PNC FINANCIAL SERVICES GROUP, INC.

To support more tailored performance evaluation and compensation benchmarking, the HR Committee uses two distinct peer groups.

Rationale for use of separate performance and compensation peer groups. Historically, the HR Committee has selected a single peer group each year that was used to help measure relative performance, as well as to determine payouts under our long-term incentive awards and for general compensation comparisons. In prior years, given the limited number of banks comparable to PNC’s size, the HR Committee considered broader market data to better understand compensation practices in the financial services industry. Across multiple meetings in 2025, the HR Committee, in coordination with its independent compensation consultant, determined that there should be two peer groups:

The HR Committee concluded that establishing separate performance and compensation peer groups provides a clearer and more purpose-built framework for assessing PNC’s performance and executive compensation. A dedicated performance peer group allows benchmarking our results against companies most comparable to PNC’s business model and operating profile, while a broader compensation peer group better reflects the competitive market for senior executive talent. This structure improves transparency, expands the sample size used for compensation benchmarking to reduce volatility, and incorporates select financial services peers that more accurately reflect PNC’s experience in recruiting and retaining senior leaders.

Performance Peer Group

Consistent with prior years, the HR Committee reviewed the composition of the 2025 peer group with management and its independent compensation consultant and determined that the existing peer group provided an appropriate mix of institutions for measuring relative performance, taking into consideration PNC’s size and mix and scope of businesses, products, and services. Accordingly, the Performance Peer Group consists of the same companies that composed our 2024 peer group and includes the following 11 companies (with assets and market capitalization measured as of December 31, 2025 and revenue measured for the full year):

2026 Performance Peer Group. Following its annual review, the HR Committee approved two changes to the 2026 Performance Peer Group. Capital One Financial (“Capital One”) was removed due to its acquisition of Discover Financial Services, which further shifts its business mix toward credit card lending and away from PNC’s strategic and operating profile. As a result, the HR Committee determined that Capital One no longer represents an appropriate comparator for evaluating PNC’s performance. The HR Committee also approved the addition of Huntington Bancshares (“Huntington”), reflecting Huntington’s continued growth and expanding retail presence in markets where PNC competes. Huntington is a meaningful competitor for middle-market and commercial clients and is also included among the peers of several existing Performance Peer Group members, such that the HR Committee considered it an appropriate addition for 2026.

Compensation Peer Group

The Compensation Peer Group includes the companies that comprise the Performance Peer Group, as well as 10 additional companies. In determining the Compensation Peer Group, the HR Committee reviewed factors such as asset size, revenue, market capitalization, regulatory categories, ownership structure, geographic scope andsub-industry (e.g., diversified banks, regional banks, consumer finance) of various financial institutions, excluding insurers, and considered the executive talent market in which PNC competes. After reviewing and discussing the proposed Compensation Peer Group with management and its independent compensation consultant, the HR Committee approved the Compensation Peer Group, as it believes that the companies included are generally most relevant as compensation benchmarking peers.

Within the Compensation Peer Group, PNC falls slightly above the median for asset size and at the median for revenue and market capitalization, as reflected in the table below (with assets and market capitalization measured as of December 31, 2025 and revenue measured for the full year):

During the HR Committee’s transition to the use of two distinct peer groups in 2025, it relied on Aon’s Radford McLagan Compensation Database (“McLagan”) only as supplemental market context for certain executive roles. The McLagan data—which included 2024 actual total compensation—contains only one company not represented in either the Performance Peer Group or the Compensation Peer Group, which is Ally Financial.