ALLY 10-K & 10-Q changes, risk factors and insider trading

We face many risks and uncertainties, any one or more of which could have a material adverse effect on our business, results of operations, financial condition (including capital and liquidity), or prospects or the value of orour return on an investment in Ally. We describe certain of these risks and uncertainties in this section, although we may be adversely affected by other risks or uncertainties that are not presently known to us, that we have failed to appreciate,identify, or that we currently consider immaterial.insignificant. These risk factors should be read in conjunction with the Regulation and Supervision section in Part I, Item 1 of this report, the MD&A in Part II, Item 7 of this report, and the Consolidated Financial Statements and notes thereto. This Annual Report on Form 10-K is qualified in its entirety by these risk factors.

Below is a summary of the principal risk factors that could adversely affect our business, results of operations, financial condition (including capital and liquidity), or prospects or the value of or return on an investment in Ally.

•Our business and financial results may be negatively affected by governmental actions related to climate and other sustainabilitysustainability-related issues.matters.

•Weak or deteriorating economic conditions, failures in underwriting, changes in underwriting standards, failures in servicing loans and operating leases, financial or systemic shocks, or continued growth in our nonprime or used vehicle financing business could increase our credit risk, which could adversely affect our business and financial results.

•The markets for automotive financing, insurance, banking, brokerage, and investment-advisoryinvestment advisory services are extremely competitive, and competitive pressures could adversely affect our business and financial results.

•ClimateClimate-related changerisks could adversely affect our business, operations, and reputation.

•Our business and operations make extensive use of models,models and certain other qualified tools, and we could be adversely affected if our design, implementation, or use of models isand certain other qualified tools are flawed.

•The market price of our common stock could be adversely impacted by anti-takeover provisions in our organizational documents and Delaware law that could delay or prevent a takeover attempt or change in controlCIC of Ally or by other banking, antitrust, or corporate laws that have or are perceived as having an anti-takeover effect.

While the scope, intensity, and focus of governmental oversight can vary from time to time, we expect a highly demanding environment for the foreseeable future. In recent years, regulatoryRegulatory and other governmental agencies have takenin athe hostpast oftaken, and in the future may continue to take actions that create more challenging and volatile financial and operating conditions for financial-services companies, including through formal rulemakings that change the law or interpretations of the law, supervisory expectations and public statements that are designed to informally compel changes in industry practices, and more aggressive approaches to enforcement that are accompanied by increasingly severe penalties. These actions are comprehensive in their coverage, such as rulemakings on cybersecurity risk governance (including incident disclosure), climate-, diversity- and other sustainability related matters (including disclosures), CRA reform, and personal-financial-data rights as well as guidance and statements on mergers and acquisitions, regulatory capital, resolution planning, automotive financing and insurance, fees for financial services, and UDAAP. Further, the level of regulatory scrutiny may fluctuate over time based on numerous factors, including as a result of changes in governmental policies in response to adverse events impacting the U.S.financial presidentialservices administrationsindustry or onefrom orchanges both houses of Congress andto public sentiment regarding financial institutions (which can be influenced by scandals and other incidents that involve participants in the industry).institutions. We are unable to predict the form or nature of any future changes to the laws, rules, regulations, or supervisory guidance and policies, including the interpretation, implementation, or enforcement thereof. FollowingChanges in laws or the failuresregulatory ofand threesupervisory largeenvironment bankscould adversely affect us in 2023, banking regulators have proposed changes, or indicated the potential for changes, regarding the regulationsubstantial and supervisionunpredictable of banking organizations, in particular those, such as Ally, with $100 billion or more in assets.ways. The introduction of new or more stringent regulatory requirements, as well as heightened supervisory expectations, could require Ally to maintain additional capital or liquidity or incur significant expenses. GovernmentalIn addition, changes in the regulatory environment or increased governmental oversight of this kind may increase our operating costs or reduce our revenues, limit the types of financial services and products we may offer, alter the investments we may make, affect the manner in which we conduct our business and operations, increase our litigation and regulatory costs, and enhance the ability of others to offer more competitive financial services and products. We continue to devote substantial time and resources to risk management, compliance, regulatory-change management, and cybersecurity and other technology initiatives, each of which—whether successful or not—also may adversely affect our ability to operate profitably or to pursue advantageous business opportunities.

Ally has elected to be treated as an FHC, which permits us to engage in a number of financial and related activities—including securities, advisory, insurance, and merchant-banking activities—beyond the business of banking. As a result, Ally and Ally Bank are subject to ongoing requirements for Ally to qualify as an FHC, including that Ally and all of its depository institution subsidiaries must be “well capitalized” and “well managed,” as defined under applicable law. If a BHC or any of its insured depository institutionsIDIs is found not to be well capitalized or well managed, the BHC can be restricted from engaging in the broader range of financial and related activities permitted for FHCs, including the ability to acquire companies engaged in those activities, and can be required to discontinue these activities or even divest any of its insured depository institutions.IDIs. In addition, if an insured-depository-institutionIDI subsidiary of a BHC fails to achieve a “satisfactory” or better rating in its most recent CRA performance evaluation, the ability of the BHC to expand its financial and related activities or make acquisitions could be restricted.

In connection with their continuous supervision and examinations of us, the FRB, the UDFI, the CFPB, the SEC, FINRA, the NYDFS, or other regulatory agencies have in the past and in the future may continue to explicitly or implicitly require changes in our business or operations. Such a requirement may be judicially enforceable or impractical for us to contest, and if we are unable to comply with the requirement in a timely and effective manner, we have in the past and in the future may become subject to formal or informal enforcement and other supervisory actions, including memoranda of understanding, written agreements, cease-and-desist orders, and prompt-corrective-action or safety-and-soundness directives. In addition, compliance failures or other violations raised in connection with supervisory evaluations have in the past and in the future may continue to result in additional requirements for us to take certain remedial actions, including changes to our controls, operations or other processes. Compliance with such remedial actions may be costly and time consuming, and failure to comply in a timely manner that is sufficient from the perspective of the applicable regulatory agency could subject us to further remedial steps or enforcement actions. The financial-services industry continues to face increased scrutiny from supervisory authorities in the examination process, including through an increasing use of horizontal reviews from a broader industry perspective as well as strict enforcement of laws at federal, state, and local levels—particularly in connection with business and other practices that may harm or appear to harm consumers and compliance with anti-money-laundering, sanctions, and related laws. In addition, violations by other financial institutions relating to a particular business activity or practice may result in increased scrutiny, or increased penalties in connection with a related enforcement action, for similar activities. Because of the regulatory and supervisory framework, financial institutions often are less inclined to litigate with governmental authorities. In general, theThe amounts paid by financial institutions in settling proceedings or investigations and the severity of other terms of regulatory settlements are likely to remain elevated. In some cases, governmental authorities have required criminal pleas or other extraordinary terms, including admissions of wrongdoing and the imposition of monitors, as part of settlements. Supervisory actions could entail significant restrictions on our existing business, our ability to develop new business or make acquisitions, our flexibility in conducting operations, and our ability to pay dividends or utilize capital. Enforcement and other supervisory actions also can result in the imposition of civil monetary penalties or injunctions, related litigation by private plaintiffs, damage to our reputation, and a loss of customer or investor confidence, and a prior enforcement action may also increase the risk that regulators and governmental authorities pursue formal enforcement actions in connection with the resolution of an inquiry or investigation, even if unrelated to the prior enforcement action. We could be required as well to dispose of specified assets and liabilities within a prescribed period of time. As a result, any enforcement or other supervisory action could have an adverse effect on our business, financial condition, results of operations, and prospects.

Our regulatory and supervisory environments—whether at international, federal, state, or local levels—are not static. No assurance can be given that applicable statutes, regulations, and other laws will not be amended or construed differently, that new laws will not be adopted, that any of these laws will not be enforced more aggressively, or that applicable laws, or the interpretation or enforcement thereof, may overlap, diverge or conflict across jurisdictions. Litigation challenging actions or regulations by federal or state authorities could, depending on the outcome, significantly affect the regulatory and supervisory framework affecting our operations. Changes in the regulatory and supervisory environments, including as a result of changes from recent elections in the United States and the corresponding change in administrative regimes, could adversely affect us in substantial and unpredictable ways, including by limiting the types of financial services and products we may offer, enhancing the ability of others to offer more competitive financial services and products, and restricting our ability to make acquisitions or pursue other profitable opportunities. Uncertainty about the timing and scope of future changes in laws, regulations and policies, or the interpretations thereof, may impact our decision making with respect to business activities or initiatives, and reacting to such changes could increase our operating and compliance costs. Further, our noncompliance with applicable laws—whether as a result of changes in interpretation or enforcement, system or human errors, or otherwise and, in some cases, regardless of whether noncompliance was inadvertent—could result in the suspension or revocation of licenses or registrations that we need to operate and in the initiation of enforcement and other supervisory actions or private litigation.

Depending on the circumstances, to satisfy the FRB in its review of our capital plan, we may be required to further cease or limit capital distributions or to issue capital instruments that could be dilutive to shareholders. The FRB also may prevent us from maintaining or expanding lending or other business activities. Any of these developments, including the mere fact of being required by the FRB to revise or resubmit our capital plan and especially if unique to us or a group of firms like us, may damage our reputation and result in a loss of customer or investor confidence.

Ally Bank is a key part of our funding strategy, and we place great reliance on deposits at Ally Bank as a source of funding. Our reliance on deposits as a source of funding has increased in recent years. As of December 31, 2024,2025, deposits represented approximately 89%87% of our liability-based funding sources. Competition for deposits and deposit customers, however, is intense and has increased in recent years, making it more challenging for us to rely on customer acquisition as a primary source of new deposit funding. Further, the elevated level of short-term interest rates in recent years have resulted in, and are expected to continue to result in, more intense competition in deposit pricing and with respect to non-deposit financial products. Ally Bank does not have a branch network but, instead, obtains its deposits through online and other digital channels, from other business lines including customers of Ally Invest, and through deposit brokers. Brokered deposits may be more price sensitive than other types of deposits and may become less available if alternative investments offer higher returns. Our brokered deposits totaled $6.7 billion at December 31, 2024,2025, which represented 4.4% of total deposit liabilities. In addition, our ability to maintain, grow, or favorably price deposits may be constrained by our focus on online and mobile banking, gaps in our product and service offerings, changes in consumer trends, our smaller scale relative to other financial institutions, competition from fintech companies and emerging financial-services providers, the recent resurgence of ILCs, the growth of digital assets and related platforms that may divert customer funds from traditional deposit products, any failures or deterioration in our customer service, or any loss of confidence in our brand or our business. In the past, we have relied on deposit growth to fund our lending activities and other business initiatives. If we are unable to maintain or grow our deposit base to meet our business objectives and liquidity requirements, we may be required to raise alternative sources of capital, which may not be available to us when needed or on favorable terms. Increased costs of funding could adversely impact our profitability and financial position, or otherwise adversely affect our ability to conduct our current business activities or meet our growth objectives. Our level and cost of deposits also could be adversely affected by regulatory or supervisory restrictions, including any applicable prior approval requirements or limits on our offered rates or brokered deposit growth, and by changes (including the pace of change) in monetary or fiscal policies that influence deposit or other interest rates. Perceptions of our existing and future financial strength or the financial strength of the financial-services industry generally, rates or returns offered by other financial institutions or third-parties, and other competitive factors beyond our control, including returns on alternative investments, will also impact the size and cost of our deposit base. For example, Ally Bank could be subject to sudden withdrawals of deposits, including as a result of negative media coverage, which may be spread through social media, regarding us or the financial services industry generally. Online and mobile banking have made it easier for customers to withdraw their deposits or transfer funds to other accounts with short notice. This may make retaining deposits during periods of stress more difficult. In addition, depositors of certain types of deposits, such as uninsured or uncollateralized deposits, may be more likely to withdraw their deposits or do so more quickly. Any such withdrawals could result in higher funding costs for us as we lose a lower cost source of funding, and significant unanticipated withdrawals could materially and adversely affect our liquidity, financial condition, and results of operations. These adverse results could be amplified during times of stress, during which our access to alternative sources of capital may be limited. Approximately 92% of total deposits at Ally Bank, excluding affiliate and intercompany deposits, were FDIC-insured as of December 31, 2024.2025.

