MORGAN STANLEY

The Financial Accounting Standards Board has issued certain accounting updates that apply to us. Accounting updates not referenced below were assessed and determined to be either not applicable or to not have a material impact on our financial condition or results of operations upon adoption.

We are currently evaluating the following accounting updates:

•Derivatives Scope Refinements and Share-Based Consideration from a Customer. This update introduces targeted refinements to the derivatives and revenue recognition accounting guidance. It expands an existing scope exception for derivative accounting to exclude certain non-exchange-traded contracts. The update also clarifies that share-based payments from a customer are treated as noncash consideration under the revenue recognition standard until the related performance obligations are fulfilled and the right to the consideration is unconditional. The update is effective beginning January 1, 2027, with early adoption permitted. Transition may be applied prospectively, or under a modified retrospective approach.

•Intangibles—Goodwill and Other—Internal - Use Software. This update introduces targeted improvements to the recognition and capitalization guidance for internal-use software costs. The update eliminates the prior “project stage” framework and instead requires capitalization of software development costs when (i) management has authorized and committed to funding the software project, and (ii) it is probable that the project will be completed and the software will be used to perform its intended function. In assessing the probability threshold, entities are required to evaluate whether significant development uncertainty exists, including whether the software contains novel or unproven functionality or whether significant performance requirements have not been identified or continue to be substantially revised. The update is effective beginning January 1, 2028, with early adoption permitted. Transition may be applied prospectively, retrospectively, or under a modified approach.

We continue to evaluate accounting updates disclosed in the “Accounting Development Updates” section of the 2024 Form 10-K, including the implementation of the Income Tax Disclosures accounting update effective for the annual reporting period beginning January 1, 2025. We do not expect a material impact on our financial condition or results of operations upon adoption.