Ally Financial : Quarter ended March 31, 2026

Published: 2026-05-14 12:16:15 ET ALLY

Published on 05/14/2026 at 12:16 pm EDT

Ally Financial Inc.

Basel III Public Disclosures

As of and for the three months ended March 31, 2026

Road Map

Ally Financial Inc. • Basel III Public Disclosures

The SEC filings of Ally Financial Inc. contain information relevant to the disclosure requirements set forth under U.S. Basel III. The following is a mapping of the disclosure topics addressed within this regulatory disclosure report to the Ally Financial Inc. Quarterly Report on Form 10-Q for the three months ended March 31, 2026, and the Annual Report on Form 10-K for the year ended December 31, 2025.

Basel III Report

Q1 2026 Form 10-Q

2025 Form 10-K

Disclosure Requirement

Page(s)

Introduction

4-5

12, 42-43, 44-45, 62

6, 10-11, 12, 38, 120,

173-174, 175

Scope of Application

Basis of Consolidation

120

Restrictions on Capital

42-43

7-10, 173-174

Subsidiary Minimum Capital Requirement

6-7

Capital Surplus of Insurance Subsidiaries

Capital Structure

Capital Components

7, 9, 40, 61, 103

99, 115, 117, 167,

169-170

Term and Conditions of Capital Instruments

8-9

40, 45, 102

98, 167, 169-170, 176

Capital Adequacy

Capital Adequacy Assessment Process

10-11

175

Risk-Weighted Assets

103

Capital Ratios

44, 103

99, 175

Capital Conservation Buffer

44, 45

175, 176

Credit Risk

Policies, Procedures, and Practices

86-87

72-73, 122-126

Credit Risk Exposures - Counterparty, Domicile, and Maturity

86-94

72-83

Past-Due Loans

22, 23, 26

123, 145, 146, 149

Allowance for Loan Losses

143

Counterparty Credit Risk

Methodology

178-179

Counterparty Credit Risk

38, 47, 57-58

178-179, 192-193

Credit Derivatives

178

Credit Risk Mitigation

Policies, Procedures, and Practices

73-74

Eligible Financial Collateral, Guarantees, and Credit Derivatives

Securitization

Policies, Procedures, and Practices

17-18

126-127, 159-160

Securitization Exposures and Activity

33-35, 100-101

95-96, 159-162

Synthetic Securitizations

45, 47, 102-103

94, 96, 98, 176, 178

Purchased Securitizations and Resecuritizations

18-19

Equities Not Subject to the Market-Risk Rule

Policies, Procedures, and Practices

121-122, 127

Carrying Value and Fair Value by Exposure

Publicly Traded

Unrealized and Realized Gains and Losses

17, 19

139, 141

Interest Rate Risk for Non-Trading Activities

Policies, Procedures, and Practices

21-22

94-95

84-85

Net Financing Revenue Sensitivity

21-22

95-96

85-86

Index of Defined Terms

Ally Financial Inc. • Basel III Public Disclosures

Term

Definition

ALCO

Asset-Liability Committee

Basel Committee

Basel Committee on Banking Supervision

BHC

Bank holding company

BHC Act

Bank Holding Company Act of 1956, as amended

Board

Board of Directors

CECL

Accounting Standards Update 2016-13 (and related Accounting Standards Updates), or current expected credit loss

CFPB

Consumer Financial Protection Bureau

CRA

Community Reinvestment Act of 1977, as amended

CVA

Credit valuation adjustment

Dodd-Frank Act

Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, as amended

DTA

Deferred tax asset

ERM

Enterprise Risk Management

EVE

Economic value of equity

FDI Act

Federal Deposit Insurance Act, as amended

FDIC

Federal Deposit Insurance Corporation

FDICIA

Federal Deposit Insurance Corporation Improvement Act of 1991, as amended

FHC

Financial holding company

FHLB

Federal Home Loan Bank

FRB

Federal Reserve Bank, or Board of Governors of the Federal Reserve System, as the context requires

GAP

Guaranteed asset protection

GDP

Gross domestic product of the United States of America

GLB Act

Gramm-Leach-Bliley Act of 1999, as amended

HTC

Historic tax credit

IB Finance

IB Finance Holding Company, LLC

LIHTC

Low-income housing tax credit

LTV

Loan-to-value

MD&A

Management's Discussion and Analysis of Financial Condition and Results of Operations

NMTC

New market tax credit

OTC

Over-the-counter

PCA

Prompt corrective action

Risk Committee of the Ally Board of Directors

RWA

Risk-weighted asset

SEC

U.S. Securities and Exchange Commission

SPE

Special-purpose entity

SSFA

Simplified Supervisory Formula Approach

STSA

Enterprise Stress Testing and Scenario Analysis

U.S. Basel III

The rules implementing the 2010 Basel III capital framework in the United States as well as related provisions of the Dodd-Frank Act, as amended from time to time

U.S. GAAP

Accounting Principles Generally Accepted in the United States of America

UDFI

Utah Department of Financial Institutions

VIE

Variable interest entity

VSC

Vehicle service contract

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 all 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.