A fractious or volatile political environment in the United States, including any related social unrest, could negatively impact business and market conditions, economic growth, financial stability, and business, consumer, investor, and regulatory sentiments, any one or more of which in turn could cause our business and financial results to suffer. Uncertainty regarding government shutdowns, government funding, debt ceilings or deficits could adversely affect economic and market conditions, as well as the credit rating of the United States. A default by the United States on its debt obligations or additional prolonged government shutdowns could result in unprecedented market volatility. A downgrade of the U.S. federal government’s credit rating, whether due to a default, concerns about a default or otherwise, could adversely affect financial markets and the value and liquidity of U.S. government securities. In addition, disruptions in the foreign relations of the United States could adversely affect the automotive and other industries on which our business depends and our tax positions and other dealings in foreign countries. We also could be negatively impacted by political scrutiny of the financial-services industry in general or our business or operations in particular, whether or not warranted, and by an environment where criticizing financial-services providers or their activities is politically advantageous.

Our business and financial results may also be affected by changes in government policies following the 2024 U.S. election and the corresponding administrative transition. There remains significant market uncertainty as to how the outcome of the election and any corresponding policy changes could impact us or our clients.policies. For example, the current U.S. administration has adopted and may consider additional tariffs, other controls on imports or exports, and other foreign policies that could affect our businesses and supply chain. Such developments have negatively impacted our business and the automobile industry and could havecontinue anto increaseddo so. The long term impacts on the automobile industry remain uncertain and could negatively impact on our business to the extent they negatively impact the automobile industry, increase the cost of automobile repairs, reduce the purchasing power or credit quality of our customers or impact the ability of third parties to provide services upon which Ally depends. In addition, in recent years the U.S. federal government and the U.S. Treasury Department have been required to take specific measures to prevent the U.S. government from breaching the federal debt ceiling. Continued uncertainty as to the U.S. federal debt ceiling, or any federal government shutdown, downgrade in the U.S. sovereign credit rating or other adverse effects of a prolonged period of elevated budget deficits, including changes in fiscal and monetary policies, could have severe repercussions on us and our clients.

Additionally, changes to tax policies, or changes to the interpretations of existing policies, could have a significant impact on our results of operations and financial condition. For example, in August 2022, the Inflation Reduction Act was signed into law in the United States and, in part, imposes a 15% corporate alternative minimum tax on certain large corporations, such as Ally, and a surcharge on stock repurchases. Tax and other fiscal policies, moreover, impact not only general economic and market conditions but also give rise to incentives or disincentives that affect how we and our customers prioritize objectives, deploy resources, and run households or operate businesses. For example, the September 30, 2025 expiration of federal electric-vehicle tax credits for both new and used vehicles, in addition to vehicle recalls and OEM marketing incentives, have negatively impacted both consumer demand for electric vehicles and the residual value of electric vehicles subject to an automotive operating lease. Both the timing and the nature of any changes in monetary or fiscal policies, as well as their consequences for the economy and the markets in which we operate, are beyond our control and difficult to predict but could adversely affect us.

More broadly, the U.S. federal government, U.S. states and certain other countries and regions have adopted or are considering legislation, regulation or policies that reflect diverse, diverging and, in some cases, potentially conflicting policy goals, for example, on social and environmental topics such as climate change, corporate diversity, equity and inclusion and companies’ actions, commitments and initiatives on such issues.goals. Compliance with such laws, regulations or policies, including any that may be adopted in the future, could, among other things, increase the costs of operating our businesses, reduce the demand for our products and services, impact our ability to meet or maintain current or future goals or targets or continue initiatives (including our sustainability targets or diversity, equity and inclusion initiatives),initiatives, and increase our legal, operational and reputationalother risks, any or all of which could materially adversely affect our results of operations. Failure, or perceived failure, to comply with any legislation, regulation or policy, including as a result of making good faith interpretations that may differ from those taken by enforcement authorities in relevant jurisdictions, could potentially result in substantial fines, criminal sanctions, reputational harm or operational changes. Changes in administration priorities can also lead to shifts in supervisory or enforcement focus—for example, public debates around “debanking” and related account-closure practices—which may alter regulatory expectations and increase compliance and reputational risks. Moreover, our customers, shareholders, employees and other stakeholders have a full range of expectations, demands and perspective on environmental, social and other topics, which are continuing to evolve. We may not be able to meet the full range of expectations and demands of all of our stakeholders, which could harm our reputation, reduce customer demand for our products and services, and subject us to legal and operational risks.

Cybersecurity and data-privacy risks have received heightened legislative and regulatory attention and have been a specific focus area in supervisory reviews. In recent years, governments and regulators in multiple jurisdictions have adopted or proposed to adopt additional legal requirements focused on cybersecurity risk management, governance and disclosure, as well as data privacy and personal financial data rights. For example, in 2021 the U.S. banking agencies have adopted a final rulerules requiring us to notify the FRB within 36 hours of any significant computer security incident and have proposed enhanced cyber risk management standards applicable to us and our service providers that would address cyber risk governance and management, management of internal and external dependencies, and incident response, cyber resilience, and situational awareness. In addition, rulemakings by the SEC and the CFPB have commenced to further regulate cybersecurity risk governance (including incident disclosure) and personal-financial-data rights, respectively. Several states and their governmental agencies, such as the NYDFS, also have adopted or proposed cybersecurity and data-privacy laws. Privacy laws in the State of California, for example, require regulated entities to establish measures to identify, manage, secure, track, produce, and delete personal information. Failure to comply with privacy laws or supervisory expectations could result in enforcement actions, civil litigation or reputational damages.

Our business and financial results may be negatively affected by governmental actions related to climate and other sustainabilitysustainability-related issues.matters.

Governments and policymakers at the federal, state, local and international levels are increasingly focused on climate- and other sustainability-related issues, including the potential for climate-related risks to impact the safety and soundness of large financial institutions. Furthermore, in recent years, there has been increasing divergence in how government and policy makers are approaching these issues. See the risk factor above, titled Our business and financial results could be adversely affected by the political environment and governmental fiscal and monetary policies.

For example, in recent years, there have been efforts by international, federal, state and local governments and regulators to mandate certain climate-related disclosures. Several states, including California, have enacted or proposed legislation, regulations or policies that would require companies to publish detailed information on its climate-related performance and governance, or otherwise address climate change and other sustainability issues.related matters. At the same time, there have been efforts by other governments and policymakers to prohibit or limit the extent to which companies, including financial institutions, factor sustainability considerations into their business and operations. Several states have enacted or proposed statutes, regulations or policies to that effect.

As a result of these and similar future developments at the federal, state, local and international levels, we may become subject to different and potentially conflicting requirements and expectations in the various jurisdictions in which we operate. Many of these requirements are subject to uncertainty, including as a result of the ongoing development of rules and regulatory guidance, as well as pending legal challenges as to the validity of certain requirements. Following the recent election in the United States and in connection with the corresponding administrative transition, there remains uncertainty as to how and to what extent these policies may further evolve. Compliance with these different and evolving requirements has required, and may continue to require, us to adopt new reporting or other governance processes, which may be more complicated or costly due to diverging requirements, uncertainties or conflicts across jurisdictions. In addition, with respect to sustainability reporting requirements adopted in various jurisdictions, climate- and sustainability-related data may be based on new and changing reporting practices or based on data that is only available to third parties, which may impact the quality and consistency of the data.

Failure to adequately respond to the changing regulatory environment or stakeholder expectations with respect to climate- or sustainability-related issues,matters, including climate-related disclosure, could result in increasesincreased costs, a reduction in business opportunities, subject us to additional legal or regulatory proceedings or otherwise adversely affect our operations, reputation and our financial results. Further, it is possible that government responses to actual or perceived changes in climate and related sustainability risks may occur more rapidly than we (or third-parties on whom we rely for certain climate- or other sustainability-related information or services) are able to adapt. Our ability to comply with these requirements and expectations, including responses to any inquiry or investigation from a regulatory agency, could have a material adverse effect on our operations, reputation and our financial results.

How governments act to address climate and related sustainability risks, as well as associated changes in the behavior and preferences of businesses and consumers, could have an adverse effect on our business and financial results. For example, physical and transition risks associated with climateclimate-related changerisks and extreme weather events could affect households, communities, businesses, and governments, which could impede business activity, affect household incomes, and alter the value of assets and liabilities. These risks are often difficult to quantify or predict, and may be propagated through the economy and financial system, the financial sector may experience credit and market risks associated with loss of income, defaults and changes in the values of assets, liquidity risks associated with changing demand for liquidity, operational risks associated with disruptions to infrastructure or other channels, or legal risks. As a result, we may change or cease some of our business or operational practices or incur additional capital, compliance, and other costs. TheClimate-related risks associated with climate change are rapidly changing and evolving in an escalating fashion, making them difficult to assess due to limited data.

Weak or deteriorating economic conditions, failures in underwriting, changes in underwriting standards, failures in servicing loans and operating leases, financial or systemic shocks, or continued growth in our nonprime or used vehicle financing business could increase our credit risk, which could adversely affect our business and financial results.

Our business and financial results depend significantly on household, business, economic, and market conditions. When those conditions are weak or deteriorating, we could simultaneously experience reduced demand for credit and increased delinquencies or defaults, including in the loans that we have securitized and in which we retain a residual interest. These kinds of conditions also could dampen the demand for products and services in our insurance, banking, brokerage, advisory, and other businesses. Increased delinquencies or defaults could also result from our failing to appropriately underwrite loans and operating leases that we originate or purchase or from our adopting—for strategic, competitive, or other reasons—more liberal underwriting standards. If delinquencies or defaults on our loans and operating leases increase, their value and the income derived from them could be adversely affected, and we could incur increased administrative and other costs in seeking a recovery on claims and any collateral. If unfavorable conditions are negatively affecting used vehicle or other collateral values at the same time, the amount and timing of recoveries could suffer as well. For example, net charge offs and delinquencies in our consumer automotive lending portfolio remained elevated in 2024 as our customers faced challenging economic conditions, such as prolonged periods of inflation and high interest rates. If the economic conditions impacting the credit quality of our customers were to worsen, we could be subject to significant losses in our credit portfolio. Weak or deteriorating economic conditions also may negatively impact the market value and liquidity of our investment securities, and we may be required to record additional impairment charges that adversely affect earnings if debt securities suffer a decline in value that is considered other-than-temporary.value. There can be no assurance that our forecasts of economic conditions, our assessments and monitoring of credit risk, and our efforts to mitigate credit risk through risk-based pricing, appropriate underwriting and investment policies, loss-mitigation strategies, and diversification are, or will be, sufficient to prevent an adverse impact to our business and financial results. In addition, because of CECL, our financial results may be negatively affected as soon as weak or deteriorating economic conditions are forecasted and alter our expectations for credit losses. A financial or systemic shock and a failure of a significant counterparty or a significant group of counterparties could negatively impact us as well, possibly to a severe degree, due to our role as a financial intermediary and the interconnectedness of the financial system.

As part of the underwriting process, we rely heavily upon information supplied by applicants and other third-parties, such as credit reporting agencies, automotive dealers and retailers (in the case of automotive consumer and commercial loans), and service providers (in the case of unsecured personal loans).providers. If any of this information is intentionally or negligently misrepresented and the misrepresentation is not detected before completing the transaction, we may experience increased credit risk.

OnUnder January 1, 2020,CECL, we adopted CECL to measure credit losses for financial assets measured at amortized cost,cost basis, which includes the vast majority of our finance receivables and loan portfolio. Under CECL, theThe allowance is established to reserve for management’s best estimate of expected lifetime losses inherent in our finance receivables and loan portfolio.

The determination of the appropriate level of the allowance for loan losses inherently involves a high degree of subjectivity and requires us to make significant estimates of current and future credit risks using existing quantitative and qualitative information, all of which may change substantially over time. Changes in economic conditions affecting borrowers, revisions to accounting rules and related guidance, new qualitative or quantitative information about existing loans, identification of additional problem loans, changes in the size or composition of our finance receivables and loan portfolio, changes to or errors in our modelsmodels, data, or loss estimation techniques including consideration of forecasted economic assumptions, the impact of natural disasters and other catastrophic events that may be difficult to predict and other factors, both within and outside of our control, may require an increase in the allowance for loan losses. For example, due to the nature of our business, our financial position and results of operations are specifically susceptible to risks associated with increases in factors such as interest rates, unemployment, or inflation, or decreases in GDP, real personal income, used vehicle values, or home values, beyond what is reflected in our models, all of which could result in an increased inability for consumers to pay their loans, and may result in an increase in the allowance for loan losses. Additionally, our shift to a full credit spectrum consumer automotive finance portfolio over the past several years has resulted in additional increases in our allowance for loan losses, and could result in additional increases in the future. Any increase in the allowance in future periods may adversely affect our financial condition or results of operations. Refer to the risk factor below, titled Our business and operations make extensive use of models,models and certain other qualified tools, and we could be adversely affected if our design, implementation, or use of models isand certain other qualified tools are flawed, for more information on how risks associated with our use of models could affect our allowance for loan losses.

