We are subject to various regulatory capital requirements administered by federal banking agencies. Failure to meet these requirements can initiate certain mandatory, and possibly additional discretionary, regulatory actions that could materially impact our financial statements. Under capital adequacy guidelines and the regulatory framework for prompt corrective action, we must maintain specific quantitative measures of capital relative to our assets, liabilities, and certain off-balance sheet exposures, as calculated under regulatory accounting standards. These measures include minimum amounts and ratios for common equity Tier 1 (“CET1”) to risk-weighted assets, Tier 1 capital, total capital, and Tier 1 capital to average assets (Tier 1 leverage ratio). At December 31, 2025 and 2024, we met all capital requirements under the Basel III capital rules.

Regulatory capital guidelines also establish “well-capitalized” thresholds as benchmarks for evaluating capital strength. At December 31, 2025 and 2024, all of our capital amounts and ratios exceeded the well-capitalized levels under the prompt corrective action framework.

Dividends declared by us may not exceed specified regulatory criteria unless otherwise approved by our regulators. In determining dividend levels, we consider current and historical earnings, retained earnings, and applicable risk-based and other regulatory capital requirements and limitations.

Our internal stress tests are designed to comprehensively evaluate the risks to which we are exposed, the potential losses under adverse scenarios, and the resulting impact on our capital levels. These stress tests subject our balance sheet and other risk characteristics to rigorous analysis using internal models.


	December 31, 2025				Minimum requirement to be “well capitalized”
(Dollar amounts in millions)	Amount		Ratio		Amount		Ratio
Basel III regulatory capital amounts and ratios
Common equity tier 1 capital (to risk-weighted assets)	$	7,936	11.5	%	$	4,494	6.5	%
Tier 1 risk-based capital (to risk-weighted assets)	8,003		11.6		5,531		8.0
Total risk-based capital (to risk-weighted assets)	9,510		13.8		6,914		10.0
Tier 1 leverage ratio	8,003		9.0		4,451		5.0


	December 31, 2024				Minimum requirement to be “well capitalized”
(Dollar amounts in millions)	Amount		Ratio		Amount		Ratio
Basel III regulatory capital amounts and ratios
Common equity tier 1 capital (to risk-weighted assets)	$	7,363	10.9	%	$	4,400	6.5	%
Tier 1 risk-based capital (to risk-weighted assets)	7,430		11.0		5,415		8.0
Total risk-based capital (to risk-weighted assets)	9,026		13.3		6,769		10.0
Tier 1 leverage ratio	7,430		8.3		4,454		5.0

The Basel III capital rules require us to maintain certain minimum capital ratios, as well as a 2.5% “capital conservation buffer,” designed to absorb losses during periods of economic stress. This buffer is composed entirely of CET1. The following schedule presents the minimum capital ratios and capital conservation buffer requirements, compared with our capital ratios at December 31, 2025:


	December 31, 2025
	Minimum capital requirement	Capital conservation buffer	Minimum capital ratio requirement with capital conservation buffer	Current capital ratio

CET1 to risk-weighted assets	4.5%	2.5%	7.0%	11.5%
Tier 1 risk-based capital (i.e., CET1 plus additional Tier 1 capital) to risk-weighted assets	6.0%	2.5%	8.5%	11.6%
Total risk-based capital (i.e., Tier 1 capital plus Tier 2 capital) to risk-weighted assets	8.0%	2.5%	10.5%	13.8%
Tier 1 leverage ratio (i.e., Tier 1 risk-based capital) to average consolidated assets	4.0%	N/A	4.0%	9.0%

Financial institutions with a CET1 to risk-weighted assets ratio above the minimum, but below the capital conservation buffer, face constraints on dividends, equity repurchases, and compensation based on the amount of the shortfall. Our internal triggers and limits, both under actual conditions and baseline projections, are more stringent than the capital conservation buffer requirements.