As a BHC, Ally is subject to regulation, supervision and examination by the FRB. Ally must also comply with regulatory risk-based and leverage capital requirements, as well as various safety and soundness standards imposed by the FRB, and is subject to certain statutory restrictions concerning the types of assets or securities it may own and the activities in which it may engage. Ally Bank, our banking subsidiary, is a member of the Federal Reserve System and is subject to regulation, supervision and examination by the FRB, and as a Utah chartered bank, by the UDFI.

In July 2013, the U.S. banking agencies finalized rules implementing the 2010 Basel III capital framework in the United States as well as related provisions of the Dodd-Frank Act, which represented substantial revisions to the prior regulatory capital standards for U.S. banking organizations. These rules have been amended by the U.S. banking agencies from time to time and, collectively with such amendments, are referred to herein as U.S. Basel III. As described below, U.S. Basel III requires qualitative and quantitative disclosures regarding a banking institution's regulatory capital, risk exposures, risk-management practices, and capital adequacy. This report also includes information on the methodologies used to calculate RWAs. The disclosure requirement applies to banking organizations with total consolidated assets of

$50 billion or more that are not a consolidated subsidiary of a BHC that is subject to these disclosure requirements. This report is designed to satisfy these requirements and should be read in conjunction with our Annual Report on Form 10-K for the year ended December 31, 2025, our Quarterly Report on Form 10-Q for the three months ended March 31, 2026, and our Consolidated Financial Statements for Holding Companies - FR Y-9C for March 31, 2026. The disclosures included in this report are not required to be and have not been audited by our independent auditors.

From time to time we have made, and in the future will make, forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. These statements can be identified by the fact that they do not relate strictly to historical or current facts.

Forward-looking statements often use words such as "believe," "expect," "anticipate," "intend," "pursue," "seek," "continue," "estimate," "project," "outlook," "forecast," "potential," "target," "objective," "trend," "plan," "goal," "initiative," "priorities," or other words of comparable meaning or future-tense or conditional verbs such as "may," "will," "should," "would," or "could." Forward-looking statements convey our expectations, intentions, or forecasts about future events, circumstances, or results. All forward-looking statements, by their nature, are subject to assumptions, risks, and uncertainties, which may change over time and many of which are beyond our control. You should not rely on any forward-looking statement as a prediction or guarantee about the future and should consider all risks and uncertainties discussed in this report and those under Item 1A, Risk Factors in our Annual Report on Form 10-K for the year ended December 31, 2025. Actual future objectives, strategies, plans, prospects, performance, conditions, or results may differ materially from those set forth in any forward-looking statement. Any forward-looking statement made by us or on our behalf speaks only as of the date that it was made. We do not undertake to update any forward-looking statement to reflect the impact of events, circumstances, or results that arise after the date that the statement was made, except as required by applicable securities laws. You, however, should consult further disclosures (including disclosures of a forward-looking nature) that we may make in any subsequent SEC filings.

Unless the context otherwise requires, references herein to our income statement mean the Consolidated Statement of Income included in the Consolidated Financial Statements in our Annual Report on Form 10-K for the year ended December 31, 2025, or the Condensed Consolidated Statement of Comprehensive Income included in the Condensed Consolidated Financial Statements in our Quarterly Report on Form 10-Q for the three months ended March 31, 2026, as applicable. Unless the context otherwise requires, references herein to our balance sheet mean the Consolidated Balance Sheet included in the Consolidated Financial Statements in our Annual Report on Form 10-K for the year ended December 31, 2025, or the Condensed Consolidated Balance Sheet included in the Condensed Consolidated Financial Statements in our Quarterly Report on Form 10-Q for the three months ended March 31, 2026, as applicable.

Our accounting and reporting policies conform to U.S. GAAP. Additionally, where applicable, the policies conform to the accounting and reporting guidelines prescribed by bank regulatory authorities.