Our share of commercial wholesale financing remains at risk of decreasing in the future as a result of intense competition and other factors. The number of dealers with whom we have wholesale relationships decreased approximately 5%3% as of December 31, 2024,2025, compared to December 31, 2023.2024. If we are not able to maintain existing relationships with significant automotive dealers or if we are not able to develop new relationships for any reason—including if we are not able to provide services on a timely basis, offer products and services that meet the needs of the dealers, compete successfully with the products and services of our competitors, or effectively counter the influence that captive automotive finance companies have in the marketplace or the exclusivity privileges that some competitors have with automotive manufacturers—our wholesale funding volumes, and the number of dealers with whom we have retail funding relationships, could decline in the future. If this were to occur, our business, results of operations, financial condition, or prospects could be adversely affected. In addition, the recent resurgence of ILCs could heighten competitive pressures, as ILCs—affiliated with fintech, technology-enabled companies, or OEMs—can offer bank-like products without being subject to the full scope of regulation and supervision applicable to bank holding companies, which could enable ILCs and similar institutions to compete more aggressively against us.

While we continue to diversify our automotive finance and insurance businesses and to expand into other financial services, GM and Stellantis dealers and their retail customers still constitute a significant portion of our customer base. In 2025, 34% of our new vehicle dealer inventory financing and 24% of our consumer automotive financing volume were transacted for GM dealers and customers, and 36% of our new vehicle dealer inventory financing and 13% of our consumer automotive financing volume were transacted for Stellantis dealers and customers. In 2024, 30% of our new vehicle dealer inventory financing and 22% of our consumer automotive financing volume were transacted for GM dealers and customers, and 46% of our new vehicle dealer inventory financing and 16% of our consumer automotive financing volume were transacted for Stellantis dealers and customers. In 2023, 28% of our new vehicle dealer inventory financing and 23% of our consumer automotive financing volume were transacted for GM dealers and customers, and 53% of our new vehicle dealer inventory financing and 20% of our consumer automotive financing volume were transacted for Stellantis dealers and customers. A significant adverse change in GM’s or Stellantis’ business—including, for example, in the production or sale of GM or Stellantis vehicles, the quality or resale value of GM or Stellantis vehicles, GM’s or Stellantis’ relationships with its key suppliers, or the rate or volume of recalls of GM or Stellantis vehicles—could negatively impact our GM and Stellantis dealer and retail customer bases and the value of collateral securing our extensions of credit to them. Any future reductions in GM and Stellantis business that we are not able to offset couldwould adversely affect our business and financial results. Refer to Note 29 to the Consolidated Financial Statements for additional information.

Our automotive finance and insurance businesses can beare impacted by the sales volume for new and used vehicles. Vehicle sales are impacted, in turn, by several economic and market conditions, including employment levels, household income and savings, vehicle affordability, interest rates, credit availability, inventory levels, customer preferences, and fuel costs. For example, new vehicle sales decreased dramatically during the economic crisis that began in 2007–2008 and did not rebound significantly until 2012 and 2013. A meaningful rise in inflation during 2021 and through 2023 prompted the FRB to sharply increase the federal funds rate during 2022 and 2023, before it decreased the rate at the end of 2024. The FRB may further raise or lower interest rates in response to economic conditions, particularly inflationary pressures and unemployment statistics. The current level of borrowing costs has adversely affected demand for new and used vehicles and could continue to do so in the future. Any future declines in new or used vehicle sales, including as a result of market conditions and other external factors over which we do not control, could have an adverse effect on our business and financial results.

General economic conditions, the supply of off-lease and other vehicles to be sold, the levels of demand for vehicle ownership and use, relative market prices for new and used vehicles, perceived vehicle quality, thehow shiftOEM’s fromprioritize gasoline toand electric vehicles, overall vehicle prices, the vehicle disposition channel, volatility in gasoline or diesel fuel prices, levels of household income and savings, interest rates, and other factors outside of our control heavily influence used vehicle prices. Consumer confidence levels and the strength of automotive manufacturers, dealers, and retailers can also influence the used vehicle market. For example, during the economic crisis that began in 2007–2008, sharp declines in used vehicle demand and sale prices adversely affected our remarketing proceeds and financial results.

Our expectation of the residual value of a vehicle subject to an automotive operating lease contract is a critical element used to determine the amount of the operating lease payments under the contract at the time the customer enters into it. As a result, to the extent that the actual residual value of the vehicle—as reflected in the sale proceeds received upon remarketing at lease termination—is less than the expected residual value for the vehicle at lease inception, we will incur additional depreciation expense and lower profit on the operating lease transaction than our priced expectations. OurFor expectationexample, residual values for certain plug-in hybrid vehicles have experienced pressure recently driven primarily by the elimination of federal electric-vehicle tax credits for both new and used vehicles, vehicle recalls, and OEM marketing incentives. In addition, during the first quarter of 2026, Stellantis announced the discontinuation of certain plug-in hybrid electric vehicle models, which could exert further downward pressure on used vehicle values isfor alsothese amodels. factorSuch decreases in determiningused vehicle values could adversely affect our pricingremarketing of new loanperformance and realized residual values for certain vehicles currently in our operating lease originations.portfolio, Incould stressedresult economicin environments,an residual-valueimpairment risk may be even more volatile than credit risk. To the extent that used vehicle prices are significantly lower thanto our expectations, our profit on vehicle loans and operating leaseslease assets, or could beresult substantially less than our expectations, even more so if our estimate of loss frequency is underestimated as well. In addition, we could be adversely affected if we fail to efficiently process and effectively market off-lease vehicles and repossessed vehicles and, asin a consequence,prospective incurincrease higher-than-expectedin disposaldepreciation costs or lower-than-expected proceeds from the vehicle sales.expense.

We are highly dependent on net interest income, which is the difference between interest income on earning assets (such as loans and investments) and interest expense on deposits and borrowings. Net interest income is significantly affected by market rates of interest, which in turn are influenced by monetary and fiscal policies, general economic and market conditions (including high or increasing levels of inflation), the political and regulatory environments, business and consumer sentiment, competitive pressures, and expectations about the future (including future changes in interest rates). We may be adversely affected by policies, laws, and events that have the effect of flattening or inverting the yield curve (that is, the difference between long-term and short-term interest rates), depressing the interest rates associated with our earning assets to levels near the rates associated with our interest expense, increasing the volatility of market rates of interest (including the rate of change), or changing the spreads among different interest rate indices. As of December 31, 2024,2025, our balance sheet is modestly asset sensitive in the near term due to our floating-rate assets and pay-fixed hedge position. However, our balance sheet remains liability sensitive over the medium term, driven by the assumed repricing of our deposits and market-based funding outpacing the assumed repricing of our floating-rate assets and pay-fixed swaps, which will also begin to roll down.swaps.

The level of and changes in market rates of interest—and, as a result, these risks and uncertainties—are beyond our control. The dynamics among these risks and uncertainties are also challenging to assess and manage. For example, while an accommodative monetary policy may benefit us to some degree by spurring economic activity among our customers, such a policy may ultimately cause us more harm by inhibiting our ability to grow or sustain net interest income. A rising interest rate environment can pose different challenges, such as potentially slowing the demand for credit, increasing delinquencies and defaults, and reducing the values of our loans and fixed-income securities. Market volatility in interest rates, including the rate of change, can create particularly difficult conditions. During 2021 and through 2023, following a meaningful rise in inflation, the FRB sharply increased the federal funds rate. The federal funds target range reached 5.25–5.50% in 2023. However, the Federal Reserve gradually lowered the federal funds target range induring 2024 and 2025, to 4.253.50–4.50%3.75% as of December 31, 2025, in response to easing inflation trends and moderate labor market pressures. The timing, pace and direction of additional interest rate changes remains uncertain, and will largely depend on trends in inflation, employment and other macroeconomic factors that are outside of our control, and could have a significant impact on our net interest income, allowances for loan losses, the value of securities portfolio and our results of operation and financial position. Refer to the section titled Market Risk in the MD&A that follows and Note 21 to the Consolidated Financial Statements.

We seekrely on third-party service providers to distinguish ourselves as a customer-centric company that delivers passionate customer service and innovative financial solutions and that is relentlessly focused on “Doing it Right.” Third-party service providers, however, are key to much ofsupport our business and operations, including online and mobile banking, brokerage, customer service, financial reporting, and operating systems and infrastructure. We rely on our third-party service providers to provide critical products and services to facilitate our business activities, including by providing data and information, technology, security and other infrastructure services. While we have implemented a supplier-risk-management program and can exert varying degrees of influence over our service providers, we do not control them, their actions, or their businesses. Our contracts with service providers, moreover, may not require or sufficiently incent them to perform at levels and in ways that we would choose to act on our own. Despite our supplier-risk-management program, there can be no assurance that our third-party service providers will notify us of any potential risks or incidents in a timely manner or that our risk-management procedures will be effective in mitigating the impact of actions by third-party service providers on our business. Service providers have not always met our requirements and expectations, and no assurance can be provided that in the future they will perform to our standards, adequately represent our brand, comply with applicable law, appropriately manage their own risks (including cybersecurity), remain financially or operationally viable, abide by their contractual obligations, or continue to provide us with the services that we require. In such a circumstance, our ability to deliver products and services to customers, to satisfy customer expectations, and to otherwise successfully conduct our business and operations have been and, in the future, could be adversely affected. These risks are amplified to the extent that we or our third-party service providers make use of cloud computing, artificial intelligenceAI or other emerging technologies that may make our systems and those of our third-party service providers more susceptible to cyberattacks,cyberattacks and other information technology risks, which in turn could have an adverse effect on our business and operations to the extent that they are not able to mitigate their cybersecurity or other information technology risks. In addition, we may need to incur substantial expenses to address issues of concern with a service provider, and if the issues cannot be acceptably resolved, we may not be able to timely or effectively replace the service provider due to contractual restrictions, the unavailability of acceptable alternative providers, or other reasons. Further, regardless of how much we can influence our service providers, issues of concern with them could result in supervisory actions and private litigation against us and could harm our reputation, business, and financial results. In these instances, we may be unable to enforce any indemnification or other rights we may have against such service providers.

As a financial-services company, we are regularly involved in pending or threatened legal proceedings and other matters and are or may be subject to potential liability in connection with them. These legal matters may be formal or informal and include litigation and arbitration with one or more identified claimants, certified or purported class actions with yet-to-be-identified claimants, and regulatory or other governmental information-gathering requests, examinations, investigations, and enforcement proceedings. Our legal matters exist in varying stages of adjudication, arbitration, negotiation, or investigation and span our business lines and operations. Claims may be based in law or equity—such as those arising under contracts or in tort and those involving banking, consumer-protection, securities, tax, employment, and other laws—and some can present novel legal theories and allege substantial or indeterminate damages. In addition, our income tax positions have been and could continue to be challenged by taxing authorities, and any adverse results could materially impact our business, results of operations, and financial condition.

Skilled employees are our most important resource, and competition for talented people is intense. Even though compensation and benefits expense are among our highest costs, we may not be able to locate and hire the best people, keep them with us, or properly motivate them to perform at a high level. This risk may be exacerbated due to some of our competitors having significantly greater scale, financial and operational resources, and brand recognition. While we strive to mitigate human-capital risks, our senior executives and other key leaders havepossess deep anddeep, broad industry experience andthat would be difficult to replace without some degreedisruption, ofmaking disruption.effective Forleadership example,continuity through succession planning critical. Delays in Octoberidentifying, 2023developing, ouror formerintegrating CEOsuccessors providedfor noticekey ofroles hiscould intentresult toin retire,operational disruption and onexecution April 29, 2024, Michael G. Rhodes was appointed as the CEO.risk. We may also experience competition in retaining employees based on remote or other flexible work arrangements, and our ability to attract or retain qualified employees may be adversely affected if our work arrangements are perceived as less favorable than those of our competitors. Continued scrutiny of compensation practices, especially in the financial services industry, has made this competition for talent only more difficult. In addition, many parts of our business are particularly dependent on key personnel, and retaining talented people in certain areas, has been challenging. Further, growth in our businesses, through acquisitions or otherwise, will further increase our need for skilled employees. If we were to lose and find ourselves unable to replace these personnel or other skilled employees or if the competition for talent were to drive our compensation costs to unsustainable levels, our management of operational and other risks could suffer, and our business and financial results could be negatively impacted.

