Upstart Holdings Inc

(c) Securities Trading Plans of Executive Officers and Directors

From time to time, some of the Company’s executive officers or directors may determine that it is advisable to diversify their investments for personal financial planning reasons or may seek liquidity for other reasons and may sell shares of common stock of the Company. To effect such sales, from time to time, some of the Company’s executive officers or directors may enter into trading plans that are designed to comply with the Company’s Insider Trading Policy and intended to satisfy the affirmative defense conditions of Rule 10b5-1(c) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”).

During the quarter ended March 31, 2025, the following directors and officers (as defined in Rule 16a-1(f) of the Exchange Act) of the Company each adopted a “Rule 10b5-1 trading arrangement” (as defined in Item 408(a) of Regulation S-K):

Name and title of director and officer: Paul Gu, Chief Technology Officer

Date ofadoption: February 26, 2025

Duration of the trading arrangement: Through May 31, 2026 or earlier if all transactions under the trading arrangement are completed

Aggregate number of securities to be sold from time to time: up to 656,500 shares, including shares issuable upon the exercise of outstanding options upon reaching the pricing targets defined in the trading arrangement.

None of the Company’s officers or directors modified orterminated a “Rule 10b5-1 trading arrangement”oradopted, modified orterminated a “non-Rule 10b5-1 trading arrangement” (as defined under Item 408(a) of Regulation S-K) during the quarter ended March 31, 2025.