Refer to Note 1 to the Consolidated Financial Statements in our Annual Report on Form 10-K for the year ended December 31, 2025, for further information on our basis of presentation and consolidation. There are no significant differences in the basis of consolidation between our Annual Report on Form 10-K for the year ended December 31, 2025, our Quarterly Report on Form 10-Q for the three months ended March 31, 2026, and this report.

The FRB and other U.S. banking agencies have adopted risk-based and leverage capital rules that establish minimum capital-to-asset ratios for BHCs, like Ally, and depository institutions, like Ally Bank.

The risk-based capital ratios are based on a banking organization's RWAs, which are generally determined under the standardized approach applicable to Ally and Ally Bank by (1) assigning on-balance-sheet exposures to broad risk-weight categories according to the counterparty or, if relevant, the guarantor or collateral (with higher risk weights assigned to categories of exposures perceived as representing greater risk), and (2) multiplying off-balance-sheet exposures by specified credit conversion factors to calculate credit equivalent amounts and assigning those credit equivalent amounts to the relevant risk-weight categories. The leverage ratio, in contrast, is based on an institution's average unweighted on-balance-sheet exposures.

Under U.S. Basel III, Ally and Ally Bank must maintain a minimum Common Equity Tier 1 risk-based capital ratio of 4.5%, a minimum Tier 1 risk-based capital ratio of 6%, and a minimum total risk-based capital ratio of 8%. On top of the minimum risk-based capital ratios, Ally and Ally Bank are subject to a capital conservation buffer requirement, which must be satisfied entirely with capital that qualifies as Common Equity Tier 1 capital. Failure to maintain more than the full amount of the capital conservation buffer requirement would result in automatic restrictions on the ability of Ally and Ally Bank to make capital distributions, including dividend payments and share repurchases and redemptions, and to pay discretionary bonuses to executive officers. U.S. Basel III also subjects Ally and Ally Bank to a minimum Tier 1 leverage ratio of 4%.

The well-capitalized standard for insured depository institutions, such as Ally Bank, reflects the capital requirements under U.S. Basel

III.

Ally and Ally Bank are currently subject to the U.S. Basel III standardized approach for credit risk but not to the U.S. Basel III advanced

approaches for credit risk or operational risk. Ally is also not currently subject to the U.S. market-risk capital rule, which applies only to banking organizations with significant trading assets and liabilities.

Under U.S. Basel III, Category I and II firms calculate their risk-weighted assets under two different methodologies-the standardized approach, and the advanced approaches that rely on internal models. These firms are generally bound to the more stringent of the two calculations. Category III and IV firms, and other banking organizations subject to risk-based capital standards apply only the standardized approach under U.S. Basel III. In March 2026, the U.S. banking agencies issued two proposed rules to customize and implement revisions to the global Basel III capital framework that were approved by the Basel Committee in December 2017.

The first proposed rule would replace this dual-stack framework for Category I and II firms with a single, new risk-weighted assets calculation referred to as the expanded risk-based approach. The advanced approaches would be removed from the regulatory capital framework. The standardized approach, as modified by the second proposed rule, would continue to apply to all other firms that are subject to risk-based capital standards. Banking organizations of any size, however, would have the option to elect to use the expanded risk-based approach instead of the revised standardized approach. Relative to the current dual-stack framework, the expanded risk-based approach is a standardized framework intended to promote simplicity, risk sensitivity, transparency, and consistency across the firms to which it would apply. Risk-weighted assets would be assigned to address credit risk, equity risk, operational risk, market risk, and CVA risk. Notably, operational risk capital requirements would be based on a new standardized calculation that would replace the current models-based approach. The proposal would also introduce a new framework for market risk and adjust the thresholds used to determine which firms-in addition to those in Category I and II-are subject to the market risk and CVA risk capital requirements.

The second proposed rule would make targeted revisions within the standardized approach currently used by Category III and IV firms, and other banking organizations subject to risk-based capital standards. These revisions are intended to improve the calibration and risk sensitivity for certain exposure categories. The proposal would require Category III and IV firms to recognize in regulatory capital most elements of accumulated other comprehensive income and loss. This change would be phased in over a period of five years. For firms subject to the standardized approach that do not elect to use the expanded risk-based approach, the proposal would also reduce the risk weight applicable to all assets not specifically assigned a different risk weight under the capital rule (such as consumer automotive loans and leases) from 100 percent to 90 percent, as well as reduce the risk weight applicable to corporate exposures from 100 percent to 95 percent.

