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The Bank of New York Mellon

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FY2018 Annual Report · The Bank of New York Mellon
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BNYB
Mellon
Annual
Report

BNY Mellon
Annual Report
2018

While we are focused on driving change,  
we do this with a keen eye towards preserving 
much of the great culture of our company.

CHARLIE SCHARF

Chairman and Chief Executive Officer

II     BNY Mellon

Companies must constantly  
think about how they must  
change and evolve or they risk 
both short-term performance  
and long-term sustainability. 

This is especially true for large companies as smaller, more nimble 
competitors target their margins and innovate more rapidly. At BNY Mellon, 
we are challenging ourselves to evolve so as to both maximize our short– and 
medium–term performance and create a path for long–term continued success. 

Our rich history of success over more than two centuries is a distinct 
advantage. While we are focused on driving change, we do this with a keen 
eye towards preserving much of the great culture of our company. Though 
we are proud of who we are and how we serve our clients, we also believe 
we can deliver more for our clients, shareholders and employees by setting 
higher standards of performance and pushing ourselves to create new and 
differentiated solutions for our clients.

Our evolution will take time, but we have confidence that we will build  
on our success. 

2018 Annual Report     III

2018 Financial
Performance

Our financial results for 2018 have a number of 
complicating factors, but I will do my best to explain 
them. On a reported basis, our earnings per share 
increased 9%. These results included several notable 
items in both 2018 and 2017 that make our results  
difficult to compare.

In last year’s letter, I discussed why we break these items out. To 
reiterate, our goal is to provide you with the necessary detail to analyze 
our performance. We try and explain our results as well as provide 
transparency on items that we believe do not fully represent the future 
earnings power of the company. As I said last year, we are going through a 
period of transition, and I am encouraging our leaders to take actions that 
will add cost in the short term but will benefit us in the long term. As such, 
I do not believe all items in our GAAP results represent the future earnings 
profile of our company, but ultimately, our disclosures will allow you to 
make your own judgment.  

Excluding notable items in 2017 and 2018, earnings per share increased 18%1. 
Approximately seven percentage points of this increase was due to benefits 

TOTAL OPERATING REVENUE ($MM)1

+3% 2018  |  $16,405

2017  |  $15,863

1For a reconciliation of these non–GAAP measures, see page XXIII.

IV     BNY Mellon

$4.04

2018

$3.72

2017

+9%

EARNINGS PER SHARE 
ON REPORTED BASIS  

$4.21

2018

+18%

$3.57

2017

OPERATING EARNINGS
PER SHARE1

EXCLUDES  
NOTABLE ITEMS

from changes in U.S. tax laws. Our overall revenue grew 3% as Investment 
Services revenue growth of 6% was partially offset by lower Investment 
Management growth of 2%. Our expenses grew 2%. We increased what we 
spend on technology by approximately $350 million while reducing all other 
expenses to partially offset the increase. Importantly, we continued to return  
a significant amount of capital to our shareholders. 

Our financial performance and franchise growth were relatively consistent 
with that of prior years, but we are reorienting our expense base toward 
technology. We have an opportunity to leverage our unique global franchise 
and great client relationships and ultimately increase the rate of revenue and 
profit growth, while also maintaining continued strong returns. 

2%

TOTAL OPERATING EXPENSE ($MM)1

2018  |  $10,868 

2017  |  $10,648

34%

2018 OPERATING  
PRE-TAX MARGIN1

2018 Annual Report     V

ME

X INCO

PRE–TA
+9%

UES
REVEN
+6%

EXPENSES

+5%

I N V E S T M E N T   S E RV I C E S   P E R F O R M A N C E 2 

Our Investment Services revenue increased 6%, expenses were up 5% and  
pre–tax income increased 9%. Our pre–tax margin was 36%, up from 35%  
in the prior year.

Our Clearance and Collateral Management and Depositary Receipts businesses 
both achieved double–digit revenue growth, while Asset Servicing and 
Corporate Trust saw mid–single–digit revenue growth. Pershing and Treasury 
Services had revenue growth in the low- to mid–single–digit range.   

Assets under custody and/or administration decreased by 1% as the negative 
impact of market declines and the stronger U.S. dollar were partially offset  
by new business.

ME

X INCO

PRE–TA
+10%

I N V E S T M E N T   M A NAG E M E N T   P E R F O R M A N C E 2

Investment Management’s financial performance reflected a difficult 
environment for the industry. Revenues increased 2%, expenses were down 
1% and pre–tax income increased 10%. Pre–tax margin was 35% for the year, 
up from 33% in 2017. Strength in our liability–driven investment (LDI) business 
was offset by weakness in our traditional active and passive strategies. 

Our assets under management declined by 9%, impacted by lower equity 
markets and outflows, particularly in our active strategies. Changes in  
foreign exchange rates and declines in market values drove approximately 
60% of the decline and outflows of $84 billion from cash, index and our  
active strategies were partially offset by $45 billion of inflows into liability–
driven strategies.

Revenues in our Wealth Management business increased 2% for the year, 
driven primarily by the impact of higher equity markets throughout the year. 

2Results on an operating basis.

UES
REVEN
+2%

EXPENSES

(1%)

VI     BNY Mellon

Our Business

Our business purpose is clear. We help markets function smoothly, we  
help investors access a broad range of banking and investment products,  
and we are viewed as one of the safest institutions that helps facilitate 
investing globally. 

Our business model is strong. We provide the expertise and scale others 
cannot achieve on their own as we process and manage cash and securities 
on our clients’ behalf. In addition, we provide value-added services to 
enhance our core capabilities. We are amongst the best in the world at 
what we do and we benefit from our clients’ growth and the growth of 
the financial markets themselves. We are positioned to benefit from the 
increasing opportunity in the wealth management space through our own 
direct relationships as well as from being a core technology and solutions 
provider to intermediaries through our Pershing platform. We have the 
opportunity to leverage this platform to create even stronger results.

F O C U S   O N   O RG A N I C   G ROW T H

While we are fortunate that our business benefits 
from rising interest rates and from strong and growing 
financial markets, we remain focused on driving growth 
based on our actions. 

Across our businesses, we are separating out those external factors to identify 
how much of our growth is organic, meaning driven by our actions and 
decisions. That discipline is forcing a different level of conversation inside 
the company about what we are doing to grow the business. As I will discuss, 
some businesses are ahead of others in this evolution.

We have seen organic growth in several of our businesses that either have 
differentiated capabilities or in which we have been investing for a number  
of years. The following graphic outlines this growth.

Businesses 
      seeing
organic 
  growth:

In CLE A R A NCE A N D COLL ATER A L M A NAGEMENT, our 
unique position as the sole provider of U.S. government clearing 
coupled with over $3 trillion of tri–party collateral management 
balances allows us to help clients optimize their funding needs in 
ways that others cannot. 

In our M A R K ETS business, we have been investing in our Foreign 
Exchange platform and expanding the scope of our product offering. 
While our focus is primarily on serving clients who we do business with 
elsewhere in the company, our updated platform and product lineup  
has enabled us to capture a greater share of our clients’ business. 

DEFINITION: Organic growth is 
the expansion of our business 
independent of external factors 
such as market performance.

Our LDI offering in Asset Management has seen strong growth. We 
have differentiated capabilities and a stellar track record in delivering 
tailored solutions to meet the specific needs of our pension fund and 
insurance clients. 

Our C ASH   
A N D LIQU IDIT Y  
capabilities span the entire 
company and represent  
more than $900 billion of 
client balances.

Other businesses have shown growth, but have been 
heavily reliant on external factors, like rising interest 
rates and financial markets. We aren’t being complacent 
about this and believe we can do more to grow 
organically and are taking action.   

In A SSET SERV ICING, we face continued pricing pressure for our 
traditional custody and administration services. Fortunately, we have 
significant scale benefits that we continue to realize and are making 
investments to provide data management solutions and expand our  
servicing of ETFs and alternative asset classes. These new capabilities  
will allow us to both protect our core and grow in new ways. 

PER SHING is an incredibly unique platform. We love our position as  
the industry leader providing a complete set of technology and processing 
solutions for our clients. While our recent performance has been muted due 
to two large client losses (which we’ve spoken about at length), we see  
a significant opportunity to accelerate organic growth in both the traditional 
broker–dealer channel and in the emerging Registered Investment Advisor 
(RIA) space. In fact, our pipeline of signed new clients in the process of being 
onboarded is the largest in many years. 

Our TR E A SU RY SERV ICE S business has benefited from the rising rate 
environment but underlying franchise growth has been stagnant. We have 
new leadership in place and see significant opportunity for organic growth 
by reorienting the business around our differentiated payments capabilities. 

In W E A LTH M A NAGEMENT, we also have new leadership in place and 
see opportunities to grow our underlying franchise. We are strengthening 
our client–facing teams while building out our banking and investment 
offerings to provide more holistic solutions to our clients. 

2018 Annual Report     IX

We have other businesses that don’t necessarily benefit as much from rising 
markets or are in periods of transition.  

We are a market leader in 
COR POR ATE TRUST. While  
our business had underperformed 
in recent years, the new 
management team’s work in 
repositioning our sales and service 
teams has yielded incremental 
growth in growing asset classes 
like insurance–linked securities 
and collateralized loan obligations 
(CLOs). We feel good about our 
efforts and are capturing additional 
share, which will benefit us when 
issuance volumes are robust. 

In ASSET M A NAGEMEN T,  
our traditional active strategies 
have not been immune to the 
broader industry headwinds.  
We are working on abating recent 
outflows by developing distinctive 
multi–asset capabilities that 
deliver solutions for our clients. 
Our ongoing work in further 
consolidating our business in 
North America into one multi–
asset company, Mellon, is a 
good example of how we are 
repositioning the business. 

As we look forward, our expectations regarding our ability to increase our 
growth rates are not outsized. 

Given the operating leverage in our business, small 
increases in revenue growth rates should drive more 
meaningful increases in our EPS growth.

X     BNY Mellon

Focusing on
Quality & Efficiency

I have said several times that scale is an important driver of our ability to be 
successful. We provide services and solutions for our clients where we can 
gain the benefits of scale that they cannot achieve on their own, or where 
we can create solutions that either they cannot or where the quality of our 
solution is greater than they could create independently. 

This is about us bringing our ability to execute day in and 
day out, building solutions efficiently, improving them 
over time and sharing those benefits with our clients.

Our focus on execution is paramount and is a necessary precursor to 
executing a longer–term strategic vision. Quality and efficiency are linked 
and critical for our success. Creating a more efficient organization will 
improve our quality and our focus on quality will lead us to efficiency. 

A simple example is where we use technology to automate something that 
was previously done by people. Automation removes the possibility for 
human error, and allows us to perform the task on a much timelier basis 
and less expensively. The same is true for simplification of our management 
processes. Removing unnecessary processes reduces our cost and will 
generally lead to better and more timely answers, which allow us to be more 
responsive to our clients.

2018 Annual Report     XI

There are a number of areas where we have made great progress in 
increasing our efficiency:  

• 

In 2018, we cleared and settled ~88 million transactions with the  
Federal Reserve, with 99.8% being fully automated.  

• 

 We settled ~$230 trillion of securities globally with ~97% fully automated. 

• 

 We process, on average, ~$2 trillion of payments each day, with  
94% fully automated. 

•  There are a number of areas where we experienced volume increases  

in 2018 and were able to significantly increase productivity. 

We need to bring this level of efficiency and automation across all our 
other businesses. This focus on execution is paramount and while making 
progress, we still have much more opportunity.

T E C H N O L O GY

All we do is enabled by technology. Our platforms allow us to process cash 
and securities and manage assets and liabilities for others. We can drive a 
more efficient and a more complete product set than we have today and we 
will invest in new platforms and capabilities to do so. We have increased our 
technology spend to accomplish this and will continue to do so. 

In 2018, we increased what we spend on technology from approximately  
$2.4 billion to $2.75 billion. We expect this to be approximately $3.0 billion  
in 2019. Remember, we expect to continue to drive efficiency elsewhere to 
help fund much of this increased investment. 

The increase in spend is directed to hardware and software for our existing 
infrastructure and to building additional capabilities. While we are spending 
more on infrastructure than what I would have hoped, it is not optional. We 
provide key services to our clients and we are obligated to have the strongest 
platforms. Today’s strength helps us earn the right to ask for more business 
as we extend our capabilities. 

~$3.0 B

2019

$2.75 B

2018

$2.4 B

2017

TECHNOLOGY
INVESTMENT

XII     BNY Mellon

We are investing in a new data center, as well as making significant 
investments in new, modern environments in our existing data centers. 
These investments are critical to strengthening our core infrastructure and 
resiliency, which are central to our value proposition. These investments  
will also help us create a more flexible operating platform from which we 
can innovate faster in the future. 

While creating the best operating platform is technology priority number 
one, it is not in lieu of investing in developing capabilities for clients. 

We are making a significant number of investments that 
are intended to differentiate us in the marketplace and 
capitalize on our growth opportunities over time. 
Below are some examples: 

• 

 Consolidating our remaining custody platforms. 

• 

 Improving transparency intra–day into performance for clients. 

•  Upgrading to a best–in–class platform for servicing traditional loan  

and CLO products in Corporate Trust. 

•  Building new capabilities to better support alternative asset managers,  

such as credit managers. 

•  Redesigning our client portal to offer an integrated experience across  
all devices to further penetrate the RIA opportunity in Pershing. 

•  Building a fully integrated Wealth Management platform across 
investments and banking that includes self–service capabilities. 

•  Continuing to extend our capabilities to service wealth managers in  

the UK through Pershing. 

• 

Increasing our investment in ETF servicing infrastructure. 

• 

 Extending LDI capabilities in the U.S.

2018 Annual Report     XIII

Talent & Leadership

It takes many strong leaders to manage a company of our 
size and complexity. I continue to be impressed with the 
subject matter expertise, desire to serve our clients and 
the proud culture within our company. 

We have made significant changes to the leadership team over the past 
couple of years with a goal of ensuring we have the best talent with a healthy 
mix of historical context and fresh thinking. 

We have promoted many from within and we have also hired great talent 
from the outside. Outside hires bring different skills and experiences, and 
help accelerate our evolution. This year we added a series of leaders to 
our executive team who we think will complement our existing leaders. 
These include: Paul Camp (Treasury Services), Catherine Keating (Wealth 
Management), Emily Portney (U.S. Asset Servicing), Roman Regelman 
(Digital) and Akash Shah (Strategy).

In addition, Lester Owens joined us in February to lead Operations 
globally. We have also added numerous leaders in Technology across our 
infrastructure, data and development teams. We expect all of these leaders 
will add meaningfully to our ability to advance our efforts. 

Our focus on talent goes beyond the leadership team. We are doing a series  
of things to ensure we have the best talent at BNY Mellon at all levels.

We are creating more differentiation in our performance ratings, salaries and 
incentive compensation. In addition, we are striving to provide even more 
direct, honest and helpful feedback to our employees. 

I understand there is a debate regarding performance reviews and ratings. 
Some believe an annual process should be replaced with continual feedback. 
I don’t disagree, but that can only be accomplished when an organization 
has a level of maturity in their performance management process that we 

XIV     BNY Mellon

 
currently lack. Therefore, I firmly believe that performance reviews and 
ratings are extremely important tools for us to ensure we provide clear 
feedback in a consistent way to everyone at our company. 

Historically we have not differentiated nearly enough in how we have 
evaluated people. While this makes for an easier conversation with 
employees, we are doing both them and the company a disservice. Candid 
feedback is critical to helping people improve their performance and ratings 
we assign should provide clarity of our conclusion—and then we can work 
towards improving performance. 

STRONG PER FOR MER S SHOU LD BE R EWA R DED more than 
average and underperformers. Salary changes and year–end bonuses should 
both be an incentive to an employee but also recognition of performance.

I would be remiss if I didn’t address the actions behind the severance charge 
we recorded in the fourth quarter of 2018. Asking people to leave the 
company is one of the toughest decisions managers need to make and one  
I wish we did not have to act on. 

Unfortunately, for us to serve all of our stakeholders over the long term,  
we must take these actions. 

As I have said many times in this letter, our clients expect us to create scale 
and pass on many of the benefits to them. If our costs are not competitive, 
we cannot price our products to both win business and benefit BNY Mellon. 
The biggest piece of our cost base is employee salary and benefits and we 
must ensure that we are employing the right number of people to deliver  
our services and build our capabilities for the future. 

Much of what we are doing is eliminating  
management layers and increasing spans of control 
across the company.

2018 Annual Report     XV

Through our planned actions, we reduced two layers throughout the entire 
organization and increased the average span of control—or the number of 
direct reports per manager—by almost 45%. While the associated changes 
result in lower costs, they also help advance our culture by improving 
decision making and accountability, allowing us to move more quickly and 
making sure we have our best people in roles, which allow them to grow 
and contribute more significantly to our growth agenda. Giving people more 
responsibility is a good thing.

D I V E R S I T Y

We believe in the power of diversity. I was taught many years ago that  
most answers are waiting to be found in the facts. That means that work  
must be done ahead of decisions, data must be analyzed and the work  
must be presented clearly and concisely. But to arrive at the right  
decision, you must have the right people around a table reviewing  
the information. 

The “right” people means a diverse group—in every way. 
This means different skills, disciplines and backgrounds. 

This includes race, ethnicity, gender and sexual orientation, as well as 
different skills, disciplines and backgrounds. Without this diversity, you  
will not have the experiences necessary to arrive at the right conclusion. 

We are working to ensure we are advancing diversity from entry levels 
all of the way to our Board of Directors. We are setting goals for ourselves 
regarding representation for diverse groups, we expect our leaders to 
personally be engaged with our employee resource groups and be externally 
visible in advancing our efforts and we are focused on increasing diverse 
representation of our senior leaders. 

B OA R D   O F   D I R E C T O R S

I would like to thank Mark Nordenberg as he retires from our Board after 
serving for more than 20 years. Mark has contributed meaningfully in many 
ways, especially in his role as Chairman of our Corporate Governance and 
Nominating Committee. Importantly, Mark has also represented us in the 
Pittsburgh community, where we employ over 7,000 people. We are grateful 
for Mark’s contributions over so many years.

XVI     BNY Mellon

Capital Allocation

We continue to believe that capital management is one of the most significant 
decisions we make, and we remain committed to continuing to use that 
resource wisely. Our prioritization has not changed. 

Our first priority will always be ensuring that our capital meets or exceeds the 
requirements and expectations of our regulators, rating agencies, clients and 
counterparties. We then compare the returns of investing organically in the 
company, pursuing mergers and acquisitions, further increasing dividends or 
buying back our common stock. 

Ultimately, we will pursue the path of highest return for 
our shareholders. 

In recent years, we have been in a position to consistently return the majority 
of the capital that we generate to shareholders. During 2018, we increased our 
dividend by 17% and repurchased $3.3 billion of common stock. This included 
the repurchase of an additional $830 million of common stock that was 
approved and executed in the fourth quarter. 

+17%

2018 DIVIDENDS

$3.3B

2018 STOCK 
REPURCHASE

100%+

SHAREHOLDER  
PAYOUT RATIO

Longer Term

While our focus on the short and medium term is necessary for us today,  
it is not sufficient. 

We have to think more strategically about where our 
businesses are going and what we need to do to create 
differentiation in a changing world. 

We are at the beginning of mapping out this journey and have a series of 
initiatives underway.

In our A SSET SERV ICING business, we are building out our capabilities  
in higher–growth products, including alternatives and ETFs. We are 
enhancing real–time intraday reporting and providing data analytics to help 
clients better manage their cash, manage risk and increase distribution. 

We are also pursuing ways to simplify and improve the integration of 
activities from portfolio management to accounting to custody for clients.  
We believe that our clients will want choice and flexibility as they seek the 
best solution based on their internal requirements and products. Their 
unique needs require that we provide an open solution that integrates 
with other platforms. We are actively working with external partners and 
advancing our own solutions to increase quality, reduce cost and provide 
more information to our clients to help them drive higher returns. 

In PER SHING, we continue to help our broker–dealer clients create more 
operating leverage by using our scale and platform to lower their costs 
and increase the quality of the products they offer. We are allocating more 
resources to the RIA marketplace as the wealth management business 
shifts towards this model. We are also dedicating more resources to 
other geographies such as the UK, where we think there are meaningful 
opportunities for growth. 

In TR E A SU RY SERV ICE S, we are investing to improve our payments  
capabilities and thinking more strategically about how payments are going  
to evolve in the future. We are also digitizing our core capabilities as our 
clients’ expectations around the way they interact and consume our  
products evolve. 

We are uniquely positioned in our CLE A R A NCE A N D COLL ATER A L 
M A NAGEM ENT business and are investing to add capabilities to extend 
the service to our market participants, help clients optimize their funding 
needs and provide more options for clients. 

The A SSET M A NAGEMEN T industry is going through dramatic change  
as returns have not supported existing fee structures. With pressure on 
performance and fees, we are working to ensure we have top–tier 
performance, investment products and solutions appropriate for today’s 
marketplace, as well as broad distribution capabilities and an efficient 
operating infrastructure. 

We have the industry–leading LI A BILIT Y–DR I V EN SOLU TIONS  
business and it’s growing well. We have strong capabilities in European  
credit and are expanding our CLO, loan and high–yield capabilities. We  
are transforming our U.S. business into Mellon, an integrated, single multi–
asset solutions provider. We are not immune to the market environment 
and expect 2019 to be a difficult year, but we remain focused on creating 
differentiated capabilities. 

Our W E A LTH M A NAGEMENT business is a strong platform for us to 
build from. We are becoming more targeted in our client base, strengthening 
our banking and investment product set, and creating stronger technology 
for both our advisors and clients. 

2018 Annual Report     XIX

At a recent all employee town hall, I was asked what my vision for success 
was for BNY Mellon. 

I responded that we should strive for our clients to think 
of us as a partner they must do business with because we 
are the unquestioned leader in our businesses. 

This is represented by the quality of our work, but more importantly in the 
value we add to them as a partner. When we achieve that, we also become 
the company that the best people in the industry want to work for. We are 
well on our way and I want to thank my more than 50,000 partners around 
the world who work every day to achieve this goal.

Charlie Scharf
Chairman and Chief Executive Officer

XX     BNY Mellon

Financial
Highlights

2018 Annual Report     XXI

Financial Highlights

The Bank of New York Mellon Corporation (and its subsidiaries)

(dollar amounts in millions, except per common share amounts and unless otherwise noted)

2018

2017

Financial Results  

Net income applicable to shareholders of The Bank of New York Mellon Corporation

$

4,266

$

4,090

Preferred stock dividends

           Net income applicable to common shareholders of  
           The Bank of New York Mellon Corporation

Earnings per common share – diluted 

Key Data

Total revenue (a)

Total expense

Fee revenue as a percentage of total revenue

Percentage of non-U.S. total revenue

Assets under custody and/or administration at year end (in trillions) (b)

Assets under management at year end (in billions) (c)

Balance Sheet at December 31

Total assets

Total deposits

Total The Bank of New York Mellon Corporation common shareholders’ equity

Capital Ratios at December 31

Consolidated regulatory capital ratios (d)

Common Equity Tier 1 (“CET1”) ratio

Tier 1 capital ratio

Total (Tier 1 plus Tier 2) capital ratio

Tier 1 leverage ratio

Supplementary leverage ratio (“SLR”) (e)

The Bank of New York Corporation common shareholders’ equity to total assets ratio 

(169)

(175)

$

$

4,097

4.04

$

$

3,915

3.72

$

16,392

$ 15,543

11,211

10,957

78%

37%

78%

36%

$

$

33.1

1,722

$

$

33.3

1,893

$ 362,873

$ 371,758

238,778

37,096

244,322

37,709

10.7%

10.3%

12.8

13.6

6.6

6.0

10.2

12.3

13.0

6.4

5.9

10.1

(a) Includes fee and other revenue, net interest revenue and income from consolidated investment management funds. 
(b) Includes the assets under custody and/or administration of CIBC Mellon Global Securities Services Company, a joint venture.
(c) Excludes securities lending cash management assets and assets managed in the Investment Services business.
(d) For our CET1, Tier 1 capital and Total capital ratios, our effective capital ratios under the U.S. capital rules are the lower of the ratios as calculated under the Standardized and Advanced 
Approaches, which for the periods noted above was the Advanced Approaches.  Beginning Jan. 1, 2018, consolidated regulatory ratios are fully phased-in.  The consolidated regulatory ratios 
for 2017 are presented on an estimated fully phased-in basis.  For additional information on our capital ratios, see “Capital” beginning on page 45.
(e) SLR became a binding measure on Jan. 1, 2018.  For additional information on our SLR, see “Capital” beginning on page 45.

XXII     BNY Mellon

Supplemental Information

Explanation of GAAP and Non-GAAP financial measures

We have included in this Letter to Shareholders certain non-GAAP measures which exclude the notable items  

described below. We believe that these measures provide additional useful information to investors as they align  

with our strategy, are consistent with how management views the business and are used to measure the annual  

performance of our executive officers.

Net Income and EPS Reconciliation                                                                                      
(dollars in millions, except per share amounts)

Results

Diluted 
EPS

Results

Diluted 
EPS

Results

Diluted 
EPS

2018

2017

2018 vs. 2017

Net income applicable to common shareholders of The Bank 
of New York Mellon Corporation – GAAP 

Exclude the impact of notable items: (a)(b)

          Total revenue

          Total noninterest expense

          Provision for income taxes

          Net impact of notable items

Net income applicate to common shareholders of 
The Bank of New York Mellon Corporation, 
excluding notable items – Non-GAAP 

$ 4,097

$ 4.04

$ 3,915 $ 3.72

5%

9%

(13)

343

(188)

(168)

(0.17)

(320)

309

(789)

160

0.15

$ 4,265

$ 4.21

$ 3,755 $ 3.57

14%

18%

(a) 2018 includes adjustments to provisional estimates for U.S. tax legislation and other changes, severance, expenses associated with consolidating real estate and litigation expense, each 
recorded in 4Q18.  Also includes expenses associated with consolidating real estate recorded in 2Q18 and adjustments to provisional estimates for U.S. tax legislation and other changes and 
litigation expense, both recorded in 3Q18.   
(b) 2017 includes the estimated net benefit of U.S. tax legislation, severance, an asset impairment and investment securities losses related to the sale of certain securities, each recorded in 
4Q17, and litigation expense recorded in 2017.   

Total Revenue and Total Noninterest Expense Reconciliation 
(dollars in millions) 

Total revenue – GAAP

Exclude:   Notable items (a)(b)

Total revenue, excluding notable items – Non-GAAP

Total noninterest expense – GAAP

Exclude:  Notable items (a)(b)

2018

$ 16,392

(13)

$ 16,405

$ 11,211

343

2017

$ 15,543

(320)

$ 15,863

$ 10,957

309

Total noninterest expense, excluding notable items – Non-GAAP

$ 10,868

$ 10,648

2018 vs. 
2017

5%

3%

2%

2%

(a) 2018 includes adjustments to provisional estimates for U.S. tax legislation and other changes, severance, expenses associated with consolidating real estate and litigation expense, each 
recorded in 4Q18.  Also includes expenses associated with consolidating real estate recorded in 2Q18 and adjustments to provisional estimates for U.S. tax legislation and other changes 
and litigation expense, both recorded in 3Q18.       
(b) 2017 includes the estimated net benefit of U.S. tax legislation, severance, an asset impairment and investment securities losses related to the sale of certain securities, each recorded in 
4Q17, and litigation expense recorded in 2017.   

2018 Annual Report     XXIII

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Pre-tax Operating Margin Reconciliation (dollars in millions)

Income before taxes – GAAP

Exclude the impact of notable items: (a)(b)

         Total revenue

         Total noninterest expense

Income before taxes, excluding notable items – Non-GAAP

Total revenue – GAAP

Exclude:  Notable items (a)(b)

Total revenue, excluding notable items – Non-GAAP 

Pre-tax operating margin – GAAP (c)

Pre-tax operating margin, excluding notable items – Non-GAAP (c)

2018

$

5,192

(13)

343

$

5,548

$ 16,392

(13)

$ 16,405

2017

$

4,610

(320)

309

$

5,239

$ 15,543

(320)

$ 15,863

2018 vs. 
2017

13%

6%

5%

3%

32%

34%

30%

33%

(a)  2018 includes adjustments to provisional estimates for U.S. tax legislation and other changes, severance, expenses associated with consolidating real estate and litigation expense, 
each recorded in 4Q18.  Also includes expenses associated with consolidating real estate recorded in 2Q18 and adjustments to provisional estimates for U.S. tax legislation and other 
changes and litigation expense, both recorded in 3Q18.   
(b) 2017 includes the estimated net benefit of U.S. tax legislation, severance, an asset impairment and investment securities losses related to the sale of certain securities, each recorded in 
4Q17, and litigation expense recorded in 2017. 
(c) Income before taxes divided by total revenue. 

Investment Services Business Reconciliation  
(dollars in millions)

Total revenue – GAAP

Total noninterest expense – GAAP

Exclude: Notable items (a)(b)

         Total noninterest expense, excluding notable items – Non-GAAP 

Provision for credit losses

Income before income taxes – GAAP

Income before income taxes, excluding notable items – Non-GAAP  

Pre-tax operating margin – GAAP (c)

Pre-tax operating margin, excluding notable items – Non-GAAP (c) 

2018

$ 12,298

$

$

$

8,058

170

7,888

1

4,239

4,409

34%

36%

(a) 2018 includes severance and litigation expense recorded in 4Q18.  Also, includes litigation expense recorded in 3Q18.       
(b) 2017 includes severance, and an asset impairment recorded in 4Q17 and litigation expense recorded in 2017.
(c) Income before taxes divided by total revenue. 

Investment Management Business Reconciliation  
(dollars in millions) 

Total revenue – GAAP

Less: Distribution and servicing expense

          Total revenue, net of distribution and servicing expense

Total noninterest expense – GAAP

Exclude:  Notable items (a)(b)

          Total noninterest expense, excluding notable items – Non-GAAP 

Provision for credit losses

Income before income taxes – GAAP

Income before income taxes, excluding notable items – Non-GAAP  

Pre-tax operating margin - GAAP (c)

Pre-tax operating margin, excluding notable items – Non-GAAP (c) 

(a) 2018 includes severance and litigation expense recorded in 4Q18.    
(b) 2017 includes severance recorded in 4Q17 and litigation expense recorded in 2017.
(c) Income before taxes divided by total revenue. 

XXIV     BNY Mellon

$

$

$

$

$

$

2018

4,084

407

3,677

2,818

28

2,790

3

1,263

1,291

31%

35%

2018 vs. 
2017

6%

4

5%

10%

9%

2018 vs. 
2017

2%

3%

(1)%

(1)%

11%

10%

2017

$ 11,585

7,747

214

$

7,534

(7)

$

$

3,845

4,059

33%

35%

2017

$

3,997

$

$

422

3,575

2,854

35

$

2,819

2

1,141

1,176

$

$

29%

33%

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
THE BANK OF NEW YORK MELLON CORPORATION
2018 Annual Report
Table of Contents 

Financial Summary

Page
2

Financial Statements:

Page

Management’s Discussion and Analysis of Financial

Condition and Results of Operations:
Results of Operations:

General
Overview
Key 2018 events
Summary of financial highlights
Fee and other revenue
Net interest revenue
Noninterest expense
Income taxes
Review of businesses
International operations
Critical accounting estimates
Consolidated balance sheet review
Liquidity and dividends
Commitments and obligations
Off-balance sheet arrangements
Capital
Trading activities and risk management
Asset/liability management

Risk Management
Supervision and Regulation
Risk Factors
Recent Accounting Developments
Business Continuity
Supplemental Information (unaudited):

Explanation of GAAP and Non-GAAP financial 

measures (unaudited)

Rate/volume analysis (unaudited)
Selected Quarterly Data (unaudited)
Forward-looking Statements
Acronyms
Glossary

Report of Management on Internal Control Over 

Financial Reporting

Report of Independent Registered Public 

Accounting Firm

4
4
4
5
7
9
12
12
13
21
23
28
39
44
44
45
50
52
54
60
78
103
104

105
107
108
109
111
112

116

117

Consolidated Income Statement
Consolidated Comprehensive Income Statement
Consolidated Balance Sheet
Consolidated Statement of Cash Flows
Consolidated Statement of Changes in Equity

Notes to Consolidated Financial Statements:

Note 1 - Summary of significant accounting and 

reporting policies

Note 2 - Accounting changes and new accounting

guidance

Note 3 - Acquisitions and dispositions
Note 4 - Securities
Note 5 - Loans and asset quality
Note 6 - Goodwill and intangible assets
Note 7 - Other assets
Note 8 - Deposits
Note 9 - Contract revenue
Note 10 - Net interest revenue
Note 11 - Income taxes
Note 12 - Long-term debt
Note 13 - Variable interest entities and securitization
Note 14 - Shareholders’ equity
Note 15 - Other comprehensive income (loss)
Note 16 - Stock-based compensation
Note 17 - Employee benefit plans
Note 18 - Company financial information (Parent

Corporation)

Note 19 - Fair value measurement
Note 20 - Fair value option
Note 21 - Commitments and contingent liabilities
Note 22 - Derivative instruments
Note 23 - Lines of business
Note 24 - International operations
Note 25 - Supplemental information to the
Consolidated Statement of Cash Flows

Report of Independent Registered Public 

Accounting Firm

Directors, Executive Committee and Other 

Executive Officers

119
121
122
123
124

126

136
139
140
145
151
152
153
153
155
155
157
157
158
162
163
164

171
174
183
184
188
195
198

198

199

200

Performance Graph
Corporate Information

201
Inside back cover

 
 
The Bank of New York Mellon Corporation (and its subsidiaries)

Financial Summary

(dollar amounts in millions, except per common share 

amounts and unless otherwise noted)
Selected income statement information:
Fee and other revenue
(Loss) income from consolidated investment management funds
Net interest revenue
Total revenue
Provision for credit losses
Noninterest expense

Income before income taxes

Provision for income taxes

Net income

Net loss (income) attributable to noncontrolling interests (a)

Net income applicable to shareholders of The Bank of New York Mellon

Corporation
Preferred stock dividends

Net income applicable to common shareholders of The Bank of New York Mellon

Corporation

Earnings per share applicable to common shareholders of The Bank of New York

Mellon Corporation:

Basic
Diluted

Average common shares and equivalents outstanding of The Bank of New York 

Mellon Corporation (in thousands):

Basic
Diluted

Selected balance sheet information (at period-end):
Interest-earning assets
Total assets
Deposits
Long-term debt
Preferred stock
Total The Bank of New York Mellon Corporation common shareholders’ equity
At Dec. 31
Assets under custody and/or administration (in trillions) (b)
Assets under management (in billions) (c)
Market value of securities on loan (in billions) (d)
Selected ratios:
Return on common equity
Return on tangible common equity – Non-GAAP (e)
Return on average assets
Pre-tax operating margin
Fee revenue as a percentage of total revenue
Percentage of non-U.S. total revenue
Net interest margin

2018

2017

2016

2015

2014

$

$

12,794
(13)
3,611
16,392
(11)
11,211
5,192
938
4,254
12

4,266

(169)

$

$

12,165
70
3,308
15,543
(24)
10,957
4,610
496
4,114
(24)

4,090

(175)

12,073
26
3,138
15,237
(11)
10,523
4,725
1,177
3,548
(1)

3,547

(122)

$

12,082
86
3,026
15,194
160
10,799
4,235
1,013
3,222
(64)

3,158

(105)

12,649
163
2,880
15,692
(48)
12,177
3,563
912
2,651
(84)

2,567

(73)

$

4,097

$

3,915

$

3,425

$

3,053

$

2,494

$
$

4.06
4.04

$
$

3.74
3.72

$
$

3.16
3.15

$
$

2.73
2.71

$
$

2.17
2.15

1,002,922
1,007,141

1,034,281
1,040,290

1,066,286
1,072,013

1,104,719
1,112,511

1,129,897
1,137,480

$ 308,749
362,873
238,778
29,163
3,542
37,096

$ 316,261
371,758
244,322
27,979
3,542
37,709

$ 280,332
333,469
221,490
24,463
3,542
35,269

$ 338,955
393,780
279,610
21,547
2,552
35,485

$ 317,646
385,303
265,869
20,264
1,562
35,879

$

$

33.1
1,722
373

$

33.3
1,893
408

$

29.9
1,648
296

$

28.9
1,625
277

28.5
1,686
289

10.8%
22.5
1.19
32
78
37
1.25

10.8%
23.9
1.14
30
78
36
1.14

9.6%
21.2
0.96
31
79
34
1.03

8.6%
19.7
0.82
28
79
36
0.96

6.8%
16.0
0.67
23
80
38
0.95

(a)  Primarily attributable to noncontrolling interests related to consolidated investment management funds. 
(b) 

Includes the assets under custody and/or administration of CIBC Mellon Global Securities Services Company (“CIBC Mellon”), a joint venture with the 
Canadian Imperial Bank of Commerce, of $1.2 trillion at Dec. 31, 2018, $1.3 trillion at Dec. 31, 2017, $1.2 trillion at Dec. 31, 2016, $1.0 trillion at Dec. 
31, 2015 and $1.1 trillion at Dec. 31, 2014.

(c)  Excludes securities lending cash management assets and assets managed in the Investment Services business.
(d)  Represents the total amount of securities on loan in our agency securities lending program managed by the Investment Services business.  Excludes 

securities for which BNY Mellon acts as an agent on behalf of CIBC Mellon clients, which totaled $58 billion at Dec. 31, 2018, $71 billion at Dec. 31, 
2017, $63 billion at Dec. 31, 2016, $55 billion at Dec. 31, 2015 and $65 billion at Dec. 31, 2014. 

(e)  Return on tangible common equity, a Non-GAAP measure, excludes goodwill and intangible assets, net of deferred tax liabilities.  See “Supplemental 
information - Explanation of GAAP and Non-GAAP financial measures” beginning on page 105 for the reconciliation of the Non-GAAP measure.

2 BNY Mellon

 
 
 
 
 
The Bank of New York Mellon Corporation (and its subsidiaries)

Financial Summary (continued)

(dollar amounts in millions, except per common share 

amounts and unless otherwise noted)

Cash dividends per common share
Common dividend payout ratio
Common dividend yield
Closing stock price per common share
Market capitalization (in billions)
Book value per common share
Tangible book value per common share – Non-GAAP (a)
Full-time employees
Year-end common shares outstanding (in thousands)
Average total equity to average total assets
Capital ratios (at period-end):
Consolidated regulatory capital ratios - fully phased-in basis: (b)(c)

Advanced:

CET1 ratio
Tier 1 capital ratio
Total (Tier 1 plus Tier 2) capital ratio

Standardized:
CET1 ratio
Tier 1 capital ratio
Total (Tier 1 plus Tier 2) capital ratio

Tier 1 leverage ratio
Supplementary leverage ratio (“SLR”)

Consolidated regulatory capital ratios - transitional basis: (b)(d)

Advanced:

CET1 ratio
Tier 1 capital ratio
Total (Tier 1 plus Tier 2) capital ratio

Tier 1 leverage ratio
SLR

BNY Mellon shareholders’ equity to total assets ratio
BNY Mellon common shareholders’ equity to total assets ratio

$

$
$
$
$

2018

2017

2016

2015

1.04

$

0.86

$

0.72

$

0.68

$

26%
2.2%

23 %
1.6 %

23%
1.5%

25%
1.6%

2014

0.66

31%
1.6%

47.07
45.2
38.63
19.04
51,300
960,426

$
$
$
$

53.86
54.6
37.21
18.24
52,500
1,013,442

$
$
$
$

47.38
49.6
33.67
16.19
52,000
1,047,488

$
$
$
$

41.22
44.7
32.69
15.27
51,200
1,085,343

$
$
$
$

40.57
45.4
32.09
14.70
50,300
1,118,228

12.1%

11.7 %

10.7%

10.2%

10.2%

10.7%
12.8
13.6

10.3 %
12.3
13.0

11.7
14.1
15.1
6.6
6.0

N/A
N/A
N/A
N/A
N/A

11.2%
10.2

11.5
13.7
14.7
6.4
5.9

10.7 %
12.7
13.4
6.6
6.1

11.1 %
10.1

9.7%

9.5%

9.8%

11.8
12.1

11.3
13.6
14.2
N/A
5.6

10.6%
12.6
13.0
6.6
6.0

11.6%
10.6

11.0
11.1

10.2
11.8
12.0
N/A
4.9

10.8%
12.3
12.5
6.0
5.4

9.7%
9.0

10.8
11.0

10.6
11.6
12.0
N/A
4.4

11.2%
12.2
12.5
5.6
N/A

9.7%
9.3

(a)  Tangible book value per common share – Non-GAAP excludes goodwill and intangible assets, net of deferred tax liabilities.  See “Supplemental 

information – Explanation of GAAP and Non-GAAP financial measures” beginning on page 105 for the reconciliation of the Non-GAAP measure.
(b)  Risk-based capital ratios at Dec. 31, 2014 do not reflect the adoption of accounting guidance related to Consolidations in Accounting Standards Update 

(“ASU”) 2015-02.

(c)  For our Common Equity Tier 1 (“CET1”), Tier 1 and Total capital ratios, our effective capital ratios under U.S. capital rules are the lower of the ratios 
as calculated under the Standardized and Advanced Approaches.  Beginning Jan. 1, 2018, consolidated regulatory ratios are fully phased-in.  The 
consolidated regulatory ratios for all prior periods are presented on an estimated fully phased-in basis.  For additional information on our regulatory 
capital ratios, see “Capital” beginning on page 45.

(d)  Reflects transitional adjustments to CET1, Tier 1 capital and Tier 2 capital required in period periods under U.S. capital rules.

BNY Mellon 3 

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

Results of Operations

General

In this Annual Report, references to “our,” “we,” 
“us,” “BNY Mellon,” the “Company” and similar 
terms refer to The Bank of New York Mellon 
Corporation and its consolidated subsidiaries.  The 
term “Parent” refers to The Bank of New York 
Mellon Corporation but not its subsidiaries.

BNY Mellon’s actual results of future operations may 
differ from those estimated or anticipated in certain 
forward-looking statements contained herein for 
reasons which are discussed below and under the 
heading “Forward-looking Statements.”  When used 
in this Annual Report, words such as “estimate,” 
“forecast,” “project,” “anticipate,” “likely,” “target,” 
“expect,” “intend,” “continue,” “seek,” “believe,” 
“plan,” “goal,” “could,” “should,” “would,” “may,” 
“might,” “will,” “strategy,” “synergies,” 
“opportunities,” “trends,” “future” and words of 
similar meaning, may signify forward-looking 
statements.

Certain business terms and commonly used acronyms 
used in this Annual Report are defined in the 
Glossary and Acronyms sections.

The following should be read in conjunction with the 
Consolidated Financial Statements included in this 
report.  Investors should also read the section titled 
“Forward-looking Statements.” 

Overview

Established in 1784 by Alexander Hamilton, we were 
the first company listed on the New York Stock 
Exchange (NYSE: BK).  With a more than 230-year 
history, BNY Mellon is a global company that 
manages and services assets for financial institutions, 
corporations and individual investors in 35 countries. 

BNY Mellon has two business segments, Investment 
Services and Investment Management, which offer a 
comprehensive set of capabilities and deep expertise 
across the investment lifecycle, enabling the 
Company to provide solutions to buy-side and sell-
side market participants, as well as leading 
institutional and wealth management clients globally.   

 4 BNY Mellon

The diagram below presents our two business 
segments and lines of business, with the remaining 
operations in the Other segment.

The Bank of New 
York Mellon 
Corporation

Investment  
Services

Investment 
Management

Asset 
Management

Wealth 
Management

Asset Servicing

Pershing

Issuer Services

Treasury 
Services

Clearance and 
Collateral 
Management

Key 2018 events 
(cid:3)

Share repurchase program and increase in cash 
dividend on common stock 

In June 2018, our Board of Directors approved the 
repurchase of up to $2.4 billion of common stock 
starting in the third quarter of 2018 and continuing 
through the second quarter of 2019.  

In July 2018, our Board of Directors approved a 17% 
increase in the quarterly cash dividend per common 
share, from $0.24 to $0.28 per share.  The first 
payment of the increased quarterly cash dividend was 
made on Aug. 10, 2018. 

In December 2018, our Board of Directors approved 
the repurchase of $830 million of additional common 
stock, all of which was repurchased in the fourth 
quarter of 2018.  These repurchases were in addition 
to the repurchase of $2.4 billion of common stock 
previously approved by the Board. 

Results of Operations (continued)

Corporate headquarters 

In July 2018, BNY Mellon relocated its corporate 
headquarters to 240 Greenwich Street in lower 
Manhattan. 

• 

Summary of financial highlights

We reported net income applicable to common 
shareholders of BNY Mellon of $4.1 billion, or $4.04 
per diluted common share, in 2018, including a net 
charge of $168 million, or $(0.17) per diluted 
common share, related to severance, expenses 
associated with consolidating real estate and litigation 
expense, partially offset by adjustments to provisional 
estimates for U.S. tax legislation.  In 2017, net 
income applicable to common shareholders of BNY 
Mellon was $3.9 billion, or $3.72 per diluted 
common share, including a net benefit of $160 
million, or $0.15 per diluted common share, related to 
the estimated net benefit related to U.S. tax 
legislation, partially offset by severance, litigation 
expense and other charges. 

Highlights of 2018 results

•  Assets under custody and/or administration 

(“AUC/A”) totaled $33.1 trillion at Dec. 31, 2018 
compared with $33.3 trillion at Dec. 31, 2017.  
The 1% decrease primarily reflects lower market 
values and the unfavorable impact of a stronger 
U.S. dollar on a spot basis, partially offset by net 
new business.  (See “Investment Services 
business” beginning on page 14.)

•  Assets under management (“AUM”) totaled $1.7 
trillion at Dec. 31, 2018 compared with $1.9 
trillion at Dec. 31, 2017.  The 9% decrease 
primarily reflects the unfavorable impact of a 
stronger U.S. dollar (principally versus the 
British pound) on a spot basis, lower market 
values, net outflows, the divestiture of 
CenterSquare Investment Management 
(“CenterSquare”) and other changes.  AUM 
excludes securities lending cash management 
assets and assets managed in the Investment 
Services business.  (See “Investment 
Management business” beginning on page 17.)

• 

Investment services fees totaled $7.8 billion in 
2018, an increase of 5% compared with $7.5 
billion in 2017, primarily reflecting higher equity 
market values, net new business, including 
growth in collateral management and higher 
Depositary Receipts revenue, partially offset by 

the previously disclosed lost business in Pershing.  
(See “Investment Services business” beginning 
on page 14.)

Investment management and performance fees 
totaled $3.7 billion in 2018 compared with $3.6 
billion in 2017, an increase of 3%, primarily 
reflecting higher market values, performance fees 
and the favorable impact of a weaker U.S. dollar 
(principally versus the British pound), partially 
offset by the impact of net outflows.  On a 
constant currency basis (Non-GAAP), investment 
management and performance fees increased 2% 
compared with 2017.  (See “Investment 
Management business” beginning on page 17.)

•  Foreign exchange and other trading revenue 

totaled $732 million in 2018 compared with $668 
million in 2017.  Foreign exchange revenue 
totaled $663 million in 2018, an increase of 4% 
compared with $638 million in 2017.  The 
increase in foreign exchange revenue primarily 
reflects higher volumes, partially offset by 
foreign currency hedging.  (See “Fee and other 
revenue” beginning on page 7.)

•  Net interest revenue totaled $3.6 billion in 2018 
compared with $3.3 billion in 2017, an increase 
of 9%.  The increase primarily reflects higher 
interest rates.  Net interest margin was 1.25% in 
2018 compared with 1.14% in 2017.  (See “Net 
interest revenue” beginning on page 9.)

•  The provision for credit losses was a credit of $11 
million in 2018 and a credit of $24 million in 
2017.  (See “Asset quality and allowance for 
credit losses” beginning on page 35.)

•  Noninterest expense totaled $11.2 billion in 2018 
compared with $11.0 billion in 2017.  The 2% 
increase primarily reflects investments in 
technology, expenses associated with 
consolidating our real estate and the unfavorable 
impact of a weaker U.S. dollar, partially offset by 
lower bank assessment charges.  (See 
“Noninterest expense” beginning on page 12.)

•  The provision for income taxes was $938 million 
(18.1% effective tax rate) in 2018, including the 
impact of the adjustments to provisional 
estimates for U.S. tax legislation and the tax 
impact of severance, expenses associated with 
consolidating real estate and litigation expense.  
(See “Income taxes” on page 12.)

•  The net unrealized pre-tax loss on our total 

securities portfolio was $907 million at Dec. 31, 

BNY Mellon 5 

Results of Operations (continued)

2018, compared with a pre-tax loss of $85 million 
at Dec. 31, 2017, including the impact of related 
hedges.  The increase in net unrealized pre-tax 
loss was primarily driven by an increase in 
interest rates.  (See “Securities” beginning on 
page 29.)

•  Our CET1 ratio calculated under the Advanced 
Approach was 10.7% at Dec. 31, 2018 and 
10.7%, on a transitional basis, at Dec. 31, 2017.  
The ratio was unchanged compared to Dec. 31, 
2017, reflecting capital deployed through 
common stock repurchases and dividend 
payments, and the final phase-in requirements 
under U.S. capital rules, offset by capital 
generated through earnings and lower risk-
weighted assets (“RWAs”).  (See “Capital” 
beginning on page 45.)

•  Our SLR was 6.0% at Dec. 31, 2018 and 6.1%, 

on a transitional basis, at Dec. 31, 2017.  (See 
“Capital” beginning on page 45.)

Results for 2017

In 2017, we reported net income applicable to 
common shareholders of BNY Mellon of $3.9 billion, 
or $3.72 per diluted common share.  These results 
were primarily driven by:

• 

• 

Investment services fees totaled $7.5 billion in 
2017, an increase of 3% compared with $7.2 
billion in 2016, primarily reflecting higher money 
market fees, higher equity market values and net 
new business, including growth in collateral 
management, partially offset by the previously 
disclosed lost business in Pershing and lower 
volumes in certain Depositary Receipts programs.

Investment management and performance fees 
totaled $3.6 billion in 2017 compared with $3.4 
billion in 2016, an increase of 7%, primarily 
reflecting higher market values, money market 
fees and performance fees, partially offset by the 
unfavorable impact of a stronger U.S. dollar 
(principally versus the British pound).

•  Foreign exchange and other trading revenue 

totaled $668 million in 2017 compared with $701 
million in 2016.  Foreign exchange revenue 
totaled $638 million in 2017, a decrease of 7%, 
compared with $687 million in 2016.  The 
decrease in foreign exchange revenue primarily 
reflects lower volatility, partially offset by higher 
volumes.

 6 BNY Mellon

•  The provision for credit losses was a credit of $24 

million in 2017.

•  Noninterest expense totaled $11.0 billion in 2017 
compared with $10.5 billion in 2016.  The 4% 
increase primarily reflects higher staff, software, 
and professional, legal and other purchased 
services expenses.

•  The provision for income taxes was $496 million 
(10.8% effective tax rate), including the estimated 
tax benefit related to U.S. tax legislation. 

Results for 2016

In 2016, we reported net income applicable to 
common shareholders of BNY Mellon of $3.4 billion, 
or $3.15 per diluted common share.  These results 
were primarily driven by:

• 

• 

Investment services fees totaled $7.2 billion, 
primarily reflecting higher money market fees 
and securities lending revenue, partially offset by 
the unfavorable impact of lost business on 
clearing services fees, the unfavorable impact of 
a stronger U.S. dollar and the downsizing of the 
UK transfer agency business.

Investment management and performance fees 
totaled $3.4 billion, primarily reflecting the 
unfavorable impact of a stronger U.S. dollar 
(principally versus the British pound), net 
outflows of AUM and lower performance fees, 
partially offset by higher market values and 
money market fees.

•  Foreign exchange and other trading revenue 
totaled $701 million, of which $687 million 
represented foreign exchange revenue. The 
decrease in foreign exchange revenue primarily 
reflects the impact of clients migrating to lower 
margin products and lower volumes.

•  The provision for credit losses was a credit of $11 

million. 

