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 March 31, 2026, the following director and officer (as defined in Rule 16a-1(f) of the Exchange Act) of the Company terminated a “Rule 10b5-1 trading arrangement” (as defined under Item 408(a) of Regulation S-K).

Name and title of director and officer: Dave Girouard, Former Chief Executive Officer, Executive Chairman

Date oftermination: March 6, 2026

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.

None of the Company’s other officers or directors adopted, modified, or terminated 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, 2026.