Residential mortgage exposures would generally be risk weighted using an LTV-based methodology under the proposal. While these risk weights are generally more punitive than those assigned to similar exposure categories under the proposed expanded risk-based approach, the standardized approach would not separately assign risk-weighted assets to address operational risk. The supervisory formula used to assign risk weights for securitization exposures would be adjusted to align with that of the proposed expanded risk-based approach with an output floor that is reduced from 20 percent to 15 percent.

Both proposals would modify the definition of regulatory capital by removing the threshold-based deduction of mortgage servicing assets, and all firms that use the expanded risk-based approach would be required to apply the more stringent threshold test to determine any capital deduction for certain DTAs and investments in the capital instruments of unconsolidated financial institutions. These proposals were issued without effective dates but generally assume transition periods that begin January 1, 2027, and have comment periods that expire June 18, 2026. As proposed, the phase-in of accumulated other comprehensive income and loss would be expected to significantly affect our levels of regulatory capital. The impact of lower capital levels would be partially offset by the recalibration of risk weights proposed in the

expanded risk-based approach or revised standardized approach. Whether and when final rules related to these proposals may be adopted and take effect, as well as what changes to the proposed rules may be reflected in any final rules after public comments are considered, remain unclear.

U.S. Basel III applies to Ally Financial Inc.

-for example, in the event that Ally or IB Finance would not meet minimum regulatory capital ratios after giving effect to the distributions. FRB supervisory guidance also directs BHCs like us to consult with the FRB prior to increasing dividends, implementing common share repurchase programs, or redeeming or repurchasing capital instruments. Further, the U.S. banking agencies are authorized to prohibit an insured depository institution, like Ally Bank, or a BHC, like Ally, from engaging in unsafe or unsound banking practices and, depending upon the circumstances, could find that paying a dividend or other capital distribution would constitute an unsafe or unsound banking practice.

These laws include an attribution rule that treats a transaction between Ally Bank and a nonaffiliate as a transaction between Ally Bank and an affiliate to the extent that the proceeds of the transaction are used for the benefit of or transferred to the affiliate.

Ally and IB Finance are BHCs under the BHC Act, and Ally has elected to be an FHC under the GLB Act. IB Finance is a direct subsidiary of Ally and the direct parent of Ally Bank, which is a commercial bank that is organized under the laws of the State of Utah and whose deposits are insured by the FDIC under the FDI Act. As BHCs, Ally and IB Finance are subject to regulation, supervision, and examination by the FRB. Ally Bank is a member of the Federal Reserve System and is subject to regulation, supervision, and examination by

the FRB, the UDFI, the FDIC, and the CFPB. Ally Bank is required to file periodic reports with regulators concerning its financial condition. Total assets of Ally Bank were $185.7 billion at March 31, 2026, based on its Call Report filing. Ally Bank's deposits are insured by the FDIC.

The risk-based capital ratios and the Tier 1 leverage ratio play a central role in PCA, which is an enforcement framework used by the

U.S. banking agencies to constrain the activities of depository institutions based on their levels of regulatory capital. Five categories have been established using thresholds for the Common Equity Tier 1 risk-based capital ratio, the Tier 1 risk-based capital ratio, the total risk-based capital ratio, and the Tier 1 leverage ratio: well capitalized, adequately capitalized, undercapitalized, significantly undercapitalized, and critically undercapitalized. FDICIA generally prohibits a depository institution from making any capital distribution, including any payment of a cash dividend or a management fee to its BHC, if the depository institution would become undercapitalized after the distribution. An undercapitalized institution is also subject to growth limitations and must submit and fulfill a capital restoration plan. Although BHCs are not subject to the PCA framework, the FRB is empowered to compel a BHC to take measures-such as the execution of financial or performance guarantees-when PCA is required in connection with one of its depository-institution subsidiaries. At March 31, 2026, Ally Bank met the capital ratios required to be well capitalized under the PCA framework.

At March 31, 2026, Ally and Ally Bank were in compliance with their regulatory capital requirements. For additional discussion of capital adequacy requirements, refer to Note 17 to the Condensed Consolidated Financial Statements in our Quarterly Report on Form 10-Q for the three months ended March 31, 2026.

