What Changed
Risk factors · Mar 7, 2025 → Mar 6, 202650 added · 4 removed between the two most recent 10-Ks. The risks a company starts — or stops — disclosing are often the story.
Newly disclosed
- The financial services industry is also experiencing a rapid increase in the frequency and sophistication of fraudulent attacks, driven by the proliferation of AI-powered tools, deepfake technology, and organized, transnational crime rings.
- Rapid innovation in financial technology - including stablecoins and other digital assets, distributed ledger technologies, real‑time payment networks, embedded banking, and artificial intelligence - may change how consumers and businesses store value, make payments, access credit, and obtain financial services.
- The regulatory landscape for AI in banking is still developing, and new regulations or guidance could require us to modify or discontinue certain uses of AI, incur significant compliance costs, or face enforcement actions.
- The use of AI in lending decisions is subject to increasing regulatory scrutiny, particularly with respect to fair lending requirements under the Equal Credit Opportunity Act and the Fair Housing Act.
- As AI technology continues to evolve rapidly, there is significant uncertainty regarding future regulatory requirements and industry standards applicable to the use of AI by financial institutions.
- Additionally, we face competitive pressures from fintech companies and other financial institutions that may be able to deploy AI technologies more aggressively or effectively than we can.
- In 2023, the failures of Silicon Valley Bank and Signature Bank highlighted the risks associated with high concentrations of uninsured deposits, as rapid deposit withdrawals contributed to those institutions' failures.
- An adverse outcome in certain overdraft fee litigation that has been brought against the bank could have a material adverse effect on our results of operations.
- Recent public settlements in overdraft-related litigation include payments by multiple institutions, reflecting the potential exposure in this area.
- As of December 31, 2025, our loans secured by commercial real estate (CRE) totaled approximately $1.055 billion representing approximately 24.7% of our total loan portfolio.
- Regulators may challenge the use of AI models that produce results that are based upon potential bias, even if such impacts are unintentional.
- Errors or failures in AI systems could result in operational disruptions, financial losses, reputational harm, or regulatory sanctions.
No longer disclosed
- Although we have programs in place related to business continuity, disaster recovery and information security to maintain the confidentiality, integrity, and availability of our systems, business applications and customer information, such disruptions may give rise to interruptions in service to customers and loss or liability to us.
- Various federal and/or state laws and regulations limit the amount of dividends that the bank may pay to the parent company. 13 Any future strategic acquisitions or divestitures may present additional risks to our business and operations.
- We are subject to liquidity risk in our operations, which could adversely impact our ability to fund various obligations.
- We have credit risk in our securities portfolio.