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 Exchange Act.

During the quarter ended September 30, 2026, the following officers or directors (as defined in Rule 16a-1(f) of the Exchange Act) of the Company each adopted 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 ofadoption: September 9, 2026

Duration of the trading arrangement: Through November 30, 2027, or earlier if all transactions under the trading arrangement are completed

Aggregate number of securities to be sold from time to time: up to 1,490,596 shares of common stock, including up to 1,356,704 shares issuable upon the exercise of outstanding options and up to 133,892 founder shares held through two trusts.

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 September 30, 2026.