PNC FINANCIAL SERVICES GROUP INC

Federal agencies and states, including the federal agencies responsible for the Federal Acquisition Regulations, California, and most recently in March 2024, the SEC, have separately proposed or finalized rules that would require certain companies or government contractors, such as PNC or PNC Bank, to disclose significant amounts of climate-related information. This information includes qualitative and quantitative disclosures of material climate-related risks and their impact, governance and management, targets and goals, and greenhouse gas emissions. The greenhouse gas emissions disclosures include the company’s direct emissions from owned or controlled sources (Scope 1) and indirect emissions from the company’s consumption of energy purchased from third parties (Scope 2), and in the case of the Federal Acquisition Regulations proposal for a “major contractor” and California laws, disclosures related to indirect emissions from upstream and downstream activities in the company’s value chain (Scope 3). If and when all the rules are finalized, PNC and PNC Bank may face potentially differing standards from the agencies or California. Numerous lawsuits have challenged the SEC and California rules, and on April 4, 2024, the SEC voluntarily stayed implementation of its final rules pending resolution of the lawsuits challenging the SEC rules.

34 The PNC Financial Services Group, Inc. –Form 10-Q