Ally and Ally Bank continue to access the securitization markets. While those markets have stabilized following the liquidity crisis that commenced in 2007–2008,However, there can be no assurances that these sources of liquidity will remain available to us.us particularly during periods of financial instability.

The cost and availability of our funding are meaningfully affected by our short- and long-term credit ratings. Each of S&P’s Rating Services, Moody’s Investors Service, Inc., Fitch, Inc., and Dominion Bond Rating ServiceDBRS rates some or all of our debt, and these ratings reflect the rating agency’s opinion of our financial strength, operating performance, strategic position, and ability to meet our obligations. Agency ratings are not a recommendation to buy, sell, or hold any security and may be revised or withdrawn at any time. Each agency’s rating should be evaluated independently of any other agency’s rating.

In August 2023, citing macroeconomic trends impacting the banking industry, such as increased costs of funding and rapid tightening in monetary policy, Moody’s downgraded the credit ratings of a number of banks. Additionally, Moody’s downgraded the outlook of a number of banks, including Ally, where the outlook was lowered from Stable to Negative. Any future downgrades to our credit ratings or their failure to meet investor expectations may result in higher non-deposit borrowing costs, reduced access to the banking and capital markets, more restrictive terms and conditions being added to any new or replacement financing arrangements. Moody’s has since upgraded our outlook from Negative to Stable in August of 2024.

The markets for automotive financing, insurance, banking, brokerage, and investment-advisoryinvestment advisory services are extremely competitive, and competitive pressures could adversely affect our business and financial results.

The markets for automotive financing, insurance, banking, brokerage, and investment-advisoryinvestment advisory services are highly competitive, and we expect competitive pressures only to remain intense in the future, especially in light of the regulatory and supervisory environments in which we operate, innovations that alter the barriers to entry, current and evolving economic and market conditions, changing customer preferences and consumer and business sentiment, and monetary and fiscal policies. In addition, the emergence, adoption, and evolution of new technologies that affect intermediation, including distributed ledgers such as digital assets and blockchain, as well as advances in robotic process automation or artificial intelligenceAI could significantly affect the competition for financial services. Refer to the section above titled Industry and Competition in Part I, Item 1 of this report. The recent resurgence of ILCs could further heighten competitive pressures, as ILCs—often affiliated with fintech and technology-enabled companies—can offer bank-like products without being subject to the full scope of regulation and supervision applicable to bank holding companies. This could enable ILCs and similar institutions to compete more aggressively against us. Competitive pressures may drive us to take actions that we might otherwise eschew, such as lowering the interest rates or fees on loans, raising the interest rates on deposits, or adopting more liberal underwriting standards. These pressures also may accelerate actions that we might otherwise elect to defer, such as substantial investment in systems or infrastructure. Whatever the reason, actions that we take in response to competition may adversely affect our results of operations and financial condition. These consequences could be exacerbated if we are not successful in introducing new products and services, achieving market acceptance of our products and services, developing and maintaining a strong customer base, continuing to enhance our reputation, or prudently managing risks and expenses.

Geopolitical conditions, government shutdowns, military conflicts (including Russia’s invasion of Ukraine and the conflicts in the Middle East), acts or threats of terrorism, natural disasters, pandemics (including the COVID-19 pandemic or similar global pandemics in the future),pandemics, disruptions in the U.S. or global economy caused by geopolitical events and related sanctions, and other conditions or events beyond our control may adversely affect our business, results of operations, financial condition, or prospects. For example, military conflicts, acts or threats of terrorism, and political, financial, or military actions taken in response could adversely affect general economic, business, or market conditions and, in turn, us, especially as an intermediary within the financial system. In addition, nation states engaged in warfare or other hostile actions may directly or indirectly use cyberattacks against financial systems and financial-services companies like us to exert pressure on one another or other countries with influence or interests at stake. We also could be negatively impacted if our key personnel, a significant number of our employees, or our systems or infrastructure were to become unavailable or damaged due to a pandemic, natural disaster, war, act of terrorism, accident, or similar cause. Furthermore, a shutdown of the United States government could adversely affect the economy and increase the risk of economic instability and market volatility, which could have an adverse impact on our business, financial condition, liquidity, and results of operations. These same risks and uncertainties arise too for the service providers and counterparties on whom we depend as well as their own third-party service providers and counterparties.

In the past, significant unforeseen events, such as the COVID-19 pandemic,events have had a significant impact on our provision for credit losses and results of operations. In the case of Russia’s invasion of Ukraine and the current conflicts in the Middle East, security risks as well as increases in fuel and other commodity costs, supply-chain disruptions, and associated inflationary pressures have impacted our business the most. Additionally, the U.S. government and governments in other jurisdictions have in the past responded, and may in the future respond, to geopolitical developments by imposing economic sanctions and export controls. We incur costs and are exposed to operational risk in connection with compliance with economic sanctions and restrictions imposed by governments. These conditions and events and others like them are highly complex and inherently uncertain, and their effect on our business, results of operations, financial condition, and prospects in the future cannot be reliably predicted.

We employ various hedging strategies to mitigate the interest rate, foreign exchange, and market risks inherent in many of our assets and liabilities. Our hedging strategies rely considerably on assumptions and projections regarding our assets and liabilities as well as general market factors. If any of these assumptions or projections prove to be incorrect or our hedges do not adequately mitigate the impact of changes in interest rates, foreign exchange rates, and other market factors, we may experience volatility in our earnings that could adversely affect our profitability and financial condition. In addition, we may not be able to find market participants that are willing to act as our hedging counterparties on acceptable terms or at all, which could have an adverse effect on the success of our hedging strategies. Our hedging strategies are not designed to eliminate all interest rate, foreign exchange, and market risks, and we were adversely impacted fromby highthe sharp increase in interest rates induring 2022, 2023,2022 and 2024.2023. Refer to the risk factors titled The levels of or changes in interest rates could affect our results of operations and financial condition and Significant fluctuations in the valuation of investment securities or market prices could negatively affect our financial results.

•our ability to grow and optimize our automotive finance and insurance businesses and to continue diversifying into and growing other consumer and commercial business lines, including corporate finance, brokerage, and personal advice;

•our ability to innovate, to anticipate the needs of current or future customers, to successfully compete, to increase or hold market share in changing competitive environments, or to dealrespond withto pricing or other competitive pressures;

•our ability to effectively dealrespond withto economic, business, or market slowdowns or disruptions;

•our ability to keep pace with changes in technology, such as artificial intelligence,AI, that affect us or our customers, counterparties, service providers, or competitors or to maintain rights or interests in associated intellectual property;

Ally Financial Inc. (together with its consolidated subsidiaries unless the context otherwise requires, Ally, the Company, we, us, or our) is a financial-services company with the nation’s largest all-digital bank and an industry-leading automotive financing and insurance business, driven by a mission to “Do It Right” and be a relentless ally for customersall and communities.stakeholders. The Company serves customers with deposits and securities brokerage and investment advisory services as well as automotive financing and insurance offerings. The Company also includes a seasoned corporate finance business that offers capital for equity sponsors and middle-market companies. Ally is a Delaware corporation and is registered as a BHC under the BHC Act, and an FHC under the GLB Act.

Dealer Financial Services is composed of our Automotive Finance and Insurance segments. Our primary customers are automotive dealers, which includesinclude OEM-franchised dealers, non-OEM-franchised dealers with a national presence, and automotive retailers, such as Carvana, CarMax, and EchoPark. A dealer may sell or lease a vehicle for cash but, more typically, enters into a retail installment sales contract or operating lease with the customer and then sells the retail installment sales contract or the operating lease and the leased vehicle, as applicable, to Ally or another automotive finance provider. The purchase by Ally or another provider is commonly described as indirect automotive lending to the customer.

Our Dealer Financial Services business is one of the largest full-service automotive finance operations in the country and offers a wide range of financial services and insurance products to automotive dealerships and their customers. We have deep dealer relationships that have been built throughout our over 100-year history, and we are leveraging competitive strengths to expand our dealer footprint. Our business model encourages dealers to use our broad range of products through incentive programs likesuch as our Ally Dealer Rewards program. Our automotive finance services include purchasing retail installment sales contracts and operating leases from dealers and automotive retailers, extending automotive loans directly to consumers, offering term loans to dealers, financing dealer floorplans and providing other lines of credit to dealers, supplying warehouse lines to automotive retailers, offering automotive-fleet financing, providing financing to companies and municipalities for the purchase or lease of vehicles, and supplying vehicle-remarketing services. WeAs alsopart of our focus on offering dealers a broad range of consumer F&I products, we offer retailVSCs, VSCsVMCs, and commercialGAP insurance primarily covering dealers’ vehicle inventories. We are a leading provider of VSCs, GAP, and VMCs.products. Our dealer-centric business model, value-added products and services, full-spectrum financing, and business expertise proven over many credit cycles, make us a premier automotive finance and insurance company ready to support and strengthen our approximately 21,400 active dealer relationships. A dealer is considered to have an active relationship with us if we provided automotive financing, remarketing, or insurance services during the three months ended December 31, 2024.2025.

Our Automotive Finance operations provide U.S.-based automotive financing services to consumers, automotive dealers and retailers, other businesses, and municipalities. Our business model, value-added products and services, full-spectrum financing, and business expertise proven over many credit cycles make us a premier automotive finance company. At December 31, 2024,2025, our Automotive Finance operations had $113.1$115.8 billion of assets and generated $5.8$5.6 billion of total net revenue induring 2024.the year ended December 31, 2025. For consumers, we provide financing for new and used vehicles. In addition, our CSG provides automotive financing for small businesses and municipalities. At December 31, 2024,2025, our CSG had $9.3$9.0 billion of loans outstanding. Through our commercial automotive financing operations, we fund purchases of new and used vehicles through wholesale floorplan financing. We manage commercial account servicing on approximately 2,6002,500 dealers that utilize our floorplan inventory lending or other commercial loans. We serviced $84.0$85.1 billion on-balance sheet consumer loans and operating leases at December 31, 2024,2025, and our commercial loan portfolio was approximately $22.9$23.1 billion at December 31, 2024.2025. The extensive infrastructure, technology, and analytics of our servicing operations, as well as the experience of our servicing personnel, enhance our ability to manage our loan losses and enable us to deliver a favorable customer experience to both our dealers and retail customers. During 2024,2025, we continued to repositionrefine our origination profile to focus on capital optimization and risk-adjusted returns. InDuring 2024,the year ended December 31, 2025, total consumer automotive originations were $39.2$43.7 billion, aan decreaseincrease of $791$4.5 millionbillion compared to 2023.the year ended December 31, 2024. The shorter-term duration consumer automotive loan and variable-rate commercial loan portfolios offer attractive asset classes where we continue to optimize risk-adjusted returns through origination mix management and pricing and underwriting discipline.

Our success as an automotive finance provider is driven by the consistent presence and broad rangebreadth of products and services we offer to dealers and automotive retailers. The automotive marketplace iscontinues dynamicto and evolving,evolve, including substantialvarying investmentslevels of investment in electrificationelectric vehicle technologies by automotive manufacturers and suppliers. We continue to identify and cultivate relationships with automotive retailers, including those with leading e-commerce platforms.platforms, Weand we also operate an online direct-lendingdirect lending platform for consumers seeking direct financing. We believe these products will enable us to respond to the growingongoing trends for atoward more streamlined and digital automotive financing processprocesses tothat serve both dealers and consumers. Furthermore, ourOur strong and expansive dealer relationships, comprehensive suite of products and services, full-spectrumfull spectrum financing, and depth of experience position us to evolveadapt withas futurevehicle shiftstechnologies inand automobileconsumer technologies,preferences including electrification.evolve. We have provided and continue to provide automobile financing for battery-electricbattery andelectric and, to a lesser extent, plug-in hybrid vehicles, including brands such as Tesla, Jeep, Alfa Romeo, and Chevrolet. This positions us to remain a leader in automotive financing asWhile we believeexpect the majoritymost of these vehicles willto continue to be sold through dealerships and automotive retailers with whom we have an established relationship. Additionally,relationships, we continue toalso partner and build relationships with automotive manufacturers whothat use a direct-to-consumerdirect to consumer model. During the year ended December 31, 2024,2025, $1.8$1.9 billion of our consumer automotive retail loan originations and purchases, and $2.5$2.1 billion of our operating lease originations and purchases, were for battery-electric and plug-in hybrid vehicles. As of December 31, 2024,2025, $2.3$3.1 billion of our consumer automotive finance receivables and loans had battery-electric or plug-in hybrid vehicles as the underlying collateral, and $3.0$4.2 billion of our investment in operating leases, net of accumulated depreciation, were battery-electric or plug-in hybrid vehicles.