•  Noninterest expense totaled $10.5 billion 

primarily reflecting lower expenses in nearly all 
categories, driven by the favorable impact of a 
stronger U.S. dollar, lower staff, other, litigation 
and legal expenses and the benefit of the business 
improvement process.  The decrease was partially 
offset by higher bank assessment charges, 
distribution and servicing and software expenses. 

•  The provision for income taxes was $1.2 billion 

(24.9% effective tax rate) in 2016.

Results of Operations (continued)

Fee and other revenue

Fee and other revenue

(dollars in millions, unless otherwise noted)
Investment services fees:
Asset servicing (a)
Clearing services
Issuer services
Treasury services

Total investment services fees

Investment management and performance fees
Foreign exchange and other trading revenue
Financing-related fees
Distribution and servicing
Investment and other income
Total fee revenue
Net securities (losses) gains

Total fee and other revenue

2018

2017

2016

$ 4,608
1,578
1,099
554
7,839
3,685
732
207
139
240
12,842
(48)
$ 12,794

$

4,383
1,553
977
557
7,470
3,584
668
216
160
64
12,162
3
$ 12,165

$

4,244
1,404
1,026
547
7,221
3,350
701
219
166
341
11,998
75
$ 12,073

2018
 vs.
2017

5 %
2
12
(1)
5
3
10
(4)
(13)
N/M
6
N/M

5 %

2017
 vs.
2016

3%

11
(5)
2
3
7
(5)
(1)
(4)

N/M
1
N/M

1%

Fee revenue as a percentage of total revenue

78%

78%

79%

(1)%
AUC/A at period end (in trillions) (b)
(9)%
AUM at period end (in billions) (c)
(a)  Asset servicing fees include securities lending revenue of $220 million in 2018, $195 million in 2017 and $207 million in 2016.
(b)  Includes the AUC/A of CIBC Mellon of $1.2 trillion at Dec. 31, 2018, $1.3 trillion at Dec. 31, 2017 and $1.2 trillion at Dec. 31, 2016.
(c)  Excludes securities lending cash management assets and assets managed in the Investment Services business. 

$
33.1
$ 1,722

29.9
1,648

33.3
1,893

$
$

$
$

11%
15%

Fee and other revenue increased 5% compared with 
2017.  The increase primarily reflects higher asset 
servicing fees, investment and other income, issuer 
servicing fees and investment management and 
performance fees, partially offset by net securities 
losses.

provided to clients, which reduce fee revenue and 
increase net interest revenue, partially offset by 
higher volumes.  

See the “Investment Services business” in “Review of 
businesses” for additional details.

Investment services fees

Investment management and performance fees 

Investment services fees increased 5% compared with 
2017 reflecting the following:

•  Asset servicing fees increased 5%, primarily 
reflecting growth in collateral management, 
higher equity market values and securities 
lending volumes. 

•  Clearing services fees increased 2%, primarily 
driven by higher equity market values and 
average long-term mutual funds balances, 
partially offset by the previously disclosed lost 
business. 

• 

Issuer services fees increased 12%, primarily 
reflecting higher Depositary Receipts revenue 
and higher volumes in Corporate Trust.

•  Treasury services fees decreased 1%, primarily 
reflecting higher compensating balance credits 

Investment management and performance fees 
increased 3% compared with 2017, primarily 
reflecting higher market values, performance fees and 
the favorable impact of a weaker U.S. dollar 
(principally versus the British pound), partially offset 
by the impact of net outflows.  On a constant 
currency basis (Non-GAAP), investment 
management and performance fees increased 2% 
compared with 2017.  Performance fees were $144 
million in 2018, $94 million in 2017 and $60 million 
in 2016.

AUM was $1.7 trillion at Dec. 31, 2018, a decrease of 
9% compared with $1.9 trillion at Dec. 31, 2017.  The 
decrease primarily reflects the unfavorable impact of 
a stronger U.S. dollar (principally versus the British 
pound) on a spot basis, lower market values, net 

BNY Mellon 7 

Results of Operations (continued)

outflows, the divestiture of CenterSquare and other 
changes. 

Distribution and servicing fees

See the “Investment Management business” in 
“Review of businesses” for additional details 
regarding the drivers of investment management and 
performance fees, AUM and AUM flows.

Foreign exchange and other trading revenue

Foreign exchange and other trading revenue
(in millions)
Foreign exchange
Other trading revenue

663 $
69

2018

$

2017

638 $
30

2016
687
14

Total foreign exchange and

other trading revenue

$

732 $

668 $

701

Foreign exchange and other trading revenue increased 
10% compared with 2017.

Foreign exchange revenue is primarily driven by the 
volume of client transactions and the spread realized 
on these transactions, both of which are impacted by 
market volatility, and the impact of foreign currency 
hedging activities.  In 2018, foreign exchange 
revenue totaled $663 million, an increase of 4% 
compared with 2017, primarily reflecting higher 
volumes, partially offset by foreign currency hedging.  
Foreign exchange revenue is primarily reported in the 
Investment Services business and, to a lesser extent, 
the Investment Management business and the Other 
segment.  

Total other trading revenue was $69 million in 2018, 
compared with $30 million in 2017.  The increase 
primarily reflects gains on Investment Management 
hedging activities.  Other trading revenue is reported 
in all three business segments. 

Financing-related fees

Financing-related fees, which are primarily reported 
in the Investment Services business and the Other 
segment, include capital markets fees, loan 
commitment fees and credit-related fees.  Financing-
related fees totaled $207 million in 2018 compared 
with $216 million in 2017, primarily reflecting lower 
fees on standby letters of credit and underwriting.

 8 BNY Mellon

Distribution and servicing fees earned from mutual 
funds are primarily based on average assets in the 
funds and the sales of funds that we manage or 
administer and are primarily reported in the 
Investment Management business.  These fees, which 
include 12b-1 fees, fluctuate with the overall level of 
net sales, the relative mix of sales between share 
classes, the funds’ market values and money market 
fee waivers.

Distribution and servicing fees were $139 million in 
2018 compared with $160 million in 2017.  The 
decrease primarily reflects the impact of lower fees 
from mutual funds.

Investment and other income

The following table provides the components of 
investment and other income.

Investment and other income
(in millions)
Corporate/bank-owned life insurance $
Expense reimbursements from joint

venture

2018

2017

145 $

153 $

2016
149

64

67

Asset-related gains (losses)
Equity investment income (loss)
Seed capital gains (a)
Lease-related gains
Other (loss) income

10
(10)
44
38
43
341
(a)  Excludes seed capital gains related to consolidated investment 
management funds, which are reflected in operations of 
consolidated investment management funds. 

Total investment and other income

(1)
37
32
56
(277)

64 $

$

71
70
4
3
1
(54)
240 $

Investment and other income includes corporate and 
bank-owned life insurance contracts, expense 
reimbursements from our CIBC Mellon joint venture, 
gains or losses from asset-related activity, equity 
investments, seed capital, lease-related activity and 
other (loss) income.  Expense reimbursements from 
our CIBC Mellon joint venture relate to expenses 
incurred by BNY Mellon on behalf of the CIBC 
Mellon joint venture.  Asset-related gains (losses) 
include real estate, loan and other asset dispositions.  
Other (loss) income primarily includes foreign 
currency remeasurement gain (loss), other 
investments, including renewable energy, and various 
miscellaneous revenues.  Investments in renewable 
energy generate losses in other income that are more 
than offset by benefits and credits recorded to the 
provision for income taxes.

Results of Operations (continued)

Investment and other income was $240 million in 
2018 compared with $64 million in 2017.  The 
increase primarily reflects the impact of U.S. tax 
legislation on our renewable energy investments 
recorded in 2017.

Net securities losses 

Net securities losses were $48 million in 2018, 
primarily reflecting the sale of debt securities.

2017 compared with 2016

Fee and other revenue totaled $12.2 billion in 2017 
compared with $12.1 billion in 2016.  The increase 
primarily reflects higher investment services fees and 
investment management and performance fees, 
partially offset by lower investment and other income 
and net securities gains.

Net interest revenue

Net interest revenue

(dollars in millions)
Net interest revenue
Add: Tax equivalent adjustment

Net interest revenue on a fully taxable equivalent 

basis (“FTE”) – Non-GAAP (a)

The increase in investment services fees primarily 
reflects higher money market fees, higher equity 
market values and net new business, including growth 
in collateral management, partially offset by 
previously disclosed lost business in Pershing and 
lower volumes in certain Depositary Receipts 
programs.

The increase in investment management and 
performance fees primarily reflects higher market 
values, money market fees and performance fees, 
partially offset by the unfavorable impact of a 
stronger U.S. dollar on an average basis (principally 
versus the British pound).

The decrease in investment and other income 
primarily reflects the impact of U.S. tax legislation on 
our renewable energy investments.

2018

2017

2016

$

3,611
20

$

3,631

$

$

3,308
47

3,355

$

$

3,138
51

3,189

2018
 vs.
2017
9%
N/M

2017
 vs.
2016
5%
N/M

8%

5%

Average interest-earning assets

$289,916

$ 290,522

$ 303,379

—%

(4)%

Net interest margin
Net interest margin (FTE) – Non-GAAP (a)
(a)  Net interest revenue (FTE) – Non-GAAP and net interest margin (FTE) – Non-GAAP include the tax equivalent adjustments on tax-
exempt income which allows for comparisons of amounts arising from both taxable and tax-exempt sources and is consistent with 
industry practice.  The adjustment to an FTE basis has no impact on net income.

1.03%
1.05%

1.14%
1.15%

11 bps
10 bps

1.25%
1.25%

11 bps
10 bps

Net interest revenue increased 9% compared with 
2017, primarily reflecting higher interest rates. 

Net interest margin increased 11 basis points 
compared with 2017, primarily reflecting higher 
yields on interest-earning assets, partially offset by 
higher interest rates paid on interest-bearing 
liabilities. 

Average interest-earning assets were $290 billion in 
2018 compared with $291 billion in 2017.  The 
decrease primarily reflects lower loans and interest-
bearing deposits with the Federal Reserve and other 
central banks, partially offset by higher trading 
securities. 

Average non-U.S. dollar deposits comprised 
approximately 30% of our average total deposits in 
2018 and 2017.  Approximately 45% of the average 
non-U.S. dollar deposits in 2018 and 2017 were euro-
denominated.

2017 compared with 2016

Net interest revenue increased 5% compared with 
2016, primarily driven by higher interest rates, 
partially offset by lower interest-earning assets driven 
by lower average deposits.  The 11 basis points 
increase in the net interest margin primarily reflects 
higher yields on interest-earning assets, partially 
offset by higher interest rates paid on interest-bearing 
liabilities.

BNY Mellon 9 

Results of Operations (continued)

Average balances and interest rates

(dollar amounts in millions, presented on an FTE basis)

Assets
Interest-earning assets:

Interest-bearing deposits with banks (primarily foreign banks)
Interest-bearing deposits with the Federal Reserve and other central banks
Federal funds sold and securities purchased under resale agreements (a)
Margin loans
Non-margin loans:
Domestic offices:

Consumer
Commercial
Foreign offices

Total non-margin loans

Securities:

U.S. government obligations
U.S. government agency obligations
State and political subdivisions
Other securities:

Domestic offices
Foreign offices

Total other securities

Trading securities (primarily domestic)

Total securities
Total interest-earning assets

Noninterest-earning assets

Total assets

Liabilities
Interest-bearing liabilities:
Interest-bearing deposits:

Domestic offices
Foreign offices

Total interest-bearing deposits

Federal funds purchased and securities sold under repurchase agreements (a)
Trading liabilities
Other borrowed funds:
Domestic offices
Foreign offices

Total other borrowed funds

Commercial paper
Payables to customers and broker-dealers
Long-term debt

Total interest-bearing liabilities

Total noninterest-bearing deposits
Other noninterest-bearing liabilities

Total liabilities

Temporary equity
Redeemable noncontrolling interests
Permanent equity
Total The Bank of New York Mellon Corporation shareholders’ equity
Noncontrolling interests

Total permanent equity

Total liabilities, temporary equity and permanent equity

Net interest revenue (FTE) – Non-GAAP
Net interest margin (FTE) – Non-GAAP
Less: Tax equivalent adjustment (c)
Net interest revenue - GAAP
Net interest margin- GAAP

Average
balance

2018

Interest

Average
rates

$

$

$

$

$

$

14,740
68,408
27,883
14,397

9,789
19,853
11,771
41,413

23,908
63,902
2,565

8,186
19,848
28,034
4,666
123,075
289,916
53,858
343,774

59,226
95,475
154,701
15,546
1,310

2,122
423
2,545
2,607
16,353
28,257
221,319
63,814
16,952
302,085

187

41,360
142
41,502
343,774

(b)

$

$

$

$

$

$

219
531
1,116
510

319
701
336
1,356

486
1,518
69

341
179
520
127
2,720
6,452

537
340
877
758
29

55
3
58
51
191
857
2,821

3,631

20
3,611

1.48%
0.78
4.00
3.54

3.26
3.53
2.85
3.27

2.03
2.37
2.69

4.17
0.90
1.85
2.74
2.21
2.23%

0.91%
0.36
0.57
4.88
2.21

2.57
0.73
2.26
1.97
1.17
3.03
1.27%

1.25%

1.25%

Percentage of assets attributable to foreign offices (d)
Percentage of liabilities attributable to foreign offices (d)
Note:  Interest and average rates were calculated on a taxable equivalent basis using dollar amounts in thousands and actual number of days in the year. 
(a) 
(b) 

Includes the average impact of offsetting under enforceable netting agreements of approximately $25 billion in 2018.
Includes fees of $7 million in 2018.  Non-accrual loans are included in average loans; the associated income, which was recognized on a cash basis, is 
included in interest income.

31%
34

(c)  The tax equivalent adjustment relates to tax-exempt securities, primarily state and political subdivisions, and is based on the U.S. federal statutory tax 

rate of 21%, adjusted for applicable state income taxes, net of the related federal tax benefit.
Includes the Cayman Islands branch office.

(d) 

 10 BNY Mellon

Results of Operations (continued)

Average balances and interest rates (continued)

(dollar amounts in millions, presented on an FTE basis)

Average
balance

2017

Interest

Average
rates

Average
balance

2016

Interest

Average
rates

Assets
Interest-earning assets:

Interest-bearing deposits with banks (primarily foreign banks)
Interest-bearing deposits with the Federal Reserve and other 

central banks

Federal funds sold and securities purchased under resale agreements (a)
Margin loans
Non-margin loans:
Domestic offices:

Consumer
Commercial
Foreign offices

Total non-margin loans

Securities:

U.S. government obligations
U.S. government agency obligations
State and political subdivisions
Other securities:

Domestic offices
Foreign offices

Total other securities

Trading securities (primarily domestic)

Total securities
Total interest-earning assets

Noninterest-earning assets

Total assets

Liabilities
Interest-bearing liabilities:
Interest-bearing deposits:

Domestic offices:
Foreign offices

Total interest-bearing deposits

Federal funds purchased and securities sold under repurchase 

agreements (a)
Trading liabilities
Other borrowed funds:
Domestic offices
Foreign offices

Total other borrowed funds

Commercial paper
Payables to customers and broker-dealers
Long-term debt

Total interest-bearing liabilities

Total noninterest-bearing deposits
Other noninterest-bearing liabilities

Total liabilities

Temporary equity
Redeemable noncontrolling interests
Permanent equity
Total The Bank of New York Mellon Corporation shareholders’ equity
Noncontrolling interests

Total permanent equity

Total liabilities, temporary equity and permanent equity

Net interest revenue (FTE) – Non-GAAP
Net interest margin (FTE) – Non-GAAP
Less: Tax equivalent adjustment (c)

Net interest revenue - GAAP
Net interest margin - GAAP

$ 14,879

$

120

0.80% $ 14,704

$

104

0.70%

198

233
265

259
417
197
873 (b)

378
986
110

210
206
416
63
1,953
$ 3,626

$

$

41
(25)
16

36

6

4
4
8
5
12
354
437

0.25

0.91
1.46

3.05
1.91
1.50
2.01

1.51
1.75
2.96

1.71
1.00
1.26
2.56
1.62
1.20%

0.08%
(0.02)
0.01

0.25

0.89

4.15
0.51
0.91
0.37
0.07
1.52
0.20%

70,213

27,192
14,500

9,548
20,976
12,915
43,439

25,674
60,268
3,226

9,141
19,541
28,682
2,449
120,299
$ 290,522
53,326
$ 343,848

$ 46,908
96,215
143,123

19,653

1,243

1,113
803
1,916
2,630
18,984
27,424
$ 214,973
71,664
16,932
303,569

180

39,687
412
40,099
$ 343,848

319

423
343

298
521
258

1,077 (b)

425
1,195
100

215
150
365
62
2,147
$ 4,429

$

107
55
162

225

7

21
5
26
29
64
561
$ 1,074

0.45

1.55
2.36

3.12
2.49
2.00
2.48

1.66
1.98
3.09

80,593

25,767
18,201

8,483
21,820
13,177
43,480

25,074
56,384
3,703

12,326
2.35
20,664
0.77
32,990
1.27
2,483
2.54
1.79
120,634
1.52% $ 303,379
55,098
$ 358,477

0.23% $ 54,547
102,399
0.06
156,946
0.11

1.14

0.57

14,489

711

93
1.86
753
0.67
846
1.36
1,337
1.08
16,925
0.34
2.05
23,334
0.50% $ 214,588
82,712
21,928
319,228

182

38,489
578
39,067
$ 358,477

$ 3,355

47
$ 3,308

1.15%

1.14%

$ 3,189

51
$ 3,138

1.05%

1.03%

Percentage of assets attributable to foreign offices (d)
Percentage of liabilities attributable to foreign offices (d)
Note:  Interest and average rates were calculated on a taxable equivalent basis using dollar amounts in thousands and actual number of days in the year. 
(a) 
(b) 

Includes the average impact of offsetting under enforceable netting agreements of approximately $6 billion in 2017 and less than $350 million in 2016.
Includes fees of $9 million in 2017 and $10 million in 2016.  Non-accrual loans are included in the average loans; the associated income, which was 
recognized on a cash basis, is included in interest income.

29%
36

30%
35

(c)  The tax equivalent adjustment relates to tax-exempt securities, primarily state and political subdivisions, and is based on the U.S. federal statutory tax 

rate of 35%, adjusted for applicable state income taxes, net of the related federal tax benefit.
Includes the Cayman Islands branch office.

(d) 

BNY Mellon 11 

Results of Operations (continued)

Noninterest expense

Noninterest expense

(dollars in millions)
Staff (a)
Professional, legal and other purchased services
Software
Net occupancy
Sub-custodian and clearing (b)
Distribution and servicing
Furniture and equipment
Business development
Bank assessment charges
Amortization of intangible assets
Other (a)(b)(c)

Total noninterest expense

2018
6,145 $
1,334
772
630
450
406
290
228
170
180
606
11,211 $

2017
6,033 $
1,276
744
570
414
419
241
229
220
209
602
10,957 $

2016
5,809
1,186
647
592
400
405
247
245
219
237
536
10,523

$

$

2018
 vs.
2017
2 %
5
4
11
9
(3)
20
—
(23)
(14)
1
2 %

2017
 vs.
2016
4%
8
15
(4)
4
3
(2)
(7)
—
(12)
12

4%

1%
Full-time employees at period end
(a)  In 2018, we adopted new accounting guidance included in ASU 2017-07, Compensation-Retirement Benefits: Improving the Presentation 
of Net Periodic Pension Cost and Net Periodic Postretirement Benefit Cost, which required the reclassification of the components of 
pension and other postretirement costs, other than the service cost component.  As a result, staff expense increased and other expense 
decreased.  Prior periods have been reclassified.  See Note 2 of the Notes to Consolidated Financial Statements for additional 
information.

52,500

51,300

52,000

(2)%

(b)  Beginning in 2018, clearing expense, which was previously included in other expense, was included with sub-custodian expense.  Prior 

periods have been reclassified. 

(c)  Beginning in 2018, merger and integration (“M&I”), litigation and restructuring charges are no longer separately disclosed.  Expenses 

previously reported in this line have been reclassified to existing expense categories, primarily other expense.

Total noninterest expense increased 2% compared 
with 2017.  The increase primarily reflects 
investments in technology, expenses associated with 
consolidating our real estate and the unfavorable 
impact of a weaker U.S. dollar, partially offset by 
lower bank assessment charges.  The investments in 
technology are included in staff, professional, legal 
and other purchased services, software and furniture 
and equipment expenses. 

Our investments in technology infrastructure and 
platforms increased throughout 2018 and are 
expected to continue at recent levels.  As a result, we 
expect to incur higher technology-related expenses in 
2019 than in 2018.  This increase is expected to be 
mostly offset by decreases in other expenses as we 
continue to manage overall expenses. 

2017 compared with 2016 

Total noninterest expense increased 4% compared 
with 2016.  The increase primarily reflects higher 
staff, software and professional, legal and other 
purchased services expenses.  The increase in staff 

expense primarily reflects higher incentive expense, 
driven by stronger performance, the annual employee 
merit increase and higher severance expense, partially 
offset by the favorable impact of a stronger U.S. 
dollar.  The increase in software expense primarily 
reflects asset impairments and increased amortization.  
The increase in professional, legal and other 
purchased services expense primarily reflects higher 
consulting and purchased services expenses.

Income taxes

BNY Mellon recorded an income tax provision of 
$938 million (18.1% effective tax rate) in 2018, 
including the impact of adjusting provisional 
estimates related to U.S. tax legislation and the tax 
impact of severance, expenses associated with 
consolidating real estate and litigation expense.  The 
income tax provision was $496 million (10.8% 
effective tax rate) in 2017, including the estimated tax 
benefit related to U.S. tax legislation.  The income tax 
provision was $1.2 billion (24.9% effective tax rate) 
in 2016.  For additional information, see Note 11 of 
the Notes to Consolidated Financial Statements.

 12 BNY Mellon

Results of Operations (continued)

Review of businesses

We have an internal information system that produces 
performance data along product and service lines for 
our two principal businesses, Investment Services and 
Investment Management, and the Other segment. 

Business accounting principles

Our business data has been determined on an internal 
management basis of accounting, rather than the 
generally accepted accounting principles used for 
consolidated financial reporting.  These measurement 
principles are designed so that reported results of the 
businesses will track their economic performance. 

For information on the accounting principles of our 
businesses, the primary products and services in each 
line of business, the primary types of revenue by 
business and how our businesses are presented and 
analyzed, see Note 23 of the Notes to Consolidated 
Financial Statements.

Business results are subject to reclassification when 
organizational changes are made.  There were no 
significant organizational changes in 2018.  The 
results are also subject to refinements in revenue and 
expense allocation methodologies, which are 
typically reflected on a prospective basis.

The results of our businesses may be influenced by 
client and other activities that vary by quarter.  In the 
first quarter, incentive expense typically increases 
reflecting the vesting of long-term stock awards for 
retirement-eligible employees.  In the third quarter, 
Depositary Receipts revenue is typically higher due 
to an increased level of client dividend payments.  
Also in the third quarter, volume-related fees may 
decline due to reduced client activity.  In the third 

quarter, staff expense typically increases reflecting 
the annual employee merit increase.  In the fourth 
quarter, we typically incur higher business 
development and marketing expenses.  In our 
Investment Management business, performance fees 
are typically higher in the fourth quarter, as the fourth 
quarter represents the end of the measurement period 
for many of the performance fee-eligible 
relationships.  

The results of our businesses may also be impacted 
by the translation of financial results denominated in 
foreign currencies to the U.S. dollar.  We are 
primarily impacted by activities denominated in the 
British pound and the euro.  On a consolidated basis 
and in our Investment Services business, we typically 
have more foreign currency-denominated expenses 
than revenues.  However, our Investment 
Management business typically has more foreign 
currency-denominated revenues than expenses.  
Overall, currency fluctuations impact the year-over-
year growth rate in the Investment Management 
business more than the Investment Services business.  
However, currency fluctuations, in isolation, are not 
expected to significantly impact net income on a 
consolidated basis.

Fee revenue in Investment Management, and to a 
lesser extent in Investment Services, is impacted by 
the value of market indices.  At Dec. 31, 2018, we 
estimate that a 5% change in global equity markets, 
spread evenly throughout the year, would impact fee 
revenue by less than 1% and diluted earnings per 
common share by $0.03 to $0.05. 

See Note 23 of the Notes to Consolidated Financial 
Statements for the consolidating schedules which 
show the contribution of our businesses to our overall 
profitability.

BNY Mellon 13 

Results of Operations (continued)

Investment Services business

(dollars in millions unless otherwise noted)

2018

2017

2016

Revenue:

Investment services fees:

Asset servicing
Clearing services
Issuer services
Treasury services
Total investment services fees

Foreign exchange and other trading revenue
Other (a)

Total fee and other revenue

Net interest revenue

Total revenue

Provision for credit losses
Noninterest expense (excluding amortization of intangible assets)
Amortization of intangible assets

Total noninterest expense
Income before taxes

Pre-tax operating margin

Securities lending revenue

Total revenue by line of business:
Asset Servicing
Pershing
Issuer Services
Treasury Services
Clearance and Collateral Management
Total revenue by line of business

Metrics:
Average loans
Average deposits

AUC/A at period end (in trillions) (b)
Market value of securities on loan at period end (in billions) (c)

Pershing:
Average active clearing accounts (U.S. platform) (in thousands)
Average long-term mutual fund assets (U.S. platform)
Average investor margin loans (U.S. platform)

Clearance and Collateral Management:
Average tri-party collateral management balances (in billions)

$

$

$

$

$

2018
 vs.
2017

2017
 vs.
2016

5 %
2
13
—
5
7
(6)
5
10
6
N/M
4
(13)
4
10 %

4 %
11
(5)
3
4
(6)
2
3
9
4
N/M
6
(4)
6
3 %

4,520
1,577
1,099
553
7,749
665
512
8,926
3,372
12,298
1
7,929
129
8,058
4,239

$

$

4,286
1,549
975
555
7,365
620
542
8,527
3,058
11,585
(7)
7,598
149
7,747
3,845

$

$

4,141
1,399
1,024
541
7,105
663
531
8,299
2,797
11,096
8
7,187
155
7,342
3,746

34%

33%

34%

198

$

168

$

170

18 %

(1)%

5,932
2,255
1,743
1,302
1,066
12,298

$

$

5,603
2,180
1,588
1,251
963
11,585

$

$

5,504
1,979
1,585
1,136
892
11,096

$
36,931
$ 203,279

$
40,142
$ 200,235

$
44,740
$ 217,882

$
$

33.1
373

$
$

33.3
408

$
$

29.9
296

6,097
$ 511,004
10,829
$

6,137
$ 487,845
9,810
$

5,949
$ 431,937
10,772
$

6 %
3
10
4
11
6 %

(8)%
2 %

(1)%
(9)%

(1)%
5 %
10 %

2 %

10
—
10
8
4 %

(10)%
(8)%

11 %
38 %

3 %
13 %
(9)%

$

2,918

$

2,502

$

2,183

17 %

15 %

(a)  Other revenue includes investment management fees, financing-related fees, distribution and servicing revenue and investment and other income. 
(b) 
Includes the AUC/A of CIBC Mellon of $1.2 trillion at Dec. 31, 2018, $1.3 trillion at Dec. 31, 2017 and $1.2 trillion at Dec. 31, 2016.
(c)  Represents the total amount of securities on loan in our agency securities lending program managed by the Investment Services business.  

Excludes securities for which BNY Mellon acts as agent on behalf of CIBC Mellon clients, which totaled $58 billion at Dec. 31, 2018, $71 billion 
at Dec. 31, 2017 and $63 billion at Dec. 31, 2016.

 14 BNY Mellon

Results of Operations (continued)

Business description

BNY Mellon Investment Services provides business 
services and technology solutions to entities including 
financial institutions, corporations, foundations and 
endowments, public funds and government agencies.  
Our lines of business include: Asset Servicing, 
Pershing, Issuer Services, Treasury Services and 
Clearance and Collateral Management.

We are one of the leading global investment services 
providers with $33.1 trillion of AUC/A at Dec. 31, 
2018.  

•  We are the primary provider of U.S. government 
securities clearance and a provider of non-U.S. 
government securities clearance.  

•  We are a leading provider of tri-party collateral 
management services with an average of $2.9 
trillion serviced globally including approximately 
$2.0 trillion of the U.S. tri-party repo market.  

•  Our agency securities lending program is one of 

the largest lenders of U.S. and non-U.S. 
securities, servicing a lendable asset pool of 
approximately $3.4 trillion in 34 separate 
markets. 

The Asset Servicing business provides a 
comprehensive suite of solutions.  As one of the 
largest global custody and fund accounting providers 
and a trusted partner, we offer services for the 
safekeeping of assets in capital markets globally as 
well as alternative investment and structured product 
strategies.  We provide custody and foreign exchange 
services, support exchange-traded funds and unit 
investment trusts and provide our clients outsourcing 
capabilities.  We deliver securities lending and 
financing solutions on both an agency and principal 
basis.  Our market leading liquidity services portal 
enables cash investments for institutional clients and 
includes fund research and analytics.

Pershing provides clearing, custody, business and 
technology solutions, delivering dependable 
operational support to financial organizations 
globally. 

The Issuer Services business includes Corporate 
Trust and Depositary Receipts.  Our Corporate 
Trust business delivers a full range of issuer and 
related investor services, including trustee, paying 
agency, fiduciary, escrow and other financial 

services.  We are a leading provider to the debt 
capital markets, providing customized and market-
driven solutions to investors, bondholders and 
lenders.  Our Depositary Receipts business drives 
global investing by providing servicing and value-
added solutions that enable, facilitate and enhance 
cross-border trading, clearing, settlement and 
ownership.  We are one of the largest providers of 
depositary receipts services in the world, partnering 
with leading companies from more than 50 
countries.

Our Treasury Services business includes global 
payments, liquidity management, payables/
receivables and trade finance services for financial 
institutions, corporations and the public sector.  

Our Clearance and Collateral Management 
business clears and settles equity and fixed-income 
transactions globally and serves as custodian for 
tri-party repo collateral worldwide.  Our collateral 
services include collateral management, 
administration and segregation.  We offer 
innovative solutions and industry expertise which 
help financial institutions and institutional 
investors with their liquidity, financing, risk and 
balance sheet challenges.

Review of financial results

AUC/A decreased 1% compared with Dec. 31, 2017 
to $33.1 trillion, primarily reflecting lower market 
values and the unfavorable impact of a stronger U.S. 
dollar on a spot basis, partially offset by net new 
business.  AUC/A consisted of 33% equity securities 
and 67% fixed-income securities at Dec. 31, 2018 and 
37% equity securities and 63% fixed-income 
securities at Dec. 31, 2017.

Total revenue of $12.3 billion increased 6% 
compared with 2017.  Net interest revenue increased 
compared with 2017 in all businesses, primarily 
driven by higher interest rates.  The drivers of fee 
revenue by line of business are indicated below.

Asset Servicing revenue of $5.9 billion increased 6% 
compared with 2017.  The increase primarily reflects 
higher net interest revenue, higher foreign exchange 
and securities lending volumes, higher equity market 
values and the favorable impact of a weaker U.S. 
dollar.

BNY Mellon 15 

Results of Operations (continued)

Pershing revenue of $2.3 billion increased 3% 
compared with 2017.  The increase primarily reflects 
higher net interest revenue and higher fees due to 
growth in average long-term mutual fund balances 
and higher clearance volumes, partially offset by the 
previously disclosed lost business.

Issuer Services revenue of $1.7 billion increased 10% 
compared with 2017.  The increase primarily reflects 
higher Depositary Receipts revenue driven by 
corporate actions and higher volumes, higher net 
interest revenue and increased volumes in Corporate 
Trust.

Treasury Services revenue of $1.3 billion increased 
4% compared with 2017.  The increase primarily 
reflects higher net interest revenue and higher 
payment volumes.

Clearance and Collateral Management revenue of 
$1.1 billion increased 11% compared with 2017.  The 
increase primarily reflects growth in collateral 
management, clearance volumes and net interest 
revenue. 

Market and regulatory trends are driving investable 
assets toward lower fee asset management products at 
reduced margins for our clients.  These dynamics are 
also negatively impacting our investment services 
fees.  However, at the same time, these trends are 
providing additional outsourcing opportunities as 
clients and other market participants seek to comply 
with new regulations and reduce their operating costs. 

Noninterest expense of $8.1 billion increased 4% 
compared with 2017.  The increase was primarily 
driven by investments in technology, higher volume-
related expenses and the unfavorable impact of a 
weaker U.S. dollar.

2017 compared with 2016 

Total revenue of $11.6 billion increased 4% compared 
with 2016.  Net interest revenue increased in most 
lines of business, primarily driven by higher interest 
rates.  Asset Servicing revenue increased primarily 
reflecting higher net interest revenue, equity market 
values and money market fees, partially offset by the 
downsizing of the UK transfer agency business.  
Pershing revenue increased primarily reflecting 
higher net interest revenue, higher money market fees 
and growth in long-term mutual fund assets.  Issuer 
Services revenue increased slightly primarily 
reflecting higher net interest revenue partially offset 
by lost business and lower volumes from weaker 
cross-border settlement activity in Depositary 
Receipts.  Treasury Services revenue increased 
primarily reflecting higher net interest revenue and 
higher payment volumes.  Clearance and Collateral 
Management revenue increased primarily reflecting 
growth in collateral management and higher 
clearance volumes, partially offset by lower net 
interest revenue. 

Noninterest expense of $7.7 billion increased 6% 
compared with 2016 primarily reflecting higher staff 
expense, including severance, higher litigation 
expense, additional technology-related costs and asset 
impairments.

 16 BNY Mellon

Results of Operations (continued)

Investment Management business

(dollars in millions)
Revenue:

Investment management fees (a)
Performance fees

Investment management and performance fees (b)

Distribution and servicing
Other (a)

Total fee and other revenue (a)

Net interest revenue
Total revenue
Provision for credit losses
Noninterest expense (excluding amortization of intangible assets)
Amortization of intangible assets

Total noninterest expense
Income before taxes

Pre-tax operating margin
Adjusted pre-tax operating margin – Non-GAAP (c)

Total revenue by line of business:

Asset Management
Wealth Management

Total revenue by line of business

2018
 vs.
2017

2%

53
3
(8)
N/M
3
(8)
2
N/M
(1)
(15)
(1)
11%

2017
 vs.
2016

6 %
57
7
8
N/M
7
1
7
N/M
4
(27)
3
18 %

2018

2017

2016

3,232
60
3,292
192
(60)
3,424
327
3,751
6
2,696
82
2,778
967

26%
29%

$

$

$

$

3,488
144
3,632
190
(41)
3,781
303
4,084
3
2,767
51
2,818
1,263

31%
34%

2,836
1,248
4,084

$

$

$

$

3,428
94
3,522
207
(61)
3,668
329
3,997
2
2,794
60
2,854
1,141

29%
32%

2,775
1,222
3,997

$

$

$

$

2,615
1,136
3,751

2%
2
2%

6 %
8
7 %

Average balances:
Average loans
Average deposits

10 %
(13)%
(a)  Total fee and other revenue includes the impact of the consolidated investment management funds, net of noncontrolling interests.  Additionally, 

$ 16,565
$ 13,615

$ 15,015
$ 15,650

$ 16,774
$ 14,291

1%
5%

other revenue includes asset servicing, foreign exchange and other trading revenue, treasury services and investment and other income. 

(b)  On a constant currency basis, investment management and performance fees increased 2% (Non-GAAP) compared with 2017.  See 

“Supplemental information – Explanation of GAAP and Non-GAAP financial measures” beginning on page 105 for the reconciliation of this 
Non-GAAP measure.

(c)  Net of distribution and servicing expense.  See “Supplemental information – Explanation of GAAP and Non-GAAP financial measures” 

beginning on page 105 for the reconciliation of this Non-GAAP measure.  In 2018, the adjusted pre-tax margin – Non-GAAP for prior periods 
was restated to include amortization of intangible assets and the provision for credit losses.  

BNY Mellon 17 

Results of Operations (continued)

AUM trends
(dollars in billions)
AUM at period end, by 
product type: (a)
Equity
Fixed income
Index
Liability-driven
investments

Multi-asset and alternative

investments

Cash

Total AUM by product

type

2018

2017

2016

$

135
200
301

659

167
260

$

$

161
206
350

667

214

295

153
186
312

554

181

262

$ 1,722

$ 1,893

$ 1,648

Changes in AUM: (a)
Beginning balance of AUM $ 1,893
Net (outflows) inflows:
Long-term strategies:

$ 1,648

$ 1,625

Equity
Fixed income
Liability-driven
investments
Multi-asset and
alternative
investments
Total long-term active
strategies inflows

Index

Total long-term

strategies (outflows)
inflows

Short-term strategies:

Cash

Total net (outflows)
inflows

Net market impact
Net currency impact
Acquisition/divestiture/

other

Ending balance of

AUM

Wealth Management 

client assets (c)

(13)
4

45

(6)

30
(34)

(4)

(35)

(39)
(48)
(53)

(31)

(b)

(14)
6

50

8

50

(17)

33

30

63

106
76

—

(15)
(5)

26

12

18

(32)

(14)

(9)

(23)

181
(137)

2

$ 1,722

$ 1,893

$ 1,648

$

239

$

262

$

240

(a)  Excludes securities lending cash management assets and 
assets managed in the Investment Services business.  
(b)  Primarily reflects a change in methodology beginning in 

2018 to exclude AUM related to equity method investments 
as well as the CenterSquare divestiture. 

(c)  Includes AUM and AUC/A in the Wealth Management 

business.  Prior period amounts were revised to include 
additional AUC/A. 

Business description

Our Investment Management business consists of two 
lines of business, Asset Management and Wealth 
Management.  With AUM of $1.7 trillion, our 
Investment Management business is the seventh 
largest global asset manager and includes our 
investment specialists and Wealth Management 
business.

 18 BNY Mellon

Our investment specialists deliver a highly diversified 
portfolio of investment strategies independently, and 
through our global distribution network, to 
institutional and retail clients globally.  The 
investment specialists offer a broad range of actively 
managed equity, fixed income, alternative and 
liability-driven investments, along with passive 
products and cash management.  Each investment 
specialist follows its own investment approach to 
innovate and develop investment solutions designed 
to deliver performance returns and outcomes that 
meet the investing goals of an increasingly 
sophisticated client base.  Our multi-boutique model 
of investment specialists is designed to provide the 
best elements of investment focus and infrastructure 
at scale for the benefit of clients.

In the third quarter of 2018, BNY Mellon announced 
the wind-down of EACM Advisors and, effective Jan. 
2, 2019, Mellon Investments Corporation (“Mellon”) 
as the new name of our specialized multi-asset 
investment manager formed from the consolidation of 
Mellon Capital Management, Standish Mellon Asset 
Management, and The Boston Company Asset 
Management.  

In addition to the investment specialists, Investment 
Management has multiple global distribution entities 
which are responsible for distributing investment 
products developed and managed by the investment 
specialists, as well as responsibility for management 
and distribution of our U.S. mutual funds and certain 
offshore money market funds.

BNY Mellon Wealth Management provides 
investment management, custody, wealth and estate 
planning and private banking services, and conducts 
business globally.  BNY Mellon Wealth Management 
has $239 billion in Wealth Management client assets 
as of Dec. 31, 2018, and an extensive network of 
offices in the U.S. and internationally.  

The results of the Investment Management business 
are driven by the period end, average and mix of 
AUM, as well as the level of activity in client 
accounts.  The overall level of AUM for a given 
period is determined by:

• 
• 

the beginning level of AUM;
the net flows of new assets during the period 
resulting from new business wins and existing 
client enrichments, reduced by the loss of clients 
and withdrawals; and

Results of Operations (continued)

• 

the impact of market price appreciation or 
depreciation, acquisitions or divestitures and 
foreign exchange rates.

The mix of AUM is determined principally by client 
asset allocation decisions among equity, fixed 
income, passive products, cash, liability-driven 
investments and multi-asset and alternative 
investments.

Managed equity assets typically generate higher 
percentage fees than liability-driven investments and 
fixed-income assets.  Also, actively managed assets 
typically generate higher management fees than 
indexed or passively managed assets of the same 
type.  

Investment management fees are dependent on the 
overall level and mix of AUM and the management 
fees expressed in basis points (one-hundredth of one 
percent) charged for managing those assets.  
Management fees are typically subject to fee 
schedules based on the overall level of assets 
managed for a single client or by individual asset 
class and style.  This is most common for institutional 
clients where we typically manage substantial assets 
for individual accounts.  

Performance fees are generally calculated as a 
percentage of a portfolio’s performance in excess of a 
benchmark index or a peer group’s performance.  

A key driver of organic growth in investment 
management and performance fees is the amount of 
net new AUM flows.  Overall market conditions are 
also key drivers, with a significant long-term 
economic driver being growth of global financial 
assets.  

Net interest revenue is determined by loan and 
deposit volumes and the interest rate spread between 
customer rates and internal funds transfer rates on 
loans and deposits.  Expenses in the Investment 
Management business are mainly driven by staffing 
costs, incentives and distribution and servicing 
expense.  

Review of financial results

AUM decreased 9% compared with Dec. 31, 2017 
primarily reflecting the unfavorable impact of a 

stronger U.S. dollar (principally versus the British 
pound) on a spot basis, lower market values, net 
outflows and the divestiture of CenterSquare and 
other changes.  Net long-term outflows of $4 billion 
in 2018 were a result of $34 billion of outflows from 
index funds and $30 billion of inflows from actively 
managed strategies, primarily liability-driven 
investments.

Total revenue of $4.1 billion increased 2% compared 
with 2017. 

Asset Management revenue of $2.8 billion increased 
2% compared with the 2017, primarily reflecting 
higher market values, performance fees and the 
favorable impact of a weaker U.S. dollar (principally 
versus the British pound), partially offset by the 
impact of net outflows.  Market and regulatory trends 
have resulted in increased demand for lower fee asset 
management products, and for performance-based 
fees.  

Wealth Management revenue of $1.2 billion increased 
2% compared with 2017, primarily reflecting higher 
equity market values and net new business, partially 
offset by lower net interest revenue. 

Revenue generated in the Investment Management 
business included 42% from non-U.S. sources in 
2018, compared with 41% in 2017.

Noninterest expense of $2.8 billion decreased 1% 
compared with 2017, primarily reflecting the 
divestiture of CenterSquare.

2017 compared with 2016

Total revenue of $4.0 billion increased 7% compared 
with 2016.  Asset Management revenue increased 
primarily reflecting higher equity market values, 
money market fees and performance fees, partially 
offset by the unfavorable impact of a stronger U.S. 
dollar (principally versus the British pound).  Wealth 
management revenue increased primarily reflecting 
higher equity market values and net interest revenue.  

Noninterest expense of $2.9 billion increased 3% 
primarily reflecting higher incentive, distribution and 
servicing and severance expenses, partially offset by 
the favorable impact of a stronger U.S. dollar.  

BNY Mellon 19 

Results of Operations (continued)

Other segment

(in millions)
Fee revenue
Net securities (losses) gains

Total fee and other revenue
Net interest (expense) revenue
Total revenue (loss)
Provision for credit losses
Noninterest expense

(Loss) income before taxes

Average loans and leases

Description of segment

The Other segment primarily includes:

• 
• 

• 
• 
• 
• 

the leasing portfolio;
corporate treasury activities, including our 
securities portfolio;
derivatives and other trading activity;
corporate and bank-owned life insurance;
renewable energy investments; and
business exits.

Revenue primarily reflects:

• 

• 

• 

• 

net interest revenue and lease-related gains 
(losses) from leasing operations;
net interest revenue from corporate treasury 
activity;
fee and other revenue from corporate and bank- 
owned life insurance and business exits; and
gains (losses) associated with investment 
securities and other assets, including renewable 
energy.

Expenses include:

• 

• 

direct expenses supporting leasing, investing, and 
funding activities; and
expenses not directly attributable to Investment 
Services and Investment Management operations.  

Review of financial results 

Loss before taxes was $298 million in 2018 compared 
with $400 million in 2017.

 20 BNY Mellon

2018
133 $
(48)
85
(64)
21
(15)
334
(298) $

2017

4 $
3
7
(79)
(72)
(19)
347
(400) $

2016
291
75
366
14
380
(25)
394
11

2,105 $

1,232 $

1,926

$

$

$

Fee revenue increased $129 million compared with 
2017, primarily reflecting the impact of U.S. tax 
legislation on our renewable energy investments 
recorded in 2017.  

Net securities losses of $48 million in 2018 primarily 
related to the sale of debt securities.

Net interest expense decreased $15 million compared 
with 2017, primarily resulting from lease-related 
adjustments recorded in 2017.

Noninterest expense decreased $13 million compared 
with 2017, primarily reflecting lower pension 
expense and a methodological change in 2017 for 
allocating employee benefits expense to the business 
segments with no impact to consolidated results, 
partially offset by expenses associated with relocating 
our corporate headquarters. 

2017 compared with 2016

Loss before taxes was $400 million in 2017 compared 
with income before taxes of $11 million in 2016.  
Total fee and other revenue decreased primarily 
reflecting the impact of U.S. tax legislation on our 
investments in renewable energy investments and 
lower net securities gains.  Net interest expense 
increased primarily reflecting the impact of interest 
rate hedging activities and lease-related adjustments, 
partially offset by higher interest rates.  Noninterest 
expense decreased primarily reflecting lower staff 
and other expense.

Results of Operations (continued)

International operations

Our primary international activities consist of asset 
servicing and global payment services in our 
Investment Services business and asset management 
in our Investment Management business.  

Our clients include central banks and sovereigns, 
financial institutions, asset managers, insurance 
companies, corporations, local authorities and high 
net worth individuals and family offices.  Through 
our global network of offices, we have developed a 
deep understanding of local requirements and cultural 
needs, and we pride ourselves on providing dedicated 
service through our multilingual sales, marketing and 
client service teams.

At Dec. 31, 2018, we had approximately 9,100 
employees in Europe, the Middle East and Africa 
(“EMEA”), approximately 14,500 employees in the 
Asia-Pacific region (“APAC”) and approximately 700 
employees in other global locations, primarily Brazil. 

We are the seventh largest global asset manager.  At 
Dec. 31, 2018, our international operations managed 
55% of BNY Mellon’s AUM, compared with 51% at 
Dec. 31, 2017.  The proportionate increase in 
international AUM primarily resulted from the 
reduction in domestic AUM and net inflows, partially 
offset by the unfavorable impact of a stronger U.S. 
dollar (principally versus the British pound).

In Europe, we maintain a presence in Undertakings 
for Collective Investment in Transferable Securities 
Directives (“UCITS”).  In Ireland, BNY Mellon 
provides fund administration services across 
domiciled and non-domiciled funds.  We offer a full 
range of tailored solutions for investment companies, 
financial institutions and institutional investors in 
Germany.  

We are a provider of non-U.S. government securities, 
fixed income and equities clearance, settling 
securities transactions directly in 8 different markets 
in Europe while for other markets using a high 
quality and established network of local agents.

We have extensive experience providing trade and 
cash services to financial institutions and central 
banks outside of the U.S.  In addition, we offer a 
broad range of servicing and fiduciary products to 
financial institutions, corporations and central banks 
depending on the state of market development.  In 
emerging markets, we lead with global payments and 

issuer services, introducing other products as the 
markets mature.  For more established markets, our 
focus is on global investment services.

We are also a full-service global provider of foreign 
exchange services, actively trading in over 100 of the 
world’s currencies.  We serve clients from trading 
desks located in Europe, Asia and North America.

Our financial results, as well as our levels of AUC/A 
and AUM, are impacted by translation from foreign 
currencies to the U.S. dollar.  We are primarily 
impacted by activities denominated in the British 
pound and the euro.  If the U.S. dollar depreciates 
against these currencies, the translation impact is a 
higher level of fee revenue, net interest revenue, 
noninterest expense and AUC/A and AUM.  
Conversely, if the U.S. dollar appreciates, the 
translated levels of fee revenue, net interest revenue, 
noninterest expense and AUC/A and AUM will be 
lower.

Foreign exchange rates
vs. U.S. dollar
Spot rate (at Dec. 31):
British pound
Euro

Yearly average rate:

British pound
Euro

2018

2017

2016

$ 1.2801 $ 1.3532 $ 1.2323
1.0538
1.2009

1.1455

$ 1.3349 $ 1.2885 $ 1.3548
1.1065
1.1390

1.1808

International clients accounted for 37% of revenues 
in 2018, compared with 36% in 2017 and 34% in 
2016.  Net income from international operations was 
$2.2 billion in 2018, compared with $1.8 billion in 
2017 and $1.6 billion in 2016.

In 2018, revenues from EMEA were $4.3 billion, 
compared with $4.0 billion in 2017 and $3.7 billion 
2016.  Revenues from EMEA increased 7% in 2018 
compared with 2017, primarily reflecting higher 
revenue in the Investment Services business, driven 
by higher net interest revenue, the favorable impact 
of a weaker U.S. dollar, growth in collateral 
management and higher clearance volumes.  
Revenues from EMEA also reflect higher revenue in 
the Investment Management business, driven by the 
favorable impact of a weaker U.S. dollar and higher 
performance fees, partially offset by net outflows.  
Our Investment Services and Investment 
Management businesses generated 68% and 32% of 
EMEA revenues, respectively.  Net income from 
EMEA was $1.3 billion in 2018, compared with $1.2 
billion in 2017 and $1.0 billion in 2016.

BNY Mellon 21 

Results of Operations (continued)

Revenues from APAC were $1.1 billion in 2018, 
compared with $997 million in 2017 and $922 
million in 2016.  Revenues from APAC increased 
11% in 2018 compared with 2017, primarily 
reflecting higher net interest revenue, securities 
lending volumes and growth in collateral 
management, as well as higher revenue in the 
Investment Management business, driven by new 
business and higher equity market values.  Our 
Investment Services and Investment Management 
businesses generated 80% and 20% of APAC 
revenues, respectively.  Net income from APAC was 
$448 million in 2018, compared with $426 million in 
2017 and $389 million in 2016.

For additional information regarding our international 
operations, including certain key subjective 
assumptions used in determining the results, see Note 
24 of the Notes to Consolidated Financial Statements.

Country risk exposure

The following table presents BNY Mellon’s top 10 
exposures by country (excluding the U.S.) as of Dec. 
31, 2018, as well as certain countries with higher risk 
profiles, and is presented on an internal risk 
management basis.  We monitor our exposure to these 
and other countries as part of our internal country risk 
management process.  

The country risk exposure below reflects the 
Company’s risk to an immediate default of the 
counterparty or obligor based on the country of 
residence of the entity which incurs the liability.  If 
there is credit risk mitigation, the country of 
residence of the entity providing the risk mitigation is 
the country of risk.  The country of risk for 
investment securities is generally based on the 
domicile of the issuer of the security.

Country risk exposure
(in billions)
Top 10 country exposure:
UK
Germany
Japan
Canada
Luxembourg
China
Belgium
France
Ireland
Netherlands

Total Top 10 country exposure

Select country exposure:
Spain
Brazil
Italy
Turkey

Total other country exposure

Interest-bearing deposits

Central banks

Banks

Lending (a)

Investment 
securities (b)

Other (c)

Total
exposure

$

$

$

$

15.9 $
18.1
8.8
—
2.9
—
2.4
—
—
—
48.1 $

— $
—
—
—
— $

0.6
0.5
1.2
1.8
0.2
2.3
0.3
0.2
0.1
—
7.2

0.3
—
0.2
—
0.5

$

$

$

$

1.9
0.9
0.1
0.3
0.2
0.8
0.1
—
0.5
0.3
5.1

$

$

— $
1.3
—
0.2
1.5

$

2.9
2.4
—
2.2
—
—
0.3
2.3
0.6
1.7
12.4

1.4
0.1
0.9
—
2.4

$

$

$

$

2.1
0.3
0.2
0.9
1.8
0.3
—
0.6
1.1
0.1
7.4

$

$

23.4
22.2
10.3
5.2
5.1
3.4
3.1
3.1
2.3
2.1
80.2 (d)

— $
—
—
—
— $

1.7
1.4
1.1
0.2
4.4

(a)  Lending includes loans, acceptances, issued letters of credit, net of participations, and lending-related commitments. 
(b)  Investment securities include both the available-for-sale and held-to-maturity portfolios.
(c)  Other exposures include securities financing and over-the-counter (“OTC”) derivative transactions, net of collateral.
(d)  The top 10 country exposures comprise approximately 80% of our total non-U.S. exposure.