Some of our insurance operations-including in the United States, Canada, and Bermuda-are subject to certain minimum aggregate capital requirements, net asset and dividend restrictions, and rules and regulations promulgated by various U.S. and foreign regulatory agencies. Under state and foreign insurance laws, dividend distributions may be made only from statutory unassigned surplus with approvals required from applicable regulatory authorities for dividends in excess of statutory limitations. Our insurance operations are also subject to applicable state and foreign laws generally governing insurance companies, as well as laws addressing products that are not regulated as insurance, such as VSCs and GAP waivers.

Because Ally Bank is an insured depository institution and Ally and IB Finance are BHCs, direct or indirect control of us-whether through the ownership of voting securities, influence over management or policies, or other means-is subject to approvals, conditions, and other restrictions under federal and state laws. Refer to the section above titled Bank Holding Company, Financial Holding Company, and Depository Institution Status for additional information. These laws may differ in their purposes, definitions and presumptions of control, and restrictions, which for example is the case as between the BHC Act and the Change in Bank Control Act. Investors are responsible for ensuring that they do not, directly or indirectly, acquire control of us in contravention of these laws.

Surplus of Insurance Subsidiaries and Subsidiary Regulatory Capital

At March 31, 2026, Ally did not have any subsidiaries whose regulatory capital was less than the minimum required regulatory capital amount.

At March 31, 2026, the aggregate capital surplus of insurance subsidiaries was $1.2 billion.

The following table presents Ally Financial Inc.'s capital components under U.S. Basel III at March 31, 2026.

($ in millions)

March 31, 2026

Common Equity Tier 1 capital

Common stock and related surplus

$ 15,231

Retained earnings

827

Accumulated other comprehensive loss

(2,773)

Adjustments and deductions made to Common Equity Tier 1 capital

2,410

Total Common Equity Tier 1 capital

15,695

Other Tier 1 capital

Additional Tier 1 capital elements

2,324

Adjustments and deductions made to Tier 1 capital

(85)

Total Tier 1 capital

17,934

Tier 2 capital

Tier 2 capital elements

984

Includable allowance for loan and lease losses

1,960

Adjustments and deductions made to Tier 2 capital

(85)

Total Tier 2 capital

2,859

Total capital (a)

$ 20,793

(a) For more information, refer to Schedule HC-R of our FR Y-9C for March 31, 2026.

Ally has issued a variety of capital instruments to meet its regulatory capital requirements and to maintain a strong capital base. The terms and conditions of Ally's significant capital instruments are described as follows.

$0.01 par value; shares authorized 1,100,000,000; issued 522,896,204; and outstanding 307,407,671.

The following table summarizes information about our Series B and Series C preferred stock.

March 31, 2026

Series B preferred stock (a) (b)

Issuance date

April 22, 2021

Carrying value ($ in millions)

$ 1,335

Par value (per share)

$ 0.01

Liquidation preference (per share)

$ 1,000

Number of shares authorized

1,350,000

Number of shares issued and outstanding

1,350,000

Dividend/coupon

Prior to May 15, 2026

4.700%

On and after May 15, 2026

Five Year Treasury

+ 3.868%

Series C preferred stock (a)

Issuance date

June 2, 2021

Carrying value ($ in millions)

$ 989

Par value (per share)

$ 0.01

Liquidation preference (per share)

$ 1,000

Number of shares authorized

1,000,000

Number of shares issued and outstanding

1,000,000

Dividend/coupon

Prior to May 15, 2028

4.700%

On and after May 15, 2028

Seven Year Treasury

+ 3.481%

We may, at our option, redeem the Series B and Series C shares on any dividend payment date on or after May 15, 2026, or May 15, 2028, respectively, or at any time within 90 days following a regulatory event that precludes the instruments from being included in additional Tier 1 capital.

On May 4, 2026, we announced our intent to redeem all of our issued and outstanding 4.700% Fixed-Rate Reset Non-Cumulative Perpetual Preferred Stock, Series B on May 15, 2026. Refer to Note 24 to the Condensed Consolidated Financial Statements in our Quarterly Report on Form 10-Q for the three months ended March 31, 2026, for additional information about this planned redemption and our issuance of additional preferred stock to partially replace this element of our capital structure.

The following table presents details about our outstanding subordinated debt instruments that were issued with an original term to maturity of five years or greater and included as Tier 2 capital.