We have focused on developing dealer relationships beyond those relationships that primarily were developed through our previous role as a captive finance company for GM and a preferred provider for Stellantis. We have established relationships with thousands of automotive dealers through our customer-centric approach and specialized incentive programs designed to drive loyalty amongst dealers to our products and services. Outside of GM and Stellantis, our other OEM-franchised dealers include brands such as Ford, Toyota, Hyundai, Kia, Nissan, Honda, and others, including automotive manufacturers who use a direct-to-consumer model. Our non-OEM-franchised dealers and automotive retailers include used-vehicle-only retailers with a national presence, such as CarMax and EchoPark, as well as online-onlyprimarily online automotive retailers, such as Carvana, CarMax, and EchoPark.Carvana.

We have continued to focus on the consumer used-vehicle segment, primarily through franchised dealers and automotive retailers. This has resulted in used-vehicle financing volume growth,growth and has positioned us as an industry leader in used-vehicle financing. The highly fragmented used-vehicle financing market, with a total financing opportunity represented by approximately 292296 million vehicles in operation, provides an attractive opportunity that we believe will further expand and support our dealer relationships and increase our risk-adjusted return on retail loan originations. As of December 31, 2024, approximately 75% of our automotive dealer relationships were with franchised dealers.

Beyond offering a full suite of solutions for our dealership customers, we also offer application pass-through programs for credit applications that do not meet our underwriting criteria, allowing dealers to provide expanded access to credit for consumers and improve sales at their dealership. Through our pass-through programs, we are able to monetize our declined applications by generating a combination of acquisition fee and servicing revenue for loans that are originated, sold to, and serviced on behalf of a third-party lender,lenders, or one-time acquisition fees for loans funded and serviced by a third party. At December 31, 2024,2025, and December 31, 2023,2024, the consumer automotive whole-loan serviced portfolio related to our pass throughpass-through program was $1.2$2.2 billion and $956$1.2 million,billion, respectively.

For consumers, we provide automotive loan financing and leasing for approximately 4.0 million new and used vehicle contracts. Retail financing for the purchase of vehicles by individual consumers generally takes the form of installment sales financing. We originated a total of approximately 1.3 million and 1.2 million automotive loans and operating leases during the years ended December 31, 2024,2025, and 2023,2024, totalingrespectively. We originated total automotive loans and operating leases of $43.7 billion and $39.2 billion during the years ended December 31, 2025, and $40.0 billion,2024, respectively.

Our consumer automotive financing operations generate revenue primarily through finance charges on retail installment sales contracts and rental payments on operating lease contracts. For operating leases, when the contract is originated, we estimate the residual value of the leased vehicle at lease termination. Periodically thereafter we revisereassess the projected residual value of the leased vehicle at lease termination and may adjust depreciation expense over the remaining life of the lease,lease or recognize impairment, if appropriate. Given the fluctuations in used vehicle values, our actual sales proceeds from remarketing the vehicle may be higher or lower than the projected residual value after adjusting for any OEM residual value guarantees, which results in gains or losses on lease termination. While all operating leases are exposed to potential reductions in used vehicle values, it is only where we take possession of the vehicle that we could be affected by potential reductions in used vehicle values. Refer to the Operating Lease Residual Risk Management and Critical Accounting Estimates sections of this MD&A for further discussion of credit risk and lease residual risk.

We continue to maintain a diverse mix of product offerings across a broad risk spectrum, subject to underwriting policies that reflect our risk appetite. Our current operating results increasingly reflect our ongoing strategy to growoptimize risk-adjusted returns while strategically refining our mix of new and used vehicle financing and expand risk-adjusted returns.financing. While we predominately focus on prime-lending markets, we seek to be a meaningful source of financing to a wide spectrum of customers and continue to carefully measure risk versus return. We place great emphasis on our risk management and risk-based pricing policies and practices and employ robust credit decisioning processes coupled with granular pricing that is differentiated across our proprietary credit tiers.

Our commercial automotive financing operations primarily fund inventory purchases of new and used vehicles by dealers, commonly referred to as wholesale floorplan financing. This represents the largest portion of our commercial automotive financing business. Wholesale floorplan loans are secured by vehicles financed (and all other vehicle inventory), which provide strong collateral protection in the event of dealership default. Additional collateral or other credit enhancements (for example, personal guarantees from dealership owners) are typically obtained to further mitigate credit risk. The amount we advance to dealers is equal to 100% of the wholesale invoice price of new vehicles, subject to payment curtailment schedules. Interest on wholesale automotive financing is generally payable monthly and is indexed to a floating-rate benchmark. The rate for a particular dealer is based on, among other considerations, competitive factors and the dealer’s creditworthiness. During 2024,the year ended December 31, 2025, we financed an average of $17.4$15.2 billion of dealer vehicle inventory through wholesale floorplan financings. Other commercial automotive lending products, which averaged $6.4 billion during 2024,the year ended December 31, 2025, consist of automotive dealer revolving lines of credit, term loans, including those to finance dealership land and buildings, and dealer and other fleet financing. We also provide comprehensive automotive remarketing services, including the use of SmartAuction, our online auction platform, which efficiently supports dealer-to-dealer and other commercial wholesale vehicle transactions. SmartAuction provides diversified fee-based revenue and serves as a means of deepening relationships with our dealership customers. In 2024,2025, Ally and other parties, including dealers, fleet rental companies, and financial institutions, utilized SmartAuction to sell approximately 556,000573,000 vehicles to dealers and other commercial customers. SmartAuction served as the remarketing channel for 35%44% of our off-lease vehicles.

Our Insurance operations offer both consumer finance protection and insurance products sold primarily through the automotive dealer channel in the U.S. and Canada, and commercial insurance products sold directly to dealers in the U.S. Our insurance business provides a strong dealer value proposition through our deep industry knowledge, strong service levels, and diversified product suite that complements our automotive finance business in order to drive strong retention rates and help protect and grow the business of our dealer customers. In addition to our product offerings, we provide consultative services and training to assist dealers in optimizing F&I results while achieving high levels of customer satisfaction and regulatory compliance. We also advise dealers regarding necessary liability and physical damage coverages critical to protecting a dealer’s business. We continue to evolve our product suite and digital capabilities to position our business for future opportunities through growing third-party relationships and sales through our online direct-lending platform. Our Insurance operations had $9.3$9.9 billion of assets at December 31, 2024,2025, and generated $1.6$1.7 billion of total net revenue during 2024.the year ended December 31, 2025.

We are a market leading provider of dealer insurance products and have approximately 5,7005,100 dealer relationships to whom we offer a variety of commercial products and levels of coverage. Vehicle inventory insurance for dealers provides physical damage protection for dealers’ floorplan vehicles that may be financed by Ally, another lender, or may be owned by the dealer. Dealers who receive wholesale financing from us are eligible for insurance incentives such as automatic eligibility for our preferred insurance programs. During 2024, we added new inventory insurance relationships, including Nissan and Toyota, andWe continue to grow our market position leveraging our scale and significant experience in this space. We also offer property, liability, and other ancillary coverages to dealers; thatstarting July 1, 2025, we are underwrittenthe byunderwriting carrier on a third-party carrier with a portionmajority of thethese insuranceproduct risk assumed through a quota share agreement.offerings.

Our dealer F&I products are primarily distributed indirectly through the automotive dealer networknetwork, which includes dealer relationships of approximately 1,5001,600 in the U.S. where we serve 2.4 million consumers.customers. As part of our focus on offering dealers a broad range of consumer F&I products, we offer VSCs, VMCs, and GAP products. Ally Premier Protection is our flagship VSC offering, which provides coverage for new and used vehicles of virtually all makes and models offering owners and lessees mechanical repair protection and roadside assistance beyond the manufacturer’s new vehicle warranty. Our GAP products cover certain amounts owed by a customer beyond their covered vehicle’s value in the event the vehicle is damaged or stolen and declared a total loss. We offer F&I products in Canada, where we serve approximately 500,000545,000 consumerscustomers and are the preferred VSC and other protection plan provider for GM Canada and VSC provider for Subaru Canada.GM. Our contract to serve as the preferred VSC and protection plan provider for GM Canada extends into the third quarter of 2027.

We also underwrite ClearGuard on the SmartAuction platform, which is a protection product designed to minimize the risk to dealers from arbitration claims for eligible vehicles sold at auction. On a smaller scale, we also periodically direct write or assume other non-automotive insurance risks. We typically assume other non-automotive insurance risks through quota share arrangements and perform services as an underwriting carrier for insurance programs managed by a third party where we cede the majority of such business to external reinsurance markets.

Our Corporate Finance operations primarily offer senior-secured loans to private equity sponsor-owned U.S.-based middle-market companies and to well-established asset managers that mostly provide leveraged loans. The portfolio is composed of floating-rate leveraged asset-based and cash flow/enterprise value loans. Our Corporate Finance operations had $9.7$13.0 billion of assets at December 31, 2024,2025, and generated $579$538 million of total net revenue during 2024,the year ended December 31, 2025, and continues to offer attractive returns and diversification benefits to our broader lending portfolio. We have continued to prudently grow our lending portfolio with a focus on a disciplined and selective approach to credit quality, including a greater focus on asset-based loans. As of December 31, 2024,2025, 58%65% of our loans and 59%64% of our lending commitments were asset based, with 100%all in a first-lien position. We seek markets and opportunities where our clients require customized, highly structured, and time-sensitive financing solutions.

Our Sponsor Finance business focuses on companies owned by private-equity sponsors with loans typically used for leveraged buyouts, refinancing and recapitalizations, mergers and acquisitions, growth, co-lending arrangements, turnarounds, and debtor-in-possession financings. Additionally, our LenderPrivate Credit Finance business provides asset managers and other financing sources with facilities to partially fund their direct-lending activities. We also provide a commercial real estate product, primarily focused on lending to skilled nursing facilities, senior housing, memory care facilities, and medical office buildings. Sponsor Finance loan facilities typically include both a revolver and term loan component. Our target commitment hold level for these individual exposures ranges from $15 million to $150 million, depending on product type. Additionally, hold sizes in our LenderPrivate Credit Finance business range from $50 million to $750$850 million. We also have a demonstrated track record of success in arranging larger transactions that we may retain on-balance sheet or syndicate to other lenders. By syndicating loans to other lenders, we are able to provide financing commitments in excess of our target hold levels and generate loan syndication fee income while reducing single obligor risk exposure. All our loans are floating-rate facilities with maturities typically ranging from twoup to seven years. In certain instances, we may be offered the opportunity to make small equity investments in our borrowers, which provides an additional revenue opportunity for our business. The portfolio is well diversified across multiple industries including financials, services, manufacturing distribution, and other specialty sectors. These specialty sectors include technology/venture finance, and defense and aerospace.aerospace, as well as energy and infrastructure finance that launched during 2025. Other smaller complementary product offerings that help strengthen our reputation as a full-spectrum provider of financing solutions include issuing letters of credit through Ally Bank and selectively offering second-out loans on certain transactions. For additional information regarding industry concentration of our Corporate Finance operations, refer to the Corporate Finance section of this MD&A.

