PNC FINANCIAL SERVICES GROUP INC

Resolution Planning

In August 2024, the Federal Reserve and FDIC finalized new guidance for holding company resolution plans submitted by triennial full filers, such as PNC, under section 165(d) of the Dodd-Frank Act and the implementing regulations. The guidance generally applies expectations from the 2019 resolution plan guidance applicable to U.S. GSIBs. Firms like PNC with a multiple point of entry resolution strategy will be required to incorporate more severe plan assumptions and include new required plan content, operational capabilities and legal entity rationalization, among other requirements. PNC’s next 165(d) resolution plan is due October 1, 2025, per an extension provided by the Federal Reserve and FDIC in finalizing the new guidance.

Other Regulatory Developments

On October 22, 2024, the CFPB issued a final rule under Section 1033 of the Dodd-Frank Act requiring certain entities, including PNC Bank, to, upon request, make available to a consumer or third party authorized by the consumer certain information the entity has concerning a consumer financial product or service covered by the rule. In issuing the rule, the CFPB said that the rule will move the U.S. closer to an “open banking” system and will let consumers more easily switch banks or other providers. In general, the final rule requires covered data providers, such as PNC Bank, to establish a developer interface satisfying specific security and other standards, accept data sharing requests by third parties authorized by the consumer through that developer interface and, in response to such a request, make that data available in electronic form to consumers and authorized third parties, including data aggregators. PNC Bank will be prohibited from charging fees for maintaining the developer interface or providing access to such data. PNC and PNC Bank may also act as authorized third parties receiving data under the rule from institutions, and the rule places data security, authorization, and other obligations on those third parties, including limitations on secondary uses of the data received. PNC Bank must comply with the rule beginning on April 1, 2026, and we are still assessing the impact of this rule.