Ally Financial Inc.

(a) None.

(b) The following provides a description of Rule 10b5-1 trading arrangements (as defined in Item 408 of Regulation S-K under the Exchange Act)adopted during the three months ended December 31, 2025, by any director or executive officer who is subject to the filing requirements of Section 16 of the Exchange Act:

During the three months ended December 31, 2025, Douglas R. Timmerman, President of Dealer Financial Services, adopted two trading arrangements intended to satisfy the affirmative defense conditions of Rule 10b5-1(c) of the Exchange Act. On November 12, 2025, Mr. Timmerman adopted an arrangement for the sale of up to 162,959 shares of common stock in the amounts and at prices determined in accordance with the formulae set forth in the arrangement. The arrangement terminates on the earlier of the date that all shares under the plan are sold and December 31, 2026. In addition, on December 3, 2025, Mr. Timmerman adopted an arrangement for the sale of up to 39,675 shares of common stock in the amounts and at prices determined in accordance with the formulae set forth in the arrangement. The arrangement terminates on the earlier of the date that all shares under the plan are sold and April 30, 2026.

Further, on November 17, 2025, William C. Hall Jr., President of Corporate Finance, adopted an arrangement intended to satisfy the affirmative defense conditions of Rule 10b5-1(c) of the Exchange Act for the sale of up to 42,108 shares of common stock in the amounts and at prices determined in accordance with the formulae set forth in the arrangement. The arrangement terminates on the earlier of the date that all shares under the plan are sold and February 5, 2027.

No directors or executive officers modified orterminated a “Rule 10b5-1 trading arrangement” or “non-Rule 10b5-1 trading arrangement” during the three months ended December 31, 2025.

Certain of our executive officers have made elections to participate in, and are participating in, our Employee Stock Purchase Program. By participating in this program, executive officers have made, and may from time to time make, contributory elections or other elections to have shares withheld to cover withholding taxes or pay the exercise price of stock awards, which may be designed to satisfy the affirmative defense conditions of Rule 10b5-1 under the Exchange Act or may constitute non-Rule 10b5-1 trading arrangements as such terms are defined under Item 408 of Regulation S-K.