Corporate and Other primarily consists of centralized corporate treasury activities (including deposit operations) such as management of the cash and corporate investment securities and loan portfolios, short- and long-term debt, retail and brokered deposit liabilities, derivative instruments, original issue discount, and the residual impacts of our corporate FTP and treasury ALM activities. Corporate and Other also includes activity related to certain equity investments, which primarily consist of FHLB and FRB stock, as well as other equity investments through Ally Ventures, our strategic investment business. Additionally, Corporate and Other includes the management of our consumer mortgage portfolio, CRA loans and investments, and reclassifications and eliminations between the reportable operating segments. Costs that are not allocated to our reportable operating segments as part of our COH methodology, which involves management judgment, are also included in Corporate and Other. These costs include operating costs of deposits, treasury activities, and other corporate activities.

We closed the sale of Ally Lending on March 1, 2024. Refer to Note 2 to the Consolidated Financial Statements for further information.

Our primary funding source is retail deposits, which we believe, at scale, is the most efficient and stable source of funding for us when compared to other funding sources. At December 31, 2024,2025, deposit liabilities totaled $151.6 billion, which reflects aan decreaseincrease of $3.1$75 billionmillion as compared to December 31, 2023.2024. Deposits as a percentage of total liability-based funding was 89%87% and 88%89% at December 31, 2024,2025, and December 31, 2023,2024, respectively. Approximately 92% of retail deposits at Ally Bank, excluding affiliate and intercompany deposits, were FDIC-insured as of December 31, 2024.2025.

At both December 31, 2024,2025, and December 31, 2023, 95%94% of Ally’s total assets were within Ally Bank.Bank, compared to approximately 95% as of December 31, 2024. Longer-term unsecured debt is the primary funding source utilized at the parent company. At December 31, 2024,2025, we had $2.5$82 billionmillion and $149$1.6 millionbillion of unsecured long-term debt principal maturing in 20252026 and 2026,2027, respectively. We have substantially reduced our reliance on market-based funding by continuing to focus on retail deposit funding.

The strategies outlined above have allowed us to build and maintain a conservative liquidity position. Total available liquidity at December 31, 2024,2025, was $68.5$66.1 billion. Absolute levels of liquidity increaseddecreased during 2024,2025, primarily due to higher cash balances andlower available FHLB borrowing capacity. Refer to the section below titled Liquidity Management, Funding, and Regulatory Capital section of this MD&A for a further discussion about liquidity risk management.

Within our consumer automotive loan portfolio, we serve a mix of consumers across the credit spectrum to achieve portfolio diversification and to optimize the risk and return of our consumer automotive portfolio. This is achieved through the utilization of robust credit decisioning processes, coupled with granular pricing that is differentiated across our proprietary credit tiers. While we are a full-spectrum automotive finance lender, the significant majority of our consumer automotive loans are underwritten within the prime-lending segment. We define prime consumer automotive loans primarily as those loans with a FICO® Score at origination of 620 or greater. The carrying value of our held-for-investment, nonprime consumer automotive loans before allowance for loan losses was approximately 10.1% and 9.7% of our total consumer automotive loans at December 31, 2024.2025, and December 31, 2024, respectively.

Within our commercial lending portfolios, our Corporate Finance operations primarily offer senior-secured loans to private equity sponsor-owned U.S.-based middle-market companies and to well-established asset managers that mostly provide leveraged loans. The portfolio is composed of floating-rate leveraged asset-based and cash flow/enterprise value loans. ThroughoutDuring 2024,the year ended December 31, 2025, this portfolio decreased due to an increased volume of paydowns compared to 2023.the Theyear portfolioended December 31, 2024, as we have continued to beprudently wellgrow positionedour lending portfolio with a focus on a disciplined and selective approach to credit quality.quality, including a greater focus on asset-based loans. Provision for credit losses for our Corporate Finance operations was $31 million for the year ended December 31, 2025, compared to $8 million for the year ended December 31, 2024, compared to $52 million for the year ended December 31, 2023.2024. Within our commercial automotive business, we continue to offer a variety of dealer-centric lending products, including funding dealer purchases of new and used vehicles through wholesale financing, automotive dealer revolving lines of credit, term loans, including those to finance dealership land and buildings, acquisitions, and dealer and other fleet financing. These commercial automotive products are an important aspect of our dealer relationships and offer a secured lending arrangement with strong collateral protections in the event of dealer default. The performance of our commercial credit portfolios continues to remain strong. Commercial nonperforming finance receivables and loans decreasedincreased $8$38 million fromto $119$149 million at December 31, 2023, to $111 million at December 31, 2024.2025. We had net recoveries within our commercial lending portfolio of $2 million and $5 million for the yearyears ended December 31, 2024,2025, compared to net charge-offs of $124 million for the year endedand December 31, 2023.2024, respectively. Refer to the Risk Management section of thethis MD&A for further details.

Our mortgage operations focusfocused on applicants with credit profiles and income streams to support repayments of the loan and operates under credit standards that consider and assess the value of the underlying real estate in accordance with prudent credit practices and regulatory requirements. We generally relyrelied on appraisals conducted by licensed appraisers in conformance with the expectations and requirements of Fannie Mae and federal regulators. When appropriate, we requirerequired credit enhancements such as private mortgage insurance. We pricepriced each mortgage loan that we originateoriginated based on several factors, including the customer’s FICO® Score, the LTV ratio, and the size of the loan. For bulk purchases, we only purchasepurchased loans from sellers with the experience toin originateoriginating high-quality loans and the financial wherewithal to support their representations and warranties. During 2024, we shifted to prioritize held-for-sale loan originations in our mortgage operations. Consumer mortgage originations will ceaseceased during the second quarter of 2025, which has and will continue to result in a gradual run-off of our remaining consumer mortgage loan portfolio.

Dealer Financial Services, which includes our Automotive Finance and Insurance operations, and Corporate Finance are our primary business lines. The remaining activity is reported in Corporate and Other, which primarily consists of centralized treasury activities (including deposit operations) as well as Ally Invest, our digital brokerage and personal advice offering, Ally Lending, Ally Credit Card, the management of our consumer mortgage portfolio, CRA loans and investments, and certain strategic investments.investments through Ally Ventures. Consumer mortgage originations will ceaseceased during the second quarter of 2025, which has and will continue to result in a gradual run-off of our remaining consumer mortgage loan portfolio. Additionally, we entered into a definitive agreement to divest our credit card business, the transaction is expected to close during the second quarter of 2025. During the first quarter of 2024, weWe closed the salesales of Ally Lending.Credit ForCard furtheron information,April refer1, 2025, and Ally Lending on March 1, 2024. Refer to Note 2 and Note 31 to the Consolidated Financial Statements.Statements for additional information on Ally Credit Card. The following table summarizes the operating results excluding discontinued operations of each business line. Operating results for each of the business lines are more fully described in the MD&A sections that follow.

Ally Financial Inc. (together with its consolidated subsidiaries unless the context otherwise requires, Ally, the Company, we, us, or our) is a financial-services company withthat includes the nation’s largest all-digital bank and an industry-leading automotive financingfinance and insurance business,businesses, driven by a mission to “Do It Right” and be a relentless ally for all stakeholders. The Company servesits customers withand depositscommunities. Ally Bank, Member FDIC, offers online banking products, including savings and securitieschecking brokerageaccounts. Ally also provides investing solutions through Ally Invest, including online brokerage, automated investing, IRAs and investmentpersonal advisoryfinancial servicesadvice. asAlly wellprovides as automotive financingconsumer and insurancedealer offerings.financing, Theinsurance, Companyand alsovehicle includesremarketing aservices. seasonedAlly’s corporate finance business that offersprovides capital forto equity sponsors and middle-market companies. Ally is a Delaware corporation and is registered as a BHC under the BHC Act and an FHC under the GLB Act.

Our Automotive Finance operations include purchasing retail installment sales contracts and operating leases from dealers and automotive retailers, extending automotive loans directly to consumers, offering term loans to dealers, financing dealer floorplans and providing other lines of credit to dealers, offering automotive-fleet financing, providing financing to companies and municipalities for the purchase or lease of vehicles, and supplying vehicle-remarketing services. Our success as an automotive finance provider is driven by the consistent presence and breadth of products and services we offer to dealers and automotive retailers. The automotive marketplace continues to evolve, including varying levels of investment in electric vehicle technologies by automotive manufacturers and suppliers. We continue to identify and cultivate relationships with automotive retailers, including those with leading e-commerce platforms, and we also operate an online direct lending platform for consumers seeking direct financing. We believe these products enable us to respond to the ongoing trends toward more streamlined and digital automotive financing processes that serve both dealers and consumers. Additionally, we provide comprehensive automotive remarketing services, including the use of SmartAuction, our online auction platform, which efficiently supports dealer-to-dealer and other commercial wholesale vehicle transactions. SmartAuction provides diversified fee-based revenue and serves as a means of deepening relationships with our dealership customers. Beyond offering a full suite of solutions for our dealership customers, we also offer application pass-through programs for credit applications that do not meet our underwriting criteria, allowing dealers to provide expanded access to credit for consumers and improve sales at their dealership. Through our pass-through programs, we are able to monetize our declined applications by generating a combination of acquisition fee and servicing revenue for loans that are originated, sold to, and serviced on behalf of third-party lenders, or one-time acquisition fees for loans funded and serviced by a third party. Our strong and expansive dealer relationships, comprehensive suite of products and services, full spectrum financing, and depth of experience position us to adapt as vehicle technologies and consumer preferences evolve. We have provided and continue to provide automobile financing for battery electric and, to a lesser extent, plug-in hybrid vehicles, including brands such as Tesla, Jeep, Alfa Romeo, and Chevrolet. While we expect most of these vehicles to continue to be sold through dealerships and automotive retailers with whom we have established relationships, we also partner with automotive manufacturers that use a direct-to-consumer model. During the threesix months ended MarchJune 31,30, 2026, $509$1.6 millionbillion of our consumer automotive retail loan originations and purchases, and $63$69 million of our operating lease originations and purchases, were for battery-electric and plug-in hybrid vehicles. As of MarchJune 31,30, 2026, $3.3$3.9 billion of our consumer automotive finance receivables and loans had battery-electric or plug-in hybrid vehicles as the underlying collateral, and $4.0$3.8 billion of our investment in operating leases, net of accumulated depreciation, were battery-electric or plug-in hybrid vehicles.

Our dealer-centric business model, value-added products and services, full-spectrum financing, and business expertise proven over many credit cycles, make us a premier automotive finance and insurance company ready to support and strengthen over 21,40021,600 active dealer relationships as of MarchJune 31,30, 2026. A dealer is considered to have an active relationship with us if we provided automotive financing, remarketing, or insurance services during the three months ended MarchJune 31,30, 2026.

•Our Corporate Finance operations primarily offer senior-secured loans to private equity sponsor-owned U.S.-based middle-market companies and to well-established asset managers that mostly provide leveraged loans. The portfolio is composed of floating-rate leveraged asset-based and cash flow/enterprise value loans. Our Corporate Finance operations had $13.8$13.9 billion of assets at MarchJune 31,30, 2026, and generated $148$293 million of total net revenue during the threesix months ended MarchJune 31,30, 2026, and continues to offer attractive returns and diversification benefits to our broader lending portfolio. Our Sponsor Finance business focuses on companies owned by private-equity sponsors with loans typically used for leveraged buyouts, refinancing and recapitalizations, mergers and acquisitions, growth, co-lending arrangements, turnarounds, and debtor-in-possession financings. Additionally, our Private Credit Finance business provides asset managers and other financing sources with facilities to partially fund their direct-lending activities. We have a commercial real estate product primarily focused on lending to skilled nursing facilities, senior housing, and medical office buildings. Additionally, we have an energy and infrastructure vertical that finances large-scale energy and infrastructure projects.

We employ an internal team of economists to enhance our planning and forecasting capabilities. This team conducts industry and market research, monitors economic risks, and helps support various forms of scenario planning and stress testing. This group closely monitors macroeconomic trends, such as unemployment rate and sales of new light motor vehicles, given the nature of our business and the potential impact on us given our exposure to these trends. As of MarchJune 31,30, 2026, the unemployment rate decreased to 4.3%.4.2%. Sales of new light motor vehicles fellrose to an average annual rate of 15.616.3 million during the firstsecond quarter of 2026. Sales of new light motor vehicles remained below the pre-pandemic annual pace of 17.0 million in 2019, which has limited incoming used vehicle supply and supported used vehicle values.

