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 June 30, 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 “Recent regulatory developments” in our Form 10-Q for the quarter ended March 31, 2026 and “Supervision and Regulation” in our 2025 Annual Report. The following discussion summarizes certain regulatory and other developments that may affect BNY.

Proposed Regulatory Rating Changes

On May 19, 2026, the Federal Financial Institutions Examination Council issued a notice of proposed rulemaking to revise the Uniform Financial Institutions Rating System, which supervisory agencies use to evaluate the safety and soundness of insured depository institutions. The proposal would place greater emphasis on factors that materially affect an institution’s financial condition and risk profile and less emphasis on concerns relating to policies and procedures. BNY is assessing the potential impact of the proposal.

Proposed Rescission of Climate-Related Disclosure Rules

On May 29, 2026, the Securities and Exchange Commission (the “SEC”) proposed to rescind the entirety of the climate-related disclosure rules it adopted in March 2024. The 2024 rules never went into force. BNY is monitoring the developments and assessing the potential impact of any final SEC action.

Proposed New York GENIUS Act Implementation

On June 9, 2026, the New York State Department of Financial Services proposed a rule to align New York’s framework for stablecoin issuers with the federal Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”). The proposed rule mirrors federal requirements for, among other things, reserve assets, custody, and risk management standards. BNY is assessing the potential impact of the proposal.

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Proposed Changes to Insured Depository Institution Resolution Planning

On June 25, 2026, the FDIC issued a notice of proposed rulemaking that would, among other things, significantly reduce the content required in FDIC resolution planning submissions, with an emphasis on collecting information that most directly supports the FDIC’s readiness to resolve a covered insured depository institution such as The Bank of New York Mellon. BNY is assessing the potential impact of the proposal.

Proposed Changes to Deposit Insurance Assessment Regulations

On June 25, 2026, the FDIC issued a notice of proposed rulemaking that would, among other things: (i) generally decrease the initial base deposit insurance assessment rate schedules for FDIC-insured institutions; and (ii) provide a resolution readiness adjustment for large or highly complex institutions if they successfully demonstrate the ability to populate a virtual data room and/or provide the FDIC temporary access to certain data and system to support the FDIC's readiness for resolution. BNY is assessing the potential impact of the proposal.

Proposed Changes to AML/CFT Program Requirements

On July 7, 2026, the Federal Reserve issued a notice of proposed rulemaking to revise the Anti-Money Laundering and Countering the Financing of Terrorism (“AML/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/CFT concerns. The proposal also would require institutions to revise their AML/CFT controls as their risk profiles change, and to concentrate on higher-risk activities and deprioritize lower-risk activities. The proposal invites comment on whether regulated entities should be permitted to share any information with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network related to AML/CFT supervisory and enforcement actions. BNY is assessing the potential impact of the proposal.