Bank of New York Mellon Corp

Recent accounting developments

The following accounting guidance issued by the Financial Accounting Standards Board (“FASB”) has not yet been adopted as of March 31, 2025.

ASU 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures

In December 2023, the FASB issued ASU 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures, which requires a company to disclose, on an annual basis, additional disaggregated information related to the existing disclosures for the effective income tax rate reconciliation and income taxes paid.

This ASU is effective on a prospective basis, with a retrospective option, for annual periods beginning after Dec. 15, 2024, and interim periods within fiscal years beginning after Dec. 15, 2025. BNY is currently evaluating this guidance and the impact on the income tax disclosures.

Recent regulatory and other developments

For a summary of additional regulatory matters relevant to our operations, see “Supervision and Regulation” in our 2024 Annual Report. The following discussion summarizes certain regulatory, legislative and other developments that may affect BNY.

Recent Executive Orders

In the United States, recent political developments have signaled a modification in the federal government’s approach to a wide number of matters. The new U.S. presidential administration has issued Executive Orders associated with, among other things, federal policy concerning tariffs and digital assets. As the federal government’s posture on these and other matters continues to evolve, BNY is reviewing the impacts of these orders on its business and operations.

Evolving Regulatory Environment - Digital Asset Matters

The regulatory framework for digital assets continues to evolve. In the United States, recent political developments support the responsible use of digital assets, including the OCC’s issuance of Interpretative Letter 1183 and the FDIC’s issuance of FIL-7-2025. These letters reaffirm that a range of crypto-related activities are permissible in the federal banking system. In addition, the Federal Reserve and the FDIC took steps to withdraw previous digital-asset related guidance, including withdrawing support from prior joint agency statements on digital asset related risks. The Federal Reserve has also withdrawn its prior guidance requiring (i) advance notification of or non-objection for certain digital asset activities and (ii) non-objection to engage in certain digital asset-related activities, including issuing, holding, or transacting in dollar tokens to facilitate payments. BNY continues to evaluate the impacts of these directives on its digital asset capabilities, in light of the requirements of all relevant regulators for its subsidiaries and operations, including the Federal Reserve Board and the New York Department of Financial Services.

Transition to T+1 Settlement in Europe

On Feb. 12, 2025, the European Commission proposed a framework to facilitate a coordinated EU/EEA transition to a T+1 settlement cycle on Oct. 11, 2027. On Feb. 19, 2025, the UK government confirmed that the UK will transition to a T+1 standard for settling securities on Oct. 11, 2027. The proposals in the UK, EU, and EEA remain subject to final legislation and regulation. As a result of the transition to T+1 settlement across European jurisdictions, BNY will be required to implement a range of technical and operational updates. BNY continues to assess the impact of these transitions on its business and operations.

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