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 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 September 30, 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: Dave Girouard, Chief Executive Officer

Date ofadoption: September 8, 2025

Duration of the trading arrangement: Through December 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 1,576,000 shares, including shares issuable upon the exercise of outstanding options upon reaching the pricing targets defined in the trading arrangement.

Name ofdirector: Kerry Whorton Cooper

Date ofadoption: September 4, 2025

Duration of the trading arrangement: Through December 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 9,000 shares.

Name ofdirector: Hilliard C. Terry III

Date ofadoption: September 3, 2025

Duration of the trading arrangement: Through December 3, 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 60,000 shares, including shares issuable upon the exercise of outstanding options upon reaching the pricing targets defined in the trading arrangement.