Our largest country risk exposure, based on our 
internal country risk management process at Dec. 31, 
2018, was to the UK, which is planning to withdraw 
from the EU.  For additional information, see “United 
Kingdom’s Withdrawal from the European Union 
(“Brexit”)” in Supervision and Regulation and “The 
United Kingdom’s referendum decision to leave the 
EU has had and may continue to have negative effects 
on global economic conditions, global financial 

markets, and our business and results of operations” 
in Risk Factors.

Select country exposure

Events in recent years have resulted in increased 
focus on Spain, Brazil, Italy and Turkey.  The country 
risk exposure to Spain and Italy primarily consisted 
of investment grade sovereign debt.  The country risk 

 22 BNY Mellon

Results of Operations (continued)

exposure to Brazil is primarily short-term trade 
finance loans extended to large financial institutions.  
We also have operations in Brazil providing 
investment services and investment management 
services.  The country risk exposure to Turkey 
consists primarily of syndicated credit facilities.  We 
mainly provide treasury and issuer services as well as 
foreign exchange products primarily to the top 10 
largest financial institutions in Turkey.  

Cross-border outstandings

Cross-border outstandings are based on the Federal 
Financial Institutions Examination Council’s 
(“FFIEC”) regulatory guidelines for reporting cross-
border risk and provides information on the 
distribution, by country and sector, of claims on 
foreign residents held by U.S. banks.  Under the 
FFIEC guidelines, cross-border outstandings are 
reported based on the domicile of the counterparty, 
issuer of collateral or guarantor.  Cross-border 
outstandings in the table below include claims of U.S. 
domiciled offices on foreign counterparties as well as 
claims of foreign offices on counterparties located 

outside those foreign jurisdictions.  The guidelines to 
determine the cross-border outstandings in the table 
below are different than how we determine and 
manage our country risk exposure.  For example, 
unfunded loan commitments as well as central bank 
deposits made by our foreign bank subsidiaries in 
their local jurisdiction are not considered cross-border 
outstandings.  As a result, the cross-border 
outstandings in the table below are not comparable to 
the country risk exposure in the previous section.

Foreign assets are subject to the general risks 
attendant on the conduct of business in each foreign 
country, including economic uncertainties and each 
foreign government’s regulations.  In addition, our 
foreign assets may be affected by changes in demand 
or pricing resulting from fluctuations in currency 
exchange rates or other factors.  

The table below shows our cross-border outstandings 
at Dec. 31 of each of the last three years where cross-
border exposure exceeds 1.00% of total assets 
(denoted with “*”) or exceeds 0.75% but less than or 
equal to 1.00% of total assets (denoted with “**”).

Cross-border outstandings

(in millions)
2018:

Canada*
Germany**
China**

2017:

Germany**
Canada**
France**

2016:

France*
Germany*
Canada*
United Kingdom**

Banks and 
other financial 
institutions (a)

$

$

$

1,888
1,655
3,030

1,530
2,256
295

1,662
2,398
2,199
1,325

$

$

$

Public
sector

381
736
—

1,344
1
2,519

2,559
1,408
1
1,584

Commercial, 
industrial 
and other

Total 
cross-border
outstandings (b)

$

$

$

2,263
1,079
5

600
1,170
130

109
357
1,211
405

$

$

$

4,532
3,470
3,035

3,474
3,427
2,944

4,330
4,163
3,411
3,314

(a)  Primarily short-term interest-bearing deposits with banks.  Also includes global trade finance loans.
(b)  Excludes assets of consolidated investment management funds.

Emerging markets exposure

Critical accounting estimates

We determine our emerging markets exposures using 
the MSCI Emerging Markets (EM) IMI Index.  Our 
emerging markets exposures totaled $11 billion at 
both Dec. 31, 2018 and Dec. 31, 2017, as higher 
interest-bearing deposits with banks in Mexico and 
China were offset by lower loans to banks in India 
and Turkey.

Our significant accounting policies are described in 
Note 1 of the Notes to Consolidated Financial 
Statements under “Summary of significant 
accounting and reporting policies.”  Our critical 
accounting estimates are those related to the 
allowance for loan losses and allowance for lending-
related commitments, fair value of financial 
instruments and derivatives, goodwill and other 
intangibles, and litigation and regulatory 

BNY Mellon 23 

Results of Operations (continued)

contingencies.  Further information on policies 
related to the allowance for loan losses and allowance 
for lending-related commitments can be found under 
“Summary of significant accounting and reporting 
policies” in Note 1 of the Notes to Consolidated 
Financial Statements.  Additionally, further 
information can be found in the Notes to 
Consolidated Financial Statements related to the 
following: the valuation of derivatives and securities 
can be found under “Fair value measurement” in Note 
19; and policies related to goodwill and intangible 
assets can be found in “Goodwill and intangible 
assets” in Note 6.

Allowance for loan losses and allowance for 
lending-related commitments

The allowance for loan losses and allowance for 
lending-related commitments represent 
management’s estimate of losses inherent in our 
credit portfolio.  This evaluation process is subject to 
numerous estimates and judgments.  

We utilize a quantitative methodology and qualitative 
framework for determining the allowance for loan 
losses and the allowance for lending-related 
commitments.  Within this qualitative framework, 
management applies judgment when assessing 
internal risk factors and environmental factors to 
compute an additional allowance for each component 
of the loan portfolio. 

The components of the allowance for loan losses and 
the allowance for lending-related commitments are 
inclusive of the qualitative allowance framework and 
consist of the following three elements: 
• 

an allowance for impaired credits of $1 million or 
greater;   
an allowance for higher risk-rated credits and 
pass-rated credits; and   
an allowance for residential mortgage loans. 

• 

• 

Our lending is primarily to institutional customers.  
As a result, our loans are generally larger than $1 
million.  Therefore, the first element, impaired 
credits, is based on individual analysis of all impaired 
loans of $1 million or greater.  The allowance is 
measured by the difference between the recorded 
value of impaired loans and their impaired value.  
Impaired value is either the present value of the 
expected future cash flows from the borrower, the 
market value of the loan, or the fair value of the 
collateral, if the loan is collateral dependent.  

 24 BNY Mellon

The second element, higher risk-rated credits and 
pass-rated credits, is based on our incurred loss 
model.  Individual credit analyses are performed on 
such loans before being assigned a credit rating.  All 
borrowers are collectively evaluated based on their 
credit rating.  The loss inherent in each loan 
incorporates the borrower’s credit rating, facility 
rating and maturity.  The loss given default, derived 
from the facility rating, incorporates a recovery 
expectation and an estimate of the use of the facility 
at default (usage given default).  The borrower’s 
probability of default is derived from the associated 
credit rating.  Borrower ratings are reviewed at least 
annually and are periodically mapped to third-party 
databases, including rating agency and default and 
recovery databases, for ongoing consistency and 
validity.  Higher risk-rated credits are reviewed 
quarterly.  

The third element, the allowance for residential 
mortgage loans, is determined by segregating six 
mortgage pools into delinquency periods, ranging 
from current through foreclosure.  Each of these 
delinquency periods is assigned a probability of 
default.  A specific loss given default is assigned for 
each mortgage pool.  BNY Mellon assigns all 
residential mortgage pools, except home equity lines 
of credit, a probability of default and loss given 
default based on default and loss data derived from 
internal historical data related to our residential 
mortgage portfolio.  The resulting incurred loss factor 
(the probability of default multiplied by the loss given 
default) is applied against the loan balance to 
determine the allowance held for each pool.  For 
home equity lines of credit, probability of default and 
loss given default are based on external data from 
third-party databases due to the small size of the 
portfolio and insufficient internal data.  

The qualitative framework is used to determine an 
additional allowance for each portfolio based on the 
factors below:  

Internal risk factors:  

•  Ratio of nonperforming loans to total non-margin 

loans;  

•  Ratio of criticized assets to total loans and 

lending-related commitments;  

•  Borrower concentration; and  
•  Significant concentrations in high-risk industries 

and countries.  

Results of Operations (continued)

Environmental risk factors: 

•  U.S. non-investment grade default rate; 
•  Unemployment rate; and 
•  Change in real gross domestic product. 

The objective of the qualitative framework is to 
capture incurred losses that may not have been fully 
captured in the quantitative reserve, which is based 
primarily on historical data.  Management determines 
the qualitative allowance each period based on 
judgment informed by consideration of internal and 
external risk factors and other considerations that 
may be deemed relevant during the period.  Once 
determined in the aggregate, our qualitative 
allowance is then allocated to each of our loan classes 
based on the respective classes’ quantitative 
allowance balances with the allocations adjusted, 
when necessary, for class specific risk factors.  

For each risk factor, we calculate the minimum and 
maximum values, and percentiles in-between, to 
evaluate the distribution of our historical experience.  
The distribution of historical experience is compared 
to the risk factor’s current quarter observed 
experience to assess the current risk inherent in the 
portfolio and overall direction/trend of a risk factor 
relative to our historical experience.

Based on this analysis, we assign a risk level–no 
impact, low, moderate, high and elevated–to each risk 
factor for the current quarter.  Management assesses 
the impact of each risk factor to determine an 
aggregate risk level.  We do not quantify the impact 
of any particular risk factor.  Management’s 
assessment of the risk factors, as well as the trend in 
the quantitative allowance, supports management’s 
judgment for the overall required qualitative 
allowance.  A smaller qualitative allowance may be 
required when our quantitative allowance has 
reflected incurred losses associated with the 
aggregate risk level.  A greater qualitative allowance 
may be required if our quantitative allowance does 
not yet reflect the incurred losses associated with the 
aggregate risk level. 

To the extent actual results differ from forecasts or 
management’s judgment, the allowance for credit 
losses may be greater or less than future charge-offs.  

The credit rating assigned to each credit is a 
significant variable in determining the allowance.  If 
each credit were rated one grade better, the allowance 
would have decreased by $62 million, while if each 

credit were rated one grade worse, the allowance 
would have increased by $99 million.  Similarly, if 
the loss given default were one rating worse, the 
allowance would have increased by $40 million, 
while if the loss given default were one rating better, 
the allowance would have decreased by $31 million.  
For impaired credits, if the net carrying value of the 
loans was 10% higher or lower, the allowance would 
have decreased or increased by less than $1 million, 
respectively.

Fair value of financial instruments and 
derivatives

The guidance included in Accounting Standards 
Codification (“ASC”) 820, Fair Value Measurement, 
defines fair value, establishes a framework for 
measuring fair value, and expands disclosures about 
assets and liabilities measured at fair value.  The 
standard also established a three-level hierarchy for 
fair value measurements based upon the transparency 
of inputs to the valuation of an asset or liability as of 
the measurement date.  

Fair value - Securities

Level 1 - Securities:  Securities where valuations are 
based on recent quoted prices for identical securities 
in actively traded markets.

Level 2 - Securities:  For securities where quotes from 
recent transactions are not available for identical 
securities, we determine fair value primarily based on 
pricing sources with reasonable levels of price 
transparency.  The pricing sources employ financial 
models or obtain comparisons to similar instruments 
to arrive at “consensus” prices.

Specifically, the pricing sources obtain recent 
transactions for similar types of securities (e.g., 
vintage or position in the securitization structure) and 
ascertain variables such as discount rate and speed of 
prepayment for the type of transaction and apply such 
variables to similar types of bonds.  We view these as 
observable transactions in the current market place 
and classify such securities as Level 2.

In addition, we have significant investments in more 
actively traded agency residential mortgage-backed 
securities (“RMBS”) and other types of securities 
such as sovereign debt.  The pricing sources derive 
the prices for these securities largely from quotes they 
obtain from three major inter-dealer brokers.  The 

BNY Mellon 25 

Results of Operations (continued)

pricing sources receive their daily observed trade 
price and other information feeds from the inter-
dealer brokers.

See Note 19 of the Notes to Consolidated Financial 
Statements for details of our securities by ASC 820, 
Fair Value Measurement, hierarchy level.

We obtain prices for our Level 1 and Level 2 
securities from multiple pricing sources.  We have 
designed controls to develop an understanding of the 
pricing sources’ securities pricing methodology and 
have implemented specific internal controls over the 
valuation of securities. 

As appropriate, we review the quality control 
procedures and pricing methodologies used by the 
pricing sources, including the process for obtaining 
prices provided by the pricing sources, their valuation 
methodology and controls for each class of security. 

Prices received from pricing sources are subject to 
validation checks that help determine the 
completeness and accuracy of the prices.  These 
validation checks are reviewed by management and, 
based on the results, may be subject to additional 
review and investigation.  We also review securities 
with no price changes (stale prices) and securities 
with zero values.

We have a surveillance process in place to monitor 
the reasonableness of prices provided by the pricing 
sources.  We utilize a hierarchy that compares 
security prices obtained from multiple pricing sources 
against established thresholds.  Discrepancies that fall 
outside of these thresholds are challenged with the 
pricing services and adjusted if necessary.  

If further research is required, we review and validate 
these prices with the pricing sources.  We also 
validate prices from pricing sources by comparing 
prices received to actual observed prices from actions 
such as purchases and sales, when possible.

At Dec. 31, 2018, approximately 99% of our 
securities were valued by pricing sources with 
reasonable levels of price transparency.

Level 3 - Securities:  Where we have used our own 
cash flow models, which included a significant input 
into the model that was deemed unobservable, to 
estimate the value of securities, we classify them as 
Level 3.  At both Dec. 31, 2018 and Dec. 31, 2017, 
we have no securities included in Level 3 of the fair 
value hierarchy.

 26 BNY Mellon

Fair value - Derivative financial instruments

Level 1 - Derivative financial instruments:  Includes 
derivative financial instruments that are actively 
traded on exchanges, principally listed equity options.

Level 2 - Derivative financial instruments:  Includes 
OTC derivative financial instruments.  Derivatives 
classified as Level 2 are valued utilizing discounted 
cash flow analysis and financial models for which the 
valuation inputs are observable or can be 
corroborated, directly or indirectly, for substantially 
the full term of the instrument.  Valuation inputs 
include interest rate yield curves, foreign exchange 
rates, equity prices, credit curves, option volatilities 
and other factors.  

Where appropriate, valuation adjustments are made to 
account for various factors such as creditworthiness 
of the counterparty, creditworthiness of the Company 
and model and liquidity risks. 

Level 3 - Derivative financial instruments:  Level 3 
derivatives include derivatives for which valuations 
are based on inputs that are unobservable and 
significant to the overall fair value measurement, and 
may include certain long-dated or highly structured 
contracts.  At both Dec. 31, 2018 and Dec. 31, 2017, 
we have no derivatives included in Level 3 of the fair 
value hierarchy.

For details of our derivative financial instruments by 
level of the valuation hierarchy, see Note 19 of the 
Notes to Consolidated Financial Statements.

Fair value option

ASC 825, Financial Instruments, provides the option 
to elect fair value as an alternative measurement basis 
for selected financial assets and financial liabilities 
which are not subject to fair value under other 
accounting standards.  The changes in fair value are 
recognized in income.  See Note 20 of the Notes to 
Consolidated Financial Statements for additional 
disclosure regarding the fair value option.

Results of Operations (continued)

Fair value - Judgments

In times of illiquid markets and financial stress, 
actual prices and valuations may significantly diverge 
from results predicted by models.  In addition, other 
factors can affect our estimate of fair value, including 
market dislocations and unexpected correlations.  The 
use of different methodologies or different 
assumptions to value certain financial instruments 
could result in a different estimate of fair value.  See 
Note 1 of the Notes to Consolidated Financial 
Statements.

Goodwill and other intangibles

We initially record all assets and liabilities acquired 
in purchase acquisitions, including goodwill, 
indefinite-lived intangibles and other intangibles, in 
accordance with ASC 805, Business Combinations.  
Goodwill, indefinite-lived intangibles and other 
intangibles are subsequently accounted for in 
accordance with ASC 350, Intangibles - Goodwill 
and Other.  The initial measurement of goodwill and 
intangibles requires judgment concerning estimates of 
the fair value of the acquired assets and liabilities.  
Goodwill ($17.4 billion at Dec. 31, 2018) and 
indefinite-lived intangible assets ($2.6 billion at Dec. 
31, 2018) are not amortized but are subject to tests for 
impairment annually or more often if events or 
circumstances indicate it is more likely than not they 
may be impaired.  Other intangible assets are 
amortized over their estimated useful lives and are 
subject to impairment if events or circumstances 
indicate a possible inability to realize the carrying 
value. 

BNY Mellon’s three business segments include seven 
reporting units for which annual goodwill impairment 
testing is performed in accordance with ASC 350, 
Intangibles - Goodwill and Other.  The Investment 
Management segment is comprised of two reporting 
units; the Investment Services segment is comprised 
of four reporting units and one reporting unit is 
included in the Other segment. 

The goodwill impairment test compares the estimated 
fair value of the reporting unit with its carrying 
amount, including goodwill.  If the estimated fair 
value of the reporting unit exceeds its carrying 
amount, goodwill of the reporting unit is considered 
not impaired.  However, if the carrying amount of the 
reporting unit were to exceed its estimated fair value, 
an impairment loss would be recorded.  A substantial 

goodwill impairment charge would not have a 
significant impact on our financial condition or our 
regulatory capital ratios, but could have an adverse 
impact on our results of operations.  In addition, due 
to regulatory restrictions, the Company’s subsidiary 
banks could be restricted from distributing available 
cash to the Parent, resulting in the Parent needing to 
issue additional long-term debt. 

In the second quarter of 2018, we performed our 
annual goodwill test on all seven reporting units using 
an income approach to estimate the fair values of 
each reporting unit.  Estimated cash flows used in the 
income approach were based on management’s 
projections as of March 31, 2018.  The discount rate 
applied to these cash flows ranged from 10.0% to 
10.25% and incorporated a 6.0% market equity risk 
premium.  Estimated cash flows extend many years 
into the future, and, by their nature, are difficult to 
estimate over such an extended time frame. 

As a result of the annual goodwill impairment test of 
the seven reporting units, no goodwill impairment 
was recognized.  The fair value of the Asset 
Management reporting unit, which is one of the two 
reporting units in the Investment Management 
segment, exceeded its carrying value by 34%.  The 
Asset Management reporting unit had $7.4 billion of 
allocated goodwill.  For the Asset Management 
reporting unit, in the future, changes in the 
assumptions, such as changes in the level of AUM 
and operating margin, could produce a non-cash 
goodwill impairment. 

Key judgments in accounting for intangibles include 
useful life and classification between goodwill and 
indefinite-lived intangibles or other intangibles 
requiring amortization. 

Indefinite-lived intangible assets are evaluated for 
impairment at least annually by comparing their fair 
values, estimated using discounted cash flow 
analyses, to their carrying values.  Other amortizing 
intangible assets ($600 million at Dec. 31, 2018) are 
evaluated for impairment if events and circumstances 
indicate a possible impairment.  Such evaluation of 
other intangible assets would be initially based on 
undiscounted cash flow projections. 

See Notes 1 and 6 of the Notes to Consolidated 
Financial Statements for additional information 
regarding goodwill, intangible assets and the annual 
and interim impairment testing. 

BNY Mellon 27 

Results of Operations (continued)

Litigation and regulatory contingencies

Significant estimates and judgments are required in 
establishing an accrued liability for litigation and 
regulatory contingencies.  For additional information 
on our policy, see “Legal proceedings” in Note 21 of 
the Notes to Consolidated Financial Statements.

Consolidated balance sheet review

One of our key risk management objectives is to 
maintain a balance sheet that remains strong 
throughout market cycles to meet the expectations of 
our major stakeholders, including our shareholders, 
clients, creditors and regulators. 

We also seek to verify that the overall liquidity risk, 
including intraday liquidity risk, that we undertake 
stays within our risk appetite.  The objective of our 
balance sheet management strategy is to maintain a 
balance sheet that is characterized by strong liquidity 
and asset quality, ready access to external funding 
sources at competitive rates and a strong capital 
structure that supports our risk-taking activities and is 
adequate to absorb potential losses.  In managing the 
balance sheet, appropriate consideration is given to 
balancing the competing needs of maintaining 
sufficient levels of liquidity and complying with 
applicable regulations and supervisory expectations 
while optimizing profitability.  

In 2018, we continued to maintain sufficient liquidity 
and comply with applicable regulations.  Our overall 
liquidity position remained strong and is managed in 
accordance with the nature of our balance sheet and 
business model.  Our liquidity coverage ratio 
(“LCR”) averaged 118% in the fourth quarter and the 
SLR was 6.0% at Dec. 31, 2018. 

At Dec. 31, 2018, total assets were $363 billion, 
compared with $372 billion at Dec. 31, 2017.  The 
decrease in total assets was primarily driven by lower 
interest-bearing deposits with the Federal Reserve 
and other central banks and loans, partially offset by 
higher federal funds sold and securities purchased 
under resale agreements.  Deposits totaled $239 
billion at Dec. 31, 2018, compared with $244 billion 
at Dec. 31, 2017.  The decrease primarily reflects 
lower interest-bearing deposits in non-U.S. offices 
and noninterest-bearing deposits principally in U.S. 
offices, partially offset by higher interest-bearing 

 28 BNY Mellon

deposits in U.S. offices.  At Dec. 31, 2018, total 
interest-bearing deposits were 54% of total interest-
earning assets, compared with 51% at Dec. 31, 2017.

At Dec. 31, 2018, we had $61 billion of liquid funds 
(which include interest-bearing deposits with banks 
and federal funds sold and securities purchased under 
resale agreements) and $74 billion of cash (including 
$68 billion of overnight deposits with the Federal 
Reserve and other central banks) for a total of $135 
billion of available funds.  This compares with 
available funds of $137 billion at Dec. 31, 2017.  
Total available funds as a percentage of total assets 
were 37% at both Dec. 31, 2018 and Dec. 31, 2017.  
For additional information on our liquid funds and 
available funds, see “Liquidity and dividends.”

Securities were $119.8 billion, or 33% of total assets, 
at Dec. 31, 2018, compared with $120.4 billion, or 
32% of total assets, at Dec. 31, 2017.  The decrease 
primarily reflects lower investment in sovereign debt/
sovereign guaranteed securities and additional 
unrealized losses on the portfolio, partially offset by 
additional investments in agency commercial 
mortgage-backed securities (“MBS”), supranational 
securities and agency RMBS.  For additional 
information on our securities portfolio, see 
“Securities” and Note 4 of the Notes to Consolidated 
Financial Statements.

Loans were $57 billion, or 16% of total assets, at 
Dec. 31, 2018, compared with $62 billion, or 17% of 
total assets, at Dec. 31, 2017.  The decrease was 
primarily driven by lower margin loans and loans to 
financial institutions.  For additional information on 
our loan portfolio, see “Loans” and Note 5 of the 
Notes to Consolidated Financial Statements.

Long-term debt totaled $29 billion at Dec. 31, 2018 
and $28 billion at Dec. 31, 2017.  The balance reflects 
issuances of $5.2 billion, offset by maturities of $3.7 
billion and a decrease in the fair value of hedged 
long-term debt.  For additional information on long-
term debt, see “Liquidity and dividends.”

The Bank of New York Mellon Corporation total 
shareholders’ equity decreased to $40.6 billion from 
$41.3 billion at Dec. 31, 2017.  For additional 
information on our capital, see “Capital” and Note 14 
of the Notes to Consolidated Financial Statements. 

Results of Operations (continued)

Securities

In the discussion of our securities portfolio, we have 
included certain credit ratings information because 
the information can indicate the degree of credit risk 

to which we are exposed.  Significant changes in 
ratings classifications for our securities portfolio 
could indicate increased credit risk for us and could 
be accompanied by a reduction in the fair value of our 
securities portfolio.  

The following table shows the distribution of our total securities portfolio.

Securities portfolio

(dollars in millions)

Agency RMBS
U.S. Treasury
Sovereign debt/sovereign 

guaranteed (c)

Agency commercial MBS
CLOs
U.S. government agencies
Supranational
Foreign covered bonds (d)
State and political

subdivisions

Other asset-backed
securities (“ABS”)

Non-agency commercial

MBS

Non-agency RMBS (e)
Corporate bonds
Other (f)

Dec. 31,
2017

 Fair
value

$ 49,746
24,848

14,128

10,083
2,909
2,603
2,108
2,615

2,973

1,043

1,368

1,854
1,255
2,375

2018
change in
unrealized
gain (loss)

$

(423) $
(22)

Dec. 31, 2018

Amortized
cost

Fair
value
51,101 $ 50,214
24,792
24,917

Fair value
as a % of 
amortized
cost (a)

Ratings (b)

Unrealized
gain (loss)

AAA/
AA-

A+/
A-

BBB+/
BBB-

BB+
and
lower

Not
rated

98 % $
99

(887)
(125)

100 % — % — % — % — %
—
100 —

— —

(49)

(50)
(57)
(49)
—
(22)

(11)

11,496

11,031
3,410
3,173
3,011
2,970

11,577

10,947
3,364
3,157
3,006
2,959

2,268

2,264

(6)

1,776

1,773

(23)

(83)
(26)
(1)

1,491

1,195
1,074
1,236

1,470

1,427
1,054
1,238

101

99
99
99
100
100

100

100

99

119
98
100

81

(84)
(46)
(16)
(5)
(11)

(4)

(3)

(21)

232
(20)
2

74

5

100 —
98 —
100 —
100 —
100 —

78

21

99 —

96

4

12
12
68
14
94 —
95% 2%

20

—
—
—
—
—

—

1

—

1 —

— —
1
1
— —
— —
— —

—

1

— —

— —

47
24
— —
6
—

5
18
—
2% 1% —%

Total securities

$ 119,908 (g) $

(822) $ 120,149 $ 119,242 (g)

99% $

(907) (g)(h)

(a)  Amortized cost reflects historical impairments.
(b)  Represents ratings by Standard & Poor's (“S&P”) or the equivalent.
(c)  Primarily consists of exposure to UK, France, Germany, Spain, Italy and the Netherlands.
(d)  Primarily consists of exposure to Canada, UK, Australia and Sweden.
(e) 
(f) 

Includes RMBS that were included in the former Grantor Trust of $1,091 million at Dec. 31, 2017 and $832 million at Dec. 31, 2018. 
Includes commercial paper with a fair value of $700 million and money market funds with a fair value of $963 million at Dec. 31, 2017.  There was no 
commercial paper or money market funds at Dec. 31, 2018.  In the first quarter of 2018, we adopted the new accounting guidance included in ASU 
2016-01, Financial Instruments-Overall: Recognition and Measurement of Financial Assets and Financial Liabilities.  As a result, the money market fund 
investments were reclassified to trading assets, primarily from available-for-sale securities.
Includes net unrealized losses on derivatives hedging securities available-for-sale of $147 million at Dec. 31, 2017 and net unrealized gains of $131 
million at Dec. 31, 2018.

(g) 

(h)  Unrealized losses of $227 million at Dec. 31, 2018 related to available-for-sale securities, net of hedges.

The fair value of our securities portfolio, including 
related hedges, was $119.2 billion at Dec. 31, 2018, 
compared with $119.9 billion at Dec. 31, 2017.  The 
decrease primarily reflects lower investment in 
sovereign debt/sovereign guaranteed securities and 
additional unrealized losses on the portfolio, partially 
offset by additional investments in agency 
commercial MBS, supranational securities and 
agency RMBS. 

including the impact of related hedges.  The increase 
in the net unrealized pre-tax loss was primarily driven 
by higher market interest rates.

The unrealized loss, net of tax, on our available-for-
sale securities portfolio included in accumulated other 
comprehensive income (“OCI”) was $167 million at 
Dec. 31, 2018, compared with an unrealized gain of 
$184 million at Dec. 31, 2017.

At Dec. 31, 2018, the total securities portfolio had a 
net unrealized loss of $907 million, compared with a 
net unrealized loss of $85 million at Dec. 31, 2017, 

At Dec. 31, 2018, 95% of the securities in our 
portfolio were rated AAA/AA-, compared with 93% 
at Dec. 31, 2017.  

BNY Mellon 29 

Results of Operations (continued)

The following table presents the amortizable purchase premium (net of discount) related to the securities portfolio 
and accretable discount related to the 2009 restructuring of the securities portfolio.

Net premium amortization and discount accretion of securities (a)
(dollars in millions)
Amortizable purchase premium (net of discount) relating to securities:

Balance at period end
Estimated average life remaining at period end (in years)
Amortization

Accretable discount related to the prior restructuring of the securities portfolio:

2018

2017

2016

$

$

1,429 $
5.0
437 $

1,987 $
5.0
547 $

2,188
4.9
641

Balance at period end
Estimated average life remaining at period end (in years)
Accretion

315
6.2
102
(a)  Amortization of purchase premium decreases net interest revenue while accretion of discount increases net interest revenue.  Both were 

274 $
6.3
100 $

207 $
6.3
86 $

$

$

Renewable energy investments 

We invest in renewable energy projects to receive an 
expected after-tax return, which consists of allocated 
renewable energy tax credits, tax deductions and cash 
distributions based on the operations of the project.  
The pre-tax losses on these investments are recorded 
in investment and other income on the consolidated 
income statement.  The corresponding tax benefits 
and credits are recorded to the provision for income 
taxes on the consolidated income statement.  

For additional information on the fair value of certain 
seed capital investments and our private equity 
investments, see Note 7 of the Notes to Consolidated 
Financial Statements.

recorded on a level yield basis.

See Note 4 of the Notes to Consolidated Financial 
Statements for the pre-tax net securities gains (losses) 
by security type.  See Note 19 of the Notes to 
Consolidated Financial Statements for details of 
securities by level in the fair value hierarchy.

Equity investments

We have several equity investments recorded in other 
assets.  These include equity method investments, 
including renewable energy, and investments in 
qualified affordable housing projects, Federal 
Reserve Bank stock, seed capital, private equity and 
other investments.  The following table presents the 
carrying values at Dec. 31, 2018 and 2017.

Equity investments
(in millions)
Renewable energy investments
Equity in a joint venture and other

investments:
CIBC Mellon
Siguler Guff
Other equity investments

Dec. 31,

2018

2017
$ 1,264 $ 1,368

548
244
272

580
246
257

Total equity in a joint venture and other
investments

$ 1,064 $ 1,083

Qualified affordable housing project
investments

Federal Reserve Bank stock
Seed capital
Federal Home Loan Bank stock
Private equity investments (a)
Total equity investments

999
484
224
111
74

1,014
477
288
82
55
$ 4,220 $ 4,367

(a)  Represents investments in small business investment 

companies (“SBICs”), which are compliant with the Volcker 
Rule.

 30 BNY Mellon

Results of Operations (continued)

Loans 

Total exposure – consolidated

(in billions)
Non-margin loans:

Financial institutions
Commercial

Subtotal institutional

Wealth management loans and mortgages
Commercial real estate
Lease financings
Other residential mortgages
Overdrafts
Other

Subtotal non-margin loans

Margin loans
Total

Dec. 31, 2018
Unfunded
commitments

Loans

Total
exposure

Dec. 31, 2017
Unfunded
commitments

Loans

Total
exposure

$

$

11.6 $
2.1
13.7
16.0
4.8
1.3
0.6
5.5
1.2
43.1
13.5
56.6 $

34.0 $
15.2
49.2
0.8
3.5
—
—
—
—
53.5
0.1
53.6 $

45.6
17.3
62.9
16.8
8.3
1.3
0.6
5.5
1.2
96.6
13.6
110.2

$

$

13.1 $
2.9
16.0
16.5
4.9
1.3
0.7
5.1
1.2
45.7
15.8
61.5 $

32.5 $
18.0
50.5
1.1
3.5
—
—
—
—
55.1
—
55.1 $

45.6
20.9
66.5
17.6
8.4
1.3
0.7
5.1
1.2
100.8
15.8
116.6  

At Dec. 31, 2018, total exposures of $110.2 billion 
decreased 5% compared with Dec. 31, 2017, 
primarily reflecting lower exposure in the commercial 
and margin loan portfolios. 

Our financial institutions and commercial portfolios 
comprise our largest concentrated risk.  These 
portfolios comprised 57% of our total exposure at 
both Dec. 31, 2018 and Dec. 31, 2017.  Additionally, 
most of our overdrafts relate to financial institutions.

Financial institutions

The financial institutions portfolio is shown below.

Financial institutions
portfolio exposure

(dollars in billions)
Securities industry
Banks
Asset managers
Insurance
Government
Other

Total

Loans

Unfunded
commitments

% due
<1 yr.

Loans

Dec. 31, 2017
Unfunded
commitments

Dec. 31, 2018
Total
exposure
25.6
7.9
7.4
2.6
0.6
1.5
45.6

22.5 $
1.6
6.1
2.5
0.5
0.8
34.0 $

% Inv.
grade
99%
77
98
100
100
96
95%

99% $
94
85
8
38
48
88% $ 13.1 $

3.6 $
7.0
1.4
0.1
0.1
0.9

Total
exposure
22.8
8.2
7.8
3.6
1.0
2.2
45.6  

19.2 $
1.2
6.4
3.5
0.9
1.3
32.5 $

$

$

3.1 $
6.3
1.3
0.1
0.1
0.7
11.6 $

The financial institutions portfolio exposure was 
$45.6 billion at Dec. 31, 2018, unchanged from Dec. 
31, 2017, primarily reflecting an increase in securities 
industry exposure, offset by lower exposure in all 
other portfolios.

Financial institution exposures are high-quality, with 
95% of the exposures meeting the investment grade 
equivalent criteria of our internal credit rating 
classification at Dec. 31, 2018.  Each customer is 
assigned an internal credit rating, which is mapped to 
an equivalent external rating agency grade based 
upon a number of dimensions, which are continually 
evaluated and may change over time.  The exposure 

to financial institutions is generally short-term.  Of 
these exposures, 88% expire within one year and 20% 
expire within 90 days.  In addition, 81% of the 
financial institutions exposure is secured.  For 
example, securities industry clients and asset 
managers often borrow against marketable securities 
held in custody.

For ratings of non-U.S. counterparties, our internal 
credit rating is generally capped at a rating equivalent 
to the sovereign rating of the country where the 
counterparty resides, regardless of the internal credit 
rating assigned to the counterparty or the underlying 
collateral.

BNY Mellon 31 

Results of Operations (continued)

At Dec. 31, 2018, the secured intraday credit 
provided to dealers in connection with their tri-party 
repo activity totaled $20.6 billion and was primarily 
included in the securities industry portfolio.  Dealers 
secure the outstanding intraday credit with high-
quality liquid collateral having a market value in 
excess of the amount of the outstanding credit. 

Our bank exposure primarily relates to our global 
trade finance.  These exposures are short-term in 
nature, with 94% due in less than one year.  The 
investment grade percentage of our bank exposure 

Commercial

The commercial portfolio is presented below.

was 77% at Dec. 31, 2018, compared with 68% at 
Dec. 31, 2017.  Our non-investment grade exposures 
are primarily in Brazil.  These loans are primarily 
trade finance loans. 

The asset manager portfolio exposure was high-
quality, with 98% of the exposures meeting our 
investment grade equivalent ratings criteria as of Dec. 
31, 2018.  These exposures are generally short-term 
liquidity facilities, with the majority to regulated 
mutual funds. 

Commercial portfolio exposure

(dollars in billions)
Manufacturing
Services and other
Energy and utilities
Media and telecom

Total

Loans

Unfunded
commitments

$

$

0.8 $
0.7
0.5
0.1
2.1 $

Dec. 31, 2018
Total
exposure
5.9
5.5
4.6
1.3
17.3

5.1 $
4.8
4.1
1.2
15.2 $

% Inv.
grade
95%
96
95
94
95%

% due
<1 yr.

Loans

Dec. 31, 2017
Unfunded
commitments

8% $
25
12
12
15% $

1.3 $
0.9
0.7
—
2.9 $

Total
exposure
7.4
6.9
5.1
1.5
20.9  

6.1 $
6.0
4.4
1.5
18.0 $

The commercial portfolio exposure was $17.3 billion 
at Dec. 31, 2018, a 17% decrease compared with 
$20.9 billion at Dec. 31, 2017, primarily reflecting 
lower exposure in the manufacturing and services and 
other portfolios.

Utilities-related exposure represents approximately 
76% of the energy and utilities portfolio at Dec. 31, 
2018.  Included in this portfolio is unsecured funded 
exposure of approximately $160 million to a 
California utility company that filed for bankruptcy in 
the first quarter of 2019.  As of Feb. 27, 2019, we 
expect our exposure to this California utility company 
to decrease by approximately $60 million as a result 
of current sales.  Our nonperforming assets are 
expected to increase in the first quarter 2019 as a 
result of the bankruptcy.  Based on current market 
conditions and facts and circumstances which may 
change, we also expect to record an additional 
provision for credit losses relating to this exposure of 
$20 million - $30 million in the first quarter of 2019.

The remaining exposure in the energy and utilities 
portfolio, which includes exposure to refining, 
exploration and production companies, integrated 
companies and pipelines, was 88% investment grade 
at Dec. 31, 2018, and 77% at Dec. 31, 2017.

 32 BNY Mellon

Our credit strategy is to focus on investment grade 
clients that are active users of our non-credit services. 
The following table summarizes the percentage of the 
financial institutions and commercial portfolio 
exposures that are investment grade.

Percentage of the portfolios
that are investment grade
Financial institutions
Commercial

2018

95%
95%

Dec. 31,
2017

93%
95%

2016

92%
94%

Wealth management loans and mortgages 

Our wealth management exposure was $16.8 billion 
at Dec. 31, 2018, compared with $17.6 billion at Dec. 
31, 2017.  Wealth management loans and mortgages 
primarily consist of loans to high-net-worth 
individuals, which are secured by marketable 
securities and/or residential property.  Wealth 
management mortgages are primarily interest-only, 
adjustable-rate mortgages with a weighted-average 
loan-to-value ratio of 62% at origination.  Less than 
1% of the mortgages were past due at Dec. 31, 2018.

Results of Operations (continued)

At Dec. 31, 2018, the wealth management mortgage 
portfolio consisted of the following geographic 
concentrations:  California - 24%; New York - 18%; 
Massachusetts - 10%; Florida - 8%; and other - 40%.

Commercial real estate

Our commercial real estate exposure totaled $8.3 
billion at Dec. 31, 2018, compared with $8.4 billion 
at Dec. 31, 2017.  Our income-producing commercial 
real estate facilities are focused on experienced 
owners and are structured with moderate leverage 
based on existing cash flows.  Our commercial real 
estate lending activities also include construction and 
renovation facilities.  Our client base consists of 
experienced developers and long-term holders of real 
estate assets.  Loans are approved on the basis of 
existing or projected cash flows and supported by 
appraisals and knowledge of local market conditions.  
Development loans are structured with moderate 
leverage, and in many instances, involve some level 
of recourse to the developer. 

At Dec. 31, 2018, 61% of our commercial real estate 
portfolio was secured.  The secured portfolio is 
diverse by project type, with 43% secured by 
residential buildings, 36% secured by office 
buildings, 11% secured by retail properties and 10% 
secured by other categories.  Approximately 97% of 
the unsecured portfolio consists of real estate 
investment trusts (“REITs”) and real estate operating 
companies, which are both predominantly investment 
grade.

At Dec. 31, 2018, our commercial real estate 
portfolio consisted of the following concentrations: 
REITs and real estate operating companies - 38%; 
New York metro - 42%; and other - 20%.

Lease financings

The leasing portfolio exposure totaled $1.3 billion at 
both Dec. 31, 2018 and Dec. 31, 2017.  At Dec. 31, 
2018, the lease financings portfolio consisted of 
exposures backed by well-diversified assets, 
including large-ticket transportation equipment, the 
largest consisting of both passenger and freight train 

cars.  Assets are both domestic and foreign-based, 
with primary concentrations in the United States and 
Germany.  Approximately 48% of the portfolio is 
additionally secured by highly rated securities and/or 
secured by letters of credit from investment grade 
issuers.  Counterparty rating equivalents at Dec. 31, 
2018 were as follows:

• 
• 
• 

55% of the counterparties were A or better;
42% were BBB; and 
3% were non-investment grade.

Other residential mortgages

The other residential mortgages portfolio primarily 
consists of 1-4 family residential mortgage loans and 
totaled $594 million at Dec. 31, 2018 and $708 
million at Dec. 31, 2017.  Included in this portfolio at 
Dec. 31, 2018 were $128 million of mortgage loans 
purchased in 2005, 2006 and the first quarter of 2007, 
of which 11% of the serviced loan balance was at 
least 60 days delinquent. 

Overdrafts

Overdrafts primarily relate to custody and securities 
clearance clients.  Overdrafts occur on a daily basis 
primarily in the custody and securities clearance 
business and are generally repaid within two business 
days.

Other loans

Other loans primarily include loans to consumers that 
are fully collateralized with equities, mutual funds 
and fixed-income securities.

Margin loans

Margin loans are collateralized with marketable 
securities, and borrowers are required to maintain a 
daily collateral margin in excess of 100% of the value 
of the loan.  Margin loans included $2.6 billion at 
Dec. 31, 2018 and $4.2 billion at Dec. 31, 2017 
related to a term loan program that offers fully 
collateralized loans to broker-dealers. 

BNY Mellon 33 

Results of Operations (continued)

Loans by category

The following table shows loans outstanding at year-end over the last five years.

Loans by category
(in millions)
Domestic:

Commercial
Commercial real estate
Financial institutions
Lease financings
Wealth management loans and mortgages
Other residential mortgages
Overdrafts
Other
Margin loans

Total domestic

Foreign:

2018

2017

2016

2015

2014

Dec. 31,

$

1,949 $
4,787
5,091
706
15,843
594
1,550
1,181
13,343
45,044

2,744 $
4,900
5,568
772
16,420
708
963
1,131
15,689
48,895

2,286 $
4,639
6,342
989
15,555
854
1,055
1,202
17,503
50,425

2,115 $
3,899
6,640
1,007
13,247
1,055
911
1,137
19,340
49,351

1,390
2,524
5,603
1,282
11,095
1,222
1,348
1,113
20,034
45,611

Commercial
Commercial real estate
Financial institutions
Lease financings
Wealth management loans and mortgages
Other (primarily overdrafts)
Margin loans

252
6
7,716
889
89
4,569
—
13,521
59,132
(a)  Net of unearned income of $358 million at Dec. 31, 2018, $394 million at Dec. 31, 2017, $527 million at Dec. 31, 2016, $674 million at 

227
46
9,259
850
100
3,637
233
14,352
63,703 $

331
15
8,347
736
99
4,418
87
14,033
64,458 $

167
—
7,483
527
108
4,264
96
12,645
61,540 $

183
—
6,492
551
122
4,031
141
11,520
56,564 $

Total foreign
Total loans (a)

$

Dec. 31, 2015 and $866 million at Dec. 31, 2014, primarily on domestic and foreign lease financings.

Foreign loans

Maturity of loan portfolio

We have credit relationships in foreign markets, 
particularly in areas associated with our securities 
servicing and trade finance activities.  Excluding 
lease financings, these activities resulted in 
outstanding foreign loans of $11.0 billion at Dec. 31, 
2018 and $12.1 billion at Dec. 31, 2017.  The 
decrease primarily resulted from lower loans to 
financial institutions and lower overdrafts.

The following table shows the maturity structure of 
our loan portfolio at Dec. 31, 2018.

Maturity of loan portfolio at Dec. 31, 2018 (a)

Within
1 year

Between
1 and 5

years  

After
5 years  

Total

$

463 $ 1,371

$

115

$ 1,949

702

2,384

1,701

4,787

940
—
—
500
5,195
524

4,119
1,550
1,181
12,843
20,858
10,283

5,091
1,550
1,181
13,343
27,901
10,847
$ 31,141 $ 5,719 (b) $ 1,888 (b) $38,748
(a)  Excludes loans collateralized by residential properties, lease 
financings and wealth management loans and mortgages.
(b)  Variable rate loans due after one year totaled $7.6 billion 

32
—
—
—
1,848
40

Foreign

Total

(in millions)
Domestic:
Commercial
Commercial
real estate
Financial
institutions
Overdrafts
Other
Margin loans
Subtotal

and fixed rate loans totaled $35 million.

 34 BNY Mellon

 
Results of Operations (continued)

Asset quality and allowance for credit losses

Our credit strategy is to focus on investment grade 
clients who are active users of our non-credit 
services.  Our primary exposure to the credit risk of a 

customer consists of funded loans, unfunded 
contractual commitments to lend, standby letters of 
credit (“SBLC”) and overdrafts associated with our 
custody and securities clearance businesses.  

The following table details changes in our allowance for credit losses.

Allowance for credit losses activity
(dollar amounts in millions)
Non-margin loans
Margin loans
Total loans
Average loans outstanding

Balance, Jan. 1
Domestic
Foreign

Total allowance at Jan. 1

Charge-offs:

Commercial
Commercial real estate
Financial institutions
Wealth management loans and mortgages
Other residential mortgages
Foreign

Total charge-offs

Recoveries:

Commercial
Financial institutions
Other residential mortgages
Foreign

Total recoveries
Net recoveries (charge-offs)

Provision for credit losses
Balance, Dec. 31,
Domestic
Foreign

Total allowance, Dec. 31,

Allowance for loan losses
Allowance for lending-related commitments
Net (recoveries) charge-offs to average loans outstanding
Net (recoveries) charge-offs to total allowance for credit losses
Allowance for loan losses as a percentage of total loans
Allowance for loan losses as a percentage of non-margin loans
Total allowance for credit losses as a percentage of total loans
Total allowance for credit losses as a percentage of non-margin loans

The allowance for credit losses decreased $9 million 
compared with Dec. 31, 2017, driven by the credit to 
provision for credit losses, partially offset by the 
impact of an update to the usage given default 
parameter in 2018.  The usage given default 
parameter associated with the estimate of the 
probability of drawdown at default was updated in 
2018, resulting in an $11 million increase to the 
allowance for lending-related commitments. 

2018

2017

2016

$ 43,080
13,484
$ 56,564
55,810

$ 45,755
15,785
$ 61,540
57,939

$ 46,868
17,590
$ 64,458
61,681

2015
$ 43,708
19,573
$ 63,281
60,672

2014
$ 39,077
20,034
$ 59,111
54,210

$

$
$

226
35
261

—
—
—
—
(1)
—
(1)

—
—
2
1
3
2
(11)

$

$

245
36
281

$

240
35
275

$

236
44
280

—
—
—
—
(1)
—
(1)

—
—
5
—
5
4
(24)

—
—
—
—
(2)
—
(2)

—
13
5
1
19
17
(11)

—
—
(170)
—
(2)
—
(172)

—
1
6
—
7
(165)
160

220
32
252
146
106
— %

$
$

(0.79)
0.26
0.34
0.45
0.58

$
$

226
35
261
159
102
(0.01)%
(1.53)
0.26
0.35
0.42
0.57

$
$

245
36
281
169
112
(0.03)%
(6.05)
0.26
0.36
0.44
0.60

240
35
275
157
118
0.27%

$
$

60.00
0.25
0.36
0.43
0.63

288
56
344

(12)
(2)
—
(1)
(2)
(3)
(20)

1
1
2
—
4
(16)
(48)

236
44
280
191
89
0.03%
5.71
0.32
0.49
0.47
0.72

The provision for credit losses was a credit of $11 
million in 2018, a credit of $24 million in 2017 and a 
credit of $11 million in 2016.

We had $13.5 billion of secured margin loans on our 
balance sheet at Dec. 31, 2018 compared with $15.8 
billion at Dec. 31, 2017 and $17.6 billion at Dec. 31, 
2016.  We have rarely suffered a loss on these types 
of loans and do not allocate any of our allowance for 
credit losses to them.  As a result, we believe that the 
ratio of total allowance for credit losses as a 

BNY Mellon 35 

Results of Operations (continued)

percentage of non-margin loans is a more appropriate 
metric to measure the adequacy of the reserve.

The allowance for loan losses and allowance for 
lending-related commitments represent 
management’s estimate of losses inherent in our 
credit portfolio.  This evaluation process is subject to 
numerous estimates and judgments.  To the extent 
actual results differ from forecasts or management’s 
judgment, the allowance for credit losses may be 
greater or less than future charge-offs.

Based on an evaluation of the allowance for credit 
losses as discussed in “Critical accounting estimates” 
and Note 1 of the Notes to Consolidated Financial 
Statements, we have allocated our allowance for 
credit losses as follows.

Nonperforming assets

Nonperforming assets
(dollars in millions)
Nonperforming loans:

Other residential mortgages
Wealth management loans and mortgages
Commercial real estate
Lease financings
Financial institutions

Total nonperforming loans

Other assets owned

Total nonperforming assets (a)

Allocation of allowance

Commercial
Commercial real estate
Foreign
Financial institutions
Wealth management (a)
Other residential mortgages
Lease financing

Dec. 31,
2016
29%
26
13
9
8
10
5
100% 100% 100% 100% 100%

2018
2017
32% 30%
30
13
9
8
6
2

2015
30%
22
13
11
7
12
5

2014
21%
18
16
11
8
14
12

29
13
9
8
8
3

Total
Includes the allowance for wealth management mortgages.

(a) 

The allocation of the allowance for credit losses is 
inherently judgmental, and the entire allowance for 
credit losses is available to absorb credit losses 
regardless of the nature of the losses. 

2018

2017

2016

2015

2014

Dec. 31,

$

$

$

$

67
9
—
—
—
76
3
79
0.14%
0.18
192.1
184.8
331.6
319.0

$

$

78
7
1
—
—
86
4
90
0.15%
0.20
184.9
176.7
303.5
290.0

$

$

91
8
—
4
—
103
4
107
0.17%
0.23
164.1
157.9
272.8
262.6

102
11
2
—
171
286
6
292
0.46%
0.67
54.9
53.8
96.2
94.2

$

$

112
12
1
—
—
125
3
128
0.22%
0.33
152.8
149.2
224.0
218.8

Nonperforming assets ratio
Nonperforming assets ratio, excluding margin loans
Allowance for loan losses/nonperforming loans
Allowance for loan losses/nonperforming assets
Total allowance for credit losses/nonperforming loans
Total allowance for credit losses/nonperforming assets
(a)  Loans of consolidated investment management funds are not part of BNY Mellon’s loan portfolio and are excluded from the 

nonperforming assets table above.  Included in the loans of consolidated investment management funds are nonperforming loans of $53 
million at Dec. 31, 2014 which are recorded at fair value and therefore do not impact the provision for credit losses and allowance for 
loan losses.  In the second quarter of 2015, BNY Mellon adopted the accounting guidance included in ASU 2015-02, Consolidations.  As 
a result, we deconsolidated substantially all of the loans of consolidated investment management funds retrospectively to Jan. 1, 2015.

Nonperforming assets activity
(in millions)
Balance at beginning of year

Additions
Return to accrual status
Charge-offs
Paydowns/sales

Balance at end of year

2018

90 $
10
(2)
(1)
(18)
79 $

2017
107
12
(5)
(1)
(23)
90

$

$

Nonperforming assets decreased $11 million 
compared with Dec. 31, 2017, primarily reflecting 
lower other residential mortgage loans driven by 
paydowns and sales.

As noted earlier, our nonperforming assets are 
expected to increase in the first quarter of 2019 as a 
result of the bankruptcy of a Californian utility 
company. 

 36 BNY Mellon

Results of Operations (continued)

The following table presents loans that are past due 
90 days or more and still accruing interest.

The following table shows the maturity breakdown of 
domestic time deposits of $100,000 or more at Dec. 
31, 2018.

(in millions)
Domestic:

Consumer
Commercial
Total domestic
Foreign

$

Total past due loans $

2018

2017

2016

2015

2014

12 $
—
12
—
12 $

5 $

—
5
—
5 $

7 $

5 $

—
7
—

—
5
—

7 $

5 $

6
—
6
—
6

Loans past due 90 days or more at Dec. 31, 2018 
primarily consisted of other residential mortgage 
loans and wealth management loans and mortgages.  
See Note 5 of the Notes to Consolidated Financial 
Statements for additional information on our past due 
loans.  See “Nonperforming assets” in Note 1 of the 
Notes to Consolidated Financial Statements for our 
policy for placing loans on nonaccrual status.