March 31, 2026 ($ in millions)

Carrying value

Qualifying amount in Tier 2 capital

6.700% Subordinated Notes due 2033

$ 488

6.646% Fixed-Rate Reset Subordinated Notes due 2040 (a)

496

Total subordinated debt

$ 984

Coupon rate resets on January 17, 2035, at a rate based on the five-year U.S. Treasury yield plus 2.450%, and we have the option to redeem these notes during the 90-day period ending on the reset date.

Ally has a capital-management framework that adheres to the FRB's capital plan rule for an effective capital adequacy process, as well as broader FRB risk management and capital management related supervisory guidance.

Capital adequacy assessment and management is conducted at both the enterprise and at Ally Bank and frameworks have been established at both levels. Governance and oversight for each level is provided by the respective Boards, committees, and management structures.

The primary goals of Ally's ERM framework are to ensure that the outcomes of Ally's risk-taking activities are consistent with Ally's risk appetite and strategies, and that there is an appropriate balance between risk taking and reward, without jeopardizing targeted capital and liquidity levels.

Ally's risk-management framework is applied on an enterprise-wide basis and includes the following key components: Governance & Organization, Strategy & Risk Appetite, and Risk Management Processes, including Risk Identification and Measurement, Risk Mitigation and Control, and Risk Monitoring and Reporting.

The ERM framework also establishes guidance for maintaining a strong risk-management culture throughout Ally. Ally's risk culture is grounded in a top-down risk-governance structure, originating with the RC, and implemented through other Board and management committees down through business-line committees, councils, members of enterprise management teams, and business-line management teams. Equally important is the bottom-up and cross business identification, assessment, and management of risks to provide information and reporting to senior management to appropriately manage and control risk exposures within Ally's established risk appetite.

To effectively manage and monitor the risks of Ally, the ERM framework also defines multiple layers of defense that clarify the general roles and responsibilities of the business-line risk owners, independent risk-management function, and internal audit function. This "multiple layers of defense" approach directly supports the balance between risk and return to protect Ally's target capital and liquidity levels. Each layer has specific responsibilities with respect to the effectiveness of Ally's governance, risk management, and internal controls.

Risk appetite is also integral to ERM. It guides decisions on the types and amount of risk Ally is willing to accept in executing on its strategic priorities and business objectives. Ally uses a combination of risk appetite statements and measures to provide the basis for risk reporting to Ally management and the Boards. In order to assess capital adequacy, risk appetite includes processes to compare current and projected capital levels (from baseline forecasting and stress testing) to regulatory well-capitalized minimums as well as internal targets and minimums. In addition, the ERM framework highlights specific processes for appropriate governance, oversight, and accountability for risk appetite.

Ally's risk-appetite metrics are monitored by the ERM function and reported to the ERM Committee and the RC. Detailed risk-appetite metrics are also reported throughout the organization to various management committees.

The objectives of the capital-planning process are to maintain capital levels that are commensurate with Ally's risk profiles, maintain capital above the minimum regulatory capital ratios and internal minimums, and continue to serve as a source of strength for Ally's depository institution, Ally Bank. In addition, we will continue to maintain capital levels that enable us to meet our obligations to creditors and counterparties and remain a viable finance intermediary during stressful conditions.

The capital-adequacy process provides a comprehensive structure to manage capital adequacy across the entire organization. The process documents key processes related to assessing the adequacy of Ally's capital and planning for short-term and long-term capital needs. It also incorporates related efforts inclusive of stress testing, material risk identification, risk appetite, modeling, and corporate governance.

The capital-adequacy process is designed to be a central integration point for decision-making processes internal to the organization. Outputs from the capital-adequacy process are used to inform and improve risk appetite and related risk guardrails, as well as initiate capital discussions and potential capital decisions based on established triggers (such as internal capital targets, internal goals/minimums, and regulatory minimums).

Ally's enterprise-wide stress-testing process measures risks throughout the organization, reflecting a required or internally driven set of economic scenarios, and ultimately influences Ally's risk-management and capital-planning practices.

Ally conducts various stress tests each year including severe stresses of macroeconomic conditions and idiosyncratic stresses that are more specific to Ally. The results of each stress test are integrated into our capital adequacy assessment and decision-making.

Ally has established a centrally coordinated enterprise stress-testing process, with close engagement of senior management and the Boards throughout the process. Ally's STSA team is a dedicated team within the independent risk-management function that develops and facilitates stress tests based on an established set of methodologies and appropriately tailored assumptions across Ally and its subsidiaries. A

Disclaimer

Ally Financial Inc. published this content on May 14, 2026, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on May 14, 2026 at 16:15 UTC.