-offs to average consumer loans 0.06  % 0.05  % 0.06  %

ALLOCATION OF THE ALLOWANCE FOR CREDIT LOSSES

December 31,
2025 2024 2023
(Dollar amounts in millions) % of total loans Allocation of ACL % of total loans Allocation of ACL % of total loans Allocation of ACL
Loan segment
Commercial 52.0  % $ 410  52.1  % $ 334  53.0  % $ 321 
Commercial real estate
22.0  204  22.7  311  23.1  258 
Consumer 26.0  110  25.2  96  23.9  150 
Total 100.0  % $ 724  100.0  % $ 741  100.0  % $ 729 

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For further discussion regarding changes in the ACL, see “The Allowance and Provision for Credit Losses” section on page 40. For additional details concerning the ACL and credit trends within each portfolio segment, see Note 6 of the Notes to Consolidated Financial Statements.

Interest Rate and Market Risk Management
Interest rate and market risk refer to the potential for adverse impacts on current or future earnings and capital arising from changes in interest rates and other market conditions. Given our involvement in transactions with a broad range of financial instruments, we are inherently exposed to these risks.
The Board approves key policies governing the management of financial risks, including interest rate and market risk. Responsibility for managing these risks has been delegated to the Asset Liability Committee (“ALCO”), which is composed of members of management. ALCO establishes and periodically updates policy limits and reviews, in coordination with the ROC, the limits and any exceptions reported by management.
We actively manage our exposure to interest rate fluctuations by positioning the balance sheet to reduce volatility in both net interest income and the economic value of equity (“EVE”). Given that a significant portion of our balance sheet funding is derived from non-maturity deposit products, we rely on behavioral models and assumptions to forecast the sensitivity of earnings to interest rate movements. These models and assumptions are subject to ongoing performance monitoring and refinement.
When observed deposit behavior diverges from model expectations, the models are updated accordingly, with greater emphasis placed on recently observed behavior. All model changes are independently reviewed by our Model Risk Management function.
Our deposit-behavior models incorporate assumptions about the correlation between the rates paid on interest-bearing deposits and fluctuations in average benchmark interest rates. This is commonly referred to as “deposit beta.” Certificates of deposit are typically modeled with a higher degree of correlation, whereas interest-bearing checking accounts are assumed to exhibit a lower sensitivity to rate changes.
Many consumer and business deposit accounts have historically demonstrated stability and limited sensitivity to rate changes, resulting in a longer duration relative to our loan portfolio. As a result, our balance sheet has typically been “asset-sensitive,” meaning that assets are expected to reprice more quickly or more significantly than our liabilities. Measures of asset sensitivity are particularly influenced by changes in deposit modeling assumptions.
To manage interest rate risk, we regularly employ a combination of interest rate derivatives, investments in fixed-rate securities, and funding strategies. Collectively, these tools help moderate the expected sensitivity of net interest income and EVE to changes in interest rates.
The following schedule presents deposit duration assumptions discussed previously:
DEPOSIT ASSUMPTIONS

December 31, 2025 December 31, 2024

Product Effective duration
(-200 bps) Effective duration (unchanged) Effective duration
(+200 bps) Effective duration
(-200 bps) Effective duration (unchanged) Effective duration
(+200 bps)

Demand deposits 4.9% 4.2% 3.7% 4.2% 3.5% 2.9%
Money market 1.9% 1.5% 1.3% 1.9% 1.6% 1.4%
Savings and interest-bearing checking 2.2% 1.8% 1.6% 2.1% 1.8% 1.6%

As previously discussed, we utilize derivative instruments to manage interest rate risk. The following schedule presents derivatives designated in qualifying hedging relationships, as well as certain derivatives used as economic hedges that are not designated as accounting hedges, at December 31, 2025. It includes the average outstanding derivative notional amounts for each reporting period presented and the weighted-average fixed rates paid or received across cash flow and fair value hedge categories. For more information regarding our hedge accounting strategies and the impact of these hedging relationships on interest income and expense, see Note 7 of the Notes to Consolidated Financial Statements.
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DERIVATIVES DESIGNATED IN QUALIFYING HEDGING RELATIONSHIPS AND CERTAIN ECONOMIC HEDGES

2026 2027 2028 2029
(Dollar amounts in millions) First Quarter Second Quarter Third Quarter Fourth Quarter First Quarter Second Quarter Third Quarter Fourth Quarter
Cash flow hedges
Cash flow hedges of assets 1

Average outstanding notional 2
$ 5,712 $ 2,437 $ 2,650 $ 2,607 $ 1,584 $ 1,428 $ 1,248 $ 724 $ 292 $ 95
Weighted-average fixed-rate received 3.59  % 3.44  % 3.37  % 3.37  % 3.40  % 3.43  % 3.41  % 3.57  % 3.82  % 3.79  %

2026 2027 2028 2029 2030 2031 2032 2033 2034 2035
Fair value hedges
Fair value hedges of debt 3