Deposits

We receive client deposits through a variety of 
Investment Services and Investment Management 
businesses and we rely on those deposits as a low-
cost and stable source of funding.

Total deposits were $238.8 billion at Dec. 31, 2018, a 
decrease of 2% compared with $244.3 billion at Dec. 
31, 2017.  The decrease primarily reflects lower 
interest-bearing deposits in non-U.S. offices and 
noninterest-bearing deposits principally in U.S. 
offices, partially offset by higher interest-bearing 
deposits in U.S. offices.

Noninterest-bearing deposits were $70.8 billion at 
Dec. 31, 2018 compared with $82.7 billion at Dec. 
31, 2017.  Interest-bearing deposits were $168.0 
billion at Dec. 31, 2018 compared with $161.6 billion 
at Dec. 31, 2017.

The aggregate amount of deposits by foreign 
customers in domestic offices was $36.4 billion and 
$39.9 billion at Dec. 31, 2018 and Dec. 31, 2017, 
respectively.  

Deposits in foreign offices totaled $99.2 billion at 
Dec. 31, 2018 and $114.8 billion at Dec. 31, 2017.  
The majority of these deposits were in amounts in 
excess of $100,000 and were primarily overnight 
foreign deposits.

Certificates
of deposit

Other time
deposits

(in millions)
3 months or less
Between 3 and 6 months
Between 6 and 12 months
Over 12 months
Total

$

$

77 $
36
88
2
203 $

Total
32,247 $ 32,324
36
88
2
32,247 $ 32,450

—
—
—

Short-term borrowings

We fund ourselves primarily through deposits and, to 
a lesser extent, other short-term borrowings and long-
term debt.  Short-term borrowings consist of federal 
funds purchased and securities sold under repurchase 
agreements, payables to customers and broker-
dealers, commercial paper and other borrowed funds.  
Certain other borrowings, for example, securities sold 
under repurchase agreements, require the delivery of 
securities as collateral.

See “Liquidity and dividends” for a discussion of 
long-term debt and liquidity metrics that we monitor.

Information related to federal funds purchased and 
securities sold under repurchase agreements is 
presented below.

2017

2018

Federal funds purchased and securities sold under
repurchase agreements
(dollars in millions)
Maximum month-end
$ 21,600
balance during the year
Average daily balance (a) $ 15,546
Weighted-average rate 
during the year (a)
Ending balance (b)
Weighted-average rate at 
Dec. 31 (b)

$ 21,850
$ 19,653

$ 15,163

$ 14,243

12.99%

4.88%

2.33%

1.14%

$

2016

$ 25,995
$ 14,489

0.25%
9,989

0.38%

(a)  Includes the impact of offsetting under enforceable netting 
agreements of $25,203 million for 2018, $5,657 million for 
2017 and less than $350 million for 2016.

(b)  Includes the impact of offsetting under enforceable netting 

agreements of $76,040 million at Dec. 31, 2018, $25,848 
million at Dec. 31, 2017 and $481 million at Dec. 31, 2016.

BNY Mellon 37 

Results of Operations (continued)

Federal funds purchased and securities sold under
repurchase agreements

Quarter ended
Sept. 30,
2018

Dec. 31,
2018

Dec. 31,
2017

(dollars in millions)
Maximum month-end
balance during the quarter $ 14,243
$ 10,980
Average daily balance (a)
Weighted-average rate 
during the quarter (a)

10.95%

$ 13,020
$ 14,199

$ 20,098
$ 20,211

5.33%

1.83%

Ending balance (b)
Weighted-average rate at 

period end (b)

$ 14,243

$ 10,158

$ 15,163

12.99%

7.33%

2.33%

(a)  Includes the impact of offsetting under enforceable netting 
agreements of $42,721 million for the fourth quarter of 
2018, $25,922 million for the third quarter of 2018 and 
$14,128 million for the fourth quarter of 2017.

(b)  Includes the impact of offsetting under enforceable netting 

agreements of $76,040 million at Dec. 31, 2018, $58,540 
million at Sept. 30, 2018 and $25,848 million at Dec. 31, 
2017.

Fluctuations of federal funds purchased and securities 
sold under repurchase agreements between periods 
reflect changes in overnight borrowing opportunities.  
The increase in the weighted-average rates, compared 
with both Sept. 30, 2018 and Dec. 31, 2017, primarily 
reflects the increase in repurchase agreement activity 
with the Fixed Income Clearing Corporation 
(“FICC”), where we record interest expense gross, 
but the average balances are reduced as a result of the 
impact of offsetting under enforceable netting 
agreements.  The increased activity primarily relates 
to government securities collateralized resale and 
repurchase agreements executed with clients that are 
novated to and settle with the FICC.

Information related to payables to customers and 
broker-dealers is presented below.  

2018

Payables to customers and broker-dealers
(dollars in millions)
Maximum month-end
$ 20,905
balance during the year
Average daily balance (a) $ 19,450
Weighted-average rate 
during the year (a)
Ending balance at Dec. 31 $ 19,731
Weighted-average
rate at Dec. 31

1.62%

1.17%

2017

2016

$ 21,621
$ 21,142

$ 22,327
$ 21,149

0.34%

0.07%

$ 20,184

$ 20,987

0.56%

0.09%

(a)  The weighted-average rate is calculated based on, and is 
applied to, the average interest-bearing payables to 
customers and broker-dealers, which were $16,353 million 
in 2018, $18,984 million in 2017 and $16,925 million in 
2016.

 38 BNY Mellon

Payables to customers and broker-dealers

Quarter ended
Sept. 30,
2018

Dec. 31,
2018

Dec. 31,
2017

(dollars in millions)
Maximum month-end
balance during the quarter $ 19,731
$ 18,955
Average daily balance (a)
Weighted-average rate 
during the quarter (a)
Ending balance
Weighted-average rate at
period end

$ 19,731

1.61%

1.62%

$ 19,232
$ 19,073

$ 21,380
$ 21,130

1.23%

0.49%

$ 18,683

$ 20,184

1.30%

0.56%

(a)  The weighted-average rate is calculated based on, and is 
applied to, the average interest-bearing payables to 
customers and broker-dealers, which were $15,727 million 
in the fourth quarter of 2018, $16,252 million in the third 
quarter of 2018 and $17,868 million in the fourth quarter of 
2017.

Payables to customers and broker-dealers represent 
funds awaiting re-investment and short sale proceeds 
payable on demand.  Payables to customers and 
broker-dealers are driven by customer trading activity 
levels and market volatility. 

Information related to commercial paper is presented 
below.

2018

Commercial paper
(dollars in millions)
Maximum month-end
balance during the year
Average daily balance
Weighted-average rate
during the year
Ending balance at Dec. 31 $ 1,939
Weighted-average rate at
Dec. 31

$ 4,470
$ 2,607

2.34%

1.97%

2017

2016

$
$

$

4,714
2,630

1.08%
3,075

$
$

$

4,950
1,337

0.37%
—

1.27%

—%

Commercial paper

Quarter ended

(dollars in millions)
Maximum month-end
balance during the quarter $
$
Average daily balance
Weighted-average rate
during the quarter
Ending balance
Weighted-average rate at
period end

$

Dec. 31,
2018

Sept. 30,
2018

Dec. 31,
2017

1,939
353

$ 4,422
$ 3,102

$ 4,714
$ 3,391

2.41%
1,939

$

2.10%
735

1.23%

$ 3,075

2.34%

2.06%

1.27%

The Bank of New York Mellon, our largest bank 
subsidiary, issues commercial paper that matures 
within 397 days from date of issue and is not 
redeemable prior to maturity or subject to voluntary 
prepayment.  The fluctuations in the commercial 
paper balances, compared with prior periods, 

Results of Operations (continued)

primarily reflects management of overall liquidity.  
The increase in weighted-average rates, compared 
with prior periods, primarily reflects increases in the 
Fed Funds effective rate and the issuance of higher-
yielding term commercial paper.

Information related to other borrowed funds is 
presented below. 

Other borrowed funds
(dollars in millions)
Maximum month-end

balance during the year
Average daily balance
Weighted-average rate

$ 3,269
$ 2,545

during the year
Ending balance at Dec. 31 $ 3,227
Weighted-average rate at

2.26%

2.64%

Dec. 31

2018

2017

2016

$
$

$

3,955
1,916

1.36%
3,028

$
$

$

1,280
846

0.91%
754

1.48%

0.89%

Other borrowed funds

(dollars in millions)
Maximum month-end
balance during the quarter $
$
Average daily balance
Weighted-average rate
during the quarter

Ending balance
Weighted-average rate at

period end

$

Quarter ended
Sept. 30,
2018

Dec. 31,
2018

Dec. 31,
2017

3,227
2,903

$ 3,269
$ 2,747

$ 3,955
$ 3,421

2.44%
3,227

2.33%

1.46%

$ 2,934

$ 3,028

2.64%

2.48%

1.48%

Other borrowed funds primarily include borrowings 
from the Federal Home Loan Bank (“FHLB”), 
overdrafts of sub-custodian account balances in our 
Investment Services businesses, capital lease 
obligations and borrowings under lines of credit by 
our Pershing subsidiaries.  Overdrafts typically relate 
to timing differences for settlements.  The increase in 
other borrowed funds, compared with prior periods 
primarily reflects an increase in borrowings from the 
FHLB partially offset by a decline in overdrafts and 
lower capital lease obligations due to the purchase of 
the leased asset.

Liquidity and dividends

BNY Mellon defines liquidity as the ability of the 
Parent and its subsidiaries to access funding or 
convert assets to cash quickly and efficiently, or to 
roll over or issue new debt, especially during periods 
of market stress, at a reasonable cost and in order to 
meet its short-term (up to one year) obligations.  
Funding liquidity risk is the risk that BNY Mellon 
cannot meet its cash and collateral obligations at a 

reasonable cost for both expected and unexpected 
cash flow and collateral needs without adversely 
affecting daily operations or our financial condition.  
Funding liquidity risk can arise from funding 
mismatches, market constraints from the inability to 
convert assets to cash, the inability to hold or raise 
cash, low overnight deposits, deposit run-off or 
contingent liquidity events. 

We also manage liquidity risks on an intraday basis.  
Intraday liquidity risk is the risk that BNY Mellon 
cannot access funds during the business day to make 
payments or settle immediate obligations, usually in 
real time.  Intraday liquidity risk can arise from 
timing mismatches, market constraints from the 
inability to convert assets to cash, the inability to 
raise cash intraday, low overnight deposits and/or 
adverse stress events.  

Changes in economic conditions or exposure to 
credit, market, operational, legal and reputational 
risks also can affect BNY Mellon’s liquidity risk 
profile and are considered in our liquidity risk 
framework.

For additional information on our liquidity policy, see 
“Risk Management - Liquidity risk.”

We monitor and control liquidity exposures and 
funding needs within and across significant legal 
entities, branches, currencies and business lines, 
taking into account, among other factors, any 
applicable restrictions on the transfer of liquidity 
among entities.

BNY Mellon also manages potential intraday 
liquidity risks.  We monitor and manage intraday 
liquidity against existing and expected intraday liquid 
resources (such as cash balances, remaining intraday 
credit capacity, intraday contingency funding and 
available collateral) to enable BNY Mellon to meet its 
intraday obligations under normal and reasonably 
severe stressed conditions.

The Parent’s policy is to have access to sufficient 
unencumbered cash and cash equivalents at each 
quarter-end to cover forecasted debt redemptions, net 
interest payments and net tax payments for the 
following 18-month period, and to provide sufficient 
collateral to satisfy transactions subject to Section 
23A of the Federal Reserve Act.  As of Dec. 31, 2018, 
the Parent was in compliance with this policy. 

BNY Mellon 39 

Results of Operations (continued)

We define available funds for internal liquidity 
management purposes as liquid funds (which include 
interest-bearing deposits with banks and federal funds 
sold and securities purchased under resale 
agreements), cash and due from banks and interest-

bearing deposits with the Federal Reserve and other 
central banks.  The following table presents our total 
available funds, including liquid funds, at period end 
and on an average basis.  

Available and liquid funds
(in millions)
Available funds:
Liquid funds:

Dec. 31,
2018

Dec. 31,
2017

Average

2018

2017

2016

Interest-bearing deposits with banks
Federal funds sold and securities purchased under resale agreements

Total liquid funds
Cash and due from banks
Interest-bearing deposits with the Federal Reserve and other central banks

Total available funds
Total available funds as a percentage of total assets

$ 14,148
46,795
60,943
5,864
67,988
$ 134,795

$ 11,979
28,135
40,114
5,382
91,510
$ 137,006

$ 14,740
27,883
42,623
5,014
68,408
$ 116,045

$ 14,879
27,192
42,071
5,039
70,213
$ 117,323

$ 14,704
25,767
40,471
4,308
80,593
$ 125,372

37%

37%

34%

34%

35%  

We had $60.9 billion of liquid funds at Dec. 31, 2018 
and $40.1 billion at Dec. 31, 2017.  Of the $60.9 
billion in liquid funds held at Dec. 31, 2018, $14.1 
billion was placed in interest-bearing deposits with 
large, highly-rated global financial institutions with a 
weighted-average life to maturity of approximately 
13 days.  Of the $14.1 billion, $1.1 billion was placed 
with banks in the Eurozone.

Total available funds were $134.8 billion at Dec. 31, 
2018, compared with $137.0 billion at Dec. 31, 2017.  
The decrease was primarily due to lower interest-
bearing deposits with the Federal Reserve and other 
central banks, partially offset by higher federal funds 
sold and securities purchased under resale 
agreements.

Average non-core sources of funds, such as federal 
funds purchased and securities sold under repurchase 
agreements, trading liabilities, commercial paper and 
other borrowed funds, were $22.0 billion for 2018 
and $25.4 billion for 2017.  The decrease primarily 
reflects a decrease in federal funds purchased and 
securities sold under repurchase agreements.

Average foreign deposits, primarily from our 
European-based Investment Services business, were 

$95.5 billion for 2018, compared with $96.2 billion 
for 2017.  Average interest-bearing domestic deposits 
were $59.2 billion for 2018 and $46.9 billion for 
2017.  The increase primarily reflects an increase in 
demand deposits. 

Average payables to customers and broker-dealers 
were $16.4 billion for 2018 and $19.0 billion for 
2017.  Payables to customers and broker-dealers are 
driven by customer trading activity and market 
volatility.

Average long-term debt was $28.3 billion for 2018 
and $27.4 billion for 2017.  The increase reflects 
issuances, partially offset by the maturities of long-
term debt.

Average noninterest-bearing deposits decreased to 
$63.8 billion for 2018 from $71.7 billion for 2017, 
reflecting lower client deposits.

A significant reduction in our Investment Services 
business would reduce our access to deposits.  See 
“Asset/liability management” for additional factors 
that could impact our deposit balances.

 40 BNY Mellon

Results of Operations (continued)

Sources of liquidity

The Parent’s three major sources of liquidity are 
access to the debt and equity markets, dividends from 
its subsidiaries, and cash on hand and cash otherwise 
made available in business-as-usual circumstances to 

the Parent through a committed credit facility with 
our intermediate holding company (“IHC”). 

Our ability to access the capital markets on favorable 
terms, or at all, is partially dependent on our credit 
ratings, which are as follows:

Credit ratings at Dec. 31, 2018

Parent:
Long-term senior debt
Subordinated debt
Preferred stock
Outlook - Parent:

The Bank of New York Mellon:
Long-term senior debt
Subordinated debt
Long-term deposits
Short-term deposits
Commercial paper

BNY Mellon, N.A.:
Long-term senior debt
Long-term deposits
Short-term deposits

Outlook - Banks:
(a)  Represents senior debt issuer default rating.
NR - Not rated.

Moody’s

A1
A2
Baa1
Stable

Aa2
NR
Aa1
P1
P1

Aa2 (a)
Aa1
P1

Stable

S&P

A
A-
BBB
Stable

AA-
A
AA-
A-1+
A-1+

AA-
AA-
A-1+

Stable

Fitch

AA-
A+
BBB
Stable

AA
NR
AA+
F1+
F1+

AA  (a)

AA+
F1+

Stable

DBRS

AA (low)
A (high)
A (low)
Stable

AA
NR
AA
R-1 (high)
R-1 (high)

AA
AA
R-1 (high)

Stable

Long-term debt totaled $29.2 billion at Dec. 31, 2018 
and $28.0 billion at Dec. 31, 2017.  The balance 
reflects issuances of $5.2 billion, offset by maturities 
of $3.7 billion and a decrease in the fair value of 
hedged long-term debt.  The Parent has $4.3 billion of 
long-term debt that will mature in 2019.  

The following table presents the long-term debt 
issued in 2018.

Debt issuances
(in millions)
Senior notes:

3-month LIBOR + 30bps senior notes due 2020
2.95% senior notes due 2023
3.50% senior notes due 2023
3.45% senior notes due 2023
3.40% senior notes due 2028
3.85% senior notes due 2028
Total debt issuances

2018

$ 1,000
1,000
750
750
750
900
$ 5,150

In the second quarter of 2018, BNY Mellon 
established programs for the issuance of notes and 
certificates of deposit (“CDs”) issued by The Bank of 
New York Mellon, our largest bank subsidiary.  These 
programs are designed to improve the diversity of our 
funding sources and provide additional flexibility in 
our liquidity planning.  In December 2018, we issued 
$1 billion of senior bank notes maturing in 2020 at an 
annual interest rate of LIBOR plus 30 basis points.  
At Dec. 31, 2018, $2.8 billion of CDs were 
outstanding. 

The Bank of New York Mellon, our largest bank 
subsidiary, issues commercial paper that matures 
within 397 days from date of issue and is not 
redeemable prior to maturity or subject to voluntary 
prepayment.  The average commercial paper 
borrowings were $2.6 billion for both 2018 and 2017.  
Commercial paper outstanding was $1.9 billion at 
Dec. 31, 2018 and $3.1 billion at Dec. 31, 2017.

BNY Mellon 41 

Results of Operations (continued)

Subsequent to Dec. 31, 2018, our U.S. bank 
subsidiaries could declare dividends to the Parent of 
approximately $3.7 billion, without the need for a 
regulatory waiver.  In addition, at Dec. 31, 2018, non-
bank subsidiaries of the Parent had liquid assets of 
approximately $1.7 billion.  Restrictions on our 
ability to obtain funds from our subsidiaries are 
discussed in more detail in “Supervision and 
Regulation - Capital Planning and Stress Testing - 
Payment of Dividends, Stock Repurchases and Other 
Capital Distributions” and in Note 18 of the Notes to 
Consolidated Financial Statements.

Pershing LLC has uncommitted lines of credit in 
place for liquidity purposes which are guaranteed by 
the Parent.  Pershing LLC has three separate 
uncommitted lines of credit amounting to $750 
million in aggregate.  There were no borrowings 
under these lines in 2018.  Pershing Limited, an 
indirect UK-based subsidiary of BNY Mellon, has 
two separate uncommitted lines of credit amounting 
to $250 million in aggregate.  Average borrowings 
under these lines were $1 million, in aggregate, in 
2018.

The double leverage ratio is the ratio of our equity 
investment in subsidiaries divided by our 
consolidated parent company equity, which includes 
our noncumulative perpetual preferred stock.  In 
short, the double leverage ratio measures the extent to 
which equity in subsidiaries is financed by Parent 
company debt.  As the double leverage ratio 
increases, this can reflect greater demands on a 
company’s cash flows in order to service interest 
payments and debt maturities.  BNY Mellon’s double 
leverage ratio is managed in a range considering the 
high level of unencumbered available liquid assets 
held in its principal subsidiaries (such as central bank 
deposit placements and government securities), the 
Company’s cash generating fee-based business 
model, with fee revenue representing 78% of total 
revenue in 2018, and the dividend capacity of our 
banking subsidiaries.  Our double leverage ratio was 
117.7% at Dec. 31, 2018 and 122.5% at Dec. 31, 
2017, and within the range targeted by management.  

 42 BNY Mellon

Uses of funds

The Parent’s major uses of funds are payment of 
dividends, repurchases of common stock, principal 
and interest payments on its borrowings, acquisitions 
and additional investments in its subsidiaries.

In 2018, we paid $1.2 billion in dividends on our 
common and preferred stock.  Our common stock 
dividend payout ratio was 26% for 2018. 

In 2018, we repurchased 63.7 million common shares 
at an average price of $51.29 per common share for a 
total cost of $3.3 billion. 

Liquidity coverage ratio

U.S. regulators have established an LCR that requires 
certain banking organizations, including BNY 
Mellon, to maintain a minimum amount of 
unencumbered high-quality liquid assets (“HQLA”) 
sufficient to withstand the net cash outflow under a 
hypothetical standardized acute liquidity stress 
scenario for a 30-day time horizon. 

The following table presents the consolidated HQLA 
at Dec. 31, 2018, and the average HQLA and average 
LCR for the fourth quarter of 2018.

Consolidated HQLA and LCR
(dollars in billions)
Securities (a)
Cash (b)

Total consolidated HQLA (c)

Dec. 31,
2018
121
61
182

$

$

Total consolidated HQLA - average (c)
Average LCR

164
118%
(a)  Primarily includes securities of U.S. government-sponsored 
enterprises, U.S. Treasury, sovereign securities, U.S. agency 
and investment-grade corporate debt.

$

(b)  Primarily includes cash on deposit with central banks.
(c)  Consolidated HQLA presented before adjustments.  After 
haircuts and the impact of trapped liquidity, consolidated 
HQLA totaled $133 billion at Dec. 31, 2018 and averaged 
$121 billion for the fourth quarter of 2018.

The U.S. LCR rule requires BNY Mellon and each of 
our affected domestic bank subsidiaries to meet an 
LCR of at least 100%.  BNY Mellon and each of our 
affected domestic bank subsidiaries were compliant 
with the U.S. LCR requirements throughout 2018. 

Results of Operations (continued)

Statement of cash flows

The following summarizes the activity reflected on 
the consolidated statement of cash flows.  While this 
information may be helpful to highlight certain macro 
trends and business strategies, the cash flow analysis 
may not be as relevant when analyzing changes in our 
net earnings and net assets.  We believe that in 
addition to the traditional cash flow analysis, the 
discussion related to liquidity and dividends and 
asset/liability management herein may provide more 
useful context in evaluating our liquidity position and 
related activity.

Net cash provided by operating activities was $6.0 
billion in 2018, compared with $4.7 billion in 2017 
and $6.3 billion in 2016.  In 2018, 2017 and 2016, 
cash flows provided by operations were principally 
the result of earnings.  In 2018, cash flows provided 
by operations was also the result of changes in 
accruals and other balances, partially offset by 
changes in trading assets and liabilities.  In 2017, 
cash flows provided by operations were partially 
offset by changes in trading assets and liabilities.  In 
2016, cash flows provided by operations also reflect 
changes in trading assets and liabilities, partially 
offset by changes in accruals and other balances.

Net cash provided by investing activities was $3.3 
billion in 2018, compared with net cash used for 
investing activities of $32.7 billion in 2017 and net 

cash provided by investing activities of $50.3 billion 
in 2016.  In 2018, 2017 and 2016, net cash provided 
by or used for investing activities primarily reflects 
changes in interest-bearing deposits with the Federal 
Reserve and other central banks and the net impact of 
securities activity.  In 2018, net cash provided by 
investing activities was partially offset by changes in 
federal funds sold and securities purchased under 
resale agreements.

Net cash used for financing activities was $8.1 billion 
in 2018, compared with net cash provided by 
financing activities of $26.8 billion in 2017 and net 
cash used for financing activities of $59.1 billion in 
2016.  In 2018, net cash used for financing activities 
primarily reflects repayments of long-term debt, 
common stock repurchases and changes in deposits, 
partially offset by proceeds from the issuance of long-
term debt.  In 2017 and 2016, net cash provided by, or 
used for, financing activities primarily reflects 
changes in deposits and changes in federal funds 
purchased and securities sold under repurchase 
agreements.  In 2017, net cash provided by financing 
activities also reflects net proceeds from the issuance 
of long-term debt, changes in commercial paper and 
other borrowed funds, partially offset by common 
stock repurchases.  In 2016, net cash used for 
financing activities also reflects repayment of long-
term debt and common stock repurchases, partially 
offset by the net proceeds from the issuance of long-
term debt.

BNY Mellon 43 

Results of Operations (continued)

Commitments and obligations

We have contractual obligations to make fixed and 
determinable payments to third parties as indicated in 
the table below.  The table excludes certain 
obligations such as trade payables and trading 
liabilities, where the obligation is short-term or 
subject to valuation based on market factors.  In 

addition to the amounts shown in the table below, at 
Dec. 31, 2018, $103 million of unrecognized tax 
benefits have been recorded as liabilities in 
accordance with ASC 740, Income Taxes.  Related to 
these unrecognized tax benefits, we have also 
recorded a liability for potential interest of $22 
million.  At this point, it is not possible to determine 
when these amounts will be settled or resolved.

Contractual obligations at Dec. 31, 2018

Payments due by period

(in millions)
Deposits without a stated maturity
Term deposits
Federal funds purchased and securities sold under repurchase agreements
Payables to customers and broker-dealers
Other borrowed funds (a)
Long-term debt (b)
Unfunded pension and post-retirement benefits
Investment commitments (c)

Total

Less than
1 year

$ 128,032 $ 128,032 $

40,592
14,243
19,731
3,227
33,614
256
479

40,543
14,243
19,731
3,227
5,080
27
201

Total contractual obligations

$ 240,174 $ 211,084 $

1-3 years

3-5 years

— $
48
—
—
—
10,883
58
230
11,219 $

— $
—
—
—
—
7,650
53
30
7,733 $

Over
5 years
—
1
—
—
—
10,001
118
18
10,138

(a)  Includes capital leases.
(b)  Includes interest.
(c)  Includes Community Reinvestment Act commitments.

We have entered into fixed and determinable commitments as indicated in the table below:

Other commitments at Dec. 31, 2018

(in millions)
Securities lending indemnifications (a)
Lending commitments
Standby letters of credit
Operating leases
Purchase obligations (b)
Commercial letters of credit
Private equity commitments (c)
Total commitments

Amount of commitment expiration per period
Less than
1 year

1-3 years

3-5 years

Total

$ 401,504 $ 401,504 $

50,631
2,817
1,459
1,374
165
41

29,766
1,972
264
722
165
17

$ 457,991 $ 434,410 $

— $

6,985
496
455
465
—
13
8,414 $

— $

13,310
349
308
148
—
11
14,126 $

Over
5 years
—
570
—
432
39
—
—
1,041

(a)  Excludes the indemnifications for securities booked at BNY Mellon resulting from the CIBC Mellon joint venture, which totaled $56 

billion at Dec. 31, 2018.

(b)  Purchase obligations are defined as agreements to purchase goods or services that are enforceable and legally binding and specify all 

significant terms.

(c)  Relates to SBIC investments, which are compliant with the Volcker Rule.

See “Liquidity and dividends” and Note 21 of the 
Notes to Consolidated Financial Statements for a 
further discussion of the source of funds for our 
commitments and obligations.

Off-balance sheet arrangements

Off-balance sheet arrangements discussed in this 
section are limited to guarantees, retained or 
contingent interests and obligations arising out of 

 44 BNY Mellon

unconsolidated variable interest entities (“VIEs”).  
For BNY Mellon, these items include certain 
guarantees.  Guarantees include SBLCs issued as part 
of our corporate banking business and securities 
lending indemnifications issued as part of our 
Investment Services business.  See Note 21 of the 
Notes to Consolidated Financial Statements for a 
further discussion of our off-balance sheet 
arrangements.

Results of Operations (continued)

Capital

Capital data
(dollars in millions except per share amounts; common shares in thousands)
At period end:
BNY Mellon shareholders’ equity to total assets ratio
BNY Mellon common shareholders’ equity to total assets ratio
Total BNY Mellon shareholders’ equity
Total BNY Mellon common shareholders’ equity (a)
BNY Mellon tangible common shareholders’ equity – Non-GAAP (a)
Book value per common share (a)
Tangible book value per common share – Non-GAAP (a)
Closing stock price per common share
Market capitalization
Common shares outstanding

2018

2017

11.2%
10.2%

11.1%
10.1%

$ 40,638
$ 37,096
$ 18,290
38.63
$
19.04
$
$
47.07
$ 45,207
960,426

41,251
$
37,709
$
18,486
$
37.21
$
18.24
$
53.86
$
$
54,584
1,013,442

Full-year:
Average common equity to average assets
Cash dividends per common share
23%
Common dividend payout ratio
Common dividend yield
1.6%
(a)  See “Supplemental information – Explanation of GAAP and Non-GAAP financial measures” beginning on page 105 for a reconciliation 

11.0%
1.04

10.5%
0.86

26%
2.2%

$

$

of GAAP to Non-GAAP.

The Bank of New York Mellon Corporation total 
shareholders’ equity decreased to $40.6 billion at 
Dec. 31, 2018 from $41.3 billion at Dec. 31, 2017.  
The decrease primarily reflects common stock 
repurchases, dividend payments and unrealized losses 
on securities available-for-sale, partially offset by 
earnings and the impact of stock awards and option 
exercises. 

We repurchased 63.7 million common shares at an 
average price of $51.29 per common share for a total 
of $3.3 billion in 2018 including the additional share 
repurchases approved in December 2018.  We expect 
to continue to repurchase shares in the first half of 
2019 under the 2018 capital plan.

The unrealized loss, net of tax, on our available-for-
sale securities portfolio included in accumulated OCI 
was $167 million at Dec. 31, 2018, compared with a 
net unrealized gain of $184 million at Dec. 31, 2017.  
The decrease in the unrealized gain, net of tax, was 
primarily driven by higher interest rates.

Capital adequacy

Regulators establish certain levels of capital for bank 
holding companies (“BHCs”) and banks, including 
BNY Mellon and our bank subsidiaries, in accordance 
with established quantitative measurements.  For the 
Parent to maintain its status as a financial holding 
company, our U.S. bank subsidiaries and BNY 
Mellon must, among other things, qualify as “well 

capitalized.”  As of Dec. 31, 2018 and Dec. 31, 2017, 
BNY Mellon and our U.S. bank subsidiaries were 
“well capitalized.”

Failure to satisfy regulatory standards, including 
“well capitalized” status or capital adequacy rules 
more generally, could result in limitations on our 
activities and adversely affect our financial condition.  
See the discussion of these matters in “Supervision 
and Regulation - Regulated Entities of BNY Mellon 
and Ancillary Regulatory Requirements” and “Risk 
Factors - Operational Risk - Failure to satisfy 
regulatory standards, including “well capitalized” and 
“well managed” status or capital adequacy and 
liquidity rules more generally, could result in 
limitations on our activities and adversely affect our 
business and financial condition.”

The U.S. banking agencies’ capital rules are based on 
the framework adopted by the Basel Committee on 
Banking Supervision (“BCBS”), as amended from 
time to time.  For additional information on these 
capital requirements, see “Supervision and 
Regulation.”  BNY Mellon is subject to the U.S. 
capital rules, which were gradually phased-in over a 
multi-year period through Jan. 1, 2019.  The phase-in 
requirements for consolidated capital were completed 
on Jan. 1, 2018.

Our risk-based capital adequacy is determined using 
the higher of RWAs determined using the Advanced 
Approach and Standardized Approach.  

BNY Mellon 45 

Results of Operations (continued)

The table below presents our consolidated and largest bank subsidiary regulatory capital ratios.

Consolidated and largest bank subsidiary regulatory

capital ratios

Consolidated regulatory capital ratios: (c)(d)

Well
capitalized

Dec. 31, 2018
Minimum

required (a)

Capital
ratios

Dec. 31, 2017
Fully

phased-in Transitional

(b)

Advanced Approach:

CET1 ratio
Tier 1 capital ratio
Total capital ratio
Standardized Approach:

CET1 ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
SLR (f)

The Bank of New York Mellon regulatory

capital ratios: (c)

Advanced Approach:

CET1 ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
SLR (f)

N/A (e)
6%
10%

N/A (e)
6%
10%
N/A (e)
N/A (e)

7.5%
9
11

7.5%
9
11
4
5

6.5%
8
10
5
6

6.375%
7.875
9.875
4
3

10.7%
12.8
13.6

11.7%
14.1
15.1
6.6
6.0

14.0%
14.3
14.7
7.6
6.8

10.3%
12.3
13.0

11.5%
13.7
14.7
6.4
5.9

N/A
N/A
N/A
N/A
6.7

10.7%
12.7
13.4

11.9%
14.2
15.1
6.6
6.1

14.1%
14.4
14.7
7.6
6.9

(a)  Minimum requirements for Dec. 31, 2018 include minimum thresholds plus currently applicable buffers.  
(b)  Reflects transitional adjustments to CET1, Tier 1 capital and Tier 2 capital required in 2017 under the U.S. capital rules.
(c)  For our CET1, Tier 1 capital and Total capital ratios, our effective capital ratios under U.S. capital rules are the lower of the ratios as 

calculated under the Standardized and Advanced Approaches.  The Tier 1 leverage ratio is based on Tier 1 capital and quarterly average 
total assets. 

(d)  See page 48 for the capital ratio requirements with the phase-in of the capital conservation buffer and the U.S. Global Systemically 

Important Bank (“G-SIB”) surcharge, as well as the introduction of the SLR buffer. 

(e)  The Federal Reserve’s regulations do not establish well capitalized thresholds for these measures for BHCs. 
(f)  SLR became a binding measure on Jan. 1, 2018.  The SLR is based on Tier 1 capital and total leverage exposure, which includes certain 

off-balance sheet exposures. 

Our CET1 ratio determined under the Advanced 
Approach was 10.7% at Dec. 31, 2018 and 10.7%, on 
a transitional basis, at Dec. 31, 2017.  The ratio was 
unchanged compared to Dec. 31, 2017, reflecting 
capital deployed through common stock repurchases 
and dividend payments, and the final phase-in 
requirements under U.S. capital rules, offset by 
capital generated through earnings and lower RWAs.  

Our SLR was 6.0% at Dec. 31, 2018 and 6.1%, on a 
transitional basis, at Dec. 31, 2017.

The Advanced Approach capital ratios are 
significantly impacted by RWAs for operational risk.  
Our operational loss risk model is informed by 
external losses, including fines and penalties levied 
against institutions in the financial services industry, 

particularly those that relate to businesses in which 
we operate, and as a result external losses have 
impacted and could in the future impact the amount 
of capital that we are required to hold.

Our capital ratios are necessarily subject to, among 
other things, anticipated compliance with all 
necessary enhancements to model calibration, 
approval by regulators of certain models used as part 
of RWA calculations, other refinements, further 
implementation guidance from regulators, market 
practices and standards and any changes BNY Mellon 
may make to its businesses.  As a consequence of 
these factors, our capital ratios may materially 
change, and may be volatile over time and from 
period to period.

 46 BNY Mellon

Results of Operations (continued)

The following table presents our capital components and RWAs.

Capital components and risk-weighted assets

(in millions)
CET1:

Common shareholders’ equity
Adjustments for:

Goodwill and intangible assets (b)
Net pension fund assets
Equity method investments
Deferred tax assets
Other

Total CET1

Other Tier 1 capital:

Preferred stock
Deferred tax assets
Net pension fund assets
Other

Total Tier 1 capital

Tier 2 capital:

Subordinated debt
Allowance for credit losses
Other

Total Tier 2 capital – Standardized Approach

Excess of expected credit losses
Less: Allowance for credit losses

Total Tier 2 capital – Advanced Approach

Total capital:

Standardized Approach
Advanced Approach

Risk-weighted assets:

Standardized Approach
Advanced Approach:

Credit Risk
Market Risk
Operational Risk

Total Advanced Approach

Average assets for Tier 1 leverage ratio
330,894 $
Total leverage exposure for SLR
360,543 $
(a)  Reflects transitional adjustments to CET1, Tier 1 capital and Tier 2 capital required in 2017 under the U.S. capital rules.
(b)  Reduced by deferred tax liabilities associated with intangible assets and tax deductible goodwill.

319,007 $
347,943 $

$
$

Dec. 31,
2018

Dec. 31, 2017
Fully
phased-in

Transitional

Approach (a)

$

37,096 $

37,709 $

37,859

(18,806)
(320)
(361)
(42)
—
17,567

(19,223)
(211)
(387)
(41)
(9)
17,838

3,542
—
—
(65)
21,044 $

3,542
—
—
(41)
21,339 $

1,250 $
252
(10)
1,492
65
252
1,305 $

1,250 $
261
(12)
1,499
31
261
1,269 $

(18,684)
(169)
(372)
(33)
(8)
18,593

3,542
(8)
(42)
(41)
22,044

1,250
261
(12)
1,499
31
261
1,269

22,536 $
22,349 $

22,838 $
22,608 $

23,543
23,313

149,618 $

155,324 $

155,621

92,917 $
3,454
68,300
164,671 $

101,366 $
3,657
68,688
173,711 $

$

$

$

$
$

$

$

$

101,681
3,657
68,688
174,026

331,600
361,249

BNY Mellon 47 

Results of Operations (continued)

The table below presents the factors that impacted the 
CET1 capital.

Minimum capital ratios and capital buffers

CET1 generation
(in millions)
CET1 – Beginning of period
Net income applicable to common shareholders of

The Bank of New York Mellon Corporation
Goodwill and intangible assets, net of related

deferred tax liabilities

Gross CET1 generated

Capital deployed:

Common stock dividends
Common stock repurchased
Total capital deployed
Other comprehensive income:
Foreign currency translation
Unrealized loss on assets available-for-sale
Defined benefit plans
Unrealized gain on cash flow hedges
Other

Total other comprehensive income

Additional paid-in capital (a)
Other (deductions) additions:
Net pension fund assets
Deferred tax assets
Embedded goodwill
Other

Total other deductions
Net CET1 deployed
CET1 – End of period

The U.S. capital rules include a series of buffers and 
surcharges over required minimums that apply to 
BHCs, including BNY Mellon, which are being 
phased-in over time.  Banking organizations with a 
risk-based ratio or SLR above the minimum required 
level, but with a risk-based ratio or SLR below the 
minimum level with buffers, will face constraints on 
dividends, equity repurchases and discretionary 
executive compensation based on the amount of the 
shortfall.  Different regulatory capital buffers apply to 
our banking subsidiaries. 

The following table presents the principal minimum 
capital ratio requirements with buffers and 
surcharges, as phased-in, applicable to the Parent and 
our U.S. insured depository institutions.  This table 
does not include the imposition of a countercyclical 
capital buffer.  Buffers and surcharges are not 
applicable to the Tier 1 leverage ratio.  The SLR 
buffer was fully implemented on Jan. 1, 2018 and the 
other buffers and surcharge were fully implemented 
on Jan. 1, 2019. 

Dec. 31,
2018
$ 17,838

4,097

417
4,514

(1,052)
(3,269)
(4,321)

(302)
(380)
(120)
(10)
(2)
(814)
453

(109)
(1)
26
(19)
(103)
(271)
$ 17,567

(a)  Primarily related to stock awards, the exercise of stock 
options and stock issued for employee benefit plans.

Capital ratio requirements

Capital conservation buffer (CET1)
U.S. G-SIB surcharge (CET1) (b)(c)

Consolidated:
CET1 ratio
Tier 1 capital ratio
Total capital ratio

Enhanced SLR buffer (Tier 1 capital)
SLR

U.S. insured depository institutions: (c)

CET1 ratio
Tier 1 capital ratio
Total capital ratio

SLR

Well
capitalized

Minimum
ratios

Minimum ratios with buffers, 
as phased-in (a)
2018
1.875%
1.125%

2019
2.5%
1.5%

N/A
6.0%
10.0%

N/A
N/A

6.5%
8.0%
10.0%

6.0%

4.5%
6.0%
8.0%

3.0%

4.5%
6.0%
8.0%

3.0%

7.5%
9.0%
11.0%

2.0%
5.0%

6.375%
7.875%
9.875%

8.5%
10.0%
12.0%

2.0%
5.0%

7.0%
8.5%
10.5%

6.0% (d)

6.0% (d)

(a)  Countercyclical capital buffer currently set to 0%. 
(b)  The fully phased-in U.S. G-SIB surcharge of 1.5% applicable to BNY Mellon is subject to change. 
(c)  The U.S. G-SIB surcharge is not applicable to the regulatory capital ratios of the bank subsidiaries. 
(d)  Well capitalized threshold. 

 48 BNY Mellon

Capital ratios vary depending on the size of the 
balance sheet at year-end and the levels and types of 
investments in assets.  The balance sheet size 
fluctuates from year to year based on levels of 
customer and market activity.  In general, when 
servicing clients are more actively trading securities, 
deposit balances and the balance sheet as a whole are 
higher.  In addition, when markets experience 
significant volatility or stress, our balance sheet size 
may increase considerably as client deposit levels 
increase.

Results of Operations (continued)

The following table shows the impact on the 
consolidated capital ratios at Dec. 31, 2018 of a $100 
million increase or decrease in common equity, or a 
$1 billion increase or decrease in RWAs, quarterly 
average assets or total leverage exposure.

Sensitivity of consolidated capital ratios at Dec. 31, 2018
Increase or decrease of

$100 million
in common 
equity

$1 billion in 
RWA, quarterly 
average assets 
or total leverage 
exposure

(in basis points)
CET1:

Standardized Approach
Advanced Approach

7 bps
6

8 bps
7

Tier 1 capital:

Standardized Approach
Advanced Approach

Total capital:

Standardized Approach
Advanced Approach

Tier 1 leverage

SLR

7
6

7
6

3

3

9
8

10
8

2

2

Issuer purchases of equity securities

Share repurchases - fourth quarter of 2018

Maximum approximate dollar
value of shares that may yet
be purchased under the
publicly announced plans or
programs at Dec. 31, 2018
1,432
$
1,356
1,257
1,257 (b)
(a)  Includes 14 thousand shares repurchased at a purchase price of $1 million from employees, primarily in connection with the employees’ 

(dollars in millions, except per share
information; common shares in thousands)
October 2018
November 2018
December 2018

Total shares 
repurchased as
 part of a publicly 
announced plan 
or program
7,763
1,479
19,702
28,944

Average price
per share
47.30
51.14
47.15
47.40

Total shares
repurchased
7,763
1,479
19,702
28,944

Fourth quarter of 2018 (a)

$

$

$

payment of taxes upon the vesting of restricted stock.  The average price per share of open market purchases was $47.39.

(b)  Represents the maximum value of the shares authorized to be repurchased through the second quarter of 2019, including employee 

benefit plan repurchases.

In June 2018, in connection with the Federal 
Reserve’s non-objection to our 2018 capital plan, 
BNY Mellon announced a share repurchase plan 
providing for the repurchase of up to $2.4 billion of 
common stock starting in the third quarter of 2018 
and continuing through the second quarter of 2019.  
This new share repurchase plan replaces all 
previously authorized share repurchase plans.

In December 2018, the Federal Reserve approved the 
repurchase of up to $830 million of additional 
common stock under our repurchase program.  Our 

Board of Directors approved the additional share 
repurchases, all of which were repurchased in the 
fourth quarter of 2018.  These repurchases were in 
addition to the Company’s repurchase of $2.4 billion 
of common stock previously approved by the Board 
and announced in June 2018.

Share repurchases may be executed through open 
market repurchases, in privately negotiated 
transactions or by other means, including through 
repurchase plans designed to comply with Rule 
10b5-1 and other derivative, accelerated share 

BNY Mellon 49 

Results of Operations (continued)

repurchase and other structured transactions.  The 
timing and exact amount of any common stock 
repurchases will depend on various factors, including 
market conditions and the common stock trading 
price; the Company’s capital position, liquidity and 
financial performance; alternative uses of capital; and 
legal and regulatory considerations.

VaR (a)
(in millions)
Interest rate
Foreign exchange
Equity
Credit
Diversification
Overall portfolio

2018
Average Minimum Maximum
$

4.1 $
4.3
0.7
0.9
(4.2)
5.8

3.0 $
2.9
—
0.6
N/M
3.6

5.5 $
8.3
1.2
2.6
N/M
10.4

Dec. 31,
2018
4.3
4.1
0.8
0.6
(3.2)
6.6

Trading activities and risk management

Our trading activities are focused on acting as a 
market-maker for our customers, facilitating customer 
trades and risk mitigating hedging in compliance with 
the Volcker Rule.  The risk from market-making 
activities for customers is managed by our traders and 
limited in total exposure through a system of position 
limits, value-at-risk (“VaR”) methodology and other 
market sensitivity measures.  VaR is the potential loss 
in value due to adverse market movements over a 
defined time horizon with a specified confidence 
level.  The calculation of our VaR used by 
management and presented below assumes a one-day 
holding period, utilizes a 99% confidence level, and 
incorporates non-linear product characteristics.  VaR 
facilitates comparisons across portfolios of different 
risk characteristics.  VaR also captures the 
diversification of aggregated risk at the firm-wide 
level.

VaR represents a key risk management measure and it 
is important to note the inherent limitations to VaR, 
which include:

•  VaR does not estimate potential losses over longer 

time horizons where moves may be extreme;
•  VaR does not take account of potential variability 

of market liquidity; and

•  Previous moves in market risk factors may not 

produce accurate predictions of all future market 
moves.

See Note 22 of the Notes to Consolidated Financial 
Statements for additional information on the VaR 
methodology.

The following tables indicate the calculated VaR 
amounts for the trading portfolio for the designated 
periods using the historical simulation VaR model.  

 50 BNY Mellon

2017
Average Minimum Maximum
$

VaR (a)
(in millions)
Interest rate
Foreign exchange
Equity
Credit
Diversification
Overall portfolio
(a)  VaR exposure does not include the impact of the Company’s 
consolidated investment management funds and seed capital 
investments.

4.9 $
8.6
1.1
1.7
N/M
9.9

2.4 $
2.6
0.1
0.5
N/M
3.2

3.6 $
4.1
0.5
1.1
(5.0)
4.3

Dec. 31,
2017
4.4
8.6
0.8
1.3
(5.2)
9.9

N/M - Because the minimum and maximum may occur on different 
days for different risk components, it is not meaningful to 
compute a minimum and maximum portfolio diversification 
effect.

The interest rate component of VaR represents 
instruments whose values predominantly vary with 
the level or volatility of interest rates.  These 
instruments include, but are not limited to: sovereign 
debt, swaps, swaptions, forward rate agreements, 
exchange-traded futures and options, and other 
interest rate derivative products.

The foreign exchange component of VaR represents 
instruments whose values predominantly vary with 
the level or volatility of currency exchange rates or 
interest rates.  These instruments include, but are not 
limited to: currency balances, spot and forward 
transactions, currency options, exchange-traded 
futures and options, and other currency derivative 
products.

The equity component of VaR consists of instruments 
that represent an ownership interest in the form of 
domestic and foreign common stock or other equity-
linked instruments.  These instruments include, but 
are not limited to: common stock, exchange-traded 
funds, preferred stock, listed equity options (puts and 
calls), OTC equity options, equity total return swaps, 
equity index futures and other equity derivative 
products.

The credit component of VaR represents instruments 
whose values predominantly vary with the credit 
worthiness of counterparties.  These instruments 

Results of Operations (continued)

include, but are not limited to, credit derivatives 
(credit default swaps and exchange-traded credit 
index instruments) and exposures from corporate 
credit spreads, and mortgage prepayments.  Credit 
derivatives are used to hedge various credit 
exposures.

The diversification component of VaR is the risk 
reduction benefit that occurs when combining 
portfolios and offsetting positions, and from the 
correlated behavior of risk factor movements.

Distribution of trading revenue (loss) (a)

(dollars in millions)
Revenue range:

Less than $(2.5)
$(2.5) – $0
$0 – $2.5
$2.5 – $5.0
More than $5.0

During 2018, interest rate risk generated 41% of 
average gross VaR, foreign exchange risk generated 
43% of average gross VaR, equity risk accounted for 
7% of average gross VaR and credit risk generated 
9% of average gross VaR.  During 2018, our daily 
trading loss exceeded our calculated VaR amount of 
the overall portfolio on one occasion. 

The following table of total daily trading revenue or 
loss illustrates the number of trading days in which 
our trading revenue or loss fell within particular 
ranges during the past five quarters. 

Quarter ended

Dec. 31,
2018

Sept. 30,
2018

June 30,
2018

March 31,
2018

Dec. 31,
2017

1
7
17
24
13

Number of days

—
6
30
20
7

1
3
21
30
9

—
2
18
32
10

2
4
23
22
11

(a)  Trading revenue (loss) includes realized and unrealized gains and losses primarily related to spot and forward foreign exchange 

transactions, derivatives and securities trades for our customers and excludes any associated commissions, underwriting fees and net 
interest revenue.

Trading assets include debt and equity instruments 
and derivative assets, primarily interest rate and 
foreign exchange contracts, not designated as hedging 
instruments.  Trading assets were $7.0 billion at Dec. 
31, 2018 and $6.0 billion at Dec. 31, 2017.  The 
increase was impacted by the reclassification of 
money market fund investments of approximately $1 
billion primarily from available-for-sale securities.

Trading liabilities include debt and equity instruments 
and derivative liabilities, primarily interest rate and 
foreign exchange contracts, not designated as hedging 
instruments.  Trading liabilities were $3.5 billion at 
Dec. 31, 2018 and $4.0 billion at Dec. 31, 2017.

Under our fair value methodology for derivative 
contracts, an initial “risk-neutral” valuation is 
performed on each position assuming time-
discounting based on a AA credit curve.  In addition, 
we consider credit risk in arriving at the fair value of 
our derivatives.  

We reflect external credit ratings as well as 
observable credit default swap spreads for both 
ourselves and our counterparties when measuring the 
fair value of our derivative positions.  Accordingly, 
the valuation of our derivative positions is sensitive to 

the current changes in our own credit spreads, as well 
as those of our counterparties. 

At Dec. 31, 2018, our OTC derivative assets, 
including those in hedging relationships, of $2.8 
billion included a credit valuation adjustment 
(“CVA”) deduction of $22 million.  Our OTC 
derivative liabilities, including those in hedging 
relationships, of $2.4 billion included a debit 
valuation adjustment (“DVA”) of $1 million related to 
our own credit spread.  Net of hedges, the CVA 
decreased by $4 million and the DVA increased by 
less than $1 million in 2018.  The net impact of these 
adjustments increased foreign exchange and other 
trading revenue by $5 million in 2018.  During 2018, 
no realized loss was charged off against CVA 
reserves.

At Dec. 31, 2017, our OTC derivative assets, 
including those in hedging relationships, of $3.1 
billion included a CVA deduction of $27 million.  Our 
OTC derivative liabilities, including those in hedging 
relationships, of $3.6 billion included a DVA of $1 
million related to our own credit spread.  Net of 
hedges, the CVA decreased by $9 million and the 
DVA decreased by $1 million in 2017.  The net 
impact of these adjustments increased foreign 

BNY Mellon 51 

Results of Operations (continued)

exchange and other trading revenue by $8 million in 
2017.  During 2017, no realized loss was charged off 
against CVA reserves.

The table below summarizes the risk ratings for our 
foreign exchange and interest rate derivative 
counterparty credit exposure during the past five 

quarters.  This information indicates the degree of 
risk to which we are exposed.  Significant changes in 
ratings classifications for our foreign exchange and 
other trading activity could result in increased risk for 
us.

Foreign exchange and other trading counterparty risk rating profile (a)

Quarter ended

Rating:
AAA to AA-
A+ to A-
BBB+ to BBB-
Non-investment grade (BB+ and lower)

Total

(a)  Represents credit rating agency equivalent of internal credit ratings.

Dec. 31,
2018

Sept. 30,
2018

June 30,
2018

March 31,
2018

Dec. 31,
2017

50%
28
18
4
100%

48%
30
19
3
100%

37%
41
18
4
100%

48%
27
20
5
100%

44%
31
20
5
100%

Asset/liability management

Our diversified business activities include processing 
securities, accepting deposits, investing in securities, 
lending, raising money as needed to fund assets and 
other transactions.  The market risks from these 
activities include interest rate risk and foreign 
exchange risk.  Our primary market risk is exposure 
to movements in U.S. dollar interest rates and certain 
foreign currency interest rates.  We actively manage 
interest rate sensitivity and use earnings simulation 
and discounted cash flow models to identify interest 
rate exposures. 