Our baseline forecast utilized in calculating the quantitative allowance for loan losses as of MarchJune 31,30, 2026, anticipated the unemployment rate peaking at approximately 4.6%4.5% in the secondthird quarter of 2026, before reverting to the historical mean of approximately 5.7% by the firstsecond quarter of 2029. Additionally, our baseline forecast anticipated GDP growth slowingincreasing to 2.0%2.2% as measured on a quarter-over-quarter seasonally adjusted annualized rate basis in 2026 and 2027, before reverting to the historical mean of approximately 2.2%2.1% by the firstsecond quarter of 2029, and increases in new light vehicle sales on a seasonally adjusted annualized rate basis peaking at more than 16 million units in the fourththird quarter of 2026,2027, before reverting to the historical mean of 15 million units by the firstsecond quarter of 2029. We also maintain a qualitative allowance framework to account for ongoing risks and volatility in the macroeconomic environment, including the impacts from tariffs, inflation, which includes the effects of elevated energy prices, consumer financial health, and geopolitical conflict and related uncertainty, that could adversely impact frequency of loss and LGD. Refer to the Risk Management section of this MD&A for further discussion on our allowance for loan losses.

Risks related to geopolitical developments, including the ongoing conflicts in the Middle East, could disrupt global supply chains, energy markets, and financial markets, and could adversely impact economic conditions. For example, rising gasoline prices could suppress demand for vehicles which could reduce used vehicle values. Sustained increasedincreases in oil and gasoline prices could contribute to broader inflationary pressures, weaken discretionary spending, and adversely affect employment and income in certain sectors, further pressuring household budgets, and credit performance.

We earned net income from continuing operations of $319$410 million and $729 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to a$352 lossmillion ofand $225$127 million for the three months and six months ended MarchJune 31,30, 2025. The increase for the three months ended MarchJune 31,30, 2026, was primarily driven by higher net financing revenue and other interest income and higher total other revenue, partially offset by higher total noninterest expense and higher provision expense. The increase for the six months ended June 30, 2026, was primarily driven by higher total other revenue, higher net financing revenue and other interest income and lower total noninterest expense, and lower total interest expense. The increase was partially offset by higher provision for credit losses.expense.

Net financing revenue and other interest income increased $111$168 million and $279 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to the three months and six months ended MarchJune 31,30, 2025. The increaseincreases waswere primarily driven by higher total financing revenue and other interest income as a result of higher average earning assets. Additionally, the increases were driven by lower total interest expense in response to lower benchmark interest rates, which decreased our cost of funds associated with our deposit liabilities. The increase for the six months ended June 30, 2026, was partially offset by the sale of Ally Credit Card, which closed on April 1, 2025.

Insurance premiums and service revenue earned was $360$368 million and $728 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $364$359 million and $723 million for the three months and six months ended MarchJune 31,30, 2025. The decreaseincreases for the three months and six months ended MarchJune 31,30, 2026, waswere primarily due to lowerhigher P&C and VSC volume. The decrease was partially offset by growth of GAP andGAP, other ancillary F&I products.products and P&C volume. The increases were partially offset by lower VSC volume.

Other lossgain on investments, net, was $21$76 million and $55 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $499a gain of $61 million and a loss of $438 million for the three months and six months ended MarchJune 31,30, 2025. The decrease in lossincrease for the three months ended MarchJune 31,30, 2026, was primarily due to favorable performance from equity securities. The increase for the six months ended June 30, 2026, was primarily attributable to a balance sheet repositioning of a portion of our available-for-sale securities during the threesix months ended MarchJune 31,30, 2025.

Other income, net of losses decreasedincreased $20$16 million for the three months ended MarchJune 31,30, 2026, and decreased $4 million for the six months ended June 30, 2026, compared to the three months and six months ended MarchJune 31,30, 2025. The increase for the three months ended June 30, 2026, was primarily driven by increased service fee income. The decrease for the six months ended June 30, 2026, was primarily driven by lower late charges and other administrative fees as a result of the sale of Ally Credit Card,Card whichand closedunfavorable onperformance Aprilfrom 1,equity-method 2025.investments. The decrease was partially offset by increased service fee income.

The provision for credit losses increased $276$46 million and $322 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to the three months and six months ended MarchJune 31,30, 2025. The increase in provision for credit losses for the three months ended June 30, 2026, was primarily driven by portfolio growth within our consumer automotive portfolio, partially offset by lower net charge-offs within our consumer automotive portfolio. The increase in provision for credit losses for the six months ended June 30, 2026, was primarily driven by a provision benefit within our consumer other portfolio associated with the transfersale of Ally Credit Card to held-for-sale that occurred during the threesix months ended MarchJune 31,30, 2025,2025. and anThe increase in portfolioprovision growthfor withincredit ourlosses consumer automotive portfolio duringfor the threesix months ended MarchJune 31,30, 2026. The increase2026, was partially offset by lower net charge-offs within our consumer other portfolio as a result of the sale of Ally Credit Card and lower net charge-offs within our consumer automotive portfolio. Refer to the Risk Management section of this MD&A for further discussion on our provision for credit losses.

We recognized total income tax expense from continuing operations of $81$127 million and $208 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to an income tax benefitexpense of $59$84 million and $25 million for the threesame monthsperiods ended March 31,in 2025. The increase in income tax expense for the three months ended MarchJune 31,30, 2026, was primarily attributable to the tax effects of an increase in pretax earnings, and an income tax benefit from the revaluation of our deferred tax assets and liabilities of a California tax law enacted during the second quarter of 2025. The increase for the six months ended June 30, 2026, was primarily attributable to the tax effects of an increase in pretax earnings, as well as the tax effects of a loss on investments recognized as a result of our balance sheet repositioning of a portion of our available-for-sale securities during the threesix months ended MarchJune 31,30, 2025.

(a)Includes net remarketing losses of $10$2 million and $19$12 million for the three months and six months ended MarchJune 31,30, 2026, andrespectively, 2025,compared respectively.to net remarketing losses of $19 million for the six months ended June 30, 2025.

Our Automotive Finance operations earned income from continuing operations before income tax expense of $336$410 million and $746 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $375$472 million and $847 million for the three months and six months ended MarchJune 31,30, 2025. The decreasedecreases for the three months and six months ended MarchJune 31,30, 2026, waswere primarily due to higher interest expense, higher provision for credit losses, and higher total noninterest expense, andwhich higher provision for credit losses. The decrease waswere partially offset by higher total financing revenue and other interest income.

Consumer automotive loan financing revenue and other interest income increased $82$95 million and $177 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to the three months and six months ended MarchJune 31,30, 2025. The increaseincreases waswere primarily driven by higher average consumer assets resulting from origination growthgrowth, andas well as higher portfolio yieldsyields, asreflecting higherthe yieldingreplacement of maturing lower-yielding assets with higher-yielding originations replace maturity of lower yielding assets resulting fromfollowing pricing actions duedesigned to our deliberate focus on maximizingmaximize risk-adjusted returns across our credit tiers.

Commercial loan financing revenue and other interest income decreasedincreased $9$25 million and $16 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to the three months and six months ended MarchJune 31,30, 2025. The decreaseincreases waswere primarily due to lower yield driven by lower benchmark interest rates, as our commercial automotive loans are generally variable-rate. The decrease was partially offset by higher average outstanding commercial balances.

Interest expense increased $63$85 million and $148 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to the same periods in 2025. The increases for the three months and six months ended MarchJune 31,30, 2025.2026, The increase waswere primarily driven by higher asset balances and higher funding costscosts, as a result of a gradual shift in the composition of our consumer portfolios continued to shift towards the loans and leases originated duringin a higher interest rate environment.

Total net operating lease revenue increaseddecreased $13$15 million and $2 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to the threesame monthsperiods ended March 31,in 2025. The increasedecreases in net operating lease revenue waswere driven by higher averagedepreciation expense which was partially offset by an increase in operating lease assetsincome, as compared to the same periods in 2025. Depreciation expense increased by $53 million and lower$81 netmillion remarketingfor losses.the three months and six months ended June 30, 2026, respectively. We recognized net remarketing losses of $10$2 million and $12 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to net remarketing losses of $19 million for the threesix months ended MarchJune 31,30, 2025. The decrease in remarketing losses for the threesix months ended MarchJune 31,30, 2026, was primarily driven by lower termination volume and slightly improved remarketing performance. In the near term, our ability to optimize remarketing gains may be limited due to used vehicle market pressures on certain plug-in hybrid vehicles following the elimination of federal electric-vehicle tax credits for both new and used vehicles, vehicle recalls, and increased OEM marketing incentives on new vehicles. Additionally,In future periods, the volatility of remarketing gains and losses may decline as a result of the shift in our operating lease portfolio mix has shifted towards contracts with a residual value guarantee,guarantees. andAdditionally, towardsas awe morehave diversediversified the mix of OEMs forwithin our operating lease portfolio, we may also see less volatility associated with those contracts without a residual value guarantee, which may reduce volatility in remarketing gains and losses in future years.guarantees. Refer to the Operating Lease Residual Risk Management section of this MD&A for further discussion.

The provision for credit losses increased $34$55 million and $89 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to the three months and six months ended MarchJune 31,30, 2025. The increaseincreases waswere primarily driven by portfolio growth within our consumer automotive portfolio, partially offset by lower net charge-offs within our consumer automotive portfolio.net-charge-offs. Refer to the Risk Management section of this MD&A for further discussion on our provision for credit losses.

Total noninterest expense increased $38$36 million and $74 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to the threesame monthsperiods ended March 31,in 2025. The increaseincreases waswere primarily due to higher direct and allocated expenses related to the growth of the business.

(c)Excludes the effects of derivative financial instruments designated as hedges, which is included within Corporate and Other. Including the impact of hedging activities, the yield was 9.28%9.25% and 9.20%9.27% for the three months and six months ended MarchJune 31,30, 2026, respectively, and 2025,9.26% respectively.and 9.23% for the three months and six months ended June 30, 2025.

(d)Excludes the effects of derivative financial instruments designated as hedges, which is included within Corporate and Other. Including the impact of hedging activities, the yield was 5.70%5.55% and 6.50%,5.62% for the three months and six months ended MarchJune 31,30, 2026, respectively, and 2025,6.41% respectively.and 6.45% for the three months and six months ended June 30, 2025.

(f)Yield includes net losses on the sale of off-lease vehicles of $10$2 million and $19$12 million for the three months and six months ended MarchJune 31,30, 2026, respectively, and 2025,net respectively.losses of $19 million for the six months ended June 30, 2025. Excluding these losses and gains on sale, the yield was 6.19%5.69% and 6.66%5.94% for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to 6.86% and 2025,6.76% respectively.for the three months and six months ended June 30, 2025.

OurDuring the three months and six months ended June 30, 2026, our portfolio yield for consumer automotive loans excluding the impact of hedging activitiesactivities, increased 165 and 10 basis pointspoints, respectively, as compared to the same periods in 2025. The increases for the three months endedand March 31, 2026, compared to the threesix months ended MarchJune 31,30, 2025.2026, The increase waswere primarily driven by a shift in portfolio mix as higher yielding originations replace the maturity of lower yielding assets resulting from pricing actions due to our deliberate focus on maximizing risk-adjusted returns across our credit tiers. OurWe portfolio yield for consumer automotive loans including the effects of derivative financial instruments designated as hedges was 2 basis points higher than our portfolio yield for consumer automotive loans excluding the effects of derivative financial instruments designated as hedges for the three months ended March 31, 2026. This is attributable to the execution ofutilize hedging strategies thatin are usedorder to mitigate interest rate risks.risks, Thethe effects of derivative financial instruments designated as hedges are included within Corporate and Other. Refer to Note 18 to the Condensed Consolidated Financial Statements for further discussion.

OurDuring the three months and six months ended June 30, 2026, our portfolio yield for commercial wholesale floorplan loansloans, excluding the impact of hedging activities decreased 84100 and 92 basis pointspoints, forrespectively, the three months ended March 31, 2026,as compared to the threesame monthsperiods ended March 31,in 2025. The decreasedecreases waswere primarily due to lower benchmark interest rates, as our commercial automotive loans are generally variable-rate.