Average outstanding notional 2
$ 1,000  $ 814  $ 500  $ 500  $ 500  $ 500  $ 500  $ 500  $ 441  $ — 
Weighted-average fixed-rate received 4.32  % 4.23  % 3.93  % 3.93  % 3.93  % 3.93  % 3.93  % 3.93  % 3.93  % —  %
Fair value hedges of assets 4

Average outstanding notional 2
$ 5,546 $ 5,533 $ 4,787 $ 3,550 $ 2,375 $ 1,943 $ 1,777 $ 1,554 $ 1,371 $ 890
Weighted-average fixed-rate paid 3.34  % 3.34  % 3.27  % 3.12  % 2.94  % 2.82  % 2.77  % 2.67  % 2.77  % 2.32  %

1 Cash flow hedges of assets consist of receive-fixed interest rate swaps used to hedge pools of floating-rate loans. This category also includes certain short-dated interest rate futures executed as economic hedges of floating-rate loans but not designated as accounting hedges. Gains and losses from these economic hedges are recorded in interest income.
2 Notional amounts for forward-starting derivatives are excluded until the trades become effective.
3 Fair value hedges of debt consist of receive-fixed swaps that hedge fixed-rate subordinated notes and senior notes.
4 Fair value hedges of assets consist of pay-fixed swaps that hedge fixed-rate AFS securities and fixed-rate commercial loans.
At December 31, 2025, we had $37 million of net losses deferred in accumulated other comprehensive income (“AOCI”) related to terminated cash flow hedges. These deferred amounts are amortized into interest income on a straight-line basis over the original maturity periods of the respective hedges, provided the forecasted transactions are expected to occur.
The following schedule presents the amounts deferred in AOCI from terminated cash flow hedges, which are expected to be fully reclassified into interest income by the fourth quarter of 2027:
SCHEDULED OCI AMORTIZATION FOR TERMINATED CASH FLOW HEDGES

2026 2027
(In millions) First Quarter Second Quarter Third Quarter Fourth Quarter First Quarter Second Quarter Third Quarter Fourth Quarter
Cash flow hedges
Cash flow hedges of assets
Periodic amortization of deferred losses $ (10) $ (8) $ (6) $ (5) $ (4) $ (3) $ (1) $ —

Earnings at Risk (EaR) and Economic Value of Equity (EVE)
Incorporating our deposit assumptions, the effects of derivatives designated in qualifying hedging relationships, and certain short-dated economic hedges, the following schedule presents our earnings at risk (“EaR”), which we define as the percentage change in projected 12-month net interest income and the estimated percentage change in EVE. Both EaR and EVE are based on a static balance sheet and reflect instantaneous, parallel shifts in interest rates ranging from -200 to +200 bps. These metrics are intended to illustrate the sensitivity of net interest income and equity value to changes in interest rates across a range of scenarios and should not be interpreted as forecasts of expected net interest income.
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INCOME SIMULATION – CHANGE IN NET INTEREST INCOME AND CHANGE IN ECONOMIC VALUE OF EQUITY

December 31, 2025 December 31, 2024
Parallel shift in rates (in bps) 1
Parallel shift in rates (in bps) 1

Repricing scenario -200 -100 0 +100 +200 -200 -100 0 +100 +200

Earnings at Risk
(EaR)
(7.8) % (4.0) % —  % 4.0  % 7.9  % (8.9) % (4.5) % —  % 4.4  % 8.7  %
Economic Value of Equity
(EVE)
(1.5) % (0.3) % —  % (0.5) % (1.4) % 0.1  % 0.6  % —  % (1.7) % (3.6) %