An earnings simulation model is the primary tool 
used to assess changes in pre-tax net interest revenue.  
The model incorporates management’s assumptions 
regarding interest rates, market spreads, changes in 
the prepayment behavior of loans and securities and 
the impact of derivative financial instruments used 
for interest rate risk management purposes.  These 
assumptions have been developed through a 
combination of historical analysis and future expected 

pricing behavior and are inherently uncertain.  Actual 
results may differ materially from projected results 
due to timing, magnitude and frequency of interest 
rate changes, and changes in market conditions and 
management’s strategies, among other factors.   

In the table below, we use the earnings simulation 
model to run various interest rate ramp scenarios 
from a baseline scenario.  The interest rate ramp 
scenarios examine the impact of large interest rate 
movements.  In each scenario, all currencies’ interest 
rates are shifted higher or lower.  The baseline 
scenario is based on our quarter-end balance sheet 
and the spot yield curve.  The 100 basis point ramp 
scenario assumes rates change 25 basis points above 
or below the yield curve in each of the next four 
quarters and the 200 basis point ramp scenario 
assumes a 50 basis point per quarter change.  Interest 
rate sensitivity is quantified by calculating the change 
in pre-tax net interest revenue between the scenarios 
over a 12-month measurement period.  

The following table shows net interest revenue sensitivity for BNY Mellon. 

Estimated changes in net interest revenue 
(in millions)
Up 200 bps parallel rate ramp vs. baseline (a)
Up 100 bps parallel rate ramp vs. baseline (a)
Down 100 bps parallel rate ramp vs. baseline (a)
Long-term up 50 bps, short-term unchanged (b)
Long-term down 50 bps, short-term unchanged (b)
(a)  In the parallel rate ramp, both short-term and long-term rates move in four equal quarterly increments.
(b)  Long-term is equal to or greater than one year.

$

Dec. 31,
2018
411 $
198
(163)
82
(98)

Sept. 30,
2018

362 $
180
(140)
83
(96)

Dec. 31,
2017
280
148
(225)
105
(122)

 52 BNY Mellon

Results of Operations (continued)

Sensitivities in the 200 bps and 100 bps parallel rate 
ramp scenarios increased in the fourth quarter of 2018 
from the third quarter of 2018 primarily driven by a 
favorable asset and liability mix change.  In the first 
quarter of 2018, we changed the net interest revenue 
sensitivity methodology to assume static deposit 
levels.  Previously, our sensitivities included 
assumptions about deposit runoff which were difficult 
to predict.  Prior period results have been restated to 
conform to the current methodology.

To illustrate the net interest revenue sensitivity to 
deposit runoff, we note that a $5 billion reduction of 
U.S. dollar denominated non-interest bearing deposits 
would reduce the net interest revenue sensitivity 
results in the ramp up 100 basis point and 200 basis 
point scenarios in the table above by approximately 
$150 million and approximately $185 million, 
respectively.  The impact would be smaller if the 
runoff was assumed to be a mixture of interest-
bearing and noninterest-bearing deposits. 

For a discussion of factors impacting the growth or 
contraction of deposits, see “Risk Factors - Our 
business, financial condition and results of operations 
could be adversely affected if we do not effectively 
manage our liquidity.”

We also project future cash flows from our assets and 
liabilities over a long-term horizon and then discount 
these cash flows using instantaneous parallel shocks 
to prevailing interest rates.  This measure reflects the 
structural balance sheet interest rate sensitivity by 
discounting all future cash flows.  The aggregation of 
these discounted cash flows is the economic value of 
equity (“EVE”).  The following table shows how the 
EVE would change in response to changes in interest 
rates.  

Estimated changes in EVE

Rate change:

Up 200 bps vs. baseline
Up 100 bps vs. baseline

Dec. 31,
2018

0.8%
0.8%

The asymmetrical accounting treatment of the impact 
of a change in interest rates on our balance sheet may 
create a situation in which an increase in interest rates 
can adversely affect reported equity and regulatory 
capital, even though economically there may be no 
impact on our economic capital position.  For 
example, an increase in rates will result in a decline 
in the value of our available-for-sale securities 
portfolio.  In this example, there is no corresponding 
change on our fixed liabilities, even though 
economically these liabilities are more valuable as 
rates rise.

These results do not reflect strategies that 
management could employ to limit the impact as 
interest rate expectations change.

To manage foreign exchange risk, we fund foreign 
currency-denominated assets with liability 
instruments denominated in the same currency.  We 
utilize various foreign exchange contracts if a liability 
denominated in the same currency is not available or 
desired, and to minimize the earnings impact of 
translation gains or losses created by investments in 
foreign markets.  We use forward foreign exchange 
contracts to protect the value of our net investment in 
foreign operations.  At Dec. 31, 2018, net investments 
in foreign operations totaled $13 billion and were 
spread across 15 foreign currencies.  

BNY Mellon 53 

corporate risk appetite.  The SRCC also reviews any 
material breaches to our risk appetite and approves 
action plans required to remediate the issue.  SRCC 
provides oversight for the risk management, 
compliance and ethics framework.  The Chief 
Executive Officer, Chief Risk Officer and Chief 
Financial Officer are among SRCC’s members.  

Primary risk types 

The understanding, identification and management of 
risk are essential elements for the successful 
management of BNY Mellon.  Our primary risk 
categories are: 

Credit

Market

Type of risk Description
Operational The risk of loss resulting from inadequate or
failed internal processes, human factors and
systems, breaches of technology and
information systems, or from external events.
Also includes fiduciary risk, reputational risk,
and litigation risk.
The risk of loss due to adverse changes in the 
financial markets.  Our market risks are 
primarily interest rate, foreign exchange, and 
equity risk.  Market risk particularly impacts 
our exposures that are fair valued such as the 
securities portfolio, trading book, and equity 
investments.
The risk of loss if any of our borrowers or
other counterparties were to default on their
obligations to us.  Credit risk is resident in the
majority of our assets, but primarily
concentrated in the loan and securities books,
as well as off-balance sheet exposures such as
lending commitments, letters of credit, and
securities lending indemnifications.
The risk that BNY Mellon cannot meet its cash
and collateral obligations at a reasonable cost
for both expected and unexpected cash flows,
without adversely affecting daily operations or
financial conditions.  Liquidity risk can arise
from cash flow mismatches, market constraints
from the inability to convert assets to cash, the
inability to raise cash in the markets, deposit
run-off, or contingent liquidity events.
The risk that BNY Mellon doesn’t effectively
manage and protect the firm’s market
positioning and stability.  This includes risks
associated with the inability to maintain a
strong understanding of clients’ needs, provide
suitable product offerings that are financially
viable and fit within the firm’s operating model
and adapt to transformational change in the
industry.

Liquidity

Strategic

Risk Management

Risk management overview

Governance 

BNY Mellon’s management is responsible for 
execution of the Company’s risk appetite and the risk 
management and compliance framework and the 
governance structure that supports it, with oversight 
provided by BNY Mellon’s Board of Directors and 
two key Board committees: the Risk Committee and 
the Audit Committee. 

The Risk Committee is comprised entirely of 
independent directors and meets on a regular basis to 
review and assess the control processes with respect 
to the Company’s inherent risks.  It also reviews and 
assesses the risk management activities of the 
Company and the Company’s risk policies and 
activities.  Policy formulation and day-to-day 
oversight of the Company’s risk management 
framework is delegated to the Chief Risk Officer, 
who, together with the Chief Auditor and Chief 
Compliance Officer, helps ensure an effective risk 
management governance structure.  The roles and 
responsibilities of the Risk Committee are described 
in more detail in its charter, a copy of which is 
available on our website, www.bnymellon.com. 

The Audit Committee is also comprised entirely of 
independent directors.  The Audit Committee meets 
on a regular basis to perform an oversight review of 
the integrity of the financial statements and financial 
reporting process, compliance with legal and 
regulatory requirements, our independent registered 
public accountant’s qualifications and independence, 
and the performance of our registered public 
accountant and internal audit function.  The Audit 
Committee also reviews management’s assessment of 
the adequacy of internal controls.  The functions of 
the Audit Committee are described in more detail in 
its charter, a copy of which is available on our 
website, www.bnymellon.com.  

The Senior Risk and Control Committee (“SRCC”) is 
the most senior management body responsible for 
ensuring that emerging risks are weighed against the 

 54 BNY Mellon

Risk Management (continued)

The following table presents the primary types of risk 
typically embedded in our balance sheet and our off-
balance sheet instruments.

On- and off-balance sheet risks
Assets:
Interest-bearing deposits with banks
Federal funds sold and securities

purchased under resale agreements

Securities
Trading assets
Loans
Goodwill
Intangible assets

credit
market, credit

market, credit, liquidity
market, credit, liquidity
credit, liquidity
operational, market
operational, market

Liabilities:
Deposits
Federal funds purchased and securities
sold under repurchase agreements

Trading liabilities
Payables to customers and broker-

dealers

liquidity
market, liquidity

market, liquidity
liquidity

Off-balance sheet instruments:
Lending commitments
Standby letters of credit
Commercial letters of credit
Securities lending indemnifications

credit, liquidity
credit, liquidity
credit, liquidity
market, credit

Operational risk

In providing a comprehensive array of products and 
services, we may be exposed to operational risk.  
Operational risk may result from, but is not limited 
to, errors related to transaction processing, breaches 
of internal control systems and compliance 
requirements, fraud by employees or persons outside 
BNY Mellon or business interruption due to system 
failures or other events.  Operational risk may also 
include breaches of our technology and information 
systems resulting from unauthorized access to 
confidential information or from internal or external 
threats, such as cyberattacks.  Operational risk also 
includes potential legal or regulatory actions that 
could arise as a result of noncompliance with 
applicable laws and/or regulatory requirements.  In 
the case of an operational event, we could suffer 
financial losses as well as reputational damage.  

To address these risks, we maintain comprehensive 
policies and procedures and an internal control 
framework designed to provide a sound operational 
environment.  These controls have been designed to 
manage operational risk at appropriate levels given 
our financial strength, the business environment and 
markets in which we operate, and the nature of our 
businesses, and considering factors such as 

competition and regulation.  Our internal auditors and 
internal control group monitor and test the overall 
effectiveness of our internal controls and financial 
reporting systems on an ongoing basis. 

We have also established procedures that are designed 
to ensure compliance with generally accepted 
conduct, ethics and business practices which are 
defined in our corporate policies.  These include 
training programs, such as for our “Code of Conduct” 
and “Know Your Customer” programs, and 
compliance training programs, such as those 
regarding information protection and suspicious 
activity reporting. 

We have established operational risk management as 
an independent risk discipline.  The organizational 
framework for operational risk is based upon a strong 
risk culture that incorporates both governance and 
risk management activities comprising:

•  Board Oversight and Governance – The Risk 

Committee of the Board oversees our operational 
risk management strategy in addition to 
overseeing our strategic management of credit 
and market risk.  The Risk Committee meets 
regularly to review operational risk management 
initiatives, discuss key risk issues and review the 
effectiveness of the risk management systems. 

•  Accountability of Businesses – Business 

managers are responsible for maintaining an 
effective system of internal controls 
commensurate with their risk profiles and in 
accordance with BNY Mellon policies and 
procedures. 

•  Corporate Operational Risk Management is 
responsible for developing risk management 
policies and tools for assessing, measuring, 
monitoring and managing operational risk for 
BNY Mellon.  The primary objectives of 
Corporate Operational Risk Management are to 
promote effective risk management, identify 
emerging risks, create incentives for generating 
continuous improvement in controls and to 
optimize capital.  

•  Technology Risk is a subset of operational risk.  
Technology Risk Management is under the 
leadership of the Global Chief Technology Risk 
Officer (“CTRO”) and drives the development of 
global technology policies, controls and methods 
for assessing, measuring and monitoring 
information and technology risk for BNY Mellon.  

BNY Mellon 55 

Risk Management (continued)

Technology Risk Management partners with the 
businesses to drive better understanding and a 
more accurate assessment of operational risks 
that can occur from technology operations.

Market risk

Our business activity tends to minimize outright or 
direct exposure to market risk, with such risk 
primarily limited to market volatility from trading 
activity in support of clients.  More significant direct 
market risk is assumed in the form of interest rate and 
credit spread risk within the investment portfolio both 
as a means for forward asset/liability management 
and net interest revenue generation.

The Company has indirect market risk exposure 
associated with the change in the value of financial 
collateral underlying securities financing and 
derivatives positions.  The Collateral Margin Review 
Committee reviews and approves the standards for 
collateral received or paid in respect of collateralized 
derivative agreements and securities financing 
transactions.

In addition to the Risk Committee, oversight of 
market risk is performed by the SRCC and Balance 
Sheet Risk Committee (“BSRC”) and through 
executive review meetings.  Detailed reviews of 
stress tests results are conducted during the Markets 
Weekly Risk Review.  Senior managers from Risk 
Management, Finance and Sales and Trading attend 
the review.  Regarding the Corporate Treasury 
function, oversight is provided by the Treasury Risk 
Committee, biweekly Portfolio Management Group 
risk meetings, Business Risk Committee and 
numerous portfolio reviews.

The Business Risk Committee for the Markets 
business also provides a forum for market risk 
oversight.  The goal of the Business Risk Committee 
meeting, which is held monthly, is to review key risk 
and control issues and related initiatives facing all 
Markets lines of business.  Also addressed during the 
Business Risk Committee meetings are trading VaR 
and trading stressed VaR exposures against limits.

Finally, the Risk Quantification Review Group 
reviews back-testing results for the Company’s VaR 
model.  

 56 BNY Mellon

Credit risk  

The extension of credit is not considered a discrete 
product and is not, typically, attributable to a specific 
business, but instead is used as a means of supporting 
our clients and our business activity more holistically.  
Specifically, we extend direct credit in order to foster 
client relationships and as a method by which to 
generate interest income from the deposits that result 
from business activity.  We extend and incur intraday 
credit exposure in order to facilitate our various 
processing activities. 

To balance the value of our activities with the credit 
risk incurred in pursuing them, we set and monitor 
internal credit limits for activities that entail credit 
risk, most often on the size of the exposure and the 
quality of the counterparty.  For credit exposures 
driven by changing market rates and prices, exposure 
measures include an add-on for such potential 
changes.  

We manage credit risk at both the individual exposure 
level as well as the portfolio level.  Credit risk at the 
individual exposure level is managed through our 
credit approval system and involves four approval 
levels up to and including the Chief Risk Officer of 
the Company.  The requisite approvals are based upon 
the size and relative risk of the aggregate exposure 
under consideration.  The Credit Risk Group is 
responsible for approving the size, terms and maturity 
of all credit exposures as well as the ongoing 
monitoring of the creditworthiness of the 
counterparty.  In addition, they are responsible for 
assigning and maintaining the internal risk ratings on 
each exposure.  

Credit risk management at the portfolio level is 
supported by the Enterprise Capital Adequacy Group, 
within Risk Management and Compliance.  The 
Enterprise Capital Adequacy Group is responsible for 
calculating two fundamental credit measures.  First, 
we project a statistically probable credit loss, used to 
help determine the appropriate loan loss reserve and 
to measure customer profitability.  Credit loss 
considers three basic components:  the estimated size 
of the exposure whenever default might occur, the 
probability of default before maturity and the severity 
of the loss we would incur, commonly called “loss 
given default.”  For institutional lending, where most 
of our credit risk is created, unfunded commitments 
are assigned a usage given default percentage.  
Borrowers/counterparties are assigned ratings by 

Risk Management (continued)

Credit Portfolio Managers on an 18-grade scale, 
which translate to a scaled probability of default.  
Additionally, transactions are assigned loss-given-
default ratings (on a 7-grade scale) that reflect the 
transactions’ structures including the effects of 
guarantees, collateral and relative seniority of 
position.  

The second fundamental measurement of credit risk 
calculated by the Enterprise Capital Adequacy Group 
is called economic capital.  Our economic capital 
model estimates the capital required to support the 
overall credit risk portfolio.  Using a Monte Carlo 
simulation engine and measures of correlation among 
borrower defaults, the economic capital model 
examines extreme and highly unlikely scenarios of 
portfolio credit loss in order to estimate credit-related 
capital, and then allocates that capital to individual 
borrowers and exposures.   

The Enterprise Capital Adequacy Group is 
responsible for the calculation methodologies and the 
estimates of the inputs used in those methodologies 
for the determination of expected loss and economic 
capital.  These methodologies and input estimates are 
regularly evaluated to ensure their appropriateness 
and accuracy.  As new techniques and data become 
available, the Enterprise Capital Adequacy Group 
attempts to incorporate, where appropriate, those 
techniques or data.  

BNY Mellon seeks to limit both on- and off-balance 
sheet credit risk through prudent underwriting and the 
use of capital only where risk-adjusted returns 
warrant.  We seek to manage risk and improve our 
portfolio diversification through syndications, asset 
sales, credit enhancements and active collateralization 
and netting agreements.  In addition, we have a 
separate Credit Risk Review Group, which is part of 
Internal Audit, made up of experienced loan review 
officers who perform timely reviews of the loan files 
and credit ratings assigned to the loans.  

Liquidity risk

Access to global capital markets and financial market 
utilities are fundamental to both our operating model 
and overall strategy.  Without such access, it would be 
difficult, if not impossible, to process payments as 
well as settle and clear transactions on behalf of 
clients.  Deterioration in our liquidity position, 
whether actual or perceived, can impact our market 
access by affecting participants’ willingness to 

transact with us.  Changes to our liquidity can be 
caused by various factors, such as funding 
mismatches, market constraints limiting the ability to 
liquidate assets, inability to issue debt, run-off of core 
deposits and contingent liquidity events, such as 
additional collateral posting.  Changes in economic 
conditions or exposure to credit, market, operational, 
legal and reputational risks can also affect our 
liquidity.  Our liquidity risk management practices are 
designed to maintain a strong liquidity profile, by 
actively managing both the quality of the investment 
portfolio and intraday liquidity positions, and by 
having sufficient deposits and other funding to meet 
timely payment and settlement obligations under both 
normal and stressed conditions.

Our overall approach to liquidity management is to 
have sources of liquidity that are sufficient in amount 
and diversity such that changes in funding 
requirements at the Parent and at our bank and 
broker-dealer subsidiaries can be accommodated 
routinely without material adverse impact on 
earnings, capital, daily operations or our financial 
condition.

The Board of Directors has the responsibility for 
oversight of liquidity risk management for the 
Company and approves the liquidity risk tolerances. 
The Asset Liability Committee (“ALCO”) is the 
senior management committee responsible for the 
oversight of liquidity management.  ALCO is 
responsible for appropriately executing Board-
approved strategies, policies and procedures for 
managing liquidity.  Senior management is 
responsible for regularly reporting the liquidity 
position of the Company to the Board of Directors.  
The BSRC provides governance over independent 
Risk oversight of liquidity risks associated with assets 
and liabilities, liquidity risk limits calibration, and the 
adequacy of related control procedures.  The Treasury 
Risk Committee, which is chaired by independent 
risk management, is responsible for reviewing 
liquidity stress tests and various liquidity metrics, 
including contractual cash flow gaps for liquidity, 
liquidity stress metrics and ratios, LCR, net stable 
funding ratio (“NSFR”) and client deposit 
concentration.  The Treasury Risk Committee 
validates and approves stress test methodologies and 
assumptions, and an independent liquidity Risk 
function provides ongoing review and oversight of 
liquidity risk management.

BNY Mellon 57 

Risk Management (continued)

BNY Mellon seeks to maintain an adequate liquidity 
cushion in both normal and stressed environments 
and seeks to diversify funding sources by line of 
business, customer and market segment.  
Additionally, we seek to maintain liquidity ratios 
within approved limits and liquidity risk tolerance, 
maintain a liquid asset buffer that can be liquidated, 
financed and/or pledged as necessary, and control the 
levels and sources of wholesale funds.

Potential uses of liquidity include withdrawals of 
customer deposits and client drawdowns on unfunded 
credit or liquidity facilities.  We actively monitor 
unfunded lending-related commitments, thereby 
reducing unanticipated funding requirements.

When monitoring liquidity, we evaluate multiple 
metrics in order to have sufficient liquidity for 
expected and unexpected events.  Metrics include 
cash flow mismatches, asset maturities, debt spreads, 
peer ratios, liquid assets, unencumbered collateral, 
funding sources and balance sheet liquidity ratios.  
We monitor the LCR, as well as various internal 
liquidity limits as part of our standard analysis to 
monitor depositor and market funding concentration, 
liability maturity profile and potential liquidity draws 
due to off-balance sheet exposure. 

We also perform liquidity stress tests (“LSTs”) to 
evaluate whether the Company and certain domestic 
bank subsidiaries maintain sufficient liquidity 
resources under multiple stress scenarios.  LSTs are 
based on scenarios that measure liquidity risks under 
unlikely but plausible conditions.  We perform these 
tests under various time horizons ranging from one 
day to one year in a base case, as well as 
supplemental tests to determine whether the 
Company and certain domestic subsidiaries’ liquidity 
is sufficient for severe market events and firm-
specific events.  The Parent’s LST framework 
includes the Resolution Liquidity Adequacy and 
Positioning (“RLAP”) test.  The RLAP test is 
designed to ensure that the liquidity needs of certain 
key subsidiaries in a stress environment can be met 
by available resources held directly within the entity 
itself or at the Parent or IHC, as applicable.  Our 
results indicate that we have sufficient RLAP 
liquidity.

 58 BNY Mellon

Strategic Risk

Our strategy includes expanding our client base, 
increasing product offerings and better aligning 
certain business activities with market demand.  
Successful realization of our strategy requires that we 
provide expertise and insight through market-leading 
solutions that drive economies of scale while 
developing highly talented people and protecting our 
financial strength and stability.  We understand and 
meet market and client expectations with suitable 
products and offerings that are financially viable and 
leverageable and that integrate into our business 
model.  

Markets, and the manner in which our clients interact 
and transact within markets, can evolve quickly, such 
as when new or disruptive technologies are 
introduced.  Failure to either anticipate or participate 
in transformational change within a given market 
could result in poor strategic positioning and potential 
negative financial impact.

Stress Testing

It is the policy of the Company to perform Enterprise-
wide Stress Testing at regular intervals as part of its 
Internal Capital Adequacy Assessment Process 
(“ICAAP”).  Additionally, the Company performs an 
analysis of capital adequacy in a stressed 
environment in its Enterprise-Wide Stress Test 
Framework, as required by the enhanced prudential 
standards issued pursuant to the Dodd-Frank Act. 

Enterprise-Wide Stress Testing performs analyses 
across the Company’s lines of business, products, 
geographic areas, and risk types incorporating the 
results from the different underlying models and 
projections given alternative stress test scenarios.  It 
is an important component of assessing the adequacy 
of capital as well as identifying any high risk touch 
points in business activities.  Furthermore, by 
integrating enterprise-wide stress testing into the 
Company’s capital planning process, the results 
provide a forward-looking evaluation of the ability to 
complete planned capital actions in a more-adverse-
than-anticipated economic environment. 

Risk Management (continued)

Global compliance

Internal audit

Our global compliance function provides leadership, 
guidance and oversight to help our businesses 
identify applicable laws and regulations and 
implement effective measures to meet the specific 
requirements.  Compliance takes a proactive 
approach by anticipating evolving regulatory 
standards and remaining aware of industry best 
practices, legislative initiatives, competitive issues, 
and public expectations and perceptions.  The 
function uses its global reach to disseminate 
information about compliance-related matters 
throughout BNY Mellon.  The Chief Compliance and 
Ethics Officer reports to the Chief Risk Officer, is a 
member of key committees of BNY Mellon and 
provides regular updates to the Risk Committee of the 
Board of Directors.

Internal Audit is an independent, objective assurance 
function that reports directly to the Audit Committee 
of the Company’s Board of Directors.  It assists the 
Company in accomplishing its objectives by bringing 
a systematic, disciplined, risk-based approach to 
evaluate and improve the effectiveness of the 
Company’s risk management, control and governance 
processes.  The scope of Internal Audit’s work 
includes the review and evaluation of the adequacy, 
effectiveness and sustainability of risk management 
procedures, internal control systems, information 
systems and governance processes.

BNY Mellon 59 

Supervision and Regulation

Evolving Regulatory Environment

BNY Mellon engages in banking, investment 
advisory and other financial activities in the U.S. and 
34 other countries, and is subject to extensive 
regulation in the jurisdictions in which it operates.  
Global supervisory authorities generally are charged 
with ensuring the safety and soundness of financial 
institutions, protecting the interests of customers, 
including depositors in banking entities and investors 
in mutual funds and other pooled vehicles, 
safeguarding the integrity of securities and other 
financial markets and promoting systemic resiliency 
and financial stability in the relevant country.  They 
are not, however, generally charged with protecting 
the interests of our shareholders or non-deposit 
creditors.  This discussion outlines the material 
elements of selected laws and regulations applicable 
to us.  The impact of certain other laws and 
regulations, such as tax law, is discussed elsewhere in 
the Annual Report.  Changes in these standards, or in 
their application, cannot be predicted, but may have a 
material effect on our businesses and results of 
operations.

The financial services industry has been the subject of 
enhanced regulatory oversight in the past decade 
globally, and this trend may continue in the future.  
Our businesses have been subject to a significant 
number of global reform measures.  In particular, the 
Dodd-Frank Act and its implementing regulations 
have significantly restructured the financial 
regulatory regime in the U.S. and enhanced 
supervision and prudential standards for large and 
internationally active BHCs like BNY Mellon.  The 
implications of the Dodd-Frank Act for our 
businesses depend to a large extent on the manner in 
which implementing regulations continue to be 
established and interpreted by the primary U.S. 
financial regulatory agencies - the Federal Reserve, 
the Federal Deposit Insurance Corporation (“FDIC”), 
the Office of the Comptroller of the Currency 
(“OCC”), the Securities and Exchange Commission 
(“SEC”) and the Commodity Futures Trading 
Commission (“CFTC”).  The implications are also 
dependent on continuing changes in market practices 
and structures in response to the requirements of the 
Dodd-Frank Act and financial reforms in other 
jurisdictions.  Certain aspects of the Dodd-Frank Act 
remain subject to further rulemaking, take effect over 
various transition periods, or contain other elements 
that make it difficult to precisely anticipate their full 
impact.  In addition, other national and global non-

 60 BNY Mellon

U.S. reform measures adopted or under consideration 
by various policy makers that are being considered 
may materially adversely impact us.

Political developments may result in legislative and 
regulatory changes to key aspects of the Dodd-Frank 
Act, its implementing regulations, and related laws, 
including the recently enacted Economic Growth, 
Regulatory Relief, and Consumer Protection Act (the 
“Reform Act”), discussed later in this section.  In 
addition, the UK referendum vote to withdraw from 
the European Union, discussed below, and the 
implementation of that decision have resulted in 
uncertainty as to the implementation, scope and 
timing of regulatory reforms affecting our UK and 
EU operations and contingency planning for our EU 
operating model.

United Kingdom’s Withdrawal from the European 
Union (“Brexit”)

The United Kingdom is scheduled to withdraw from 
the European Union on March 29, 2019.  In 
anticipation of this event, BNY Mellon has assessed 
the impact of this withdrawal on our businesses.  Our 
program currently assumes that the UK will leave the 
EU without an agreement in place, meaning that, 
among other things, UK firms will lose the benefit of 
transacting within the EU by relying on their existing 
“passport” on March 29, 2019.

BNY Mellon maintains a presence in the UK through 
the London branch of The Bank of New York Mellon, 
The Bank of New York Mellon (International) 
Limited and a number of its investment management 
subsidiaries, and in the remaining EU member states, 
through The Bank of New York Mellon SA/NV 
(“BNY Mellon SA/NV”) and through certain of its 
investment management subsidiaries.  We have 
undertaken, and continue to undertake, adjustments to 
the operations of BNY Mellon SA/NV so that it may 
provide a wider range of services to clients domiciled 
in the EU. 

Enhanced Prudential Standards

The Federal Reserve has adopted rules (“Final SIFI 
Rules”) to implement liquidity requirements, stress 
testing of capital and overall risk management 
requirements affecting U.S. SIFIs.  BNY Mellon must 
comply with enhanced liquidity and overall risk 
management standards, which include maintenance of 
a buffer of highly liquid assets based on projected 

Supervision and Regulation (continued)

funding needs for 30 days.  The liquidity buffer is in 
addition to the U.S. banking agencies’ rules regarding 
the LCR, discussed below, and is described by the 
Federal Reserve as being “complementary” to those 
liquidity standards.

Financial Services Regulatory Reform Legislation

The Reform Act became law in May 2018.  
Provisions of the Reform Act that may impact BNY 
Mellon include the elimination of the Dodd-Frank 
company-run stress test requirements for BHCs, 
banks, and other financial companies with less than 
$250 billion in assets, including BNY Mellon, N.A.; 
the elimination of the “adverse scenario” as a 
required stress scenario, reducing the minimum 
number of supervisory scenarios from three (baseline, 
adverse, and severely adverse) to two (baseline and 
severely adverse); and its direction to U.S. banking 
agencies to exclude certain central bank deposit 
placements from the total leverage exposure (the SLR 
denominator) of custody banks, including BNY 
Mellon and The Bank of New York Mellon, to the 
extent of the value of client deposits at the custody 
bank that are linked to fiduciary, custody or 
safekeeping accounts.  See “Regulatory Stress-Testing 
Requirements” and “Leverage Ratios” below.

Single Counterparty Credit Limits

On June 14, 2018, the Federal Reserve approved a 
final rule imposing single-counterparty credit limits 
(“SCCLs”) on, among other organizations, domestic 
BHCs, including BNY Mellon, that are G-SIBs or 
that have $250 billion or more in total consolidated 
assets.  The SCCLs apply to the credit exposure of a 
covered firm and all of its subsidiaries to a single 
counterparty and all of its affiliates and connected 
entities.  The final rule introduces new definitions of 
“subsidiary” and “affiliate” under a financial 
consolidation standard that is consistent with 
accounting standards.  The final rule will apply to 
BNY Mellon beginning Jan. 1, 2020. 

The final rule establishes two primary credit exposure 
limits: (1) a covered domestic BHC may not have 
aggregate net credit exposure to any unaffiliated 
counterparty in excess of 25% of its tier 1 capital, and 
(2) a U.S. G-SIB is further prohibited from having 
aggregate net credit exposure in excess of 15% of its 
tier 1 capital to any “major counterparty” (defined as 
a G-SIB or a nonbank SIFI). The final rule adopts a 
risk-sensitive exposure measurement methodology 

for securities financing transactions (“SFTs”) that 
permits the use of any method authorized under the 
Federal Reserve’s capital rules, including internal 
models.

BNY Mellon is still evaluating the impact that the 
final rule will have, which will depend on various 
factors including, for example, the Federal Reserve’s 
interpretation of the final rule, whether interpretive 
guidance is published and the impact of the final rule 
on other covered firms.

Capital Planning and Stress Testing

Payment of Dividends, Stock Repurchases and Other 
Capital Distributions

The Parent is a legal entity separate and distinct from 
its banks and other subsidiaries.  Therefore, the 
Parent primarily relies on dividends, interest, 
distributions, and other payments from its 
subsidiaries, including extensions of credit from the 
IHC, to meet its obligations, including its obligations 
with respect to its securities, and to provide funds for 
share repurchases and payment of common and 
preferred dividends to its stockholders, to the extent 
declared by the Board of Directors.  Various federal 
and state laws and regulations limit the amount of 
dividends that may be paid to the Parent by our bank 
subsidiaries without regulatory consent.  If, in the 
opinion of the applicable federal regulatory agency, a 
depository institution under its jurisdiction is engaged 
in or is about to engage in an unsafe or unsound 
practice (which, depending on the financial condition 
of the bank, could include the payment of dividends), 
the regulator may require, after notice and hearing, 
that the bank cease and desist from such practice.  
The OCC, the Federal Reserve and the FDIC have 
indicated that the payment of dividends would 
constitute an unsafe and unsound practice if the 
payment would reduce a depository institution’s 
capital to an inadequate level.  Moreover, under the 
Federal Deposit Insurance Act, as amended (the “FDI 
Act”), an insured depository institution (“IDI”) may 
not pay any dividends if the institution is 
undercapitalized or if the payment of the dividend 
would cause the institution to become 
undercapitalized.  In addition, the federal bank 
regulatory agencies have issued policy statements 
which provide that FDIC-insured depository 
institutions and their holding companies should 
generally pay dividends only out of their current 
operating earnings.

BNY Mellon 61 

Supervision and Regulation (continued)

In general, the amount of dividends that may be paid 
by our U.S. banking subsidiaries, including to the 
Parent, is limited to the lesser of the amounts 
calculated under a “recent earnings” test and an 
“undivided profits” test.  Under the recent earnings 
test, a dividend may not be paid if the total of all 
dividends declared and paid by the entity in any 
calendar year exceeds the current year’s net income 
combined with the retained net income of the two 
preceding years, unless the entity obtains prior 
regulatory approval.  Under the undivided profits test, 
a dividend may not be paid in excess of the entity’s 
“undivided profits” (generally, accumulated net 
profits that have not been paid out as dividends or 
transferred to surplus).  The ability of our bank 
subsidiaries to pay dividends to the Parent may also 
be affected by the capital adequacy standards 
applicable to those subsidiaries, which include 
minimum requirements and buffers.

There are also limitations specific to the IHC’s ability 
to make distributions or extend credit to the Parent.  
The IHC is not permitted to pay dividends to the 
Parent if certain key capital, liquidity and operational 
risk indicators are breached.  Additionally, if our 
projected financial resources deteriorate so severely 
that resolution of the Parent becomes imminent, the 
committed lines of credit provided by the IHC to the 
Parent will automatically terminate, with all 
outstanding amounts becoming due.

BNY Mellon’s capital distributions are subject to 
Federal Reserve oversight.  The major component of 
that oversight is the Federal Reserve’s 
Comprehensive Capital Analysis and Review 
(“CCAR”), implementing its capital plan rule.  That 
rule requires BNY Mellon to submit an annual capital 
plan to the Federal Reserve.  We are also required to 
collect and report certain related data on a quarterly 
basis to allow the Federal Reserve to monitor 
progress against the annual capital plans.  Generally, 
BNY Mellon and other affected BHCs may pay 
dividends, repurchase stock and make other capital 
distributions only in accordance with a capital plan 
that has been reviewed by the Federal Reserve and as 
to which the Federal Reserve has not objected.  The 
Federal Reserve may object to our capital plan for 
quantitative or qualitative reasons, including if the 
plan does not show that the covered BHC will meet, 
for each quarter throughout the nine-quarter planning 
horizon covered by the capital plan, all minimum 
regulatory capital ratios under applicable capital rules 
as in effect for that quarter on a pro forma basis under 

 62 BNY Mellon

the base case and stressed scenarios (including a 
severely adverse scenario provided by the Federal 
Reserve).  The capital plan rule also stipulates that we 
may not make a capital distribution unless after 
giving effect to the distribution it will meet all 
minimum regulatory capital ratios.

The purpose of CCAR is to ensure that these BHCs 
have robust, forward-looking capital planning 
processes that account for their unique risks and that 
permit continued operations during times of 
economic and financial stress.  The 2018 CCAR 
instructions, consistent with prior Federal Reserve 
guidance, provide that capital plans contemplating 
dividend payout ratios exceeding 30% of projected 
after-tax net income will receive particularly close 
scrutiny.  BNY Mellon’s common stock dividend 
payout ratio was 26% for 2018.  See “Capital” for 
information about our 2018 capital plan.

Regulatory Stress-Testing Requirements

In addition to the CCAR stress testing requirements, 
Federal Reserve regulations also include 
complementary Dodd-Frank Act Stress Tests 
(“DFAST”).  The CCAR and DFAST requirements 
substantially overlap, and the Federal Reserve 
implements them at the BHC level on a coordinated 
basis.  Under these DFAST regulations, we are 
required to undergo regulatory stress tests conducted 
by the Federal Reserve annually, and to conduct our 
own internal stress tests pursuant to regulatory 
requirements twice annually.  In addition, The Bank 
of New York Mellon is required to conduct its own 
annual internal stress test (although the bank is 
permitted to combine certain reporting and disclosure 
of its stress test results with the results of BNY 
Mellon).  The Reform Act revised the Dodd-Frank 
company-run stress test requirements for BHCs 
subject to enhanced prudential standards, such as 
BNY Mellon, to require periodic, rather than semi-
annual, company-run stress tests.  Proposed Federal 
Reserve regulations would require BNY Mellon and 
other affected BHCs to conduct an annual, but not a 
mid-cycle, company-run stress test effective 
beginning with the 2020 cycle.  The Reform Act also 
eliminated the Dodd-Frank company-run stress test 
requirements for BHCs, banks, and other financial 
companies with less than $250 billion in assets, 
including BNY Mellon, N.A.  Results from our 
annual company-run stress tests are reported to the 
appropriate regulators and published.  The Federal 
Reserve published the results of its most recent 

Supervision and Regulation (continued)

annual 2018 DFAST stress-test on June 21, 2018.  We 
published the results of our most recent company-run 
annual stress test on June 21, 2018, and the results of 
our company-run mid-year stress test on Oct. 12, 
2018.

Capital Requirements - Generally

As a BHC, we are subject to U.S. capital rules, 
administered by the Federal Reserve.  Our bank 
subsidiaries are subject to similar capital 
requirements administered by the Federal Reserve in 
the case of The Bank of New York Mellon and by the 
OCC in the case of our national bank subsidiaries, 
BNY Mellon, N.A. and The Bank of New York 
Mellon Trust Company, National Association.  These 
requirements are intended to ensure that banking 
organizations have adequate capital given the risk 
levels of their assets and off-balance sheet exposures.

Notwithstanding the detailed U.S. capital rules, the 
federal banking agencies retain significant discretion 
to set higher capital requirements for categories of 
BHCs or banks or for an individual BHC or bank as 
situations warrant.  

U.S. Capital Rules - Minimum Risk-Based Capital 
Ratios and Capital Buffers

Consistent with the terms of the Basel III framework 
and the Dodd-Frank Act, as amended by the Reform 
Act, the U.S. capital rules require Advanced 
Approaches banking organizations, such as BNY 
Mellon, to satisfy minimum risk-based capital ratios 
using both the U.S. capital rules’ standardized 
approach risk-weightings framework (the 
“Standardized Approach”) and the advanced 
approaches risk-weighting framework (the 
“Advanced Approaches”).  See “Capital” for details 
on these requirements.  In addition, these minimum 
ratios are supplemented by a capital conservation 
buffer required threshold that began being phased in 
on Jan. 1, 2016, in increments of 0.625% per year 
until it reached 2.5% on Jan. 1, 2019.  The capital 
conservation buffer can only be satisfied with CET1 
capital.

When systemic vulnerabilities are meaningfully 
above normal, the capital conservation buffer may be 
expanded up to an additional 2.5% through the 
imposition of a countercyclical capital buffer.  For 

internationally active banks such as BNY Mellon, the 
countercyclical capital buffer required threshold is a 
weighted average of the countercyclical capital 
buffers deployed in each of the jurisdictions in which 
the bank has private sector credit exposures.  The 
Federal Reserve, in consultation with the OCC and 
FDIC, has affirmed the current countercyclical capital 
buffer level for U.S. exposures of 0% and noted that 
any future modifications to the buffer would 
generally be subject to a 12-month phase-in period.  
Any countercyclical capital buffer required threshold 
arising from exposures outside the United States will 
also generally be subject to a 12-month phase-in 
period.

The U.S. capital rules’ buffers are also 
supplemented by a risk-based capital surcharge on 
G-SIBs which requires G-SIBs to calculate their 
surcharges under two methods (referred to as 
“method 1” and “method 2”) and use the higher of 
the two surcharges.  The first method is based on 
the BCBS’s framework and considers a G-SIB’s 
size, interconnectedness, cross-jurisdictional 
activity, substitutability and complexity.  The 
second method uses similar inputs, but is 
calibrated to result in significantly higher 
surcharges and replaces substitutability with a 
measure of reliance on short-term wholesale 
funding.  Consistent with the phase-in of the 
capital conservation buffer, the G-SIB capital 
surcharge began to be phased-in beginning on Jan. 
1, 2016 and became fully effective on Jan. 1, 
2019.  The G-SIB surcharge applicable to BNY 
Mellon is 1.5% on a fully phased-in basis.

U.S. Capital Rules - Deductions from and 
Adjustments to Capital Elements

The U.S. capital rules provide for a number of 
deductions from and adjustments to CET1 capital.  
These include, for example, providing that unrealized 
gains and losses on all available-for-sale debt 
securities may not be filtered out for regulatory 
capital purposes, and the requirement that mortgage 
servicing rights, deferred tax assets dependent upon 
future taxable income and significant investments in 
non-consolidated financial entities be deducted from 
CET1 to the extent that any one such category 
exceeds 10% of CET1 or all such categories in the 
aggregate exceed 15% of CET1.

BNY Mellon 63 

Supervision and Regulation (continued)

U.S. Capital Rules - Advanced Approaches Risk-
Based Capital Rules

amount and the relevant risk weight for the 
counterparty and collateral posted.

Under the U.S. capital rules’ Advanced Approaches 
framework, credit risk risk-weightings are generally 
based on risk-sensitive approaches that largely rely on 
the use of internal credit models and parameters, 
whereas under the Standardized Approach credit risk 
risk-weightings are generally based on supervisory 
risk-weightings which vary primarily by counterparty 
type and asset class.  BNY Mellon is required to 
comply with Advanced Approaches reporting and 
public disclosures.  Under the U.S. capital rules, this 
means, among other things, for purposes of 
determining whether we meet minimum risk-based 
capital requirements, our CET1 ratio, Tier 1 capital 
ratio, and total capital ratio is the lower of that 
calculated under the Standardized Approach and 
under the Advanced Approaches framework.

U.S. Capital Rules - Generally Applicable Risk-Based 
Capital Rules:  Standardized Approach

The agencies’ generally applicable risk-based capital 
rules (i.e., the Standardized Approach) calculate risk-
weighted assets in the denominator of capital ratios 
using a broad array of risk weighting categories that 
are intended to be risk sensitive.  The risk-weights for 
the Standardized Approach generally range from 0% 
to 1,250%.  Higher risk-weights under the 
Standardized Approach apply to a variety of 
exposures, including certain securitization exposures, 
equity exposures, claims on securities firms and 
exposures to counterparties on OTC derivatives.

Concerning securities finance transactions, including 
transactions in which we serve as agent and provide 
securities replacement indemnification to a securities 
lender, the U.S. capital rules do not permit a banking 
organization to use a simple VaR approach to 
calculate exposure amounts for repo-style 
transactions or to use internal models to calculate the 
exposure amount for the counterparty credit exposure 
for repo-style transactions under the Standardized 
Approach (although these methodologies are allowed 
in the Advanced Approaches).  Under the 
Standardized Approach, a banking organization may 
use a collateral haircut approach to recognize the 
credit risk mitigation benefits of financial collateral 
that secures a repo-style transaction, including an 
agented securities lending transaction, among other 
transactions.  To apply the collateral haircut approach, 
a banking organization must determine the exposure 

 64 BNY Mellon

Federal Reserve Proposed Changes to CCAR and its 
Capital Rules 

On April 10, 2018, the Federal Reserve issued a 
proposed rule that would integrate its regulatory 
capital, capital planning, and stress test rules, as well 
as the CCAR process. The proposal would introduce 
a stress capital buffer (“SCB”) that would be part of 
the firm’s quarterly capital requirements.  The 
proposal would replace the current static 2.5% capital 
conservation buffer with an SCB requirement for 
Standardized Approach capital ratios that would, 
among other things, be tied to the projected decrease 
in a firm’s common equity Tier 1 capital ratio in the 
Federal Reserve’s supervisory severely adverse 
scenario. The proposed rule would introduce a new 
requirement that firms reduce their planned capital 
distributions if those distributions would not be 
consistent with the applicable buffer constraints based 
on the firms’ own baseline scenario projections. In 
addition, the proposed rule would introduce a stress 
leverage buffer (“SLB”) that is analogous to the SCB 
and applies to firms’ Tier 1 leverage ratios.  Under the 
proposal, a firm’s first SCB and SLB would become 
effective on Oct. 1, 2019.

Leverage Ratios

The U.S. capital rules require a minimum 4% 
leverage ratio for all banking organizations, as well as 
a 3% Basel III-based SLR for Advanced Approaches 
banking organizations, including BNY Mellon, which 
became effective Jan. 1, 2018.  Unlike the Tier 1 
leverage ratio, the SLR includes certain off-balance 
sheet exposures in the denominator, including the 
potential future credit exposure of derivative 
contracts and 10% of the notional amount of 
unconditionally cancelable commitments.

The Reform Act directed the U.S. banking agencies to 
exclude certain central bank deposit placements from 
the total leverage exposure (the SLR denominator) of 
custody banks, including BNY Mellon and The Bank 
of New York Mellon.  The U.S. banking agencies 
have not yet proposed rules implementing this 
provision.  See “Federal Reserve and OCC Proposed 
Amendments to the Enhanced Supplementary 
Leverage Ratio Requirements for U.S. G-SIBs” below 
for a discussion of additional proposed amendments 
to applicable SLR requirements.

Supervision and Regulation (continued)

The U.S. G-SIBs (including BNY Mellon) are subject 
to an enhanced SLR, which requires us to maintain an 
SLR of greater than 5% (composed of the current 
minimum requirement of 3% plus a greater than 2% 
buffer) and requires bank subsidiaries of those BHCs 
to maintain at least a 6% SLR in order to qualify as 
“well capitalized” under the prompt corrective action 
regulations discussed below.  The final enhanced SLR 
rule for U.S. G-SIBs, like the SLR more generally 
applicable to all Advanced Approaches banking 
organizations, became effective on Jan. 1, 2018.  At 
Dec. 31, 2018, our SLR was 6.0% and the SLR for 
our primary banking subsidiary, The Bank of New 
York Mellon, was 6.8%.

Federal Reserve and OCC Proposed Amendments to 
the Enhanced Supplementary Leverage Ratio 
Requirements for U.S. G-SIBs 

On April 11, 2018, the Federal Reserve and the OCC 
issued a joint notice of proposed rule-making that 
would recalibrate the enhanced SLR standards that 
apply to U.S. G-SIBs and certain of their IDI 
subsidiaries.  The proposed rule would replace the 2% 
SLR buffer that currently applies to all U.S. G-SIBs 
with a buffer equal to 50% of the firm’s risk-based G-
SIB surcharge. 

For IDI subsidiaries of U.S. G-SIBs regulated by the 
Federal Reserve or the OCC, the proposal would 
replace the current 6% SLR threshold requirement for 
those institutions to be considered “well capitalized” 
under the agencies’ prompt corrective action 
framework with an SLR of at least 3% plus 50% of 
the G-SIB surcharge applicable to their top-tier 
holding companies. The proposed rule would also 
make corresponding changes to the total loss-
absorbing capacity (“TLAC”) SLR buffer and long-
term debt requirements for U.S. G-SIBs, as well as 
technical changes to the Federal Reserve’s TLAC 
rule.  The Federal Reserve and OCC have not yet 
issued a final rule. 

These proposed amendments are separate from the 
Reform Act’s change to the SLR denominator of 
custody banks discussed above under the heading 
“Leverage Ratios.”

BCBS Revisions to Components of Basel III

In December 2017 the BCBS released revisions to 
Basel III intended to reduce variability of RWA and 
improve the comparability of banks’ risk-based 

capital ratios.  Among other measures, the final 
revisions:  (1) establish a revised Standardized 
Approach for credit risk that enhances the 
Standardized Approach’s granularity and risk 
sensitivity; (2) adjust the internal ratings-based 
approaches for credit risk by removing the use of the 
advanced internal ratings-based approach for certain 
asset classes and establishing input floors for the 
calculation of RWA; (3) replace the advanced 
measurement approach for operational risk with a 
revised Standardized Approach for operational risk 
based on measures of a bank’s income and historical 
losses; (4) revise the leverage ratio exposure measure, 
establish a “leverage ratio buffer” for G-SIBs, set at 
50% of a G-SIB’s risk-based capital surcharge, and 
allow national discretion to exclude central bank 
placements in limited circumstances (see “Federal 
Reserve and OCC Proposed Amendments to the 
Enhanced Supplementary Leverage Ratio 
Requirements for U.S. G-SIBs” above); and (5) 
introduce a new 72.5% output floor based on the 
Standardized Approach.  The revised standards are 
effective Jan. 1, 2022, with the output floor phasing 
in from 2022 to 2027.

In January 2019, the BCBS released revised 
minimum capital requirements for market risk.  The 
revised standards also come into effect Jan. 1, 2022.  
There is continuing uncertainty regarding whether 
and how the U.S. regulators will implement these 
revised Basel standards.

Standardized Approach for Measuring Counterparty 
Credit Risk Exposures

On Oct. 30, 2018, the Federal Reserve, FDIC and 
OCC jointly issued a Notice of Proposed Rulemaking 
(“NPR”), which would amend the U.S. capital rules 
to implement a new approach for calculating the 
exposure amount for derivative contracts, which is 
called the Standardized Approach for Counterparty 
Credit Risk (“SA-CCR”).  The NPR also incorporates 
SA-CCR into the determination of exposure amount 
of derivatives for total leverage exposure under the 
SLR and the cleared transaction framework under the 
U.S. capital rules.  Further, the NPR would make 
technical amendments to the capital rule with respect 
to cleared transactions.  The effective date of the 
proposed SA-CCR rule for the Advanced Approaches 
Banks would be July 1, 2020.  BNY Mellon is 
evaluating what effect such amendments to the U.S. 
capital rules, if implemented, would have on our 
financial condition or results of operations.

BNY Mellon 65 

Supervision and Regulation (continued)

Total Loss-Absorbing Capacity

On Dec. 15, 2016, the Federal Reserve issued a final 
rule (the “TLAC Rule”) establishing external TLAC 
and related requirements for U.S. G-SIBs, including 
BNY Mellon, at the top-tier holding company level.  
The rule became effective on Jan. 1, 2019, and at 
Dec. 31, 2018, we had sufficient TLAC to be 
compliant with the requirement.

Under the TLAC Rule, U.S. G-SIBs are required to 
maintain a minimum eligible external TLAC equal to 
the greater of (a) 18% of RWAs plus a buffer (to be 
met using only CET1) equal to the sum of 2.5% of 
RWAs, the G-SIB surcharge calculated under method 
1 and any applicable countercyclical buffer; and (b) 
7.5% of their total leverage exposure (the 
denominator of the SLR) plus a buffer (to be met 
using only Tier 1 Capital) equal to 2%.

U.S. G-SIBs are also required to maintain minimum 
external eligible long-term debt (“LTD”) equal to the 
greater of (a) 6% of RWAs plus the G-SIB surcharge 
(calculated using the greater of method 1 and method 
2), and (b) 4.5% of total leverage exposure.  In order 
to be deemed eligible LTD, debt instruments must, 
among other requirements, be unsecured, not be 
structured notes, be governed by U.S. law, and have a 
maturity of at least one year from the date of 
issuance.  In addition, the TLAC Rule requires that 
LTD issued on or after Dec. 31, 2016 (i) not have 
acceleration rights, other than in the event of non-
payment or the bankruptcy or insolvency of the issuer 
and (ii) be governed by U.S. law. However, debt 
issued by a U.S. G-SIB prior to Dec. 31, 2016 is 
permanently grandfathered to the extent these 
securities would be ineligible only due to containing 
impermissible acceleration rights or being governed 
by foreign law.

Further, the top-tier holding companies of U.S. G-
SIBs are not permitted to issue certain guarantees of 
subsidiary liabilities, incur liabilities guaranteed by 
subsidiaries, issue short-term debt to third parties, or 
enter into derivatives and certain other financial 
contracts with external counterparties.  Certain 
liabilities are capped at 5% of the value of the U.S. 
G-SIB’s eligible external TLAC instruments.  The 
Federal Reserve considered requiring internal TLAC 
at domestic subsidiaries of U.S. G-SIBs, but has not 
proposed rules regarding these instruments.  

