PNC FINANCIAL SERVICES GROUP INC

Resolution and Recovery Planning

In June 2024, the FDIC revised its rule requiring certain insured depository institutions, including PNC Bank, to periodically submit a resolution plan that, in the event of a hypothetical failure, should enable the FDIC to resolve the bank under the Federal Deposit Insurance Act. Under the final rule, most banks with $100 billion or more in assets, including PNC Bank, are required to submit full resolution plans on a three-year cycle, with interim informational supplements due in off-years. The FDIC may also engage in capabilities testing between full resolution plan submissions. The final rule significantly expands the required content elements and adds virtual data room and valuation capabilities as significant components of the resolution planning process. The final rule indicates that covered institutions will not be required to submit a resolution submission or interim informational supplement until at least 270 days from the effective date of October 1, 2024.

The OCC has proposed revisions to its recovery planning guidelines that apply to certain large insured national banks, including PNC Bank. The proposal would incorporate an annual testing requirement into recovery plans, and would require covered banks to consider both financial risks and non-financial risks – including operational and strategic risks – in their recovery plans. The proposal contemplates that PNC Bank would have 12 months from the effective date of the amendments to comply with the changes.

Capital, Capital Planning and Liquidity

In June 2024, the Federal Reserve announced the results of its supervisory stress tests conducted as part of the 2024 CCAR process. PNC remained well above its risk-based minimum capital requirements in the supervisory stress tests, and PNC’s SCB for the four-quarter period beginning October 1, 2024, will remain the regulatory minimum of 2.5%. See the Liquidity and Capital Management portion of the Risk Management section in this Financial Review for a discussion of PNC’s capital actions.