ASSOCIATED BANC-CORP

The Corporation maintains disclosure controls and procedures as required under Rule 13a-15 promulgated under the Securities Exchange Act that are designed to ensure that information required to be disclosed in the Corporation's Exchange Act reports is recorded, processed, summarized and reported within the time periods specified in the SEC’s rules and forms, and that such information is accumulated and communicated to the Corporation’s management, including its Chief Executive Officer and Chief Financial Officer, as appropriate, to allow timely decisions regarding required disclosure.

As of September 30, 2026, the Corporation’s management carried out an evaluation, under the supervision and with the participation of the Corporation’s Chief Executive Officer and Chief Financial Officer, of the effectiveness of its disclosure controls and procedures. Based on the foregoing, its Chief Executive Officer and Chief Financial Officer concluded that the Corporation’s disclosure controls and procedures were effective as of September 30, 2026.

On April 1, 2026, the Corporation completed its acquisition of American National. The Corporation is in the process of integrating the acquired operations, business processes and systems into its overall internal control environment and has begun to extend its oversight and monitoring activities to include the acquired operations. Management's evaluation of internal control over financial reporting as of September 30, 2026 did not include an assessment of the internal control over financial reporting of American National. The Corporation continues evaluating and integrating American National into the Corporation's control environment in connection with the conversion of systems and operations in the fourth quarter of 2026.

Other than the integration activities associated with the American National acquisition, no changes were made to the Corporation’s internal control over financial reporting (as defined in Rule 13a-15(f) of the Exchange Act) during the last fiscal quarter that have materially affected, or are reasonably likely to materially affect, the Corporation’s internal control over financial reporting.