 66 BNY Mellon

Foreign jurisdictions may impose internal TLAC 
requirements on the foreign subsidiaries of U.S. G-
SIBs.  The draft Capital Requirements Regulation II 
in the European Union would require EU material 
subsidiaries of non-EU G-SIBs (including BNY 
Mellon) to maintain a minimum level of internal loss 
absorbing capacity, broadly in line with the Financial 
Stability Board (“FSB”) TLAC term sheet, 
promulgated by the Financial Stability Board in 
November 2015.  The Bank of New York Mellon SA/
NV is likely to be considered an EU material 
subsidiary for purposes of this regulation.

Prompt Corrective Action

The FDI Act, as amended by the Federal Deposit 
Insurance Corporation Improvement Act of 1991 
(“FDICIA”), requires the federal banking agencies to 
take “prompt corrective action” in respect of 
depository institutions that do not meet specified 
capital requirements.  FDICIA establishes five capital 
categories for FDIC-insured banks: “well 
capitalized,” “adequately capitalized,” 
“undercapitalized,” “significantly undercapitalized,” 
and “critically undercapitalized.”  The FDI Act 
imposes progressively more restrictive constraints on 
operations, management and capital distributions the 
less capital the institution holds.  While these 
regulations apply only to banks, such as The Bank of 
New York Mellon and BNY Mellon, N.A., the 
Federal Reserve is authorized to take appropriate 
action against the parent bank holding company, such 
as the Parent, based on the under-capitalized status of 
any banking subsidiary. In certain circumstances, the 
Parent would be required to guarantee the 
performance of the capital restoration plan if one of 
our banking subsidiaries were undercapitalized.

The federal banking agencies’ prompt corrective 
action framework (“PCA rules”) contain “well 
capitalized” thresholds for IDIs.  Under these rules, 
an IDI is deemed to be “well capitalized” if it has 
capital ratios as detailed in the “Capital” disclosure.

The PCA rules require an Advanced Approaches 
banking organization to maintain an SLR of at least 
3% to qualify for the “adequately capitalized” status.  
In addition, the U.S. federal banking agencies’ 
revisions to the enhanced SLR establish a SLR “well 
capitalized” threshold of 6% for certain IDIs of U.S. 
G-SIBs, including The Bank of New York Mellon and 
BNY Mellon N.A.

Supervision and Regulation (continued)

Current Expected Credit Losses Accounting Standard 

In June 2016, the Financial Accounting Standards 
Board issued an update to the accounting standards 
for credit losses that included the “Current Expected 
Credit Losses” (“CECL”) methodology, which 
replaces the existing incurred loss methodology for 
certain financial assets. Upon adopting CECL, a 
company will record a one-time adjustment to its 
credit loss allowances as of the beginning of its fiscal 
year of adoption equal to the difference between the 
amounts of its credit loss allowances under the 
incurred loss methodology and CECL. 

On Dec. 21, 2018 the Federal Reserve, the OCC and 
the FDIC approved a final rule modifying their 
regulatory capital rules and providing an option to 
phase in over a period of three years the regulatory 
capital effects of adopting the CECL methodology. 
During the phase in, the agencies will continue to 
monitor the impact of CECL adoption.  The final rule 
will take effect April 1, 2019.  The Federal Reserve 
also indicated that it would maintain the current 
framework for calculating credit loss allowances in 
CCAR, and would not incorporate CECL into 
supervisory stress testing, through the 2021 stress test 
cycle.

Liquidity Standards - Basel III and U.S. Rules and 
Proposals

BNY Mellon is subject to the Final U.S. LCR Rule, 
which is designed to ensure that BNY Mellon and 
certain domestic bank subsidiaries maintain an 
adequate level of unencumbered HQLA equal to 
their expected net cash outflow for a 30-day time 
horizon under an acute liquidity stress scenario.  As 
of Dec. 31, 2018, the Parent and its domestic bank 
subsidiaries were in compliance with applicable 
LCR requirements.

The BCBS issued the final NSFR document in 
October 2014 which contemplates an additional 
liquidity measure, referred to as NSFR, which is 
designed to promote more medium- and long-term 
funding of the assets and activities of banking entities 
over a one-year time horizon.  In May 2016, the 
Federal Reserve, FDIC and OCC proposed an NSFR 
rule that would implement a quantitative long-term 
liquidity requirement applicable to large and 
internationally active banking organizations, 
including BNY Mellon.  The proposed NSFR rule 
would implement a test similar to the Basel III 

framework’s test for medium- and long-term funding 
of the assets and activities of banking entities over a 
one-year time horizon.  Under the proposed rule, 
BNY Mellon’s NSFR would be expressed as a ratio 
of its available stable funding to its required stable 
funding amount, and BNY Mellon would be required 
to maintain an NSFR of 1.0.  BNY Mellon continues 
to evaluate the potential effects of this proposal on its 
operations.  The proposed NSFR rule would have 
been effective Jan. 1, 2018 had it been finalized as 
proposed; however, final rules have not been issued.

Separately, as noted above, the Final SIFI Rules 
address liquidity requirements for BHCs with $100 
billion or more in total assets, including BNY Mellon.  
These enhanced liquidity requirements include an 
independent review of liquidity risk management; 
establishment of cash flow projections; a contingency 
funding plan, and liquidity risk limits; liquidity stress 
testing under multiple stress scenarios and time 
horizons tailored to the specific products and profile 
of the company; and maintenance of a liquidity buffer 
of unencumbered highly liquid assets sufficient to 
meet projected net cash outflows over 30 days under 
a range of stress scenarios.

Volcker Rule

The Dodd-Frank Act imposed broad prohibitions and 
restrictions on proprietary trading and investments in 
or sponsorship of hedge funds and private equity 
funds by banking organizations and their affiliates, 
commonly referred to as the “Volcker Rule.”

The Volcker Rule, subject to certain exceptions, 
prohibits “banking entities,” including BNY Mellon, 
from engaging in proprietary trading and limits our 
sponsorship of, and investments in, private equity and 
hedge funds (“covered funds”), including our ability 
to own or provide seed capital to covered funds.  In 
addition, the Volcker Rule restricts us from engaging 
in certain transactions with covered funds (including, 
without limitation, certain U.S. funds for which BNY 
Mellon acts as both sponsor/manager and custodian).

The restrictions concerning proprietary trading do not 
contain a broad exemption for asset-liability 
management functions, but contain more limited 
exceptions for, among other things, bona fide 
liquidity risk management and risk-mitigating 
hedging activities, as well as certain classes of 
exempted instruments, including government 
securities.  Ownership interests in covered funds that 

BNY Mellon 67 

Supervision and Regulation (continued)

banking organizations organize and offer are 
generally limited to 3% of the total number or value 
of the outstanding ownership interests of any 
individual fund at any time more than one year after 
the date of its establishment, and with respect to the 
aggregate value of all such ownership interests in 
covered funds (when combined with ownership 
interests in covered funds held under the Volcker 
Rule’s ABS issuer exemption and underwriting and 
market-making exemption), 3% of the banking 
organization’s Tier 1 capital.  Moreover, a banking 
entity relying on the Volcker Rule’s exemption for 
sponsoring covered funds must deduct from its Tier 1 
capital the value of related ownership interests.

The final Volcker Rule regulations also require us to 
develop and maintain an extensive compliance 
program, subject to CEO attestation, addressing 
proprietary trading and covered fund activities.

In June 2018, the Federal Reserve, OCC, FDIC, 
CFTC and SEC approved a proposal to modify the 
current regulations implementing the Volcker Rule. 
The proposal would establish three categories of 
institutions based on trading activity, and the scope 
and scale of compliance requirements would vary 
based on such categories.

In addition, the proposal would revise the definitions 
applicable to the prohibition on proprietary trading so 
that all financial instruments accounted for at fair 
value on a recurring basis would be subject to the 
prohibition, unless an exception or exemption applies.  
The proposal would also revise certain of the 
exceptions and exemptions.  It remains uncertain 
whether or when the proposal will be finalized.

Derivatives

Title VII of the Dodd-Frank Act imposes a 
comprehensive regulatory structure on the OTC 
derivatives markets in which BNY Mellon operates, 
including requirements relating to the business 
conduct of dealers, trade reporting, margin and 
recordkeeping. Title VII also requires persons acting 
as swap dealers, including The Bank of New York 
Mellon, to register with the CFTC and become 
subject to the CFTC’s supervisory, examination and 
enforcement powers.

In addition, because BNY Mellon is subject to 
supervision by the Federal Reserve, we must comply 
with the U.S. prudential margin rules with respect to 

 68 BNY Mellon

its OTC swap transactions. The variation margin 
requirements of these rules already apply, and the 
initial margin requirements are expected to become 
applicable in September 2019.  Furthermore, various 
BNY Mellon subsidiaries are also subject to OTC 
derivatives regulation by local authorities in Europe 
and Asia.

EU Money Market Fund Reforms

The European Union’s Money Market Funds 
Regulation (“MMFR”) has applied since July 21, 
2018 for new MMFs and Jan. 21, 2019 for existing 
MMFs.  MMFR is a significant change for the money 
market fund sector in the EU and aims to ensure that 
MMFs can better withstand redemption pressure in 
stressed market conditions by enhancing their 
liquidity profile and stability.  In particular, constant 
net asset value (“CNAV”) MMFs as they currently 
exist will need to convert into variable net asset value 
MMFs, low volatility net asset value MMFs or public 
debt CNAV MMFs. Other significant restrictions 
would apply, such as (i) the need for MMFs to apply 
liquidity fees and redemption gates and diversify 
asset portfolios, (ii) extensive valuation and reporting 
requirements and (iii) prohibitions on external 
support.

SEC Rules on Mutual Funds

On Oct. 13, 2016, the SEC adopted regulations that 
impose new requirements on mutual funds, exchange-
traded funds and other registered investment 
companies.  The new rules will require mutual funds 
(other than money market funds) to provide portfolio-
wide and position-level holdings data to the SEC on a 
monthly basis.  This data would include the pricing of 
portfolio securities, information regarding repurchase 
and securities lending activities, and the terms of 
derivatives contracts.  Information contained in 
reports for the last month of each fund’s fiscal quarter 
would be made available to the public within 60 days 
of the end of the relevant quarter.

The rules also impose liquidity risk management 
requirements that are intended to reduce the risk that 
funds will not be able to meet shareholder 
redemptions and to minimize the impact of 
redemptions on remaining shareholders.  Each fund 
will be required to establish a liquidity risk 
management program; classify the investments in its 
portfolio into one of four liquidity categories; 
maintain a highly liquid investment minimum; and 

Supervision and Regulation (continued)

limit illiquid investments to 15% of net assets.  The 
rules also permit funds to use swing pricing in certain 
circumstances although the SEC has delayed the 
effective date of these swing pricing provisions.  The 
compliance dates for the reporting requirements 
depend on the applicable reporting form.  Most funds 
were required to comply with the liquidity risk 
management requirements by Dec. 1, 2018.  BNY 
Mellon is still evaluating the cost of compliance and 
the impact of the new regulations on its activities.

Recovery and Resolution

As required by the Dodd-Frank Act, the Federal 
Reserve and FDIC have jointly issued a final rule 
requiring large financial institutions, such as BNY 
Mellon, to submit periodically to the Federal Reserve 
and the FDIC a plan - referred to as the 165(d) 
resolution plan - for its rapid and orderly resolution in 
the event of material financial distress or failure.  In 
addition, the FDIC requires certain large IDIs, such as 
The Bank of New York Mellon, to submit 
periodically to the FDIC a plan for resolution in the 
event of the institution’s failure.  The public portions 
of our resolution plans are available on the Federal 
Reserve’s and FDIC’s websites.

If the Federal Reserve and FDIC jointly determine 
that our future submissions are not credible and the 
covered BHC fails to address the deficiencies in a 
timely manner, the FDIC and the Federal Reserve 
may jointly impose more stringent capital, leverage or 
liquidity requirements or restrictions on our growth, 
activities or operations.  If we continue to fail to 
adequately remedy any deficiencies, we could be 
required to divest assets or operations that the 
regulators determine necessary to facilitate our 
orderly resolution.

In connection with our single point of entry resolution 
strategy, we have established the IHC to facilitate the 
provision of capital and liquidity resources to certain 
key subsidiaries in the event of material financial 
distress or failure.  In 2017, we entered into a binding 
support agreement that requires the IHC to provide 
that support.  The support agreement required the 
Parent to transfer its intercompany loans and most of 
its cash to the IHC, and requires the Parent to 
continue to transfer cash and other liquid financial 
assets to the IHC.

BNY Mellon and the other U.S. G-SIBs are subject to 
heightened supervisory expectations for recovery and 

resolution preparedness under Federal Reserve rules 
and guidance.  These expectations relate to 
capabilities critical to operational resilience and 
contingency planning, including: effective processes 
for managing, identifying and valuing collateral; a 
comprehensive understanding of obligations and 
exposures associated with payment, clearing and 
settlement activities; the ability to analyze liquidity 
and funding sources, uses and risks; demonstrated 
management information systems capabilities on a 
legal entity basis; and robust arrangements for the 
continued provision of shared and outsourced 
services.  The Federal Reserve incorporates reviews 
of these key capabilities as part of its ongoing 
supervision of BNY Mellon.  

The European Union Bank Recovery and Resolution 
Directive (“BRRD”) applies to various subsidiaries 
and branches of BNY Mellon.  BRRD provides for 
recovery and resolution planning and a set of 
harmonized powers to resolve or implement recovery 
of relevant institutions, including branches of non-
European Economic Area (“EEA”) banks operating 
within the EEA.  BRRD includes rules regarding the 
preparation of recovery and resolution plans, giving 
relevant EEA regulators powers to impose 
requirements on an institution before resolution 
actions become necessary; a set of resolution tools 
and powers to facilitate the resolution of failing 
entities, such as the power to “bail-in” the debt of an 
institution (including certain deposit obligations); and 
the power to require a firm to change its structure to 
remove impediments to resolvability.  Certain BRRD-
related requirements are currently subject to review 
under the EU Banking Reform Package, referred to 
below, and the European Commission is expected to 
commence a broader review of BRRD during 2019.

BRRD includes a minimum requirement for own 
funds, defined as regulatory capital, and eligible 
liabilities (“MREL”) to ensure that institutions 
maintain enough capital capable of being written 
down and/or bailed-in.  MREL will be set on a case-
by-case basis for each institution subject to BRRD.  
MREL is the EU equivalent of TLAC, and is 
generally aligned with the FSB’s TLAC proposals.  In 
contrast with TLAC, MREL will apply to all EU-
domiciled credit institutions and certain other firms 
subject to BRRD (not only G-SIBs).

In addition, BRRD requires such institutions and 
firms to prepare recovery plans or group recovery 
plans.  Under BRRD, resolution authorities (rather 

BNY Mellon 69 

Supervision and Regulation (continued)

than the institutions themselves) are responsible for 
drawing up resolution plans. 

Final Rule on Resolution Stays for Qualified 
Financial Contracts

In 2017, the Federal Reserve, OCC and FDIC 
adopted final rules requiring U.S. G-SIBs (and their 
subsidiaries and controlled entities) and the U.S. 
operations of foreign G-SIBs to amend their covered 
qualified financial contracts (“QFCs”), thereby 
facilitating the application of U.S. special resolution 
regimes as necessary.  QFCs generally include 
derivatives, repurchase agreements and securities 
lending arrangements, among others.  The final rule 
includes two key requirements.  First, the final rule 
requires that covered QFCs of such G-SIBs explicitly 
provide for the suspension or stay of transfer 
restriction rights with respect to such QFCs, allowing 
any resolution transfers under U.S. special resolution 
regimes to apply to such QFCs.  Second, the final rule 
requires that covered QFCs of these G-SIBs be 
amended to stay the exercise of default or cross-
default rights by relevant QFC counterparties.  This 
stay would last for a period of up to 48 hours.

The final rule allows these G-SIBs to comply with the 
rule by amending covered QFCs (with the consent of 
relevant counterparties) using the International Swaps 
and Derivatives Association (“ISDA”) 2018 U.S. 
Resolution Stay Protocol (the “Protocol”), ISDA 
2015 Universal Stay Protocol or by executing 
appropriate bilateral amendments to the covered 
QFCs.  BNY Mellon entities which have been 
confirmed to engage in covered QFC activities have 
adhered to the Protocol in compliance with the final 
rule’s first phase implementation date of Jan. 1, 2019.  
BNY Mellon is evaluating the impact of the final rule 
on its activities, in particular regarding non G-SIB 
counterparty compliance by the second phase 
implementation date of July 1, 2019.

Cybersecurity Regulation

The New York State Department of Financial 
Services (“NYSDFS”) requires financial institutions 
regulated by NYSDFS, including BNY Mellon, to 
establish a cybersecurity program, adopt a written 
cybersecurity policy, designate a chief information 
security officer, and have policies and procedures in 
place to ensure the security of information systems 
and non-public information accessible to, or held by, 
third parties.  The NYSDFS rule also includes a 

 70 BNY Mellon

variety of other requirements to protect the 
confidentiality, integrity and availability of 
information systems, as well as the annual delivery of 
a certificate of compliance.

Insolvency of an Insured Depository Institution or a 
Bank Holding Company; Orderly Liquidation 
Authority

If the FDIC is appointed as conservator or receiver 
for an IDI such as The Bank of New York Mellon or 
BNY Mellon National Association (“BNY Mellon, 
N.A.”), upon its insolvency or in certain other 
circumstances, the FDIC has the power to:

•  Transfer any of the depository institution’s assets 
and liabilities to a new obligor, including a newly 
formed “bridge” bank without the approval of the 
depository institution’s creditors;

•  Enforce the terms of the depository institution’s 

contracts pursuant to their terms without regard to 
any provisions triggered by the appointment of 
the FDIC in that capacity; or

•  Repudiate or disaffirm any contract or lease to 
which the depository institution is a party, the 
performance of which is determined by the FDIC 
to be burdensome and the disaffirmance or 
repudiation of which is determined by the FDIC 
to promote the orderly administration of the 
depository institution.

In addition, under federal law, the claims of holders 
of domestic deposit liabilities and certain claims for 
administrative expenses against an IDI would be 
afforded a priority over other general unsecured 
claims against such an institution, including claims of 
debt holders of the institution, in the “liquidation or 
other resolution” of such an institution by any 
receiver.  As a result, whether or not the FDIC ever 
sought to repudiate any debt obligations of The Bank 
of New York Mellon or BNY Mellon, N.A., the debt 
holders would be treated differently from, and could 
receive, if anything, substantially less than, the 
depositors of the bank.

The Dodd-Frank Act created a new resolution regime 
(known as the “orderly liquidation authority”) for 
systemically important financial companies, 
including BHCs and their affiliates.  Under the 
orderly liquidation authority, the FDIC may be 
appointed as receiver for the systemically important 

Supervision and Regulation (continued)

institution, and its failed nonbank subsidiaries, for 
purposes of liquidating the entity if, among other 
conditions, it is determined at the time of the 
institution’s failure that it is in default or in danger of 
default and the failure poses a risk to the stability of 
the U.S. financial system.

If the FDIC is appointed as receiver under the orderly 
liquidation authority, then the powers of the receiver, 
and the rights and obligations of creditors and other 
parties who have dealt with the institution, would be 
determined under the Dodd-Frank Act’s orderly 
liquidation authority provisions, and not under the 
insolvency law that would otherwise apply.  The 
powers of the receiver under the orderly liquidation 
authority were based on the powers of the FDIC as 
receiver for depository institutions under the FDI Act.  
However, the provisions governing the rights of 
creditors under the orderly liquidation authority were 
modified in certain respects to reduce disparities with 
the treatment of creditors’ claims under the U.S. 
Bankruptcy Code as compared to the treatment of 
those claims under the new authority.  Nonetheless, 
substantial differences in the rights of creditors exist 
as between these two regimes, including the right of 
the FDIC to disregard the strict priority of creditor 
claims in some circumstances, the use of an 
administrative claims procedure to determine 
creditors’ claims (as opposed to the judicial procedure 
utilized in bankruptcy proceedings), and the right of 
the FDIC to transfer assets or liabilities of the 
institution to a third party or a “bridge” entity.

Depositor Preference

Under U.S. federal law, claims of a receiver of an IDI 
for administrative expenses and claims of holders of 
U.S. deposit liabilities (including foreign deposits that 
are payable in the U.S. as well as in a foreign branch 
of the depository institution) are afforded priority 
over claims of other unsecured creditors of the 
institution, including depositors in non-U.S. branches.  
As a result, such depositors could receive, if 
anything, substantially less than the depositors in U.S. 
offices of the depository institution.

Transactions with Affiliates

Transactions between BNY Mellon’s banking 
subsidiaries, on the one hand, and the Parent and its 
nonbank subsidiaries and affiliates, on the other, are 
subject to certain restrictions, limitations and 
requirements, which include limits on the types and 

amounts of transactions (including extensions of 
credit and asset purchases by our banking 
subsidiaries) that may take place and generally 
require those transactions to be on arm’s-length 
terms.  In general, extensions of credit by a BNY 
Mellon banking subsidiary to any nonbank affiliate, 
including the Parent, must be secured by designated 
amounts of specified collateral and are limited in the 
aggregate to 10% of the relevant bank’s capital and 
surplus for transactions with a single affiliate and to 
20% of the relevant bank’s capital and surplus for 
transactions with all affiliates.  There are also 
limitations on affiliate credit exposures arising from 
derivative transactions and securities lending and 
borrowing transactions.

Deposit Insurance

Our U.S. banking subsidiaries, including The Bank of 
New York Mellon and BNY Mellon, N.A., accept 
deposits, and those deposits have the benefit of FDIC 
insurance up to the applicable limit.  The current limit 
for FDIC insurance for deposit accounts is $250,000 
per depositor at each insured bank.  Under the FDI 
Act, insurance of deposits may be terminated by the 
FDIC upon a finding that the IDI has engaged in 
unsafe and unsound practices, is in an unsafe or 
unsound condition to continue operations or has 
violated any applicable law, regulation, rule, order or 
condition imposed by a bank’s federal regulatory 
agency.

The FDIC’s Deposit Insurance Fund (the “DIF”) is 
funded by assessments on IDIs.  The FDIC assesses 
DIF premiums based on a bank’s average 
consolidated total assets, less the average tangible 
equity of the IDI during the assessment period.  For 
larger institutions, such as The Bank of New York 
Mellon and BNY Mellon, N.A., assessments are 
determined based on CAMELS ratings and forward-
looking financial measures to calculate the 
assessment rate, which is subject to adjustments by 
the FDIC, and the assessment base.

Under the FDIC’s regulations, a custody bank, 
including The Bank of New York Mellon and BNY 
Mellon, N.A., may deduct from its assessment base 
100% of cash and balances due from depository 
institutions, securities, federal funds sold, and 
securities purchased under agreement to resell with a 
Standardized Approach risk-weight of 0% and may 
deduct 50% of such asset types with a Standardized 
Approach risk-weight of greater than 0% and up to 

BNY Mellon 71 

Supervision and Regulation (continued)

and including 20%.  This assessment base deduction 
may not exceed the average value of deposits that are 
classified as transaction accounts and are identified 
by the bank as being directly linked to a fiduciary or 
custodial and safekeeping account.

The Dodd-Frank Act requires the DIF reserve ratio to 
reach a minimum of 1.35% by Sept. 30, 2020, and 
authorizes the FDIC to implement special 
assessments on IDIs to reach the required ratio.  On 
Sept. 30, 2018, the FDIC announced that the DIF 
reserve ratio had reached 1.36%.

Source of Strength and Liability of Commonly 
Controlled Depository Institutions

BHCs are required by law to act as a source of 
strength to their bank subsidiaries.  Such support may 
be required by the Federal Reserve at times when we 
might otherwise determine not to provide it.  In 
addition, any loans by BNY Mellon to its bank 
subsidiaries would be subordinate in right of payment 
to depositors and to certain other indebtedness of its 
banks.  In the event of a BHC’s bankruptcy, any 
commitment by the BHC to a federal bank regulator 
to maintain the capital of a subsidiary bank will be 
assumed by the bankruptcy trustee and entitled to a 
priority of payment.  In addition, in certain 
circumstances, BNY Mellon’s IDI subsidiaries could 
be held liable for losses incurred by another BNY 
Mellon IDI subsidiary.  In the event of impairment of 
the capital stock of one of BNY Mellon’s national 
bank subsidiaries or The Bank of New York Mellon, 
BNY Mellon, as the banks’ stockholder, could be 
required to pay such deficiency.

Incentive Compensation Arrangements Proposal

Section 956 of the Dodd-Frank Act requires federal 
regulators to prescribe regulations or guidelines 
regarding incentive-based compensation practices at 
certain financial institutions, including BNY Mellon. 
In April 2016, a joint proposed rule was released, 
replacing a previous 2011 proposal, which each of six 
agencies must separately approve.  The timeframe for 
final implementation is currently unknown.

Anti-Money Laundering and the USA PATRIOT Act

A major focus of governmental policy on financial 
institutions has been aimed at combating money 
laundering and terrorist financing.  The USA 
PATRIOT Act of 2001 contains numerous anti-money 

 72 BNY Mellon

laundering requirements for financial institutions that 
are applicable to BNY Mellon’s bank, broker-dealer 
and investment adviser subsidiaries and mutual funds 
and private investment companies advised or 
sponsored by our subsidiaries.  Those regulations 
impose obligations on financial institutions to 
maintain a broad anti-money laundering program that 
includes internal controls, independent testing, 
compliance management personnel, training, and 
customer due diligence processes, as well as 
appropriate policies, procedures and controls to 
detect, prevent and report money laundering, terrorist 
financing and other suspicious activity, and to verify 
the identity of their customers.  Certain of those 
regulations impose specific due diligence 
requirements on financial institutions that maintain 
correspondent or private banking relationships with 
non-U.S. financial institutions or persons.

Financial Crimes Enforcement Network (“FinCEN”) 
Final Customer Due Diligence Rule

Effective July 11, 2016, FinCEN issued final rules 
under the Bank Secrecy Act to clarify and strengthen 
customer due diligence (“CDD”) requirements, 
including a new requirement to identify and verify the 
identity of beneficial owners of legal entity 
customers.  Covered financial institutions, including 
The Bank of New York Mellon and BNY Mellon, 
N.A. must comply with these rules.  The rule 
reaffirms four pillars of an effective anti-money 
laundering (“AML”) program (development of 
internal policies, procedures and related controls; 
designation of a compliance officer; a thorough and 
ongoing training program; and independent review 
for compliance) and adds a fifth: CDD, wherein a 
covered financial institution is required to implement 
and maintain risk-based procedures for conducting 
CDD that include the identification and verification 
of  any beneficial owner(s) of each legal entity 
customer at the time a new account is opened on or 
after May 11, 2018.

New York State Department of Financial Services 
Anti-Money Laundering and Anti-Terrorism 
Regulations

Effective Jan. 1, 2017, the NYSDFS issued 
regulations requiring regulated institutions, including 
The Bank of New York Mellon, to maintain a 
transaction monitoring program to monitor 
transactions for potential Bank Secrecy Act (“BSA”) 
and AML violations and suspicious activity reporting, 

Supervision and Regulation (continued)

and a watch list filtering program to interdict 
transactions prohibited by applicable sanctions 
programs.

The final regulations require a regulated institution to 
maintain programs to monitor and filter transactions 
for potential BSA and AML violations and prevent 
transactions with sanctioned entities.  The final 
regulation requires regulated institutions annually to 
submit a Board resolution or senior officer 
compliance finding confirming steps taken to 
ascertain compliance with the regulation. 

Privacy and Data Protection

The privacy provisions of the Gramm-Leach-Bliley 
Act generally prohibit financial institutions, including 
BNY Mellon, from disclosing nonpublic personal 
financial information of consumer customers to third 
parties for certain purposes (primarily marketing) 
unless customers have the opportunity to “opt out” of 
the disclosure.  The Fair Credit Reporting Act 
restricts information sharing among affiliates for 
marketing purposes.

In the EU, privacy law is primarily regulated by the 
General Data Protection Regulation (“GDPR”), 
which has been directly binding and applicable for 
each EU member state since May 25, 2018.  The 
GDPR contains enhanced compliance obligations and 
increased penalties for non-compliance compared to 
prior EU data protection legislation.

Acquisitions/Transactions

Federal and state laws impose notice and approval 
requirements for mergers and acquisitions involving 
depository institutions or BHCs.  The Bank Holding 
Company Act of 1956, as amended by the Gramm-
Leach-Bliley Act and by the Dodd-Frank Act (the 
“BHC Act”) requires the prior approval of the Federal 
Reserve for the direct or indirect acquisition by a 
BHC of more than 5% of any class of the voting 
shares or all or substantially all of the assets of a 
commercial bank, savings and loan association or 
BHC.  In reviewing bank acquisition and merger 
applications, the bank regulatory authorities will 
consider, among other things, the competitive effect 
of the transaction, financial and managerial resources, 
including the capital position of the combined 
organization, convenience and needs of the 
community factors, including the applicant’s record 
under the Community Reinvestment Act of 1977 (the 

“CRA”), the effectiveness of the subject 
organizations in combating money laundering 
activities and the risk to the stability of the U.S. 
banking or financial system.  In addition, prior 
Federal Reserve approval would be required for BNY 
Mellon to acquire direct or indirect ownership or 
control of any voting shares of a company with assets 
of $10 billion or more that is engaged in activities 
that are “financial in nature.”

New Rating System for the Supervision of Large 
Financial Institutions

On Nov. 2, 2018, the Federal Reserve issued a final 
rule (the “LFI Rule”) that establishes a new rating 
system for the supervision of large financial 
institutions (“LFIs”), including BNY Mellon.  The 
LFI rating system applies to, among other entities, all 
bank holding companies with total consolidated 
assets of $100 billion or more. The LFI Rule became 
effective on Feb. 1, 2019.  

The LFI rating system includes a new four-level 
rating scale and three component ratings.  The four 
levels are: Broadly Meets Expectations; 
Conditionally Meets Expectations; Deficient-1; and 
Deficient-2.  The component ratings are assigned for: 
Capital Planning and Positions; Liquidity Risk 
Management and Positions; and Governance and 
Controls.  A firm must be rated “Broadly Meets 
Expectations” or “Conditionally Meets Expectations” 
for each of its component ratings to be considered 
“well managed” in accordance with various statutes 
and regulations that permit additional activities, 
prescribe expedited procedures or provide other 
benefits for “well managed” firms. 

The Federal Reserve is expected to assign initial 
ratings under the new rating system in 2019 for those 
bank holding companies that are subject to the Large 
Institution Supervision Coordinating Committee 
(“LISCC”) framework, including BNY Mellon. 

Regulated Entities of BNY Mellon and Ancillary 
Regulatory Requirements

BNY Mellon is registered as a financial holding 
company (“FHC”) under the BHC Act.  We are 
subject to supervision by the Federal Reserve.  In 
general, the BHC Act limits an FHC’s business 
activities to banking, managing or controlling banks, 
performing certain servicing activities for 
subsidiaries, engaging in activities incidental to 

BNY Mellon 73 

Supervision and Regulation (continued)

banking, and engaging in any activity, or acquiring 
and retaining the shares of any company engaged in 
any activity, that is either financial in nature or 
complementary to a financial activity and does not 
pose a substantial risk to the safety and soundness of 
depository institutions or the financial system 
generally.

A BHC’s ability to maintain FHC status is dependent 
on: (i) its U.S. depository institution subsidiaries 
qualifying on an ongoing basis as “well capitalized” 
and “well managed” under the prompt corrective 
regulations of the appropriate regulatory agency 
(discussed above under “Prompt Corrective Action”); 
(ii) the BHC itself qualifying on an ongoing basis as 
“well capitalized” and “well managed” under 
applicable Federal Reserve regulations; and (iii) its 
U.S. depository institution subsidiaries continuing to 
maintain at least a “satisfactory” rating under the 
CRA.

An FHC that does not continue to meet all the 
requirements for FHC status will, depending on 
which requirements it fails to meet, lose the ability to 
undertake new activities, or make acquisitions, that 
are not generally permissible for BHCs without FHC 
status.  As of Dec. 31, 2018, BNY Mellon and our 
U.S. bank subsidiaries were “well capitalized” based 
on the ratios and rules applicable to them.

The Bank of New York Mellon, BNY Mellon’s 
largest banking subsidiary, is a New York state-
chartered bank, and a member of the Federal Reserve 
System and is subject to regulation, supervision and 
examination by the Federal Reserve, the FDIC and 
the NYSDFS.  BNY Mellon’s national bank 
subsidiaries, BNY Mellon, N.A. and The Bank of 
New York Mellon Trust Company, National 
Association, are chartered as national banking 
associations subject to primary regulation, 
supervision and examination by the OCC.

We operate a number of broker-dealers that engage in 
securities underwriting and other broker-dealer 
activities in the United States.  These companies are 
SEC-registered broker-dealers and members of 
Financial Industry Regulatory Authority, Inc. 
(“FINRA”), a securities industry self-regulatory 
organization.  BNY Mellon’s nonbank subsidiaries 
engaged in securities-related activities are regulated 
by supervisory agencies in the countries in which 
they conduct business.

 74 BNY Mellon

Certain of BNY Mellon’s public finance and advisory 
activities are regulated by the Municipal Securities 
Rulemaking Board and are required under the SEC’s 
Municipal Advisors Rule to register with the SEC if 
they provide advice to municipal entities or certain 
other persons on the issuance of municipal securities, 
or about certain investment strategies or municipal 
derivatives.

Certain of BNY Mellon’s subsidiaries are registered 
with the CFTC as commodity pool operators, 
introducing brokers and/or commodity trading 
advisors and, as such, are subject to CFTC regulation.  
The Bank of New York Mellon is provisionally 
registered as a Swap Dealer (as defined in the Dodd-
Frank Act) with the CFTC, and is a member of the 
National Futures Association (“NFA”) in that same 
capacity.  As a Swap Dealer, The Bank of New York 
Mellon is subject to regulation, supervision and 
examination by the CFTC and NFA.

Certain of our subsidiaries are registered investment 
advisors under the Investment Advisers Act of 1940, 
as amended, and as such are supervised by the SEC.  
They are also subject to various U.S. federal and state 
laws and regulations and to the laws and regulations 
of any countries in which they conduct business.  Our 
subsidiaries advise both public investment companies 
which are registered with the SEC under the 
Investment Company Act of 1940 (the “‘40 Act”), 
including the Dreyfus family of mutual funds, and 
private investment companies which are not 
registered under the ‘40 Act.

Certain of our investment management, trust and 
custody operations provide services to employee 
benefit plans that are subject to the Employee 
Retirement Income Security Act of 1974, as amended 
(“ERISA”), administered by the U.S. Department of 
Labor (“DOL”).  ERISA imposes certain statutory 
duties, liabilities, disclosure obligations and 
restrictions on fiduciaries, as applicable, related to the 
services being performed and fees being paid.

SEC Proposal of Regulation Best Interest 

The SEC proposed Regulation Best Interest in May of 
2018, which would require a broker-dealer to act in 
the “best interest” of a retail customer when making a 
recommendation of any securities transaction or 
investment strategy to any such customer.  Regulation 
Best Interest is designed to make it clear that a 
broker-dealer may not put its financial interests ahead 

Supervision and Regulation (continued)

of the interests of a retail customer in making 
recommendations.  The SEC also proposed to help 
address investor confusion about the nature of their 
relationships with investment professionals through a 
new short-form disclosure document.  Form CRS 
would provide retail investors with information about 
the nature of their relationship with their investment 
professional, and would supplement other more 
detailed disclosures.  In addition, the SEC issued 
interpretive guidance for broker-dealers and 
investment advisers and an interpretation regarding 
the standard of conduct for investment advisers.  
Comments to these proposals were accepted through 
August 2018, and the SEC is expected to proceed to 
final rulemaking in 2019.  BNY Mellon is 
considering Regulation Best Interest and these related 
developments and evaluating what material impact, if 
any, they may have on BNY Mellon.

Operations and Regulations Outside the United 
States

In Europe, branches of The Bank of New York 
Mellon are subject to regulation in the countries in 
which they are established, in addition to being 
subject to oversight by the U.S. regulators referred to 
above.  BNY Mellon SA/NV is a public limited 
liability company incorporated under the laws of 
Belgium, holds a banking license issued by the 
National Bank of Belgium (“NBB”) and is authorized 
to carry out all banking and savings activities as a 
credit institution.  The European Central Bank 
(“ECB”) has responsibility for the direct supervision 
of significant banks and banking groups in the euro 
area, including BNY Mellon SA/NV.  The ECB’s 
supervision is carried out in conjunction with the 
relevant national prudential regulator (NBB in BNY 
Mellon SA/NV’s case), as part of the single 
supervisory mechanism (“SSM”).  BNY Mellon SA/
NV conducts its activities in Belgium as well as 
through its branch offices in the UK, Ireland, Italy, 
Luxembourg, the Netherlands, France and Germany.

Certain of our financial services operations in the UK 
are subject to regulation and supervision by the 
Financial Conduct Authority (“FCA”) and the 
Prudential Regulation Authority (“PRA”).  The PRA 
is responsible for the authorization and prudential 
regulation of firms that carry on PRA-regulated 
activities, including banks.  PRA-authorized firms are 
also subject to regulation by the FCA for conduct 
purposes.  In contrast, FCA-authorized firms (such as 
investment management firms) have the FCA as their 

sole regulator for both prudential and conduct 
purposes.  As a result, FCA-authorized firms must 
comply with FCA prudential and conduct rules and 
the FCA’s Principles for Businesses, while dual-
regulated firms must comply with the FCA conduct 
rules and FCA Principles, as well as the applicable 
PRA prudential rules and the PRA’s Principles for 
Businesses.

The PRA regulates The Bank of New York Mellon 
(International) Limited, our UK-incorporated bank, as 
well as the London branch of The Bank of New York 
Mellon.  Certain of BNY Mellon’s UK-incorporated 
subsidiaries are authorized to conduct investment 
business in the UK.  Their investment management 
advisory activities and their sale and marketing of 
retail investment products are regulated by the FCA.  
Certain UK investment funds, including investment 
funds of BNY Mellon, are registered with the FCA 
and are offered for sale to retail investors in the UK.

Since the financial crisis, the European Union and its 
Member States have engaged in a significant 
overhaul of bank regulation and supervision.  To 
increase the resilience of banks and to reduce the 
impact of potential bank failures, new rules on capital 
requirements for banks and bank recovery and 
resolution have been adopted.

Aspects of the European Union’s Banking Union 
have entered into force in most EU jurisdictions.  The 
UK is not participating in the Banking Union.  The 
key components of the Banking Union include the 
single resolution mechanism (“SRM”) and the SSM.  
The SRM approach endorses the bail-in rules 
established in the BRRD and is described in more 
detail above in the section addressing Recovery and 
Resolution.

In addition, the Capital Requirements Directive IV 
(“CRD IV”) and Capital Requirements Regulation 
(“CRR”) affect BNY Mellon’s EU subsidiaries by 
implementing Basel III and other changes, including 
the enhancement of the quality of capital, and the 
strengthening of capital requirements for counterparty 
credit risk, resulting in higher capital requirements.  
In the EU Member States, CRD IV/CRR also 
introduces substantive parts of the new European 
supervisory architecture, including the development 
of a single set of harmonized prudential rules for 
financial services.  This set of rules replaces existing 
separately implemented rules within EU Member 
States with a harmonized approach to implementation 

BNY Mellon 75 

Supervision and Regulation (continued)

across the EU.  Elements of CRD IV/CRR apply not 
only to BNY Mellon banking branches and 
subsidiaries but also to investment management and 
brokerage entities.  CRD IV/CRR became effective 
on Jan. 1, 2014, with certain provisions to be phased 
in from 2014 to 2019.

In December 2017, the European Commission 
published legislative proposals for a new harmonized 
prudential regime for investment firms.  Under these 
proposals, most EU investment firms would be 
subject to a more tailored, proportionate prudential 
regime that is separate from the CRD IV/CRR 
regime.  If these proposals are implemented, certain 
of BNY Mellon’s EU investment firms would be 
expected to become subject to this new prudential 
regime.  The extent to which these proposals will be 
advanced and implemented is uncertain.  

Our Investment Management and Investment 
Services businesses are subject to significant 
regulation in numerous jurisdictions around the world 
relating to, among other things, the safeguarding, 
administration and management of client assets and 
client funds.

Various new, revised and/or proposed European 
Union directives and regulations have or will have a 
significant impact on our provision of many of our 
products and services, including the Markets in 
Financial Instruments Directive II and Markets in 
Financial Instruments Regulations (collectively, 
“MiFID II”), the Alternative Investment Fund 
Managers Directive (“AIFMD”), the Directive on 
Undertakings for Collective Investments in 
Transferable Securities (“UCITS V”), the Central 
Securities Depositories Regulation (“CSDR”), the 
regulation on OTC derivatives, central counterparties 
and trade repositories (commonly known as 
“EMIR”), the Securities Financing Transactions 
Regulation (“SFTR”), the Payment Services Directive 
II (“PSD II”) and the Benchmarks Regulation.  These 
European Union directives and regulations may 
impact our operations and risk profile but may also 
provide new opportunities for the provision of BNY 
Mellon products and services.  Several of these 
European directives and regulations are still subject 
to finalization by the legislature and/or substantial 
secondary legislation.  This creates uncertainty as to 
business impact.

The types of activities in which the foreign branches 
of our banking subsidiaries and our international 

 76 BNY Mellon

subsidiaries may engage are subject to various 
restrictions imposed by the Federal Reserve.  Those 
foreign branches and international subsidiaries are 
also subject to the laws and regulatory authorities of 
the countries in which they operate and, in the case of 
banking subsidiaries, may be subject to regulatory 
capital requirements in the jurisdictions in which they 
operate.

EU Banking Reform Package

In November 2016, the European Commission 
published the so-called EU Banking Reform Package. 
This legislative package would amend CRD IV, CRR, 
BRRD and the Single Resolution Mechanism 
Regulation (“SRMR”).

The proposed amendments to CRD IV include a 
proposal for non-EU G-SIBs (such as BNY Mellon) 
and certain other non-EU banking groups to have up 
to two “EU intermediate parent undertakings” (“EU 
IPUs”).  All EU credit institutions and certain EU 
investment firms in such non-EU G-SIBs/banking 
groups would need to fall within a corporate structure 
headed by one of the EU IPUs.  If this proposal is 
ultimately implemented, BNY Mellon would need to 
undertake some changes in its corporate structure.  

The proposed amendments to CRR include provisions 
relating to the leverage ratio, NSFR, MREL 
(including closer alignment to the final FSB TLAC 
standard), a revised Basel market risk framework, 
counterparty credit risk, exposures to CCPs, 
exposures to collective investment undertakings, 
large exposures and reporting/disclosure 
requirements.  

The EU Banking Reform Package is due to be 
finalized during 2019.  The time frame for 
implementation of the various elements of the 
legislative package remains unclear at present.

European Deposit Insurance Scheme

The European Commission has proposed a European 
Deposit Insurance Scheme (“EDIS”) for euro area 
member states.  Under the EDIS proposal, existing 
national euro area deposit guarantee schemes would 
transition over a number of years to a mutualized 
deposit guarantee scheme applicable in the euro area.  
The EDIS proposal has stalled and it is unclear 
whether it will be implemented in its current form, or 
at all.

Supervision and Regulation (continued)

European Financial Markets and Market 
Infrastructure

The EU continues to develop proposals and 
regulations in relation to financial markets and 
market infrastructures.  MiFID II took effect on Jan. 
3, 2018.  It affects EU Member States and those 
financial institutions conducting business in the EEA 
and has required significant change to comply with 
relevant regulatory requirements, including extensive 
transaction reporting and market transparency 
obligations and a heightened focus on how financial 
institutions conduct business with and disclose 
information to their clients.  

Capital Markets Union

A key policy objective of the 2014-19 European 
Commission is to develop a Capital Markets Union 
(“CMU”) in the EU.  Related initiatives that have 
already been substantially progressed include a new 
Prospectus Regulation and a new Securitization 
Regulation.  The Prospectus Regulation applies from 
July 21, 2019 (with certain elements subject to an 
earlier phase-in period).  The Securitization
Regulation has applied to securitization transactions 
from Jan. 1, 2019.

A number of CMU-related priorities remain to be 
addressed during 2019.  The European Commission 
proposes to enhance the powers of the European 
Supervisory Agencies (“ESAs”), including the 
European Banking Authority (“EBA”), the European 
Securities and Markets Authority (“ESMA”) and the 
European Insurance and Occupational Pensions 

Authority (“EIOPA”).  In addition, the European 
Commission wishes to enhance cross-border funds 
distribution and to promote sustainable finance.

Investment Services and Investment Management in 
the European Union

The AIFMD has a direct effect on our alternative fund 
manager clients and our depository business and 
other products offered across Europe as well as upon 
our investment management business.  AIFMD 
imposes heightened obligations upon depositories, 
which have operational effects.

Our businesses servicing regulated funds in Europe 
and our investment management businesses in Europe 
are also affected by the revised directive governing 
UCITS V.

On July 12, 2018, the European Commission adopted 
regulations for depositary safekeeping duties under 
AIFMD and UCITS V.  The Commission recognized 
the use of omnibus account structures when 
accounting for assets in a chain of custody, but 
determined that depositaries and trustees must 
maintain their own books and records and will no 
longer be allowed to rely on a custodian’s records.  
BNY Mellon has initiated a project to implement any 
changes necessary to comply with these regulations 
by the Commission’s deadline of April 1, 2020.

The European Commission is expected to commence 
a review of AIFMD and UCITS V legislation during 
2019, following the Commission’s initiation of an 
industry survey on AIFMD conducted during 2018.

BNY Mellon 77 

Risk Factors

Making or continuing an investment in securities 
issued by us involves certain risks that you should 
carefully consider.  The following discussion sets 
forth the most significant risk factors that could affect 
our business, financial condition or results of 
operations.  Some of these risks are interrelated and 
the occurrence of one may exacerbate the effect of 
others.  However, factors other than those discussed 
below or in other of our reports filed with or 
furnished to the SEC also could adversely affect our 
business, financial condition or results of operations.  
We cannot assure you that the risk factors described 
below or elsewhere in our reports address all potential 
risks that we may face.  These risk factors also serve 
to describe factors which may cause our results to 
differ materially from those described in forward-
looking statements included herein or in other 
documents or statements that make reference to this 
Annual Report.  See “Forward-looking Statements.”

Operational Risk

A communications or technology disruption or 
failure that results in a loss of information, delays 
our ability to access information or impacts our 
ability to provide services to our clients may 
materially adversely affect our business, financial 
condition and results of operations.

We use communications and information systems to 
conduct our business.  Our businesses are highly 
dependent on our ability to process large volumes of 
data that require global capabilities and scale from 
our technology platforms.  If our technology or 
communications fail, or those of industry utilities or 
our service providers fail, we could experience, and 
have in the past experienced, production and system 
outages or failures or other significant operational 
delays.  Any such outage, failure or delay could 
adversely affect our ability to effect transactions or 
service our clients, which could expose us to liability 
for damages, result in the loss of business, damage 
our reputation, subject us to regulatory scrutiny or 
sanctions or expose us to litigation, any of which 
could have a material adverse effect on our business, 
financial condition and results of operations.  Security 
or technology disruptions, failures or delays that 
impact our communications or information systems 
could also adversely affect our ability to manage our 
exposure to risk or expand our business.

Upgrading our computer systems, software and 
networks may also subject us to disruptions, failures 
or delays due to the complexity and 

 78 BNY Mellon

interconnectedness of our systems, software and 
networks.  The failure to upgrade or maintain these 
computer systems, software and networks could 
result in greater susceptibility to attacks, unauthorized 
access and misuse, and could also prevent us from 
achieving our business continuity and resiliency 
objectives.  There can be no assurance that any such 
disruptions, failures or delays will not occur or, if 
they do occur, that they will be adequately addressed.  

Third parties with which we do business or that 
facilitate our business activities, including exchanges, 
clearing houses, financial intermediaries or vendors 
that provide services or security solutions for our 
operations, could also be sources of technology risk 
to us, including from breakdowns, failures or delays 
of their own systems or capacity constraints or other 
services that impair our ability to process transactions 
and communicate with customers and counterparties.  
In addition, we are exposed to the risk that a 
technology disruption or other information security 
event at a vendor common to our third-party service 
providers could impede their ability to provide 
products or services to us.  We may not be able to 
effectively monitor or mitigate operational risks 
relating to the use of common vendors by third-party 
service providers.

As our business areas evolve, whether due to the 
introduction of technology, new service offering 
requirements for our clients, or changes in regulation 
relative to these service offerings, unforeseen risks 
materially impacting our business operations could 
arise.  The technology used can become increasingly 
complex and rely on the continued effectiveness of 
the programming code and integrity of the inputted 
data.  Rapid technological changes and competitive 
pressures require us to make significant and ongoing 
investments in technology not only to develop 
competitive new products and services or adopt new 
technologies, but to sustain our current businesses.  
Our financial performance depends in part on our 
ability to develop and market these new products and 
services in a timely manner at a competitive price and 
adopt or develop new technologies that differentiate 
our products or provide cost efficiencies.  The failure 
to ensure adequate review and consideration of 
critical business changes prior to and during 
introduction and deployment of key technological 
systems or failure to adequately align evolving client 
commitments and expectations with operational 
capabilities, may adversely impact our ability to 
service and retain customers and could have a 
negative impact on our operations.  The costs we 

Risk Factors (continued)

incur in enhancing our technology could be 
substantial and may not ultimately improve our 
competitiveness or profitability.  

We continue to evaluate and strengthen our business 
continuity and operational resiliency capabilities and 
have increased our investments in technology to 
steadily enhance those capabilities, including our 
ability to resume and sustain our operations.  There 
can be no guarantee, however, that a technology 
outage will not occur or that our business continuity 
and operational resiliency capabilities will enable us 
to maintain our operations and appropriately respond 
to events.  For a discussion of operational risk, see 
“Risk Management - Operational Risk” and 
“Business Continuity.”

As a result of financial entities, central agents, 
clearing agents and houses, exchanges and 
technology systems across the globe becoming more 
interdependent and complex, a technology failure that 
significantly degrades, deletes or compromises the 
systems or data of one or more financial entities or 
suppliers could have a material impact on 
counterparties or other market participants, including 
us.  A disruptive event or, failure or delay experienced 
by one institution could disrupt the functioning of the 
overall financial system.

A cybersecurity incident, or a failure to protect our 
computer systems, networks and information and 
our clients’ information against cybersecurity 
threats, could result in the theft, loss, unauthorized 
access to, disclosure, use or alteration of 
information, system or network failures, or loss of 
access to information.  Any such incident or failure 
could adversely impact our ability to conduct our 
businesses, damage our reputation and cause losses.

Our businesses rely heavily on technology, and are 
vulnerable to cybersecurity threats and disruptions 
that are occurring globally with greater frequency.  
Cybersecurity threats, which can include, among 
other things, hacker attacks, computer viruses or 
other malicious software, denial of service efforts, 
limited availability of services, phishing attacks, 
cyberattacks on our service providers, and 
unauthorized access attempts, could adversely impact 
our business.  These cybersecurity risks are expected 
to continue to increase and intensify.  While we 
deploy a broad range of sophisticated defenses, it is 
possible we could suffer a material adverse impact or 
disruption.

Cybersecurity incidents may occur through 
intentional or unintentional acts by individuals or 
groups having authorized or unauthorized access to 
our systems or our clients’ or counterparties’ 
information, which may include confidential 
information.  These individuals or groups include 
employees, vendors and customers, as well as others 
with malicious intent.  Third parties may also attempt 
to place individuals within BNY Mellon or 
fraudulently induce employees, vendors, customers or 
other users of our systems to disclose sensitive 
information in order to gain access to our data or that 
of our clients.  A cybersecurity incident that results in 
the theft, loss, unauthorized access to, disclosure, use 
or alteration of information, system or network 
failures, or loss of access to information, may require 
us to reconstruct lost data (which may not be 
possible), reimburse clients for data and credit 
monitoring services, result in loss of customer 
business, or damage to our computers or systems and 
those of our customers and counterparties.  These 
impacts could be costly and time-consuming and 
materially negatively impact our business operations, 
financial condition and reputation. 

