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, 2026.

Accounting Standards Update (“ASU”) 2024-03, Income Statement - Reporting Comprehensive Income - Expense Disaggregation Disclosures (Subtopic 220-40): Disaggregation of Income Statement Expenses

In November 2024, the FASB issued ASU 2024-03, Income Statement - Reporting Comprehensive Income - Expense Disaggregation Disclosures (Subtopic 220-40): Disaggregation of Income Statement Expenses, which requires the disaggregation of specific types of expenses, including, but not limited to, employee compensation, depreciation and intangible asset amortization, to be presented in the Notes to the Consolidated Financial Statements. This ASU also requires the disclosure of the total amount of selling expenses, and on an annual basis, the definition of selling expenses.

This ASU is effective for annual reporting periods beginning after Dec. 15, 2026 and interim reporting periods beginning after Dec. 15, 2027 with early adoption permitted. BNY is currently evaluating this guidance and the impact on the expense disclosures.

ASU 2025-06, Intangibles—Goodwill and Other—Internal-Use Software (Subtopic 350-40): Targeted Improvements to the Accounting for Internal-Use Software

In September 2025, the FASB issued ASU 2025-06, Intangibles—Goodwill and Other—Internal-Use Software (Subtopic 350-40): Targeted Improvements to the Accounting for Internal-Use Software, which amends certain aspects of the accounting for, and disclosure of, software costs. This ASU provides guidance on how to evaluate whether it is probable that a project will be completed and the software will be used to perform the function intended (referred to as the ‘probable-to-complete recognition threshold’).

This ASU is effective for annual reporting periods beginning after Dec. 15, 2027, and interim reporting periods within those annual reporting periods, with

early adoption permitted. The guidance allows for either prospective, retrospective or a modified prospective application. BNY is currently evaluating this guidance.

Recent regulatory developments

For a summary of additional regulatory matters relevant to our operations, see “Supervision and Regulation” in our 2025 Annual Report. The following discussion summarizes certain regulatory and other developments that may affect BNY.

Changes to the Capital Rule

On March 19, 2026, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the FDIC, and the Office of the Comptroller of the Currency (the “OCC”) (collectively, the “Agencies”) issued proposed rules that would substantially revise the capital requirements applicable to large banking organizations and to banking organizations with significant trading activity, including BNY. The proposed rules would implement international capital standards most recently issued by the BCBS and would replace the Agencies’ July 2023 proposals. Separately, on March 19, 2026, the Federal Reserve proposed revisions to the capital surcharge calculation methodology applicable to G-SIBs, including BNY.

The primary structural change the proposed rules would implement is to streamline the risk-based capital requirements applicable to G-SIBs like BNY. Currently, these organizations are subject to two sets of risk-based capital ratio requirements, one based on the standardized approach, and one based on the advanced approaches, and are required to abide by the more restrictive requirements. Under the proposed rules, Category I and II banking organizations, including BNY, would instead be subject to a single set of risk-based capital requirements based on the Expanded Risk-Based Approach (“ERBA”). The Agencies stated ERBA would improve risk sensitivity relative to the current U.S. capital rules. The proposals would also apply operational risk-based capital requirements for banking organizations subject to ERBA. The proposed revisions to the G-SIB surcharge framework would, among other changes, increase its risk sensitivity and index certain inputs to nominal GDP growth. The proposals would also result in several other changes including more standardized operational-risk formula and revisions to

42 BNY the treatment of securities finance transactions. BNY is evaluating the impact of these proposals.

Developments in Anti-Money Laundering and Countering The Financing of Terrorism Regulation

On April 7, 2026, the FDIC, National Credit Union Administration, and OCC issued a notice of proposed rulemaking to revise anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) program requirements. The proposed rule would require institutions to establish and maintain a risk-based set of internal policies, procedures, and controls to address AML and CFT concerns. The proposal also would require institutions to revise their AML and CFT controls as their risk profiles change, and to concentrate on higher-risk activities and deprioritize lower-risk activities. The proposal clarifies that banks may share any information with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) related to AML and CFT supervisory and enforcement actions. FinCEN issued a related rule on April 7, 2026, which also encourages prioritization of higher-risk activities. The proposals would require Federal banking regulators to consult with FinCEN prior to taking certain types of supervisory or enforcement actions related to AML/CFT. BNY is assessing the impact of the proposals.

Digital Asset Regulatory Developments

On Feb. 25, 2026, the OCC issued a notice of proposed rulemaking to implement provisions of the “Guiding and Establishing National Innovation for U.S. Stablecoins Act” or the “GENIUS Act”, which would establish requirements for OCC-licensed payment stablecoin issuers and provides for certain requirements related to, among other things, reserve assets, custody, redemption, capital, and risk management standards. On April 7, 2026, the FDIC issued a notice of proposed rulemaking to implement provisions of the GENIUS Act, which would establish requirements for FDIC-supervised permitted payment stablecoin issuers and insured depository institutions. BNY is assessing the impact of the proposals.