Bank of New York Mellon Corp

Recent accounting developments

The following accounting guidance has been proposed or issued by the Financial Accounting Standards Board (“FASB”) has not yet been adopted as of Sept. 30, 2026.

Accounting Standards Update (“ASU”) 2024-03, Income Statement - Reporting Comprehensive Income - Expense Disaggregation Disclosures (Subtopic 220-40): Disaggregation of Income Statement Expenses

In November 2024, the FASB issued ASU 2024-03, Income Statement - Reporting Comprehensive Income - Expense Disaggregation Disclosures (Subtopic 220-40): Disaggregation of Income Statement Expenses, which requires the disaggregation of specific types of expenses, including, but not limited to, employee compensation, depreciation and intangible asset amortization, to be presented in the Notes to the Consolidated Financial Statements. This ASU also requires the disclosure of the total amount of selling expenses, and on an annual basis, the definition of selling expenses.

This ASU is effective for annual reporting periods beginning after Dec. 15, 2026 and interim reporting periods beginning after Dec. 15, 2027, with early adoption permitted. BNY is currently evaluating this guidance and the impact on the expense disclosures.

ASU 2025-06, Intangibles—Goodwill and Other—Internal-Use Software (Subtopic 350-40): Targeted Improvements to the Accounting for Internal-Use Software

In September 2025, the FASB issued ASU 2025-06, Intangibles—Goodwill and Other—Internal-Use Software (Subtopic 350-40): Targeted Improvements to the Accounting for Internal-Use Software, which amends certain aspects of the accounting for, and disclosure of, software costs. This ASU provides guidance on how to evaluate whether it is probable that a project will be completed and the software will be used to perform the function intended (referred to as the ‘probable-to-complete recognition threshold’).

This ASU is effective for annual reporting periods beginning after Dec. 15, 2027, and interim reporting periods within those annual reporting periods, with

early adoption permitted. The guidance allows for either prospective, retrospective or a modified prospective application. BNY is currently evaluating this guidance.

Proposed ASU, Derivatives and Hedging (Topic 815): Targeted Improvements to Accounting for Interest Rate Risk Hedging and Net Investment Hedging

In June 2026, the FASB issued a proposed ASU, Derivatives and Hedging (Topic 815): Targeted Improvements to Accounting for Interest Rate Risk Hedging and Net Investment Hedging, which is intended to better align hedge accounting with an entity’s risk management activities and enhance the operability of hedge accounting. The proposed ASU would permit interest rate risk to be hedged for held-to-maturity debt securities, expand the SOFR rates eligible for designation as benchmark interest rates and permit certain float-to-float cross-currency swaps to be used as hedging instruments in net investment hedges.

In October 2026, the FASB completed its redeliberation of the proposed ASU and made tentative decisions regarding the guidance. The FASB affirmed the proposed amendments and directed the staff to proceed toward issuance of a final ASU. BNY is currently evaluating the proposed guidance.

Recent regulatory developments

For a summary of additional regulatory matters relevant to our operations, see “Recent regulatory developments” in our Form 10-Q for the quarters ended March 31, 2026 and June 30, 2026 and “Supervision and Regulation” in our 2025 Annual Report. The following discussion summarizes certain regulatory and other developments that may affect BNY.

Stress Testing Revisions

On Sept. 30, 2026, the Board of Governors of the Federal Reserve (“Federal Reserve”) issued two final rules revising its supervisory stress testing framework. One final rule (the “Transparency and Public Accountability Rule”) requires the Federal Reserve to request public comment annually on material model changes and the stress test scenarios. The other final rule (the “Volatility Rule”), among other things, requires the Federal Reserve to average

44 BNY the results from the two most recent stress tests (starting in 2029, and using 2027 and 2028) to set firms’ SCB requirements for firms subject to the stress test in two consecutive years. In addition, the Federal Reserve proposed revisions to the noninterest income model used in the stress test. The Federal Reserve explained this change is intended to capture heterogeneity across firms. BNY is assessing the impact of the proposal.

Revised Statement of Supervisory Operating Principles

On Sept. 24, 2026, the Federal Reserve issued an updated version of its Statement of Supervisory Operating Principles, setting out the policy priorities and expectations for implementation by Federal Reserve supervisory staff. Among the changes is a directive for examiners to prioritize “risks that pose a significant probability of significant harm to the financial condition of the firm, one or more other firms, the Deposit Insurance Fund (“DIF”), the firm’s resolvability, or U.S. financial stability.”

Rule on Unsafe and Unsound Practice

On Aug. 27, 2026, the Office of the Comptroller of the Currency (“OCC”) and FDIC jointly adopted a rule defining “unsafe or unsound practice” for purposes of Section 8 of the Federal Deposit Insurance Act and revised the regulatory framework around issuance of matters requiring attention (“MRAs”). Under the rule, to qualify as an unsafe or unsound practice, it must be contrary to generally accepted standards of prudent operation and meet one of three criteria: a) it is “likely” to cause material harm to the financial condition of the institution; b) material harm has occurred; or c) there is likely a material risk of loss to the DIF. The agencies also stated an MRA may only be issued if there is an actual violation of banking or banking-related law or regulation, or if the conduct is contrary to generally accepted standards of prudent operation and could “reasonably be expected to”, or has, caused: a) material harm to financial condition or b) a material risk of loss to the DIF.

The same day, the OCC proposed clarifying the standard for MRA issuance such that it would only issue an MRA for a “substantive” as opposed to “actual” violation of banking or banking-related law or regulation. The OCC stated this was intended to capture conduct which could meaningfully impact the

institution or its customers. BNY is assessing the impact of the proposal.

Proposed Revisions to Rules on Bank Lending to Insiders

On July 31, 2026, the Federal Reserve released a notice of proposed rulemaking (“Federal Reserve Proposal”) to modernize Regulation O, which governs loans by member banks to their insiders (directors, certain officers and principal shareholders) and insiders of their affiliates. In addition, the FDIC proposed revisions to its rules governing extensions of credit to insiders of FDIC-supervised institutions (“FDIC Proposal”). Among other changes, the Federal Reserve Proposal would index thresholds to nominal GDP. The FDIC Proposal would align certain thresholds under the FDIC’s rules governing extensions of credit to insiders with those included in the Federal Reserve Proposal and would use the same methodology to update the thresholds going forward. The agencies expect the proposal to reduce burdens on banks and their insiders. BNY is assessing the impact of the proposals.

GENIUS Act Federal Reserve Implementation

On Sept. 24, 2026, the Federal Reserve issued two proposals affecting stablecoin issuers under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”). The first proposal, among other things, would require that Federal Reserve-supervised payment stablecoin issuers fully back their stablecoins with permissible reserve assets, establish standardized capital requirements, and establish rules for Federal Reserve-supervised firms that safekeep assets backing payment stablecoins. The second proposal would establish a tailored application process for Board-supervised banks applying to issue payment stablecoins. BNY is assessing the impact of the proposals.

GENIUS Act OCC Implementation

On Oct. 21, 2026, the OCC issued a final rule to implement provisions of the GENIUS Act, which establishes requirements for OCC-supervised payment stablecoin issuers and provides for certain requirements related to, among other things, reserve assets, custody, redemption, capital, and risk management standards. The rule is effective Jan. 18, 2027.

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