While we seek to mitigate these risks to ensure the 
integrity of our systems and information and 
continuously evolve our cybersecurity capabilities, it 
is possible that we may not anticipate or implement 
effective preventive measures against all 
cybersecurity threats, or detect all such threats, 
especially because the techniques used change 
frequently or are not recognized until after they are 
launched.  Moreover, attacks can originate from a 
wide variety of sources, including outside third 
parties who are involved with organized crime or who 
may be linked to terrorist organizations or hostile 
foreign governments, or from cross-contamination of 
legitimate parties (clients, utilities, peer institutions, 
etc).

The failure to maintain an adequate technology 
infrastructure and applications with effective 
cybersecurity controls relative to the type, size and 
complexity of operations, markets and products 
traded, access to trading venues and our market 
interconnectedness could impact operations and 
impede our productivity and growth, which could 
cause our earnings to decline or could impact our 
ability to comply with regulatory obligations leading 
to regulatory fines and sanctions.  We may be 
required to expend significant additional resources to 
modify, investigate or remediate vulnerabilities or 
other exposures arising from cybersecurity threats.  

BNY Mellon 79 

Risk Factors (continued)

A successful cyberattack could occur and persist for 
an extended period of time before being detected.  In 
addition, because any investigation of a cybersecurity 
incident would be inherently unpredictable, the extent 
of a particular cybersecurity incident and the path of 
investigating the incident may not be immediately 
clear.  It may take a significant amount of time before 
such an investigation can be completed and full and 
reliable information about the incident is known.  
While such an investigation is ongoing, we may not 
necessarily know the extent of the harm or how best 
to remediate it, certain errors or actions could be 
repeated or compounded before they are discovered 
and remediated, and communication to the public, 
regulators, clients and other stakeholders may be 
inaccurate, any or all of which could further increase 
the costs and consequences of a cybersecurity 
incident.

Our business may be materially adversely affected 
by operational risk.

We are required to accurately process large numbers 
of transactions each day on a timely basis.  The 
transactions we process or execute are operationally 
complex and can involve numerous parties, 
jurisdictions, regulations and systems, and as such, 
are subject to execution and processing errors and 
failures.  As our businesses evolve to even more 
complex and voluminous transactions, at ever 
increasing speeds, we must also evolve our processes, 
controls, workforce and technology, to accurately and 
timely execute those transactions, which may result in 
an increased risk of error or significant operational 
delay.  When errors or delays do occur, they may be 
difficult to detect and fix in a timely manner.

As a result, operational errors or significant 
operational delays could materially negatively impact 
our ability to conduct our business or service our 
clients, which could adversely affect our results of 
operations due to potentially higher expenses and 
lower revenues, could lower our capital ratios, create 
liability for us or our clients or negatively impact our 
reputation.  Recurring operational issues may raise 
concerns among regulators regarding our governance 
and control environment and culture.

Affiliates or third parties with which we do business 
or that facilitate our business activities could also be 
sources of execution and processing errors, failures or 
significant operational delays.  In certain jurisdictions 
we may be deemed to be statutorily liable for 
operational errors, fraud, breakdowns or delays by 

 80 BNY Mellon

these affiliates or third parties.  Additionally, as a 
result of regulations, including the Alternative 
Investment Fund Managers Directive and the 
Undertakings for Collective Investment in 
Transferable Securities V, where, in the European 
Economic Area we act as depositary, the Company 
could be exposed to restitution risk for, among other 
things, errors or fraud perpetrated by a sub-custodian 
resulting in a loss or delay in return of client’s 
securities.  Where we are not acting as a European 
Economic Area depositary, but where we provide 
custody services to a European Economic Area 
depositary, we may accept similar liabilities to that 
depositary as a matter of contract.

We rely on a variety of measures to protect our 
intellectual property and proprietary information, 
including copyrights, trademarks, patents and 
controls on access and distribution.  These measures 
may not prevent misappropriation or infringement of 
our intellectual property or proprietary information 
and a resulting loss of competitive advantage.  
Furthermore, if a third party were to assert a claim of 
infringement or misappropriation of its proprietary 
rights, obtained through patents or otherwise, against 
us, we could be required to spend significant amounts 
to defend such claims, develop alternative methods of 
operations, pay substantial money damages, obtain a 
license from the third party or possibly stop providing 
one or more products or services.

We are also subject to laws and regulations relating to 
the privacy of the information of clients, employees 
or others, and any failure to comply with these laws 
and regulations could expose us to liability and/or 
reputational damage.  As privacy-related laws and 
regulations, such as the EU General Data Protection 
Regulation (or GDPR), the California Consumer 
Privacy Act of 2018, and the New York Department 
of Financial Services’ cybersecurity regulation, are 
implemented, the time and resources needed for us to 
comply with such laws and regulations, as well as our 
potential liability for non-compliance and reporting 
obligations in the case of data breaches, may 
significantly increase.  In addition, our businesses are 
increasingly subject to laws and regulations relating 
to privacy, surveillance, encryption and data use in 
the jurisdictions in which we operate.  Compliance 
with these laws and regulations may require us to 
change our policies, procedures and technology for 
information security and segregation of data, which 
could, among other things, make us more vulnerable 
to operational failures, and to monetary penalties for 
breach of such laws and regulations.

Risk Factors (continued)

Our risk management framework may not be 
effective in mitigating risk and reducing the 
potential for losses.

Our risk management framework seeks to mitigate 
risk and loss to us.  We have established 
comprehensive policies and procedures and an 
internal control framework designed to provide a 
sound operational environment for the types of risk to 
which we are subject, including operational risk, 
credit risk, market risk, liquidity risk and strategic 
risk.  We have also established frameworks to 
mitigate risk and loss to us as a result of the actions of 
affiliates or third parties with which we do business 
or that facilitate our business activities.  However, as 
with any risk management framework, there are 
inherent limitations to our current and future risk 
management strategies, including risks that we have 
not appropriately anticipated or identified.

Our regulators remain focused on ensuring that 
financial institutions build and maintain robust risk 
management policies.  If our regulators perceive the 
quality of our risk models and framework to be 
insufficient, it may negatively impact our regulators’ 
evaluations of our capital plans and stress tests.  
Accurate and timely enterprise-wide risk information 
is necessary to enhance management’s decision-
making in times of crisis.  If our risk management 
framework proves ineffective or if our enterprise-
wide management information is incomplete or 
inaccurate, we could suffer unexpected losses, which 
could materially adversely affect our results of 
operations or financial condition.

In certain instances, we rely on models to measure, 
monitor and predict risks.  However, these models are 
inherently limited because they involve techniques, 
including the use of historical data, trends, 
assumptions, and judgments that cannot anticipate 
every economic and financial outcome in the markets 
in which we operate, nor can they anticipate the 
specifics and timing of such outcomes, especially 
during severe market downturns or stress events.  
These models may not appropriately capture all 
relevant risks or accurately predict future events or 
exposures.  The risk of the unsuccessful development 
or implementation of our models, systems or 
processes cannot be completely eliminated.  The 
models that we use to assess and control our market 
risk exposures also reflect assumptions about the 
degree of correlation among prices of various asset 
classes or other market indicators.  The 2008 financial 
crisis and resulting regulatory reform highlighted 

both the importance and some of the limitations of 
managing unanticipated risks.  In times of market 
stress or other unforeseen circumstances, previously 
uncorrelated indicators may become correlated, or 
previously correlated indicators may move in 
different directions.  These types of market 
movements have at times limited the effectiveness of 
our hedging strategies and have caused us to incur 
significant losses, and they may do so in the future.

In addition, our businesses and the markets in which 
we operate are continuously evolving.  We may fail to 
fully understand the implications of changes in our 
businesses or the financial markets or fail to 
adequately or timely enhance our risk framework to 
address those changes.  If our risk framework is 
ineffective, either because it fails to keep pace with 
changes in the financial markets, regulatory 
requirements, our businesses, our counterparties, 
clients or service providers or for other reasons, we 
could incur losses, suffer reputational damage or find 
ourselves out of compliance with applicable 
regulatory or contractual mandates or expectations.

An important aspect of our risk management 
framework is creating a risk culture that it is 
sustainable and appropriate to our role as a major 
financial institution in which all employees fully 
understand that there is risk in every aspect of our 
business and the importance of managing risk as it 
relates to their job functions.  If we fail to create the 
appropriate environment that sensitizes all of our 
employees to managing risk, our business could be 
adversely impacted.  For more information on how 
we monitor and manage our risk management 
framework, see “Risk Management - Risk 
management overview.”

We are subject to extensive government rulemaking, 
policies, regulation and supervision.  These rules 
and regulations have, and in the future may, compel 
us to change how we manage our businesses, which 
could have a material adverse effect on our 
business, financial condition and results of 
operations.  In addition, these rules and regulations 
have increased our compliance and operational risk 
and costs.

As a large, internationally active financial services 
company, we operate in a highly regulated 
environment, and are subject to a comprehensive 
statutory and regulatory regime, including oversight 
by governmental agencies both inside and outside the 
U.S.  Regulations and related regulatory guidance and 

BNY Mellon 81 

Risk Factors (continued)

supervisory oversight impact how we analyze certain 
business opportunities, our regulatory capital and 
liquidity requirements, the revenue profile of certain 
of our core activities and the products and services 
we provide.  Any changes to the regulatory 
frameworks and environment in which we operate 
and the significant management attention and 
resources necessary to address those changes could 
materially adversely affect our business, financial 
condition and results of operations and have other 
negative consequences.

The evolving regulatory environment and uncertainty 
about the timing and scope of future regulations may 
contribute to decisions we may make to suspend, 
reduce or withdraw from existing businesses, 
activities or initiatives, which may result in potential 
lost revenue or significant restructuring or related 
costs or exposures.

The monetary, tax and other policies of various 
governments, agencies and regulatory authorities both 
in the U.S. and globally have a significant impact on 
interest rates, currencies, commodity pricing 
(including oil), the imposition of tariffs or other 
limitations on international trade and travel, and 
overall financial market performance, which can 
impact our business and results of operations.  
Changes in these policies are beyond our control and 
can be difficult to predict and we cannot determine 
the ultimate effect that any such changes would have 
upon our business, financial condition or results of 
operations.

Basel III and the Dodd-Frank Act have had a 
significant impact on the regulatory structure of the 
global financial markets and have imposed significant 
operational, compliance and risk management costs, 
both as an initial matter, as we have had to develop 
and integrate appropriate systems and procedures, 
and on a recurring basis, as we monitor, support and 
refine those systems and procedures.  While U.S. 
regulators have finalized regulations implementing 
various provisions of the Dodd-Frank Act and Basel 
III, additional regulations or modifications to existing 
regulations are expected to continue to occur.  In 
addition, there is uncertainty about the timing and 
scope of any changes to Basel III and Dodd-Frank 
Act and other regulations, as well as the cost of 
complying with any new regulatory regimes.  The full 
impact of these standards on us, our business 
strategies and financial performance will remain 
uncertain as long as regulatory reforms continue to be 
adopted and market practices develop in response to 

 82 BNY Mellon

such reforms, and regulatory changes could 
materially adversely impact us.

The regulatory and supervisory focus of U.S. banking 
agencies is primarily intended to protect the safety 
and soundness of the banking system and federally 
insured deposits, and not to protect investors in our 
securities.  Regulatory and supervisory standards and 
expectations across jurisdictions may be divergent 
and otherwise may not conform and/or may be 
applied in a manner that is not harmonized within a 
jurisdiction (in relation to national versus non-
national financial services providers) and/or across 
jurisdictions.  Additionally, banking regulators have 
wide supervisory discretion in the ongoing 
examination and enforcement of applicable banking 
statutes, regulations, and guidelines, and may restrict 
our ability to engage in certain activities or 
acquisitions, or may require us to maintain more 
capital or highly liquid assets.

The U.S. capital rules subject us and our U.S. 
banking subsidiaries to more stringent capital 
requirements, which could restrict growth, activities 
or operations, trigger divestiture of assets or 
operations or limit our ability to return capital to 
shareholders.  Failure to meet current or future capital 
requirements, either at the end of each fiscal quarter 
or under hypothetical stressed conditions during the 
annual CCAR exercise, could materially adversely 
affect our financial condition.  Additional impacts 
relating to compliance with these rules could include, 
but are not limited to, potential dilution of existing 
shareholders and competitive disadvantage compared 
to financial institutions not under the same regulatory 
framework.  In addition, the SLR subjects us to a 
more stringent leverage requirement, which could 
restrict growth, activities, operations or could result 
in certain restrictions on capital distributions and 
discretionary bonus payments.

The LCR requires us to maintain significant holdings 
of high quality and potentially lower-yielding liquid 
assets.  In calculating the LCR, we must also 
determine which deposits should be considered to be 
stable deposits.  Stable deposits must meet a series of 
requirements and typically receive favorable outflow 
treatment under the LCR.  BNY Mellon uses 
qualitative and quantitative analysis to identify core 
stable deposits.  It is possible that our LCR could fall 
below 100% as a consequence of the inherent 
uncertainties associated with this analysis (including 
as a result of additional guidance from our 
regulators).  In addition to facing potential regulatory 

Risk Factors (continued)

consequences (which could be significant), we may 
be required to remedy this shortfall by liquidating 
assets in our investment portfolio or raising additional 
debt, each of which could materially negatively 
impact our net interest revenue.

If and when the final rule regarding the NSFR is 
ultimately implemented in the U.S., those 
requirements could also require BNY Mellon to 
further increase its holdings of high quality, and 
potentially lower-yielding, liquid assets, and to 
reevaluate the composition of its liabilities structure 
to include more longer-dated debt.

Our global activities are also subject to extensive 
regulation by various non-U.S. regulators, including 
governments, securities exchanges, central banks and 
other regulatory bodies in the jurisdictions in which 
we operate, relating to, among other things, the 
safeguarding, administration and management of 
client assets and client funds.  

Various new, revised and proposed European Union 
directives and regulations have an impact on our 
provision of many of our products and services.  
Implementation of, and revisions to, these directives 
and regulations have affected our operations and risk 
profile, including the Capital Requirements Directive/
Regulation, the Bank Recovery and Resolution 
Directive, the Deposit Guarantee Scheme Directive, 
MiFID II, AIFMD, UCITS V and PSD II.

In addition, we are subject in our global operations to 
rules and regulations relating to corrupt and illegal 
payments and money laundering, economic sanctions 
and embargo programs administered by the U.S. 
Office of Foreign Assets Control and similar bodies 
and governmental agencies worldwide, and laws 
relating to doing business with certain individuals, 
groups and countries, such as the U.S. Foreign 
Corrupt Practices Act, the USA PATRIOT Act, the 
Iran Threat Reduction and Syria Human Rights Act of 
2012 and the UK Bribery Act.  While we have 
invested and continue to invest significant resources 
in training and in compliance monitoring, the 
geographical diversity of our operations, employees, 
clients and customers, as well as the vendors and 
other third parties that we deal with, presents the risk 
that we may be found in violation of such rules, 
regulations or laws and any such violation could 
subject us to significant penalties or adversely affect 
our reputation.  In addition, such rules could impact 
our ability to engage in business with certain 
individuals, entities, groups and countries, which 

could materially adversely affect certain of our 
businesses and results of operations.

Failure to comply with laws, regulations or policies 
applicable to our business could result in sanctions by 
regulatory or governmental authorities, civil money 
penalties and reputational damage, which could have 
a material adverse effect on our business, financial 
condition and results of operations.  If violations do 
occur, they could damage our reputation, increase our 
legal and compliance costs, and ultimately adversely 
impact our results of operations.  Laws, regulations or 
policies currently affecting us and our subsidiaries, or 
regulatory and governmental authorities’ 
interpretation of these statutes and regulations may 
change at any time, which may adversely impact our 
business and results of operations.

See “Supervision and Regulation” for additional 
information regarding the potential impact of the 
regulatory environment on our business.

Regulatory or enforcement actions or litigation 
could materially adversely affect our results of 
operations or harm our businesses or reputation.

Like many major financial institutions, we and our 
affiliates are the subject of inquiries, investigations, 
lawsuits and proceedings by counterparties, clients, 
other third parties and regulatory and other 
governmental agencies in the U.S. and abroad, as 
well as the Department of Justice (the “DOJ”) and 
state attorneys general.  See “Legal proceedings” in 
Note 21 of the Notes to Consolidated Financial 
Statements for a discussion of material legal and 
regulatory proceedings in which we are involved.  
The number of these investigations and proceedings, 
as well as the amount of penalties and fines sought, 
has remained elevated for many firms in the financial 
services industry, including us.  We may become 
subject to heightened regulatory scrutiny, inquiries or 
investigations, and potentially client-related inquiries 
or claims, relating to broad, industry-wide concerns 
that could lead to increased expenses or reputational 
damage.  The current trend of large settlements by 
financial institutions with governmental entities may 
adversely affect the outcomes for other financial 
institutions in similar actions, especially where 
governmental officials have announced that the large 
settlements will be used as the basis or a template for 
other settlements.  Separately, policy makers in 
Europe continue to focus on protection of client 
assets, as well as tax avoidance and evasion.

BNY Mellon 83 

Risk Factors (continued)

Regulatory authorities may compel companies to 
provide investigators with all relevant facts relating to 
the individuals substantially involved in or 
responsible for the alleged misconduct in order to 
qualify for any cooperation credit in criminal 
investigations of corporate wrongdoing, or maximum 
cooperation credit in civil investigations of corporate 
wrongdoing, resulting in increased fines and 
penalties.

The complexity of the federal and state regulatory 
and enforcement regimes in the U.S., coupled with 
the global scope of our operations and the increased 
aggressiveness of the regulatory environment 
worldwide, also means that a single event may give 
rise to a large number of overlapping investigations 
and regulatory proceedings, either by multiple federal 
and state agencies in the U.S. or by multiple 
regulators and other governmental entities in different 
jurisdictions.  Responding to inquiries, investigations, 
lawsuits and proceedings, regardless of the ultimate 
outcome of the matter, is time-consuming and 
expensive and can divert the attention of our senior 
management from our business.  The outcome of such 
proceedings may be difficult to predict or estimate 
until late in the proceedings, which may last a number 
of years.

Certain of our subsidiaries are subject to periodic 
examination, special inquiries and potential 
proceedings by regulatory authorities.  If compliance 
failures or other violations are found during an 
examination, inquiry or proceeding, a regulatory 
agency could initiate actions and impose sanctions for 
violations, including, for example, regulatory 
agreements, cease and desist orders, civil monetary 
penalties or termination of a license and could lead to 
litigation by investors or clients, any of which could 
cause our earnings to decline.

Our businesses involve the risk that clients or others 
may sue us, claiming that we or third parties for 
whom they say we are responsible have failed to 
perform under a contract or otherwise failed to carry 
out a duty perceived to be owed to them, including 
perceived fiduciary or contractual duties.  This risk 
may be heightened during periods when credit, equity 
or other financial markets are deteriorating in value or 
are particularly volatile, or when clients or investors 
are experiencing losses.  As a publicly held company, 
we are also subject to the risk of claims under the 
federal securities laws.  Volatility in our stock price 
increases this risk.

 84 BNY Mellon

Actions brought against us may result in lawsuits, 
enforcement actions, injunctions, settlements, 
damages, fines or penalties, which could have a 
material adverse effect on our financial condition or 
results of operations or require changes to our 
business.  Claims for significant monetary damages 
are asserted in many of these legal actions, while 
claims for disgorgement, penalties and/or other 
remedial sanctions may be sought in regulatory 
matters.  Although we establish accruals for our 
litigation and regulatory matters in accordance with 
applicable accounting guidance when those matters 
proceed to a stage where they present loss 
contingencies that are both probable and reasonably 
estimable, there may be a material exposure to loss in 
excess of any amounts accrued, or in excess of any 
loss contingencies disclosed as reasonably possible.  
Such loss contingencies may not be probable and 
reasonably estimable until the proceedings have 
progressed significantly, which could take several 
years and occur close to resolution of the matter.

Each of the risks outlined above could result in 
increased regulatory supervision and affect our ability 
to attract and retain customers or maintain access to 
the capital markets.

Our businesses may be negatively affected by 
adverse events, publicity, government scrutiny or 
other reputational harm.

We are subject to reputational, legal and regulatory 
risk in the ordinary course of our business.  The 
public perception of financial institutions remains 
negative.  Harm to our reputation can result from 
numerous sources, including adverse publicity arising 
from events occurring at BNY Mellon or in the 
financial markets, our perceived failure to comply 
with legal and regulatory requirements or deliver 
appropriate standards of service and quality by either 
us or our vendors, or a failure to appropriately 
describe our products and services, the purported 
actions of our employees, alleged financial reporting 
irregularities involving ourselves or other large and 
well-known companies and perceived conflicts of 
interest.  In particular, a cybersecurity event 
impacting us or our customers’ data could have a 
negative impact on our reputation and customer 
confidence in BNY Mellon and its cybersecurity 
defenses and business continuity and resiliency 
capabilities.  Our reputation could also be harmed by 
the failure of an affiliate, joint venture or a vendor or 
other third party with which we do business to 
comply with laws or regulations.  Damage to our 

Risk Factors (continued)

reputation could affect the confidence of clients, 
rating agencies, regulators, employees, stockholders 
and other stakeholders and could in turn have an 
impact on our business and results of operations.

status could lose the ability to undertake new 
activities or make acquisitions that are not generally 
permissible without FHC status or to continue such 
activities.

Additionally, governmental scrutiny from regulators, 
legislative bodies and law enforcement agencies with 
respect to financial services companies has remained 
at elevated levels.  Press coverage and other public 
statements that assert some form of wrongdoing 
(including, in some cases, press coverage and public 
statements that do not directly involve BNY Mellon) 
often result in some type of investigation or in 
lawsuits.  Certain enforcement authorities have 
recently required admissions of wrongdoing, and in 
some cases, criminal pleas, as part of the resolution of 
matters brought by them against financial institutions.  
Any such resolution of a matter involving BNY 
Mellon could lead to increased exposure to civil 
litigation, could adversely affect our reputation and 
ability to do business in certain products and in 
certain jurisdictions and could have other negative 
effects.

Failure to satisfy regulatory standards, including 
“well capitalized” and “well managed” status or 
capital adequacy and liquidity rules more generally, 
could result in limitations on our activities and 
adversely affect our business and financial 
condition.

Under U.S. and international regulatory capital 
adequacy rules and other regulatory requirements, 
BNY Mellon and our subsidiary banks must meet 
thresholds that include quantitative measures of 
assets, liabilities and certain off-balance sheet items, 
subject to qualitative judgments by regulators about 
components, risk weightings and other factors.  As 
discussed in “Supervision and Regulation,” BNY 
Mellon is registered with the Federal Reserve as a 
BHC and an FHC.  An FHC’s ability to maintain its 
status as an FHC is dependent upon a number of 
factors, including its U.S. bank subsidiaries’ 
qualifying on an ongoing basis as “well capitalized” 
and “well managed” under the banking agencies’ 
prompt corrective action regulations as well as 
applicable Federal Reserve regulations.  Failure by an 
FHC or one of its U.S. bank subsidiaries to qualify as 
“well capitalized” and “well managed”, if 
unremedied over a period of time, would cause it to 
lose its status as an FHC and could affect the 
confidence of clients in it, compromising its 
competitive position.  Additionally, an FHC that does 
not continue to meet all the requirements for FHC 

The failure by one of our bank subsidiaries to 
maintain its status as “well capitalized” could lead to, 
among other things, higher FDIC assessments and 
could have reputational and associated business 
consequences.  

If we or our subsidiary banks fail to meet U.S. and 
international minimum capital rules and other 
regulatory requirements, we may not be able to 
deploy capital in the operation of our business or 
distribute capital to stockholders, which may 
adversely affect our business.  

Failure to meet any current or future capital or 
liquidity requirements, including those imposed by 
the U.S. capital rules, the LCR, or by regulators in 
implementing other portions of the Basel III 
framework, could materially adversely affect our 
financial condition.  The current regulatory 
environment is fluid as requirements are introduced 
and amended.  See “Supervision and Regulation.”  
Compliance with U.S. and international regulatory 
capital and liquidity requirements may impact our 
ability to return capital to shareholders and may 
impact our operations by requiring us to liquidate 
assets, increase borrowings, issue additional equity or 
other securities, or cease or alter certain operations, 
which may adversely affect our results of operations.

Finally, our estimated regulatory capital ratios, 
liquidity metrics, and related components are based 
on our current interpretation, expectations and 
understanding of the applicable rules and are subject 
to, among other things, ongoing regulatory review, 
regulatory approval of certain statistical models, 
additional refinements, modifications or 
enhancements (whether required or otherwise) to our 
models, and further implementation guidance.  Any 
modifications resulting from these ongoing reviews 
or the continued implementation of the U.S. capital 
rules, the LCR, the resolution planning process, and 
related amendments could result in changes in our 
risk-weighted assets, capital components, liquidity 
inflows and outflows, HQLA, or other elements 
involved in the calculation of these measures, which 
could impact these ratios.  Further, because 
operational risk is currently measured based not only 
upon our historical operational loss experience but 
also upon ongoing events in the banking industry 

BNY Mellon 85 

Risk Factors (continued)

generally, our level of operational risk-weighted 
assets could significantly increase or otherwise 
remain elevated and may potentially be subject to 
significant volatility, negatively impacting our capital 
and liquidity ratios.  The uncertainty caused by these 
factors could ultimately impact our ability to meet our 
goals, supervisory requirements, and regulatory 
standards.

A failure or circumvention of our controls and 
procedures could have a material adverse effect on 
our business, reputation, results of operations and 
financial condition.

Management regularly reviews and updates our 
internal controls, disclosure controls and procedures, 
and corporate governance policies and procedures.  
Any system of controls, however well designed and 
operated, is based in part on certain assumptions and 
can provide only reasonable, not absolute, assurances 
that the objectives of the system will be met.  Any 
failure or circumvention of our controls and 
procedures or failure to comply with regulations 
related to controls and procedures could have a 
material adverse effect on our business, reputation, 
results of operations and financial condition.  If we 
identify material weaknesses in our internal control 
over financial reporting or are otherwise required to 
restate our financial statements, we could be required 
to implement expensive and time-consuming 
remedial measures and could lose investor confidence 
in the accuracy and completeness of our financial 
reports.  In addition, there are risks that individuals, 
either employees or contractors, may circumvent 
established control mechanisms in order to, for 
example, exceed exposure, liquidity, trading or 
investment management limitations, or commit fraud.

The application of our Title I preferred resolution 
strategy or resolution under the Title II orderly 
liquidation authority could adversely affect the 
Parent’s liquidity and financial condition and the 
Parent’s security holders.

In 2017, in connection with our single point of entry 
resolution strategy under Title I of the Dodd-Frank 
Act, the Parent entered into a binding support 
agreement with certain key subsidiaries to facilitate 
the provision of capital and liquidity resources to 
them in the event of material financial distress or 
failure.  The support agreement requires the Parent to 
transfer significant excess liquid financial assets to 
the IHC on an ongoing basis, subject to certain 
amounts retained by the Parent to meet its near-term 

 86 BNY Mellon

cash needs, in exchange for unsecured subordinated 
funding notes issued by the IHC as well as a 
committed line of credit to the Parent to service its 
near term obligations.  The Parent’s and the IHC’s 
obligations under the support agreement are secured.

If our projected liquidity resources deteriorate so 
severely that resolution of the Parent becomes 
imminent, the committed line of credit the IHC 
provided to the Parent will automatically terminate, 
with all amounts outstanding becoming due and 
payable, and the support agreement will require the 
Parent to transfer most of its remaining assets (other 
than stock in subsidiaries and a cash reserve to fund 
bankruptcy expenses) to the IHC.  As a result, during 
a period of severe financial stress the Parent could 
become unable to meet its debt and payment 
obligations (including with respect to its securities), 
causing the Parent to seek protection under 
bankruptcy laws earlier than it otherwise would have.

If the Parent were to become subject to a bankruptcy 
proceeding and our single point of entry strategy is 
successful, our material entities will not be subject to 
insolvency proceedings and their creditors would not 
be expected to suffer losses, while the Parent’s 
security holders, including unsecured debt holders, 
could face significant losses, potentially including the 
loss of their entire investment.  The single point of 
entry strategy - in which the Parent would be the only 
legal entity to enter resolution proceedings - is 
designed to result in greater risk of loss to holders of 
our unsecured senior debt securities and other 
securities than would be the case under a different 
resolution strategy.

Further, if the single point of entry strategy is not 
successful, our liquidity and financial condition 
would be adversely affected and all security holders 
may, as a consequence, be in a worse position than if 
the strategy had not been implemented.  

In addition, Title II of the Dodd-Frank Act established 
an orderly liquidation process in the event of the 
failure of a large systemically important financial 
institution, such as BNY Mellon, in order to avoid or 
mitigate serious adverse effects on the U.S. financial 
system.  Specifically, if BNY Mellon is in default or 
danger of default, and certain specified conditions are 
met, the FDIC may be appointed receiver under the 
orderly liquidation authority, and we would be 
resolved under that authority instead of the U.S. 
Bankruptcy Code. 

Risk Factors (continued)

U.S. supervisors have indicated that a single point of 
entry strategy may be a desirable strategy to resolve a 
large financial institution such as BNY Mellon under 
Title II in a manner that would, similar to our 
preferred strategy under our Title I resolution plan, 
impose losses on shareholders, unsecured debt 
holders and other unsecured creditors of the Parent, 
while permitting the holding company’s subsidiaries 
to continue to operate and remain solvent.  Under 
such a strategy, assuming the Parent entered 
resolution proceedings and its subsidiaries remained 
solvent, losses at the subsidiary level would be 
absorbed by the Parent and ultimately borne by the 
Parent’s security holders (including holders of the 
Parent’s unsecured debt securities), while third-party 
creditors of the Parent’s subsidiaries would not be 
expected to suffer losses.  Accordingly, the Parent’s 
security holders (including holders of unsecured debt 
securities and other unsecured creditors) could face 
losses in excess of what otherwise would have been 
the case.

If our resolution plan is determined not to be 
credible or not to facilitate an orderly resolution 
under the U.S. Bankruptcy Code, our business, 
reputation, results of operations and financial 
condition could be materially negatively impacted.  

We must develop and submit to the Federal Reserve 
and the FDIC for review plans for our rapid and 
orderly resolution in the event of material financial 
distress or failure.  If the agencies determine that our 
future submissions are not credible or would not 
facilitate an orderly resolution under the U.S. 
Bankruptcy Code, and we fail to address any such 
deficiencies in a timely manner, the agencies may 
jointly impose more stringent capital, leverage or 
liquidity requirements or restrictions on our growth, 
activities or operations.  

Acts of terrorism, impacts from climate change, 
natural disasters, pandemics, global conflicts and 
other geopolitical events may have a negative impact 
on our business and operations.

In conducting our business and maintaining and 
supporting our global operations, which includes 
vendors and other third parties, we are subject to risks 
of loss from the outbreak of hostilities, acts of 
terrorism, impacts from client change, natural 
disasters, pandemics, global conflicts or other similar 
catastrophic events that could have a negative impact 
on our business and operations.  We may also be 
impacted by unfavorable political, economic, legal or 

other developments, including but not limited to 
social or political instability, changes in governmental 
policies or policies of central banks, sanctions, 
expropriation, nationalization, confiscation of assets, 
price, capital and exchange controls, the imposition 
of tariffs or other limitations on international trade 
and travel, and changes in laws and regulations.

While we have business continuity and disaster 
recovery plans in place, such events could still 
damage our facilities, disrupt or delay normal 
business operations (including communications and 
technology), result in harm or cause travel limitations 
on our employees, with a similar impact on our 
clients, suppliers and counterparties.  Catastrophic 
events, including those caused by climate change, 
could also negatively impact the purchase of our 
products and services if those events result in reduced 
capital markets activity, lower asset price levels, or 
disruptions in general economic activity, or in 
financial market settlement functions, which could 
negatively impact our business and results of 
operation.  In addition, catastrophic events, including 
those caused by climate change, war, terror attacks, 
political unrest, global conflicts, efforts to combat 
terrorism and other potential military activities and 
outbreaks of hostilities may lead, and in some cases 
have led, to an increase in delinquencies, 
bankruptcies or defaults that could result in our 
experiencing higher levels of non-performing assets, 
net charge-offs and provisions for credit losses, 
negatively impacting our business and operations.

Market Risk

We are dependent on fee-based business for a 
substantial majority of our revenue and our fee-
based revenues could be adversely affected by 
slowing in market activity, weak financial markets, 
underperformance and/or negative trends in savings 
rates or in investment preferences.

Our principal operational focus is on fee-based 
business, which is distinct from commercial banking 
institutions that earn most of their revenues from 
loans and other traditional interest-generating 
products and services.  In 2018, 78% of our total 
revenue was fee-based.  Our fee-based businesses 
include investment management and performance 
fees, custody, corporate trust, depositary receipts, 
clearing, collateral management and treasury 
services, which are highly competitive businesses.

BNY Mellon 87 

Risk Factors (continued)

Fees for many of our products and services are based 
on the volume of transactions processed, the market 
value of assets managed and administered, securities 
lending volume and spreads, and fees for other 
services rendered.  Corporate actions, cross-border 
investing, global mergers and acquisitions activity, 
new debt and equity issuances, and secondary trading 
volumes all affect the level of our revenues.  If the 
volumes of these activities decrease due to weak 
financial markets or otherwise, our revenues will also 
decrease, which would negatively impact our results 
of operations.

Poor investment returns in our investment 
management business, due to either weak market 
conditions or underperformance (relative to our 
competitors or to benchmarks) by funds or accounts 
that we manage or investment products that we 
design or sell, could result in reduced market values 
of portfolios that we manage and/or administer and 
may affect our ability to retain existing assets and to 
attract new clients or additional assets from existing 
clients.  Market and regulatory trends have resulted in 
increased demand for lower fee asset management 
products, and for performance-based fees.  
Significant declines in the volume of capital markets 
activity would reduce the number of transactions we 
process and the amount of securities we lend and 
therefore would also have an adverse effect on our 
results of operations.

Our business generally benefits when individuals 
invest their savings in mutual funds and other 
collective funds, unit investment trusts or exchange-
traded funds, or contribute more to defined 
contribution plans.  The current shift to lower fee 
investment products has adversely impacted our fees.  
When our investment management revenues decline, 
we may have, and in the past have had, declines in 
the fair value in our Asset Management reporting 
unit, one of the two reporting units in our Investment 
Management segment.  If the fair value of the Asset 
Management reporting unit declines below its 
carrying value, we would be required to take an 
impairment charge.

Weakness and volatility in financial markets and the 
economy generally may materially adversely affect 
our business, results of operations and financial 
condition.

As a financial institution, our Investment 
Management, Depositary Receipts and Markets, 
including Securities Lending, businesses, are 

 88 BNY Mellon

particularly sensitive to economic and market 
conditions, including in the capital and credit 
markets.  When these markets are volatile or 
disruptive, we could experience a decline in our 
marked-to-market assets, including in our securities 
portfolio and our equity investments, including seed 
capital.  Our results of operations may be materially 
affected by conditions in the financial markets and 
the economy generally, both in the U.S. and 
elsewhere around the world.  A variety of factors 
impact global economies and financial markets, 
including interest rates and their associated yield 
curves, commodity pricing, such as a continued 
weakness in oil prices when compared to historic 
levels, certain market and political instabilities, 
volatile debt and equity market values, the strength of 
the U.S. dollar, the imposition of tariffs or other 
limitations on international trade or travel, high 
unemployment and governmental budget deficits 
(including, in the U.S., at the federal, state and 
municipal level), contagion risk from possible default 
by other countries on sovereign debt, declining 
business and consumer confidence and the risk of 
increased inflation.  Any resulting economic pressure 
on consumers and lack of confidence in the financial 
markets may adversely affect certain portions of our 
business, financial condition and results of 
operations.  In particular, we face the following risks 
in connection with these factors, some of which are 
discussed at greater length in separate risk factors:

•  Geopolitical tension and economic instability in 
countries around the world can at times increase 
the demand for low-risk investments, particularly 
in U.S. Treasuries and the dollar.  A “flight to 
safety” has historically increased BNY Mellon’s 
balance sheet, which has negatively impacted, 
and could continue to negatively impact, our 
leverage-based regulatory capital measures.  A 
sustained “flight to safety” has historically 
triggered a decline in trading, capital markets and 
cross-border activity which would likely decrease 
our revenue, negatively impacting our results of 
operations, financial condition and, if sustained in 
the long term, our business.

•  The fees earned by our Investment Management 
business are higher as assets under management 
and/or investment performance increase.  Those 
fees are also impacted by the composition of the 
assets under management, with higher fees for 
some asset categories as compared to others.  
Uncertain and volatile capital markets could 
result in reductions in assets under management 

Risk Factors (continued)

because of investors’ decisions to withdraw assets 
or from simple declines in the value of assets 
under management as markets decline.  At Dec. 
31, 2018, we estimate that a 5% change in global 
equity markets, spread evenly throughout the 
year, would impact fee revenue by less than 1% 
and diluted earnings per common share by $0.03 
to $0.05.

•  Market conditions resulting in lower transaction 
volumes could have an adverse effect on the 
revenues and profitability of certain of our 
businesses such as clearing, settlement, payments 
and trading.

•  Uncertain and volatile capital markets, 

particularly declines, could reduce the value of 
our investments in securities, including pension 
and other post-retirement plan assets and produce 
downward pressure on our stock price and credit 
availability without regard to our underlying 
financial strength. 

•  Derivative instruments we hold to hedge and 
manage exposure to market risks including 
interest rate risk, equity price risk, foreign 
currency risk and credit risk associated with our 
products and businesses might not perform as 
intended or expected, resulting in higher realized 
losses and unforeseen stresses on liquidity.  Our 
derivative-based hedging strategies also rely on 
the performance of counterparties to such 
derivatives.  These counterparties may fail to 
perform for various reasons resulting in losses on 
under-collateralized positions.

•  A decline in oil prices may continue to negatively 
impact capital markets and may impact the ability 
of certain of our clients, including oil and gas 
exploration and production companies and 
sovereign funds in oil-exporting countries, to 
continue using our services or repay outstanding 
loans.  Increased defaults among oil and gas 
exploration and production companies may also 
negatively impact the high-yield market and our 
high-yield funds.

•  The process we use to estimate our projected 
credit losses and to ascertain the fair value of 
securities held by us is subject to uncertainty in 
that it requires use of statistical models and 
difficult, subjective and complex judgments, 
including forecasts of economic conditions and 
how these conditions might impair the ability of 
our borrowers and others to meet their 
obligations.  In uncertain and volatile capital 
markets, our ability to estimate our projected 

credit losses may be impaired, which could 
adversely affect our overall profitability and 
results of operations.

Our international clients accounted for 37% of our 
revenue in 2018.  Given the scope of our global 
operations, clients and counterparties, persistent 
disruptions in the global financial markets, or the 
attempt of a country to abandon the euro or persistent 
weakness in a leading global currency could have a 
material adverse impact on our business or results of 
operations.

For a discussion of our management of market risk, 
see “Risk Management - Market risk.”

Transitions away from, or changes in the 
calculation of, LIBOR and other benchmark rates 
could adversely impact our business and results of 
operations.

In 2017, the UK Financial Conduct Authority 
announced that it will no longer persuade or compel 
contributing banks to submit rates for the calculation 
of LIBOR after 2021.  As a result, a transition is 
underway to move away from LIBOR and other 
interbank offered rates (“IBORs”) to transaction-
based alternative risk-free rates.  This transition is 
further supported by the requirements of the EU 
Benchmarks Regulation (“BMR”), where IBORs 
which are not anchored in transaction-based data and 
rely on quotes or estimates submitted by contributing 
banks would not satisfy the relevant BMR 
requirements and would either need to be reformed or 
discontinued after 2019.  Any change to any 
alternative rate or benchmark as a result of the move 
away from LIBOR or other IBOR or any other 
proposals for reform or other initiatives or 
investigations, further uncertainty in the timing and 
manner of implementation of such changes, or a 
waning recognition of LIBOR or other IBOR as an 
acceptable benchmark may cause LIBOR, the 
applicable or alternative rates or benchmarks to 
perform differently, or have other consequences 
which cannot be predicted.  In the event any such 
benchmark or other referenced financial metric is 
significantly changed or discontinued (for example, 
in the transition away from LIBOR and other 
IBORs), or ceases to be recognized as an acceptable 
benchmark, there may be uncertainty as to the 
calculation of the applicable interest rate or payment 
amount, depending on the terms of the governing 
instrument.  

BNY Mellon 89 

Risk Factors (continued)

As a result of our business activities and our 
underlying operations, we may be adversely impacted 
by the changes involving LIBOR and other 
benchmark rates.  We are responsible for the use of 
benchmark rates in a variety of agency, trustee and 
other fiduciary capacities, as well as in our 
operational functions and could be subject to claims 
alleging that notwithstanding any uncertainty around 
the rate environment, we did not correctly discharge 
our responsibilities.

Fluctuations in interest rates triggered by the 
transition away from LIBOR and other benchmark 
rates could adversely affect the availability or cost of 
floating-rate funding.  We could experience losses on 
a product or have to pay more or receive less on 
securities that we own or have issued.  Mismatches 
may arise between existing IBOR-based and 
proposed alternative benchmark rates, based on a 
number of factors, including differences in currency 
denominations as between these rates, differences in 
the extent to which transactions that serve as the basis 
for such alternative benchmark rates may be secured 
or unsecured, and differences in the tenor of 
transactions that serve as the basis for alternative 
benchmark rates.  Divergences between existing 
IBOR-based and proposed alternative benchmark 
rates may result in our hedges being ineffective.  In 
addition, uncertainty relating to LIBOR or another 
benchmark could result in pricing volatility, increased 
capital requirements, loss of market share in certain 
products, adverse tax or accounting consequences, 
higher compliance, legal and operational costs, and 
risks associated with client disclosures, discretionary 
actions taken or negotiation of fallback provisions, as 
well as business continuity and systems and model 
disruption, all of which may adversely impact our 
business and results of operations.

The United Kingdom’s referendum decision to leave 
the EU has had and may continue to have negative 
effects on global economic conditions, global 
financial markets, and our business and results of 
operations.

On March 29, 2019, the UK is scheduled to withdraw 
from the EU.  There is a substantial risk that the UK 
and EU will not have ratified any terms for the UK’s 
withdrawal from the EU by the scheduled withdrawal 
date.  Further, the UK’s withdrawal from the EU, and 
in particular the countries’ failure to agree to terms, 
has created an uncertain political and economic 
environment in the UK, and may create such 
environments in other EU member states. 

 90 BNY Mellon

In anticipation of the UK’s withdrawal from the EU, 
we have executed plans adjusting our business and 
operations so we may continue providing our 
products and services to our UK and EU clients.  Our 
plans have been, and continue to be, based on the UK 
exiting the EU on March 29, 2019 without an 
agreement between the UK and EU on the terms of 
the withdrawal and therefore with no transition 
period.  Accordingly, our plans assume that our UK 
subsidiaries will, on March 29, 2019, lose their EU 
financial services passport and as a result will not be 
able to provide regulated services into the EU without 
needing to obtain local authorization.  BNY Mellon 
maintains a presence in the UK through the London 
branch of The Bank of New York Mellon and through 
The Bank of New York Mellon (International) 
Limited, which is a credit institution incorporated and 
authorized in the UK.  BNY Mellon maintains a 
presence in the EU through The Bank of New York 
Mellon SA/NV (“BNY Mellon SA/NV”), which is 
headquartered in Belgium and has a branch network 
in a number of other EU countries.  BNY Mellon SA/
NV benefits from a general banking license for the 
provision of banking and investments services.  We 
have undertaken, and continue to undertake, 
adjustments to the operations of BNY Mellon SA/NV 
so that it may provide a wider range of services to 
clients domiciled in the EU. 

If the UK leaves the EU without an agreement, we, 
including our European affiliates, may face additional 
operational, regulatory and compliance costs, 
including costs relating to the transfer of business 
operations and, potentially, personnel from our UK 
operations to BNY Mellon SA/NV.  The outcome of 
the UK’s decision to exit the EU has also created 
uncertainty with regard to divergent regulatory 
standards, which may affect operational capabilities 
such as the transfer of data between the UK and EU 
after the UK leaves the EU.  The effects of the UK’s 
exit from the EU, including those described above, 
could adversely affect our business, results of 
operations and financial condition.

Changes in interest rates and yield curves could 
have a material adverse effect on our profitability.

We earn revenue, known as “net interest revenue,” on 
the difference between the interest income earned on 
our interest-earning assets, such as the loans we make 
and the securities we hold in our investment securities 
portfolio, and the interest expense incurred on our 
interest-bearing liabilities, such as deposits and 

Risk Factors (continued)

borrowed money.  Our net interest margin, which is 
the result of dividing net interest revenue by average 
interest-earning assets, and our cash flows, are 
sensitive to changes in the spread between short-term 
and long-term interest rates (the “yield curve”).  Our 
net interest margin tends to increase in a positive 
yield curve environment and decrease when the yield 
curve flattens or inverts.  A  flattening of the yield 
curve, on its own or together with a low interest rate 
environment, may adversely impact our revenue and 
results of operations by compressing our net interest 
spreads, particularly if we are unable to replace our 
higher-yielding maturing assets with assets of 
comparable yields, which will constrain our ability to 
achieve desired net interest margins.

The 100 basis point rise in rates in the past year, or 
future rate rises, could trigger one or more of the 
following, which could adversely impact our 
business, results of operations and financial 
condition, including:

• 

• 

• 

• 

• 

• 

• 

less liquidity in bonds and fixed-income funds in 
the case of a sharp rise in interest rates resulting 
in lower performance, yield and fees;

increased number of delinquencies, bankruptcies 
or defaults and more nonperforming assets and 
net charge-offs, as borrowers may have more 
difficulty making higher interest payments;

difficulty in modeling predicted deposit levels 
and depositor behavior, which could impact our 
ability to manage liquidity and capital;

decreases in deposit levels and higher 
redemptions from our fixed-income funds or 
separate accounts, as clients move funds into 
investments with higher rates of return;

decreases in stable deposit levels, which may 
result in further pressure on our LCR measure;

a decline in our risk-based capital ratios;

reduction in accumulated other comprehensive 
income (“OCI”) in our shareholders’ equity and 
therefore our tangible common equity due to the 
impact of rising long term rates on our available-
for-sale securities in our investment portfolio; or

• 

higher funding costs.

A declining short-term rate environment will 
likely adversely impact our revenue and results of 
operations by:

• 

• 

• 

• 

continued compression of our net interest 
spreads, depending on our balance sheet position; 

constraining our ability to achieve a net interest 
margin consistent with historical averages; 

sustained weakness of our spread-based revenues, 
resulting in continued voluntary waiving of 
particular fees on certain money market mutual 
funds and related distribution fees by us in order 
to prevent the yields on such funds from 
becoming uneconomic; and

adversely impacting the value of fixed-rate 
mortgage-backed securities we hold if there are 
increases in mortgage prepayment speeds, which 
can be caused by refinancing activity.

Additionally, low short-term rates may result in 
excess deposits with high potential runoff rates, 
which in turn would increase our assets and result in 
further pressure on our LCR measure.

A more detailed discussion of the interest rate and 
market risks we face is contained in “Risk 
Management.”

We may experience write-downs of securities that we 
own and other losses related to volatile and illiquid 
market conditions, reducing our earnings and 
impacting our financial condition.

We maintain an investment securities portfolio of 
various holdings, types and maturities.  At Dec. 31, 
2018, these securities were primarily classified as 
available-for-sale, which are recorded on our balance 
sheet at fair value with unrealized gains or losses 
reported as a component of accumulated other 
comprehensive income, net of tax.  The securities in 
our held-to-maturity portfolio, recorded on our 
balance sheet at amortized cost, were $34.0 billion 
and comprised approximately 28% of our investment 
securities portfolio at Dec. 31, 2018.  To the extent 
unhedged, the accounting and regulatory treatment of 
our investment securities portfolio in an available-for-
sale accounting environment may have more 
volatility than a more traditional held-for-investment 
loan portfolio, or a securities portfolio comprised 
exclusively of U.S. Treasury securities.

Our investment securities portfolio represents a 
greater proportion of our consolidated total assets 
(approximately 33% at Dec. 31, 2018), and our loans 
represent a smaller proportion of our consolidated 
total assets (approximately 16% at Dec. 31, 2018), in 

BNY Mellon 91 

Risk Factors (continued)

comparison to many other major U.S. financial 
institutions due to our custody and trust bank business 
model.  As such, our capital levels and results of 
operations and financial condition are materially 
exposed to the risks associated with our investment 
portfolio.

If any of our available-for-sale securities experience 
an other-than-temporary impairment, it would 
negatively impact our earnings.  If our held-to-
maturity securities experience a loss in fair value, it 
would negatively impact the fair value of our 
securities portfolio, although it would not impact our 
earnings unless a credit event occurred.  Many of 
these securities experienced significant liquidity, 
valuation and credit quality deterioration during the 
2008 financial crisis and could experience a similar 
deterioration in another financial crisis.  U.S. state 
and municipal bonds have been experiencing stress in 
light of fiscal concerns.

Under the U.S. capital rules, after-tax changes in the 
fair value of available-for-sale investment securities 
are included in CET1 capital.  Since loans held for 
investment, or securities in a held-to-maturity 
accounting classification, are not subject to a fair-
value accounting framework, changes in the fair 
value of these instruments (other than incurred credit 
losses) are not similarly included in the determination 
of CET1 capital.  As a result, we may experience 
increased variability in our CET1 capital relative to 
those other major financial institutions who maintain 
a lower proportion of their consolidated total assets in 
an available-for-sale accounting classification.

Generally, the fair value of available-for-sale 
securities in the securities portfolio is determined 
based upon market values available from third-party 
sources.  During periods of market disruption, it may 
be difficult to value certain of our investment 
securities if trading becomes less frequent and/or 
market data becomes less observable.  As a result, 
valuations may include inputs and assumptions that 
are less observable or require greater estimation and 
judgment as well as valuation methods which are 
more complex.  These values may not be ultimately 
realizable in a market transaction, and such values 
may change very rapidly as market conditions change 
and valuation assumptions are modified.  Decreases 
in value may have a material adverse effect on our 
results of operations or financial condition.  If any of 
our securities suffer credit losses, as we experienced 
with some of our investments in 2009, we may 
recognize the credit losses as an other-than-temporary 

 92 BNY Mellon

impairment which could impact our revenue in the 
quarter in which we recognize the losses.  The 
decision on whether to record an other-than-
temporary impairment or write-down is determined in 
part by management’s assessment of the financial 
condition and prospects of a particular issuer, 
projections of future cash flows and recoverability of 
the particular security.  Management’s conclusions on 
such assessments are highly judgmental and include 
assumptions and projections of future cash flows 
which may ultimately prove to be incorrect as 
assumptions, facts and circumstances change.  On the 
other hand, securities held in a held-to-maturity 
accounting environment are limited in the actions we 
can take absent a significant deterioration in the 
issuer’s creditworthiness.  Therefore, we may be 
constrained in our ability to liquidate a held-to-
maturity security that is deteriorating in value, which 
would negatively impact the fair value of our 
securities portfolio.  If our determinations change 
about our intention or ability to not sell securities that 
have experienced a reduction in fair value below their 
amortized cost, we could be required to recognize an 
other-than-temporary loss in earnings for the entire 
difference between fair value and amortized cost.

For information regarding our investment securities 
portfolio, refer to “Consolidated balance sheet review 
- Investment securities” and for information regarding 
the sensitivity of and risks associated with the market 
value of portfolio investments and interest rates, refer 
to “Critical accounting estimates - Fair value - 
Securities.”

Our FX revenue may be adversely affected by 
decreases in market volatility and the cross-border 
investment activity of our clients.

