Bank of New York Mellon Corp (BNY) Risk Factors

Recent key developments

Concrete developments — dated events, named agreements and instruments, legal proceedings — that Bank of New York Mellon Corp surfaced in its latest filing.

• Outcome of the 2024 U.S. elections has resulted in significant changes to operations, policies, and priorities of U.S. governmental agencies, creating uncertainty and regulatory divergence.2024
• For the year ended December 31, 2025, 72% of total revenue was fee-based.December 31, 2025
• At December 31, 2025, approximately 68% of securities were classified as available-for-sale and approximately 32% as held-to-maturity.December 31, 2025
• Investment securities portfolio represented approximately 32% of consolidated total assets at December 31, 2025.December 31, 2025
• Litigation in Russia regarding payments excused under international sanctions laws.
• Subject to U.S. Foreign Corrupt Practices Act, Bank Secrecy Act as amended by USA PATRIOT Act, Iran Threat Reduction and Syria Human Rights Act of 2012, UK Bribery Act, and economic sanctions administered by OFAC.2012
• BNY is registered with the Federal Reserve as a Bank Holding Company (BHC) and Financial Holding Company (FHC).
• Parent entered into a binding support agreement with key subsidiaries to transfer cash and assets to the IHC in exchange for unsecured subordinated funding notes and a committed line of credit.
• Parent is subject to Title I preferred resolution strategy or Title II orderly liquidation authority under the Dodd-Frank Act.
• Committed lines of credit from IHC to Parent automatically terminate if resolution is imminent.
• LCR and NSFR requirements mandate significant holdings of high-quality liquid assets and stable deposit analysis.
• U.S. capital rules subject BNY and its U.S. banking subsidiaries to stringent capital requirements, including GSIB surcharge based on short-term wholesale funding.
• Develop and submit resolution plans to Federal Reserve and FDIC; if deemed not credible, may face restrictions or required divestitures.
• Subject to special assessment under the FDI Act in the event of failure of a bank or non-bank financial institution.
• Investments in digital asset services and related products introduce incremental cybersecurity, third-party, and regulatory risks.
• Wove integrative wealth management advisory platform being developed.
• Execution of a plan to transition to a platforms operating model.
• Headquarters located near the Hudson River waterfront in New York, subject to more frequent or severe weather events.
• Subject to enforcement actions and investigations regarding sustainability-related investing practices, with potential civil litigation claims.
• Compliance risks from regulations addressing 'greenwashing', including the EU's SFDR.