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RECENT ACCOUNTING PRONOUNCEMENTS (Policies)
 3 Months Ended
Mar. 31, 2026
Accounting Policies [Abstract]  
Basis of Accounting .
Investments where we possess significant influence over the investee's operating and financial policies are accounted for using the equity method. All intercompany accounts and transactions have been eliminated during consolidation. Assets held in an agency or fiduciary capacity are excluded from the consolidated financial statements.
These financial statements have been prepared in accordance with accounting principles generally accepted (“GAAP”) in the United States (“U.S.”) and prevailing practices within the financial services industry for interim financial information, and in conformity with the instructions to Form 10-Q and Article 10 of Regulation S-X. Accordingly, they do not include all of the information and footnotes required by GAAP for complete financial statements. In the opinion of management, all normal and recurring adjustments considered necessary for a fair presentation of the interim financial statements have been included. References to GAAP, including standards issued by the Financial Accounting Standards Board, are cited based on the applicable accounting guidance.
Subsequent Events We evaluated events occurring between March 31, 2026 and the date of issuance of the accompanying financial statements. Based on this evaluation, we concluded that no material events occurred that would require adjustments to the consolidated financial statements.
Change in Accounting Policy, Derivatives
We enter into International Swaps and Derivatives Association, Inc. master netting arrangements, or similar agreements, with certain derivative counterparties. Where legally enforceable, these arrangements provide the right to liquidate collateral and offset amounts due with the same counterparty in the event of default. Under applicable accounting guidance, derivative fair values and the related rights to reclaim cash collateral (receivables) or
obligations to return cash collateral (payables) may be presented on a net basis when subject to such master netting arrangements.
Historically, derivative assets and liabilities, as well as related cash collateral, were presented on a gross basis. Effective in the first quarter of 2026, we elected to change our accounting policy to present derivative assets, derivative liabilities, and related cash collateral on a net basis on the consolidated balance sheet when supported by a legally enforceable master netting arrangement. This change is considered a preferable method of accounting because it more appropriately reflects how we manage counterparty credit exposure and aligns with industry practice.
Recent Accounting Pronouncements and Developments
Standard
Description
Effective date
Effect on the financial statements or other significant matters
Standards not yet adopted by the Bank as of March 31, 2026
ASU 2024-03,
Income Statement—Reporting Comprehensive Income—Expense Disaggregation Disclosures (Subtopic 220-40)
This accounting standards update (“ASU”) requires additional disclosures of certain costs and expenses in both interim and annual reporting periods, including:
•Amounts of employee compensation, depreciation, and intangible asset amortization included in certain expense lines presented on the face of the income statement within continuing operations.
•A qualitative description of the amounts remaining in relevant expense captions that are not separately disaggregated quantitatively.
Annual periods beginning January 1, 2027; Interim periods beginning January 1, 2028.The overall effect of this standard is not expected to have a material impact on our consolidated financial statements.
ASU 2025-06, Intangibles—Goodwill and Other—Internal-Use Software
(Subtopic 350-40)
This ASU modernizes the accounting treatment for internal-use software to better reflect current development practices, including agile and iterative approaches. Key provisions include:
•Elimination of Prescriptive Project Stages: The guidance no longer requires classification of costs by development phase, thereby removing rigid stage-based criteria.
•Capitalization Criteria: Capitalization of eligible software development costs commences once management has both authorized and committed to funding the project, and it is probable that the project will be completed, and requires consideration of development uncertainties.
Annual and interim periods beginning after December 15, 2027.The overall effect of this standard is not expected to have a material impact on our consolidated financial statements.
ASU 2025-08, Financial Instruments—Credit Losses (Topic 326): Purchased Loans
This ASU broadens the population of financial assets subject to the gross-up method under Topic 326 to include all purchased seasoned loans (excluding credit cards), which are defined as:
•Non-purchase credit deteriorated (“PCD”) loans acquired in a business combination.
•Non-PCD loans acquired in an asset acquisition more than 90 days after their origination date.
Annual and interim periods beginning after December 15, 2026.The overall effect of this standard is not expected to have a material impact on our consolidated financial statements.
ASU 2025-09, Derivatives and Hedging (Topic 815)—Hedge Accounting Improvements
This ASU introduces targeted improvements to accounting standards codification (“ASC”) Topic 815 to better align hedge accounting with common risk management strategies. The updates address multiple items, including the following:
•Similar risk assessment for cash flow hedges.
•Hedging interest payments on choose-your-rate debt.
•Net written options as hedging instruments.
Annual and interim periods beginning after December 15, 2026.The overall effect of this standard is not expected to have a material impact on our consolidated financial statements.
Standards adopted by the Bank during the first quarter of 2026
There were no accounting standards adopted during the three months ended March 31, 2026 that had a material effect on our consolidated financial statements.
Allowance for Credit Losses
Allowance for Credit Losses
The allowance for credit losses (“ACL”), which consists of the allowance for loan and lease losses (“ALLL”) and the reserve for unfunded lending commitments (“RULC”), represents our estimate of current expected credit losses related to the loan and lease portfolio and unfunded lending commitments as of the balance sheet date. For additional information regarding our policies and methodologies used to estimate the ACL, see Note 6 of our 2025 Form 10-K.
The ACL on AFS and HTM debt securities is estimated separately from the ACL on loans. For HTM debt securities, the ACL is evaluated using the same methodology applied to loans and leases measured at amortized cost. For more information regarding our methodology used to estimate the ACL on AFS and HTM debt securities, see Note 5 of our 2025 Form 10-K.