Our portfolio yield for investment in operating leases, net, including gains and losses on the sale of off-lease vehicles, increaseddecreased 4127 and 62 basis points to 5.61% and 5.67% for the three months and six months ended MarchJune 31,30, 2026, respectively, as compared to the6.88% threeand months ended March 31, 2025. The increase was due to lower net remarketing losses, which decreased $9 million6.29% for the three months endedand March 31, 2026, compared to the threesix months ended MarchJune 31,30, 2025. The decreases were primarily due to higher depreciation expense. In the near term, our ability to optimize remarketing gains may be limited due to used vehicle market pressures on certain plug-in hybrid vehicles following the elimination of federal electric-vehicle tax credits for both new and used vehicles, vehicle recalls, and increased OEM marketing incentives on new vehicles. Additionally,In future periods, the volatility of remarketing gains and losses may decline as a result of the shift in our operating lease portfolio mix has shifted towards contracts with a residual value guarantee,guarantees. andAdditionally, towardsas awe morehave diversediversified the mix of OEMs forwithin our operating lease portfolio, we may also see less volatility associated with those contracts without a residual value guarantee, which may reduce volatility in remarketing gains and losses in future years.guarantees. Refer to the Operating Lease Residual Risk Management section of this MD&A for further discussion.

Retail loan originations with a term of 76 months or more represented 22%24% and 23% of total retail loan originations for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to 23% for both the three months and six months ended MarchJune 31,30, 2025. Substantially all the loans originated with a term of 76 months or more during both the three months and six months ended MarchJune 31,30, 2026, and 2025, were considered to be prime and in credit tiers S, A, or B. Our underwriting processes are designed to consider various deal structure variables—such as payment-to-income, LTV, debt-to-income, and FICO® score—that compensate for longer loan terms and mitigate underwritinglayered risk.

During the three months ended MarchJune 31,30, 2026, approximately 81%82% of our used retail loan originations were for vehicles with a model year of 2020 or newer. According to the Bureau of Transportation Statistics, the average age of light vehicles in operation in the United States during 2025 was approximately 13 years. Substantially all used retail loan originations with a term of 76 months or more during the three months ended MarchJune 31,30, 2026, were for vehicles with a model year of 2020 or newer.

(a)Includes CSG originations of $1.2 billion and $891$915 million for the three months ended MarchJune 31,30, 2026, and 2025, respectively.

Total consumer automotive loan and operating lease originations increased $1.3$2.3 billion and $3.6 billion for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to the threesame monthsperiods ended March 31,in 2025. The increaseincreases waswere primarily driven by strategic partnerships, strong dealer engagement, and growth in application volume from our dealer network.

The following tabletables presentspresent the percentage of retail loan and operating lease originations and purchases, in dollars, by FICO® Score and product type. We define prime consumer automotive loans primarily as those loans with a FICO® Score at origination of 620 or greater.

Originations with a FICO® Score of less than 620 (considered nonprime) represented 12%11% of total consumer loan and operating lease originations for both the three months and six months ended MarchJune 31,30, 2026, compared to 9% and 8% for the three months and six months ended MarchJune 31,30, 2025, respectively, reflecting our strategy to focus on maximizing risk-adjusted returns across our credit tiers. Consumer loans and operating leases with FICO® Scores of less than 540 represented 2% of total originations for each of the three months and six months ended MarchJune 31,30, 2026, respectively, as compared to 1% for each the three months and six months ended MarchJune 31,30, 2025. Nonprime applications are subject to more stringent underwriting criteria (for example, maximum payment-to-income ratio, maximum debt-to-income ratio, and maximum amount financed), and our nonprime loan portfolio generally does not include any loans with a term of 76 months or more. The carrying value of our held-for-investment, nonprime consumer automotive loans before allowance for loan losses was $9.1$9.6 billion and $8.6 billion at MarchJune 31,30, 2026, and December 31, 2025, respectively, or approximately 10.5%10.7% and 10.1% of our total consumer automotive loans at MarchJune 31,30, 2026, and December 31, 2025, respectively. For discussion of our credit-risk-management practices and performance, refer to the section below titled Risk Management.

During the fourth quarter of 2025, we amended our agreement with Carvana, a leading e-commerce platform forfocused on buying and selling used vehicles. Specifically, we increased our committed facility by $2.0 billion to a maximum of $6.0 billion to support our continued efforts to optimize risk-adjusted returns. This commitment is effective for 364 days. As part of the agreement, we are committed to purchase finance receivables, related to both new and used vehicles, on a periodic basis within prescribed eligibility requirements and risk appetite, consistent with purchase practices in prior years. All the finance receivables purchased through this channel are included in non-OEM-franchised dealers and automotive retailers in our consumer origination metrics. While different vintages and credit tiers exhibit varying performance, collectively to date, finance receivables purchased from Carvana have generally exhibited consistent delinquency and loss performance compared to loans with similar credit characteristics acquired through our indirect dealer channel. Consumer finance receivables and loans sourced from Carvana represented 11.1%12.1% and 10.4% of our total consumer automotive finance receivables and loans as of MarchJune 31,30, 2026, and December 31, 2025, respectively. Loan purchases from Carvana were 14%16% and 15% of our total consumer automotive financing originations during the three months and six months ended MarchJune 31,30, 2026, respectively, as compared to 7%11% duringand 9% for the threesame monthsperiods ended March 31,in 2025.

Average commercial wholesale financing receivables outstanding increased $142$2.3 millionbillion and $1.2 billion during the three months and six months ended MarchJune 31,30, 2026, respectively, as compared to the threesame monthsperiods ended March 31,in 2025. The increaseincreases waswere primarily due to an increase within the Stellantis dealer channel.

Carvana's commercial line of credit totals $1.5 billion, with a scheduled maturity in the second quarter of 2027. The line of credit represents a commitment to fund Carvana’s wholesale floorplan financing of used vehicles and is consistent in form and structure with our other wholesale floorplan financing arrangements. This includes the line of credit being fully collateralized to mitigate counterparty credit risk in the event of a default. At MarchJune 31,30, 2026, Carvana’s gross wholesale floorplan assets outstanding balance was $79$126 million.

We also provide other forms of commercial financing for the automotive industry including automotive dealer term and revolving loans and automotive fleet financing. Automotive dealer term and revolving loans are loans that we make to dealers to finance other aspects of the dealership business, including acquisitions. These loans are usually secured by real estate or other dealership assets and are typically personally guaranteed by the individual owners of the dealership. Additionally, these loans generally include cross-collateral and cross-default provisions. Automotive fleet financing credit lines may be obtained by dealers, their affiliates, and other independent companies that are used to purchase vehicles, which they lease or rent to others. The average balance of other commercial automotive loans increased $1.1$1.6 billion toand $7.5$1.4 billion for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to the same periods in 2025, to an average $7.9 billion and $7.7 billion for the three months and six months ended MarchJune 31,30, 2025.2026.

(a)Includes interest expense of $13 million and $14$26 million for the three months and six months ended MarchJune 31,30, 2026, respectively, and 2025,$15 respectively.million and $29 million for the three months and six months ended June 30, 2025.

(b)Includes net unrealized lossesgains on equity securities of $59$29 million and net unrealized losses of $30 million for the three months and six months ended June 30, 2026, respectively, and net unrealized gains of $30 million and $15 million for the three months and six months ended MarchJune 31,30, 2026, and 2025, respectively.2025.

Our Insurance operations earned income from continuing operations before income tax expense of $28$53 million and $81 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $2$28 million and $30 million for the three months and six months ended MarchJune 31,30, 2025. The increaseincreases for the three months ended MarchJune 31,30, 2026, was primarily driven by higher other gain on investments, net. The increase for the six months ended June 30, 2026, was primarily driven by lower insurance losses and loss adjustment expenses and higher interest and dividends on investment securities, cash and cash equivalents, and other earning assets, net. The increase was partially offset by higher other loss on investments, net.

Insurance premiums and service revenue earned was $360$368 million and $728 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $364$359 million and $723 million for the three months and six months ended MarchJune 31,30, 2025. The decreaseincreases for the three months and six months ended MarchJune 31,30, 2026, waswere primarily due to lowerhigher P&C and VSC volume. The decrease was partially offset by growth of GAP andGAP, other ancillary F&I products.products and P&C volume. The increases were partially offset by lower VSC volume.

Other lossgain on investments, net was $21$76 million and $55 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $4$59 million and $55 million for the three months and six months ended MarchJune 31,30, 2025. This included realized gains of $38$47 million and $85 million during the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $11$29 million and $40 million for the three months and six months ended MarchJune 31,30, 2025. The increase for the three months ended MarchJune 31,30, 2026, was driven by nethigher unrealizedrealized lossesgains on equity securities of $59 million for the three months ended March 31, 2026, compared to net unrealized losses on equity securities of $15 million during the three months ended March 31, 2025. The increase for the three months ended March 31, 2026, was primarily due to equity securities performance in line with the broader market.securities.

Insurance losses and loss adjustment expenses totaled $121$208 million and $329 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $161$203 million and $364 million for the three months and six months ended MarchJune 31,30, 2025. The decreaseincrease for the three months ended MarchJune 31,30, 2026, was primarily due to higher weather-related losses. The decrease for the six months ended June 30, 2026, was primarily due to lower weatherweather-related losses. Weather-related loss and loss adjustment expenses from our vehicle inventory insurance business were $16$99 million and $115 million during the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $58$91 million and $149 million during the three months and six months ended MarchJune 31,30, 2025. We utilized our excess of loss reinsurance and ceded weather-related losses on our vehicle inventory insurance business during the first quarter of 2025, as losses exceeded the retention limit, helping to partially mitigate the impact of weather-related losses, primarily due to severe hailstorms. In April 2026, we renewed our annual excess of loss reinsurance agreement and continue to utilize this coverage for our vehicle inventory insurance to manage our risk of weather-related losses, under which retention limits vary for each quarter.

Our combined ratio was 96.2%116.6% and 106.4% for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to 106.5%117.1% and 111.8% for the three months and six months ended MarchJune 31,30, 2025. The decrease for the three months ended MarchJune 31,30, 2026, was primarily driven by higher P&C earned premiums. The decrease for the six months ended June 30, 2026, was primarily driven by lower weatherweather-related losses.losses, as well as higher F&I earned premiums.

(c)Primarily includes non-automotive assumed reinsurance and revenue associated with performing services as an underwriting carrier. Written premiums were impacted by the return of previously written business to the primary carrier, resulting in a temporary reduction in reported premiums for the three months and six months ended June 30, 2026.

Insurance premiums and service revenue written increasedwas $4$382 million and $771 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $349 million and $734 million the three months and six months ended MarchJune 31,30, 2025. The increaseincreases wasfor the three months and six months ended June 30, 2026, were primarily due to growth in our P&C, GAP and other ancillary F&I products. The increaseincreases waswere partially offset by lower VSC volume.

In addition to these cash and investment securities, the Insurance segment has interest-bearing intercompany arrangements with Corporate and Other, callable on demand. The intercompany loan balance due to Insurance was $854$814 million and $807 million at MarchJune 31,30, 2026, and December 31, 2025, respectively, and related interest income of $6$5 million and $5$11 million was recognized for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $4 million and 2025,$9 respectively.million for the three months and six months ended June 30, 2025.

Our Corporate Finance operations earned income from continuing operations before income tax expense of $94$122 million and $216 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $76$96 million and $172 million for the three months and six months ended MarchJune 31,30, 2025. The increaseincreases for the three months and six months ended MarchJune 31,30, 2026, waswere primarily due to higher net financing revenue and other interest income, higher total other revenue, and lower provision for credit losses.

Net financing revenue and other interest income was $113$116 million and $229 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to $104$108 million and $212 million for the three months and six months ended MarchJune 31,30, 2025. The increaseincreases for the three months and six months ended MarchJune 31,30, 2026, waswere primarily due to higher interest and fees on finance receivables and loans, driven by portfolio growth, partially offset by higher interest expense.

Other revenue increased $6$10 million and $16 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to the three months and six months ended MarchJune 31,30, 2025. The increaseincreases waswere primarily driven by higher realized gains on nonmarketable equity investments and higher syndication income.

The provision for credit losses decreased $6$10 million and $16 million for the three months and six months ended MarchJune 31,30, 2026, respectively, compared to the three months and six months ended MarchJune 31,30, 2025. The decreasedecreases waswere primarily driven by lower portfoliospecific growthreserves, including the favorable resolution of one exposure in our legacy health care cash flow vertical during the three months and six months ended June 30, 2026. This resolution resulted in a partial charge-off and release of the remaining related specific reserve, reducing provision expense. The decrease for the six months ended June 30, 2026, was also driven by lower reserve activitybuild as comparedrelated to theslower sameasset period in 2025.growth. Refer to the Risk Management section of this MD&A for further discussion on our provision for credit losses.