1 Assumes rates do not decline below zero in the negative rate shifts.
Asset sensitivity, as measured by EaR, declined during 2025, primarily due to shifts in the composition of funding balances. Under current deposit assumptions, interest rate risk remains within established policy limits. For interest-bearing deposits with indeterminable maturities, the weighted average modeled beta was 52%.
Prepayment assumptions are a key factor in the management of interest rate risk. Certain assets within our portfolio, such as 1-4 family residential mortgages and mortgage-backed securities, are subject to borrower-driven prepayments, which can significantly affect projected cash flows. At December 31, 2025 and 2024, estimated lifetime prepayment speeds for loans were 14.8% and 13.7%, respectively, reflecting the impact of declining mortgage rates. For mortgage-backed securities, estimated prepayment speeds were 7.0% for both periods.
Our EaR analysis primarily evaluates the impact of parallel rate shocks across the term structure of benchmark interest rates. Additionally, we perform non-parallel rate shock scenarios to identify potential risks that may not be captured under parallel rate assumptions. In these non-parallel rate scenarios, the most significant effects on EaR typically stem from movements in short-term interest rates.
EaR has inherent limitations in capturing anticipated changes in net interest income in changing interest rate environments, primarily due to timing mismatches in the repricing behavior of assets and liabilities. To address this, we provide measures of “latent” and “emergent” interest rate sensitivity, which compare current-quarter net interest income with projected net interest income for the same quarter one year forward. Unlike EaR, which assesses net interest income variability over a 12-month horizon, latent and emergent sensitivity metrics provide additional insight into near-term earnings dynamics amid changing rate conditions. As previously noted, these measures are intended to illustrate the sensitivity of net interest income and equity value to changes in interest rates across a range of scenarios and should not be interpreted as forecasts of expected net interest income.
Latent interest rate sensitivity captures anticipated changes in net interest income driven by prior interest rate movements that have not yet been fully reflected in current revenue but are expected to materialize in the near term, assuming no changes in interest rates and a static balance sheet. Latent sensitivity is projected to increase net interest income by approximately 7.0% for 2026, compared with 2025.
Emergent interest rate sensitivity reflects the projected incremental changes in net interest income resulting from future interest rate movements, measured relative to the latent level of net interest income. Assuming interest rates follow the forward curve at December 31, 2025, emergent sensitivity is modeled to reduce net interest income by approximately 2.8% from the latent level, yielding a cumulative increase of 4.2% in net interest income for 2026, compared with 2025. Under a parallel interest rate shock of +/- 100 bps to the implied forward rate path, cumulative net interest income sensitivity is projected to range between 0.5% and 9.8%.
Our strategic focus on business banking plays a significant role in our asset-liability management approach. At December 31, 2025, $30.5 billion of commercial and CRE loans were scheduled to reprice within the next six months. To manage the interest rate exposure associated with these variable-rate loans, we had $2.8 billion in notional of receive-fixed swaps designated as cash flow hedges, as well as $4.0 billion in notional of short-dated Secured Overnight Financing Rate (“SOFR”) futures. Additionally, at December 31, 2025, $4.7 billion in variable-rate consumer loans were also scheduled to reprice within the same period. For additional information regarding derivative instruments, see Notes 3 and 7 of the Notes to Consolidated Financial Statements.
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Fixed Income
We are subject to market risk arising from fluctuations in the fair value of financial instruments, including trading securities and interest rate swaps used to hedge interest rate exposure. Our underwriting activities include municipal and corporate securities, and we actively trade in municipal, agency, and U.S. Treasury securities. These activities expose us to potential losses resulting from adverse price movements in fixed-income markets.
Changes in the fair value of AFS securities and interest rate swaps that qualify as cash flow hedges are recognized in AOCI each reporting period. For additional information on investment securities and AOCI, refer to the “Capital Management” section on page 80. For more information on the accounting treatment of investment securities, see Note 5 of the Notes to Consolidated Financial Statements.
Equity Investments
Through our equity investment activities, we hold both publicly traded equity securities and non-marketable equity securities in governmental entities and institutions, such as the FRB and the FHLB. Depending on our ownership interest and level of influence over an investee’s operations, equity investments may be accounted for using various methods, including cost less impairment (adjusted for observable price changes), fair value, the equity method, or proportional or full consolidation. Regardless of the accounting method, the value of these investments is subject to fluctuations, and we may incur losses if the fair value declines below the acquisition cost. The Equity Investments Committee and Securities Valuation Committee are responsible for evaluating, monitoring, and approving equity investments in both private and public companies.
We hold investments primarily in pre-public companies, largely through a variety of SBIC funds. This investment strategy is intended to support the financing, growth, and expansion of diverse businesses, generally within our geographic footprint. At December 31, 2025 and 2024, our equity exposure to these investments totaled approximately $271 million and $204 million, respectively.
Occasionally, companies within our SBIC portfolio may complete an initial public offering (“IPO”), which introduces additional market risk due to post-IPO lock-up restrictions. In the second quarter of 2025, one of our SBIC investments successfully completed an IPO. This investment is marked-to-market until our shares have been fully divested. For additional information regarding the valuation of SBIC investments, see Note 3 of the Notes to Consolidated Financial Statements.

Liquidity Risk Management
Liquidity refers to our ability to meet cash, contractual, and collateral obligations while effectively managing both anticipated and unanticipated cash flow requirements without negatively impacting our operations or financial strength. We manage liquidity to provide funding for customer credit needs, financial and contractual commitments, and other corporate activities. Our primary sources of liquidity include deposits, borrowings, equity, and the repayment or sale of assets such as loans and investment securities. Investment securities are primarily held as a source of contingent liquidity and are generally comprised of instruments that can be readily converted to cash through secured borrowing arrangements, with the securities pledged as collateral.
Our Treasury group is responsible for managing liquidity and funding under the oversight of ALCO. The Treasurer recommends changes to existing funding plans and liquidity and funding policies, which are submitted to ALCO for approval. Policy changes also require approval from the ERMC and the Board. In addition, we maintain and regularly test a contingency funding plan designed to identify potential sources and uses of liquidity.
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