Our foreign exchange trading generates revenues 
which are primarily driven by the volume of client 
transactions and the spread realized on these 
transactions, both of which are impacted by market 
volatility and the impact of foreign exchange hedging 
activities.  Our clients’ cross-border investing activity 
could decrease in reaction to economic and political 
uncertainties, including changes in laws or 
regulations governing cross-border transactions, such 
as currency controls or tariffs.  Uncertainties resulting 
from terrorist attacks, military actions and other 
events may also negatively affect cross-border 
investments activity, which could negatively impact 
revenue.

Risk Factors (continued)

Volumes and/or spreads in some of our products tend 
to benefit from currency volatility and are likely to 
decrease during times of lower currency volatility.  
Our revenues also depend on our ability to manage 
the risk associated with the currency transactions we 
execute and program pricing.

Furthermore, a shift by custody clients from the 
standing instruction programs to other trading options 
combined with competitive market pressures on the 
foreign exchange business may negatively impact our 
FX revenue.  Continued growth of electronic FX 
trading capabilities is resulting in a shift of volume to 
lower margin channels.

Credit and Liquidity Risk

The failure or perceived weakness of any of our 
significant counterparties, many of whom are major 
financial institutions and sovereign entities, and our 
assumption of credit and counterparty risk, could 
expose us to loss and adversely affect our business.

We have exposure to clients and counterparties in 
many different industries, particularly financial 
institutions, as a result of trading, clearing and 
financing, providing custody services, securities 
lending services or other relationships.  We routinely 
execute transactions with global clients and 
counterparties in the financial industry as well as 
sovereigns and other governmental or quasi-
governmental entities.  Our direct exposure consists 
of the extension of secured and unsecured credit to 
clients and use of our balance sheet.  In addition to 
traditional credit activities, we also extend intraday 
credit in order to facilitate our various processing, 
settlement and intermediation activities.  Our ability 
to engage in funding or other transactions could be 
adversely affected by the actions and commercial 
soundness of other financial institutions or sovereign 
entities, as defaults or non-performance (or even 
uncertainty concerning such default or non-
performance) by one or more financial institutions, or 
the financial services industry generally, have in the 
past led to market-wide liquidity problems and could 
lead to losses or defaults by us or by other institutions 
(including our counterparties and/or clients) in the 
future.  The consolidation and failures of financial 
institutions during the 2008 financial crisis increased 
the concentration of our client and counterparty risk.

As a result of our membership in several industry 
clearing or settlement exchanges and central 
counterparty clearinghouses, we may be required to 

guarantee obligations and liabilities or provide 
financial support in the event that other members do 
not honor their obligations or default.  These 
obligations may be limited to members that dealt with 
the defaulting member or to the amount (or a multiple 
of the amount) of our contribution to a clearing or 
settlement exchange guarantee fund, or, in a few 
cases, the obligation may be unlimited.

The degree of client demand for short-term credit also 
tends to increase during periods of market turbulence, 
exposing us to further credit-related risks.  For 
example, investors in mutual funds for which we act 
as custodian may engage in significant redemption 
activity due to adverse market or economic 
conditions.  We may then extend intraday credit to 
our fund clients in order to facilitate their ability to 
pay such redemptions.  This may negatively impact 
our leverage-based capital ratios, and in times of 
sustained market volatility, may result in significant 
leverage-based ratio declines.

When we provide credit to clients in connection with 
providing cash management, clearing, custodial and 
other services, we are exposed to potential loss if the 
client experiences credit difficulties.  We are also 
generally not able to net exposures across affiliated 
clients or counterparties and may not be able to net 
exposures to the same legal entity across multiple 
products.  In addition, we may incur a loss in relation 
to one entity or product even though our exposure to 
one of the entities’ affiliates is over-collateralized.  
Moreover, not all of our client or counterparty 
exposure is secured.

In our agency securities lending program, we act as 
lender’s agent on behalf of our clients, the lenders of 
securities, in securities lending transactions with our 
clients’ counterparties (including broker-dealers), 
acting as borrowers, wherein securities are lent by our 
clients and the securities loans are collateralized by 
cash or securities posted by such counterparties.  
Typically, in the case of cash collateral, our clients 
authorize us as their agent to invest the cash collateral 
in approved investments pursuant to each client’s 
investment guidelines and instructions.  Such 
approved investments may include reverse repurchase 
transactions with repo counterparties.  In many cases, 
in the securities loans we enter into on behalf of our 
clients, we contractually agree to replace the client’s 
loaned securities that the borrower failed to return 
due to certain defaults by the borrower, mainly the 
borrower’s insolvency.  Therefore, in situations where 
the market value of the loaned securities that the 

BNY Mellon 93 

Risk Factors (continued)

borrower failed to return to a client (which loaned 
securities we are obligated to replace and return to the 
client) exceeds the amount of proceeds resulting from 
the liquidation of the client’s approved investments 
and cash and non-cash collateral of such client, we 
may be responsible for the shortfall amount necessary 
to purchase any replacement securities.  In addition, 
in certain cases, we may also undertake the risk of 
loss in certain circumstances related to approved 
investments that are reverse repurchase transactions 
as described above.  In these two scenarios, we, rather 
than our clients, are exposed to the risks of the 
defaulting counterparty in the securities lending 
transactions and, where applicable, in the reverse 
repurchase transactions.  For further discussion on 
our securities lending indemnifications, see 
“Commitments and contingent liabilities - Off-
balance sheet arrangements” in Note 21 of the Notes 
to Consolidated Financial Statements.

From time to time, we assume concentrated credit 
risk at the individual obligor, counterparty or group 
level, potentially exposing us to a single market or 
political event or a correlated set of events.  For 
example, we may be exposed to defaults by 
companies located in countries with deteriorating 
economic conditions or by companies in certain 
industries.  Such concentrations may be material.  
Our material counterparty exposures change daily, 
and the counterparties or groups of related 
counterparties to which our risk exposure is material 
also vary during any reported period; however, our 
largest exposures tend to be to other financial 
institutions, clearing organizations, and governmental 
entities, both inside and outside the U.S.  
Concentration of counterparty exposure presents 
significant risks to us and to our clients because the 
failure or perceived weakness of our counterparties 
(or in some cases of our clients’ counterparties) has 
the potential to expose us to risk of financial loss.  
Changes in market perception of the financial 
strength of particular financial institutions or 
sovereign issuers can occur rapidly, are often based 
on a variety of factors and are difficult to predict.

Although our overall business is subject to these 
interdependencies, several of our businesses are 
particularly sensitive to them, including our currency 
and other trading activities, our securities lending and 
securities finance businesses and our investment 
management business.  If we experience any of the 
losses described above, it may materially and 
adversely affect our results of operations.

 94 BNY Mellon

We are also subject to the risk that our rights against 
third parties may not be enforceable in all 
circumstances.  In addition, deterioration in the credit 
quality of third parties whose securities or obligations 
we hold, including a deterioration in the value of 
collateral posted by third parties to secure their 
obligations to us under derivatives contracts and other 
agreements, could result in losses and/or adversely 
affect our ability to rehypothecate or otherwise use 
those securities or obligations for liquidity purposes.  
Disputes with clients and counterparties as to the 
valuation of collateral can significantly increase in 
times of market stress and illiquidity.  In addition, 
disruptions in the liquidity or transparency of the 
financial markets may result in our inability to sell, 
syndicate or realize the value of our positions, 
thereby leading to increased concentrations.  An 
inability to reduce our positions may not only 
increase the market and credit risks associated with 
such positions, but may also increase the level of 
RWA on our balance sheet, thereby increasing our 
capital requirements and funding costs, all of which 
could adversely affect the operations and profitability 
of our businesses.

Under evolving regulatory restrictions on credit 
exposure, which include a broadening of the measure 
of credit exposure, we may be required to limit our 
exposures to specific obligors or groups, including 
financial institutions, to levels that we may currently 
exceed.  These credit exposure restrictions under such 
evolving regulations may adversely affect our 
businesses and may require us to modify our 
operating models or the policies and practices we use.

Our business, financial condition and results of 
operations could be adversely affected if we do not 
effectively manage our liquidity.

BNY Mellon’s operating model and overall strategy 
rely heavily on our access to financial market utilities 
and global capital markets.  Without such access, it 
would be difficult to process payments and settle and 
clear transactions on behalf of our clients.  
Deterioration in our liquidity position, whether actual 
or perceived, can impact our market access by 
affecting participants’ willingness to transact with us.  
Changes to our liquidity can be caused by various 
factors, such as funding mismatches, market 
constraints disabling asset to cash conversion, 
inability to issue debt, run-off of core deposits, and 
contingent liquidity events such as additional 
collateral posting.  Changes in economic conditions 

Risk Factors (continued)

or exposure to credit, market, operational, legal and 
reputational risks can also affect our liquidity.

manner that could have a negative impact on our 
capital ratios.

Our business is dependent in part on our ability to 
meet our cash and collateral obligations at a 
reasonable cost for both expected and unexpected 
cash flows.  We also must manage liquidity risks on 
an intraday basis, in a manner designed to ensure that 
we can access required funds during the business day 
to make payments or settle immediate obligations, 
often in real time.  We receive client deposits through 
a variety of investment management and investment 
servicing businesses and we rely on those deposits as 
a low-cost and stable source of funding.  Our ability 
to continue to receive those deposits, and other short-
term funding sources, is subject to variability based 
on a number of factors, including volume and 
volatility in the global securities markets, the relative 
interest rates that we are prepared to pay for those 
deposits, and the perception of the safety of those 
deposits or other short-term obligations relative to 
alternative short-term investments available to our 
clients.  We could lose deposits if we suffer a 
significant decline in the level of our business 
activity, our credit ratings are materially downgraded, 
interest rates rise, or we are subject to significant 
negative press or significant regulatory action or 
litigation, among other reasons.  If we were to lose a 
significant amount of deposits we may need to 
replace such funding with more expensive funding 
and/or reduce assets, which would reduce our net 
interest revenue.

In addition, our access to the debt capital markets is a 
significant source of liquidity.  Events or 
circumstances often outside of our control, such as 
market disruptions, government fiscal and monetary 
policies, or loss of confidence by securities 
purchasers or counterparties in us or in the funds 
markets, could limit our access to capital markets, 
increase our cost of borrowing, adversely affect our 
liquidity, or impair our ability to execute our business 
plan.  In addition, clearing organizations, regulators, 
clients and financial institutions with which we 
interact may exercise the right to require additional 
collateral based on market perceptions or market 
conditions, which could further impair our access to 
and cost of funding.  Market perception of sovereign 
default risks can also lead to inefficient money 
markets and capital markets, which could further 
impact BNY Mellon’s funding availability and cost.  
Conversely, if we experience excess liquidity inflows, 
it could increase interest expense, limit our financial 
flexibility, and increase the size of our total assets in a 

Under the U.S. capital rules, the size of the capital 
surcharge that applies to U.S. G-SIBs is based in part 
on its reliance on short-term wholesale funding, 
including certain types of deposit funding, which may 
increase the cost of such funding.  Furthermore, 
certain non-U.S. authorities, including the European 
Commission, have proposed legislation or regulations 
requiring large banks to incorporate a separate 
subsidiary in countries in which they operate, and to 
maintain independent capital and liquidity at foreign 
subsidiaries.  If adopted, these requirements could 
hinder our ability to efficiently manage our funding 
and liquidity in a centralized manner.  There can be 
no assurances that these measures will be successful 
in limiting BNY Mellon’s liquidity risk.

In addition, our cost of funding could be affected by 
actions that we may take in order to satisfy applicable 
LCR and NSFR requirements, to lower our G-SIB 
surcharge, to satisfy the amount of eligible long-term 
debt outstanding under the TLAC Rule, to address 
obligations under our resolution plan or to satisfy 
regulatory requirements in non-U.S. jurisdictions 
relating to the pre-positioning of liquidity in certain 
subsidiaries.

If we are unable to raise funds using the methods 
described above, we would likely need to finance or 
liquidate unencumbered assets, such as our central 
bank deposits and bank placements, or securities in 
our investment portfolio to meet funding needs.  We 
may be unable to sell some of our assets, or we may 
have to sell assets at a discount from market value, 
either of which could adversely affect our financial 
condition and results of operations.  Further, our 
ability to sell assets may be impaired if other market 
participants are seeking to sell similar assets at the 
same time, which could occur in a liquidity or other 
market crisis.  Additionally, if we experience cash 
flow mismatches, deposit run-off or market 
constraints resulting from our inability to convert 
assets to cash or access capital markets, our liquidity 
could be severely impacted.  During periods of 
market uncertainty, our level of client deposits has in 
recent years tended to increase; however, because 
these deposits have high potential run-off rates, we 
have historically deposited these so-called excess 
deposits with central banks and in other highly liquid 
and low-yielding instruments.

BNY Mellon 95 

Risk Factors (continued)

If we are unable to continue to fund our assets 
through deposits or access capital markets on 
favorable terms or if we suffer an increase in our 
borrowing costs or otherwise fail to manage our 
liquidity effectively, our liquidity, net interest margin, 
financial results and condition may be materially 
adversely affected.  In certain cases, this could 
require us to raise additional capital through the 
issuance of preferred or common stock, which could 
dilute the ownership of existing stockholders, and/or 
reduce our common stock dividend to preserve 
capital.

For a further discussion of our liquidity, see 
“Liquidity and dividends.”

We could incur losses if our allowance for credit 
losses, including loan and lending-related 
commitments reserves, is inadequate.

When we loan money, commit to loan money or 
provide credit or enter into another contract with a 
counterparty, we incur credit risk, or the risk of loss if 
our borrowers do not repay their loans or our 
counterparties fail to perform according to the terms 
of their agreements.  Our revenues and profitability 
are adversely affected when our borrowers default, in 
whole or in part, on their loan obligations to us or 
when there is a significant deterioration in the credit 
quality of our loan portfolio.  We reserve for potential 
future credit losses by recording a provision for credit 
losses through a charge to earnings.  The allowance 
for loan losses and allowance for lending-related 
commitments represents management’s estimate of 
probable losses inherent in our credit portfolio.  We 
use a quantitative methodology and qualitative 
framework for determining the allowance for loan 
losses and the allowance for lending-related 
commitments.  Within this qualitative framework, 
management applies judgment when assessing 
internal risk factors and environmental factors to 
compute an additional allowance for each component 
of the loan portfolio.  As is the case with any such 
judgments, we could fail to identify these factors or 
accurately estimate their impact.  We cannot provide 
any assurance as to whether charge-offs related to our 
credit exposure may occur in the future.  Current and 
future market and economic developments may 
increase default and delinquency rates and negatively 
impact the quality of our credit portfolio, which may 
impact our charge-offs.  Although our current 
estimates contemplate current conditions and how we 
expect them to change in the future, it is reasonably 
possible that actual conditions could be worse than 

 96 BNY Mellon

anticipated in those estimates, which could materially 
affect our results of operations and financial 
condition.  See “Critical accounting estimates.”

Any material reduction in our credit ratings or the 
credit ratings of our principal bank subsidiaries, 
The Bank of New York Mellon or BNY Mellon, 
N.A., could increase the cost of funding and 
borrowing to us and our rated subsidiaries and have 
a material adverse effect on our results of 
operations and financial condition and on the value 
of the securities we issue.

Our debt and preferred stock and the debt and 
deposits of our principal bank subsidiaries, The Bank 
of New York Mellon and BNY Mellon, N.A., are 
currently rated investment grade by the major rating 
agencies.  These rating agencies regularly evaluate us 
and our rated subsidiaries and their outlook on us and 
our rated subsidiaries.  Their credit ratings are based 
on a number of factors, including our financial 
strength, performance, prospects and operations as 
well as factors not entirely within our control, 
including conditions affecting the financial services 
industry generally as well as the U.S. government.  
Rating agencies employ different models and 
formulas to assess the financial strength of a rated 
company, and from time to time rating agencies have, 
in their discretion, altered these models.  Changes to 
rating agency models, general economic conditions, 
or other circumstances outside of our control could 
impact a rating agency’s judgment of the rating or 
outlook it assigns us or our rated subsidiaries.  There 
can be no assurance that we or our rated subsidiaries 
will maintain our respective credit ratings or outlook 
on our securities.

A material reduction in our credit ratings or the credit 
ratings of our rated subsidiaries, which can occur at 
any time without notice, could have a material 
adverse effect on our access to credit markets, the 
related cost of funding and borrowing, our credit 
spreads, our liquidity and on certain trading revenues, 
particularly in those businesses where counterparty 
creditworthiness is critical.  In addition, in connection 
with certain over-the-counter derivatives contracts 
and other trading agreements, counterparties may 
require us or our rated subsidiaries to provide 
additional collateral or to terminate these contracts 
and agreements and collateral financing arrangements 
in the event of a credit ratings downgrade below 
certain ratings levels.  The requirement to provide 
additional collateral or terminate these contracts and 
agreements could impair our liquidity by requiring us 

Risk Factors (continued)

to find other sources of financing or to make 
significant cash payments or securities movements.  A 
downgrade by any one rating agency, depending on 
the agency’s relative ratings of the firm at the time of 
the downgrade, may have an impact comparable to 
the impact of a downgrade by all rating agencies.  If a 
rating agency downgrade were to occur during 
broader market instability, our options for responding 
to events may be more limited and more expensive.  
An increase in the costs of our funding and 
borrowing, or an impairment of our liquidity, could 
have a material adverse effect on our results of 
operations and financial condition.  A material 
reduction in our credit ratings also could decrease the 
number of investors and counterparties willing or 
permitted to do business with or lend to us and 
adversely affect the value of the securities we have 
issued or may issue in the future.

We cannot predict what actions rating agencies may 
take, or what actions we may elect or be required to 
take in response thereto, which may adversely affect 
us.  For further discussion on the impact of a credit 
rating downgrade, see “Disclosure of contingent 
features in OTC derivative instruments” in Note 22 of 
the Notes to Consolidated Financial Statements.

Strategic Risk

New lines of business, new products and services or 
transformational or strategic project initiatives may 
subject us to additional risks, and the failure to 
implement these initiatives could affect our results 
of operations.

From time to time, we may launch new lines of 
business, offer new products and services within 
existing lines of business or undertake 
transformational or strategic projects.  There are 
substantial risks and uncertainties associated with 
these efforts.  We invest significant time and 
resources in developing and marketing new lines of 
business, products and services and executing on our 
transformational and strategic initiatives.  For 
example, we have devoted considerable resources to 
developing new technology solutions for our clients.  
If these technology solutions are not successful, it 
could adversely impact our reputation, business and 
results of operations.

Regulatory requirements can affect whether 
initiatives are able to be brought to market in a 
manner that is timely and attractive to our customers.  
Initial timetables for the development and 

introduction of new lines of business or new products 
or services and price and profitability targets may not 
be met.  Furthermore, our revenues and costs may 
fluctuate because new businesses or products and 
services generally require startup costs while 
revenues may take time to develop, which may 
adversely impact our results of operations. 

From time to time we undertake transformational or 
strategic project initiatives.  Significant effort and 
resources are necessary to manage and oversee the 
successful completion of these initiatives.  These 
initiatives often place significant demands on 
management and a limited number of employees with 
subject matter expertise and may involve significant 
costs to implement as well as increase operational 
risk as employees learn to process transactions under 
new systems.  The failure to properly execute on 
these transformational or strategic initiatives could 
adversely impact our business, reputation and results 
of operations.

Legal, regulatory and reputational risks may also 
exist in connection with dealing with new products or 
markets, or clients and customers whose businesses 
focus on such products or markets, where there is 
regulatory uncertainty or different or conflicting 
regulations depending on the regulator or the 
jurisdiction.

We are subject to competition in all aspects of our 
business, which could negatively affect our ability to 
maintain or increase our profitability.

Many businesses in which we operate are intensely 
competitive around the world.  Competitors include 
other banks, trading firms, broker-dealers, investment 
banks, asset managers, insurance companies, 
financial technology firms and a variety of other 
financial services and advisory companies whose 
products and services span the markets in which we 
operate.  We compete on the basis of a number of 
factors, including transaction execution, capital or 
access to capital, products and services, innovation, 
reputation, lending limits, rates and price.  Larger and 
more geographically diverse companies, and financial 
technology firms that invest substantial resources in 
developing and designing new technology (in 
particular digital and mobile technology) and that are 
not subject to the same level of regulation, may be 
able to offer financial products and services at more 
competitive prices than we are able to offer.  Pricing 
pressures, as a result of the willingness of competitors 
to offer comparable or improved products or services 

BNY Mellon 97 

Our business may be adversely affected if we are 
unable to attract and retain employees.

Our success depends, in large part, on our ability to 
attract new employees, retain and motivate our 
existing employees, and continue to compensate our 
employees competitively amid heightened regulatory 
restrictions.  Competition for the most skilled 
employees in most activities in which we engage can 
be intense, and we may not be able to recruit and 
retain key personnel.

We rely on certain employees with subject matter 
expertise to assist in the implementation of important 
initiatives.  As technology and risk management 
increase in focus in the financial industry, 
competition for technologists and risk personnel has 
intensified, which could constrain our ability to 
execute on certain of our strategic initiatives.

Our ability to attract and retain key executives and 
other employees may be negatively affected by recent 
legislation and other existing restrictions applicable to 
incentive and other compensation programs, 
including limits on our ability to deduct for federal 
income tax purposes compensation in excess of $1 
million paid to certain current and former executives, 
as well as deferral, clawback requirements and other 
limits on incentive compensation.  Some of these 
restrictions may not apply to some of our competitors 
and to other institutions with which we compete for 
talent, in particular as we are more often competing 
for personnel with financial technology providers and 
other entities that are not regulated banking 
organizations that may not have the same limitations 
on compensation as we do.

The loss of employees’ skills, knowledge of the 
market, industry experience, and the cost of finding 
replacements may hurt our business.  If we are unable 
to continue to attract and retain highly qualified 
employees, our performance, including our 
competitive position, could be adversely affected.

Risk Factors (continued)

at a lower price, may result in a reduction in the price 
we can charge for our products and services, which 
could, and in some cases has, negatively affected our 
ability to maintain or increase our profitability.  Low 
economic growth may result in clients exiting 
markets, which could lead to a loss of business for us.

In addition, technological advances have made it 
possible for other types of non-depository 
institutions, such as financial technology firms, 
outsourcing companies and data processing 
companies, to offer a variety of products and services 
competitive with certain areas of our business.  In the 
future, financial technology firms may be able to 
provide additional traditional banking products and 
services by obtaining a bank-like charter, such as the 
OCC’s fintech charter.  

Markets, and the manner in which our clients interact 
and transact within markets, can evolve quickly, 
particularly if new or disruptive technologies are 
introduced.  Our failure to either anticipate, or 
participate in, the transformational change within a 
given market could result in potential negative 
financial impact.  Competitors may develop 
technological advances that could negatively impact 
our transaction execution or the pricing of our 
clearing, settlement, payments and trading activities.  
Increased competition in any of these areas may 
require us to make additional capital investments in 
our businesses in order to remain competitive.  For 
example, along with other financial institutions, we 
are researching ways to adapt robotics and distributed 
ledger technology to bank services.  If we are not able 
to adapt these technologies as successfully as our 
peers, we may become less competitive.  In addition, 
even if successful from a competitive standpoint, the 
use and implementation of new and emerging 
technologies may increase the risk that we experience 
cybersecurity or other information technology events.

Furthermore, recently implemented and proposed 
regulations may impact our ability to conduct certain 
of our businesses in a cost-effective manner or at all.  
The more restrictive laws and regulations applicable 
to the largest U.S. financial services institutions, 
including the U.S. capital rules, can put us at a 
competitive disadvantage relative to both our non-
U.S. competitors and certain U.S. competitors.  See 
“Supervision and Regulation.”

 98 BNY Mellon

Risk Factors (continued)

Our strategic transactions present risks and 
uncertainties and could have an adverse effect on 
our business, results of operations and financial 
condition.

From time to time, to achieve our strategic objectives, 
we have acquired, disposed of, or invested in 
(including through joint venture relationships) 
companies and businesses, and may do so in the 
future.  Our ability to pursue or complete strategic 
transactions is in certain instances subject to 
regulatory approval and we cannot be certain when or 
if, or on what terms and conditions, any required 
regulatory approvals would be granted.  Moreover, to 
the extent we pursue a strategic transaction, there can 
be no guarantee that the transaction will close when 
anticipated, or at all.  If a strategic transaction does 
not close, or if the strategic transaction fails to 
maximize shareholder value or required regulatory 
approval is not obtained, it could have an adverse 
effect on our business, results of operations and 
financial condition.

Each acquisition poses integration challenges, 
including successfully retaining and assimilating 
clients and key employees, capitalizing on certain 
revenue synergies and integrating the acquired 
company’s culture, control functions, systems and 
technology.  In some cases, acquisitions involve entry 
into new businesses or new geographic or other 
markets, and these situations also present risks and 
uncertainties in instances where we may be 
inexperienced in these new areas.  We may be 
required to spend a significant amount of time and 
resources to integrate these acquisitions.  The 
anticipated integration benefits may take longer to 
achieve than projected and the time and cost needed 
to consolidate control functions, platforms and 
systems may significantly exceed our estimates.  If 
we fail to successfully integrate strategic acquisitions, 
including doing so in a timely and cost-effective 
manner, we may not realize the expected benefits, 
which could have an adverse impact on our business, 
financial condition and results of operations.  In 
addition, we may incur expenses, costs, losses, 
penalties, taxes and other liabilities related to the 
conduct of the acquired businesses prior to the date of 
our ownership (including in connection with the 
defense and/or settlement of legal and regulatory 
claims, investigations and proceedings) which may 
not be recoverable through indemnification or 
otherwise.  If the purchase price we pay in an 
acquisition exceeds the fair value of assets acquired 
less the liabilities we assume, then we may need to 

recognize goodwill on our consolidated balance 
sheet.  Goodwill is an intangible asset that is not 
eligible for inclusion in regulatory capital under 
applicable requirements.  Further, if the value of the 
acquisition declines, we may be required to record an 
impairment charge.

Each disposition also poses challenges, including 
separating the disposed businesses, products and 
systems in a way that is cost-effective and is not 
disruptive to us or our customers.  In addition, the 
inherent uncertainty involved in the process of 
evaluating, negotiating or executing a potential sale 
of one of our companies or businesses may cause the 
loss of key clients, employees and business partners 
which could have an adverse impact on our business, 
financial condition and results of operations.

Joint ventures and non-controlling investments 
contain potentially increased financial, legal, 
reputational, operational, regulatory and/or 
compliance risks.  We may be dependent on joint 
venture partners, controlling shareholders or 
management who may have business interests, 
strategies or goals that are inconsistent with ours.  
Business decisions or other actions or omissions of 
the joint venture partner, controlling shareholders or 
management may adversely affect the value of our 
investment, impacting our results of operations, result 
in litigation or regulatory action against us and 
otherwise damage our reputation and brand.

Other Risks

Tax law changes or challenges to our tax positions 
with respect to historical transactions may adversely 
affect our net income, effective tax rate and our 
overall results of operations and financial condition.

In 2017, U.S. tax legislation was signed into law, 
resulting in tax benefits to us.  We continue to 
monitor the tax impacts of additional guidance 
provided by the Internal Revenue Service with 
respect to this and other tax laws.  Future tax laws or 
the expiration of or changes in existing tax laws, or 
the interpretation of those laws worldwide, could also 
have a material impact on our business or net income.  
Our actions taken in response to, or reliance upon, 
such changes in the tax laws may impact our tax 
position in a manner that may result in lower 
earnings.

In the course of our business, we receive inquiries 
and challenges from both U.S. and non-U.S. tax 

BNY Mellon 99 

Risk Factors (continued)

authorities on the amount of taxes we owe.  If we are 
not successful in defending these inquiries and 
challenges, we may be required to adjust the timing 
or amount of taxable income or deductions or the 
allocation of income among tax jurisdictions, all of 
which can require a greater provision for taxes or 
otherwise negatively affect earnings.  Probabilities 
and outcomes are reviewed as events unfold, and 
adjustments to the reserves are made when necessary, 
but the reserves may prove inadequate because we 
cannot necessarily accurately predict the outcome of 
any challenge, settlement or litigation or the extent to 
which it will negatively affect us or our business.  See 
Note 11 of the Notes to Consolidated Financial 
Statements for further information.

Our ability to return capital to shareholders is 
subject to the discretion of our Board of Directors 
and may be limited by U.S. banking laws and 
regulations, including those governing capital and 
the approval of our capital plan, applicable 
provisions of Delaware law or our failure to pay full 
and timely dividends on our preferred stock.

Holders of our common and preferred stock are only 
entitled to receive such dividends or other 
distributions of capital as our Board of Directors may 
declare out of funds legally available for such 
payments.  Although we have historically declared 
cash dividends on our common and preferred stock, 
we are not required to do so.  In addition to the Board 
of Directors’ approval, our ability to take certain 
actions, including our ability to make certain 
acquisitions, declare dividends or repurchase our 
common stock, is dependent on, among other things, 
Federal Reserve non-objection under the annual 
regulatory review of the results of the CCAR process 
and the supervisory stress tests required under the 
Dodd-Frank Act.  These evaluations, in turn, are 
dependent on, among other things, our successful 
demonstration that we can maintain capital levels 
above regulatory minimums in the event of a stressed 
market environment, as well as the Federal Reserve’s 
qualitative assessment of the robustness of our capital 
adequacy process and the assumptions and analysis 
underlying the capital plan.  There can be no 
assurance that the Federal Reserve will not object to 
our future capital plans or that we will perform 
adequately on our supervisory stress tests.  If the 
Federal Reserve objects to our proposed capital 
actions or we underperform on our stress tests, we 
may be required to revise our stress-testing or capital 
management approaches, resubmit our capital plan or 
postpone, or cancel or alter our planned capital 

 100 BNY Mellon

actions, and we would not be permitted to make any 
capital distributions other than those to which the 
Federal Reserve has indicated in writing its non-
objection.  In addition, if there have been or will be 
changes in our risk profile (including a material 
change in business strategy or risk exposure), 
financial condition or corporate structure, we may be 
required to resubmit our capital plan to the Federal 
Reserve.

Our ability to accurately predict or explain the 
outcome of the CCAR process is influenced by 
evolving supervisory criteria.  The Federal Reserve’s 
annual assessment of our capital adequacy and 
planning process involves not only a quantitative 
assessment through the Federal Reserve’s proprietary 
stress test models but also a qualitative assessment.  
The qualitative assessment involves a number of 
factors and is expected to continue to evolve on an 
ongoing basis as a result of the Federal Reserve’s 
horizontal review of capital plan submissions.  
Similarly, the Federal Reserve may, as part of its 
stated goal to continually evolve its annual stress 
testing requirements, adjust several parameters of the 
annual stress testing process, including the severity of 
the stress test scenario and the addition of 
components deemed important by the Federal 
Reserve (e.g., a counterparty failure).  Further, 
because the Federal Reserve’s proprietary stress test 
models and qualitative assessment may differ from 
the modeling techniques and capital planning 
practices employed by us, it is foreseeable that our 
stress test results (using our own models, estimation 
methodologies and processes) may not be consistent 
with those disclosed by the Federal Reserve.  In 
addition, the Federal Reserve has proposed to replace 
the capital conservation buffer with a “stress capital 
buffer,” which would result in the integration of the 
G-SIB surcharge with stress-based capital 
requirements.

The Federal Reserve’s instructions for the 2018 
CCAR provide that, for large BHCs like BNY 
Mellon, common stock dividend payout ratios 
exceeding 30% of after-tax net income available to 
common shareholders under certain baseline 
scenarios will receive particularly close scrutiny.  A 
failure to increase dividends along with our 
competitors, or any reduction of, or elimination of, 
our common stock dividend would likely adversely 
affect the market price of our common stock, impact 
our return on equity and market perceptions of BNY 
Mellon.

Risk Factors (continued)

Our ability to declare or pay dividends on, or 
purchase, redeem or otherwise acquire, shares of our 
common stock or any of our shares that rank junior to 
preferred stock as to the payment of dividends and/or 
the distribution of any assets on any liquidation, 
dissolution or winding-up of BNY Mellon will be 
prohibited, subject to certain exceptions, in the event 
that we do not declare and pay in full dividends for 
the then-current dividend period of our Series A 
preferred stock or the last preceding dividend period 
of our Series C, Series D, Series E or Series F 
preferred stock.

In addition, regulatory capital rules that are or will be 
applicable to us including the U.S. capital rules risk-
based capital requirements, the SLR, enhanced SLR, 
the TLAC Rule and the U.S. G-SIB surcharge may 
limit or otherwise restrict how we utilize our capital, 
including common stock dividends and stock 
repurchases, and may require us to increase or alter 
the mix of our outstanding regulatory capital 
instruments.

Any requirement to increase our regulatory capital 
ratios or alter the composition of our capital could 
require us to liquidate assets or otherwise change our 
business and/or investment plans, which may 
negatively affect our financial results.  Further, any 
requirement to maintain higher levels of capital may 
constrain our ability to return capital to shareholders 
either in the form of common stock dividends or 
stock repurchases.

The Parent is a non-operating holding company, 
and as a result, is dependent on dividends from its 
subsidiaries and extensions of credit from its IHC to 
meet its obligations, including with respect to its 
securities, and to provide funds for share 
repurchases and payment of dividends to its 
stockholders.

The Parent is a non-operating holding company, 
whose principal assets and sources of income are its 
principal U.S. bank subsidiaries - The Bank of New 
York Mellon and BNY Mellon, N.A. - and its other 
subsidiaries, including the IHC.  The Parent is a legal 
entity separate and distinct from the IHC, as well as 
its banks and other subsidiaries.  Therefore, the 
Parent primarily relies on dividends, interest, 
distributions, and other payments from its 
subsidiaries, including extensions of credit from the 
IHC, to meet its obligations, including its obligations 
with respect to its securities, and to provide funds for 
share repurchases and payment of common and 

preferred dividends to its stockholders, to the extent 
declared by the Board of Directors.

There are various limitations on the extent to which 
our bank and other subsidiaries can finance or 
otherwise supply funds to the Parent (by dividend or 
otherwise) and certain of our affiliates.  Each of these 
restrictions can reduce the amount of funds available 
to meet the Parent’s obligations.  Many of our 
subsidiaries, including our bank subsidiaries, are 
subject to laws and regulations that restrict dividend 
payments or authorize regulatory bodies to block or 
reduce the flow of funds from those subsidiaries to 
the Parent or other subsidiaries.  In addition, our bank 
subsidiaries would not be permitted to distribute a 
dividend if doing so would constitute an unsafe and 
unsound practice or if the payment would reduce their 
capital to an inadequate level.  Our subsidiaries may 
also choose to restrict dividend payments to the 
Parent in order increase their own capital or liquidity 
levels.  Our bank subsidiaries are also subject to 
restrictions on their ability to lend to or transact with 
non-bank affiliates, minimum regulatory capital and 
liquidity requirements, and restrictions on their ability 
to use funds deposited with them in bank or 
brokerage accounts to fund their businesses.  See 
“Supervision and Regulation” and “Liquidity and 
dividends” and Note 18 of the Notes to Consolidated 
Financial Statements.  Further, we evaluate and 
manage liquidity on a legal entity basis, which may 
place legal and other limitations on our ability to 
utilize liquidity from one legal entity to satisfy the 
liquidity requirements of another, including the 
Parent.

There are also limitations specific to the IHC’s ability 
to make distributions or extend credit to the Parent.  
The IHC is not permitted to pay dividends to the 
Parent if certain key capital, liquidity and operational 
risk indicators are breached, and if the resolution of 
the Parent is imminent, the committed lines of credit 
provided by the IHC to the Parent will automatically 
terminate, with all outstanding amounts becoming 
due.  See “The application of our Title I preferred 
resolution strategy or resolution under the Title II 
orderly liquidation authority could adversely affect 
the Parent’s liquidity and financial condition and the 
Parent’s security holders.”

Because the Parent is a holding company, its rights 
and the rights of its creditors, including the holders of 
its securities, to a share of the assets of any subsidiary 
upon the liquidation or recapitalization of the 
subsidiary will be subject to the prior claims of the 

BNY Mellon 101 

Risk Factors (continued)

subsidiary’s creditors (including, in the case of our 
banking subsidiaries, their depositors) except to the 
extent that the Parent may itself be a creditor with 
recognized claims against the subsidiary.  The rights 
of holders of securities issued by the Parent to benefit 
from those distributions will also be junior to those 
prior claims.  Consequently, securities issued by the 
Parent will be effectively subordinated to all existing 
and future liabilities of our subsidiaries.

Changes in accounting standards governing the 
preparation of our financial statements and future 
events could have a material impact on our reported 
financial condition, results of operations, cash flows 
and other financial data.

From time to time, the FASB, the SEC and bank 
regulators change the financial accounting and 
reporting standards governing the preparation of our 
financial statements or the interpretation of those 
standards.  These changes are difficult to predict and 
can materially impact how we record and report our 
financial condition, results of operations, cash flows 
and other financial data.  In some cases, we may be 
required to apply a new or revised standard 
retrospectively or to apply an existing standard 
differently, also retrospectively, in each case 
potentially resulting in the restatement of our prior 
period financial statements and our related 
disclosures.

Additionally, our accounting policies and methods are 
fundamental to how we record and report our 
financial condition and results of operations.  The 
preparation of financial statements in conformity with 
U.S. GAAP requires management to make estimates 
based upon assumptions about future economic and 
market conditions which affect reported amounts and 
related disclosures in our financial statements.  
Amounts subject to estimates are items such as the 
allowance for loan losses and lending-related 
commitments, the fair value of financial instruments 
and derivatives, goodwill and other intangibles and 
litigation and regulatory contingencies.  Among other 
effects, such changes in estimates could result in 
future impairments of, goodwill and intangible assets 
and establishment of allowances for loan losses and 
lending-related commitments as well as litigation and 
regulatory contingencies.  If subsequent events occur 
that are materially different than the assumptions and 
estimates we used, our reported financial condition, 
results of operation and cash flows may be materially 
negatively impacted.  See “Recent Accounting 
Developments” for a discussion of recent 
developments to our accounting standards.

 102 BNY Mellon

Recent Accounting Developments

Recently issued accounting standards

The following ASUs issued by the Financial 
Accounting Standards Board (“FASB”) have not yet 
been adopted.  

ASU 2016-02, Leases 

In February 2016, the FASB issued an ASU, Leases.  
The primary objective of this ASU is to increase 
transparency and comparability by recognizing lease 
assets and liabilities on the balance sheet and expand 
related disclosures.  This ASU requires a “right-of-
use” asset and a payment obligation liability on the 
balance sheet for most leases and subleases.  
Additionally, depending on the lease classification 
under the standard, it may result in different expense 
recognition patterns and classification than under 
existing accounting principles.  For leases classified 
as finance leases, it will result in higher expense 
recognition in the earlier periods and lower expense 
in the later periods of the lease.  

The Company adopted this guidance on Jan. 1, 2019 
using the alternative transition method, which allows 
the adoption of the accounting standard prospectively 
without adjusting comparative prior period financial 
information.  We recognized right-of-use assets of 
$1.3 billion and lease liabilities of $1.5 billion on the 
consolidated balance sheet, both based on the present 
value of the expected remaining lease payments. 

ASU 2018-02, Income Statement—Reporting 
Comprehensive Income: Reclassification of Certain 
Tax Effects from Accumulated Other Comprehensive 
Income

In February 2018, the FASB issued an ASU, Income 
Statement—Reporting Comprehensive Income: 
Reclassification of Certain Tax Effects from 
Accumulated Other Comprehensive Income.  This 
ASU permits a reclassification from accumulated 
other comprehensive income to retained earnings for 
the tax effects of items within accumulated other 
comprehensive income that do not reflect the lower 

statutory tax rate which was enacted by the U.S. tax 
legislation.  BNY Mellon adopted this guidance in the 
first quarter of 2019, which resulted in a $90 million 
reclassification from accumulated other 
comprehensive income to retained earnings. 

ASU 2016-13, Financial Instruments – Credit Losses: 
Measurement of Credit Losses on Financial 
Instruments  

In June 2016, the FASB issued an ASU, Financial 
Instruments – Credit Losses: Measurement of Credit 
Losses on Financial Instruments.  This ASU 
introduces a new current expected credit losses 
model, which will apply to financial assets subject to 
credit losses and measured at amortized cost, 
including held-to-maturity securities and certain off-
balance sheet credit exposures.  The guidance will 
also change current practice for the impairment 
model for available-for-sale debt securities.  The 
available-for-sale debt securities model will require 
the use of an allowance to record estimated credit 
losses and subsequent recoveries.  

The standard requires a cumulative effect of initial 
application to be recognized in retained earnings at 
the date of initial application.  BNY Mellon has 
developed expected credit loss models and 
approaches that include forecasting and other 
methodologies, and our focus for the remainder of 
2019 is on model validation as well as business 
process refinements and testing to ensure the 
expected credit losses are calculated in accordance 
with the standard.  We are continuing to assess the 
impact of the standard on our consolidated financial 
statements, disclosures and internal control.  The 
adoption impact will depend on several factors 
including the composition and remaining expected 
lives of financial instruments at the time of adoption, 
the establishment of an allowance for expected credit 
losses on held-to-maturity securities, and the 
macroeconomic conditions and forecasts that exist at 
that date.  We plan to adopt the new standard on Jan. 
1, 2020.

BNY Mellon 103 

Business Continuity

Business continuity and operational resiliency are 
priorities for the Company.  Core elements of our 
business continuity and operational resiliency 
strategies include advance planning, maintaining 
multiple data centers, testing our capabilities, 
maintaining diversity of business operations and 
telecommunications infrastructure, and reviewing the 
business continuity and information security 
capabilities of our service providers.  These 
capabilities are intended to enable the Company to 
maintain its operations and appropriately respond to 
events that could damage our physical facilities, 
cause delays or disruptions to operational functions 
(including telecommunications networks), or impair 
the ability of our employees to work, of our vendors 
to provide services to us, or of our clients and 
counterparties to communicate and transact with us.  
Those events include information security incidents, 
technology disruptions, acts of terrorism, natural 
disasters, pandemics and global conflicts.

We continue to evaluate and strengthen our business 
continuity and operational resiliency capabilities and 
have increased our investments in technology to 
steadily enhance those capabilities, including our 
ability to resume and sustain our operations.

 104 BNY Mellon

Supplemental Information (unaudited)

Explanation of GAAP and Non-GAAP 
financial measures

BNY Mellon has included in this Annual Report 
certain Non-GAAP financial measures on a tangible 
basis, as a supplement to generally accepted 
accounting principles (“GAAP”) information.  
Tangible common shareholders’ equity excludes 
goodwill and intangible assets, net of deferred tax 
liabilities.  BNY Mellon believes that the return on 
tangible common equity measure is an additional 
useful measure for investors because it presents a 
measure of those assets that can generate income.  
BNY Mellon has provided a measure of tangible book 
value per common share, which it believes provides 
additional useful information as to the level of 
tangible assets in relation to shares of common stock 
outstanding.  

The presentation of the growth rates of investment 
management and performance fees on a constant 

currency basis permits investors to assess the 
significance of changes in foreign currency exchange 
rates.  Growth rates on a constant currency basis were 
determined by applying the current period foreign 
currency exchange rates to the prior period revenue.  
BNY Mellon believes that this presentation, as a 
supplement to GAAP information, gives investors a 
clearer picture of the related revenue results without 
the variability caused by fluctuations in foreign 
currency exchange rates.  

BNY Mellon has presented the operating margin for 
the Investment Management business net of 
distribution and servicing expense that was passed to 
third parties who distribute or service our managed 
funds.  BNY Mellon believes that this measure is 
useful when evaluating the performance of the 
Investment Management business relative to industry 
competitors.  

The following table presents the reconciliation of the return on common equity and tangible common equity.

Return on common equity and tangible common equity reconciliation
(dollars in millions)
Net income applicable to common shareholders of The Bank of New York

Mellon Corporation – GAAP

Add:  Amortization of intangible assets
Less: Tax impact of amortization of intangible assets

Adjusted net income applicable to common shareholders of The Bank of

New York Mellon Corporation, excluding amortization of intangible assets
– Non-GAAP

Average common shareholders’ equity
Less:  Average goodwill

Average intangible assets

Add:  Deferred tax liability – tax deductible goodwill (a)
  Deferred tax liability – intangible assets (a)

Average tangible common shareholders’ equity – Non-GAAP

2018

2017

2016

2015

2014

$

$

4,097
180
42

$

3,915
209
72

3,425
237
81

$

3,053
261
89

$

2,494
298
104

$

4,235

$

4,052

$

3,581

$

3,225

$

2,688

$ 37,818
17,458
3,314
1,072
692
$ 18,810

$ 36,145
17,441
3,508
1,034
718
$ 16,948

$ 35,504
17,497
3,737
1,497
1,105
$ 16,872

$ 35,564
17,731
3,992
1,401
1,148
$ 16,390

$ 36,618
18,063
4,305
1,340
1,216
$ 16,806

Return on common shareholders’ equity – GAAP 
Return on tangible common shareholders’ equity – Non-GAAP
(a)  Deferred tax liabilities are based on fully phased-in U.S. capital rules.

10.8%
22.5%

10.8%
23.9%

9.6%
21.2%

8.6 %
19.7 %

6.8%
16.0%

BNY Mellon 105 

Supplemental Information (unaudited) (continued)

The following table presents the reconciliation of book value and tangible book value per common share.

Book value and tangible book value per common share reconciliation
(dollars in millions, unless otherwise noted)
BNY Mellon shareholders’ equity at year end – GAAP
Less:  Preferred stock

BNY Mellon common shareholders’ equity at year end – GAAP

$

Less:  Goodwill

Intangible assets

Add:  Deferred tax liability – tax deductible goodwill (a)
Deferred tax liability – intangible assets (a)

BNY Mellon tangible common shareholders’ equity at year 

end – Non-GAAP

Dec. 31,

2018
40,638 $
3,542
37,096
17,350
3,220
1,072
692

2017
41,251 $
3,542
37,709
17,564
3,411
1,034
718

2016
38,811 $
3,542
35,269
17,316
3,598
1,497
1,105

2015
38,037 $
2,552
35,485
17,618
3,842
1,401
1,148

2014
37,441
1,562
35,879
17,869
4,127
1,340
1,216

$

18,290 $

18,486 $

16,957 $

16,574 $

16,439

Year-end common shares outstanding (in thousands)

960,426

1,013,442

1,047,488

1,085,343

1,118,228

Book value per common share – GAAP
Tangible book value per common share – Non-GAAP
(a)  Deferred tax liabilities are based on fully phased-in U.S. capital rules.

$
$

38.63 $
19.04 $

37.21 $
18.24 $

33.67 $
16.19 $

32.69 $
15.27 $

32.09
14.70

The following table presents the impact of changes in foreign currency exchange rates on our consolidated 
investment management and performance fees.

Constant currency reconciliation – Consolidated
(dollars in millions)
Investment management and performance fees
Impact of changes in foreign currency exchange rates

Adjusted investment management and performance fees – Non-GAAP

2018
3,685 $
—
3,685 $

2017
3,584
34
3,618

$

$

2018 vs.
2017
3%

2%

The following table presents the impact of changes in foreign currency exchange rates on investment management 
and performance fees reported in the Investment Management business. 

Constant currency reconciliation - Investment Management business
(dollars in millions)
Investment management and performance fees
Impact of changes in foreign currency exchange rates

Adjusted investment management and performance fees – Non-GAAP

2018
3,632 $
—
3,632 $

2017
3,522
34
3,556

$

$

2018 vs.
2017
3%

2%

The following table presents the reconciliation of the pre-tax operating margin for the Investment Management 
business. 

Pre-tax operating margin reconciliation - Investment Management business
(dollars in millions)
Income before income taxes – GAAP

Total revenue – GAAP
Less:  Distribution and servicing expense

Adjusted total revenue, net of distribution and servicing expense – Non-GAAP

Pre-tax operating margin – GAAP (a)
Adjusted pre-tax operating margin, net of distribution and servicing expense – Non-GAAP (a)
(a)  Income before taxes divided by total revenue.

2018

$ 1,263

$ 4,084
407
$ 3,677

2017

1,141

3,997
422
3,575

$

$

$

2016
967

3,751
404
3,347

$

$

$

31%
34%

29%
32%

26%
29%

 106 BNY Mellon

Supplemental Information (unaudited) (continued)

Rate/volume analysis

Rate/volume analysis (a)

(dollar amounts in millions, presented on an FTE basis)

Interest revenue
Interest-earning assets:

Interest-bearing deposits with banks (primarily foreign banks)
Interest-bearing deposits with the Federal Reserve and other central banks
Federal funds sold and securities purchased under resale agreements
Margin loans
Non-margin loans:

Domestic offices:
Consumer
Commercial
Foreign offices

Total non-margin loans

Securities:

U.S. government obligations
U.S. government agency obligations
State and political subdivisions - tax exempt
Other securities:

Domestic offices
Foreign offices

Total other securities

Trading securities (primarily domestic)

Total securities

Total interest revenue

Interest expense
Interest-bearing liabilities:
Interest-bearing deposits:

Domestic offices
Foreign offices

Total interest-bearing deposits

Federal funds purchased and securities sold under repurchase agreements
Trading liabilities
Other borrowed funds:
Domestic offices
Foreign offices

Total other borrowed funds

Commercial paper
Payables to customers and broker-dealers
Long-term debt

Total interest expense

Changes in net interest revenue

$

$

$

$
$

2018 over (under) 2017

2017 over (under) 2016

Due to change in
Average
balance

Average
rate

Net
change

Due to change in
Average
balance

Average
rate

Net
change

(1) $
(9)
11
(2)

100 $
221
682
169

8
(29)
(25)
(46)

(31)
76
(19)

13
209
103
325

92
247
(12)

99
212
693
167

21
180
78
279

61
323
(31)

(25)
3
(22)
60
64
17 $

151
26
177
5
509

126
29
155
65
573
2,006 $ 2,023

35 $
—
35
(56)
—

24
(2)
22
—
(10)
18
9 $
8 $

395 $
285
680
589
22

430
285
715
533
22

10
—
10
22
137
278

34
(2)
32
22
127
296
1,738 $ 1,747
276

268 $

$

1 $

15 $

(28)
14
(62)

33
(17)
(4)
12

9
71
(15)

(62)
(11)
(73)
(1)
(9)
(72) $

(1) $
3
2
17
4

20
—
20
8
2
69
122 $
(194) $

$

$

$
$

149
176
140

6
121
65
192

38
138
5

67
(45)
22
—
203
875 $

67 $
77
144
172
(3)

(3)
1
(2)
16
50
138
515 $
360 $

16
121
190
78

39
104
61
204

47
209
(10)

5
(56)
(51)
(1)
194
803

66
80
146
189
1

17
1
18
24
52
207
637
166

(a)  Changes which are solely due to balance changes or rate changes are allocated to such categories on the basis of the respective percentage changes in 

average balances and average rates.  Changes in interest revenue or interest expense arising from the combination of rate and volume variances are 
allocated proportionately to rate and volume based on their relative absolute magnitudes.

BNY Mellon 107 

 
 
Selected Quarterly Data (unaudited)

Selected Quarterly Data

(dollar amounts in millions,
except per share amounts)

Consolidated income statement

Fee and other revenue

(Loss) income from consolidated investment

management funds

Net interest revenue

Total revenue

Provision for credit losses

Noninterest expense

Income before taxes

Provision (benefit) for income taxes

Net income

Net loss (income) attributable to noncontrolling

interests

Net income applicable to shareholders of The

Bank of New York Mellon Corporation

Preferred stock dividends

Net income applicable to common shareholders
of The Bank of New York Mellon Corporation

Basic earnings per common share
Diluted earnings per common share
Average balances

Interest-bearing deposits with banks

Securities
Trading securities

Loans
Total interest-earning assets

Total assets
Deposits

Long-term debt
Preferred stock

Total The Bank of New York Mellon Corporation

common shareholders’ equity

Net interest margin
Annualized return on common equity

Pre-tax operating margin
Common stock data (a)

Closing price per share
Cash dividends per share

Market capitalization (b)

Quarter ended

2018

2017

Dec. 31

Sept. 30

June 30 March 31

Dec. 31

Sept. 30

June 30 March 31

$

3,146

$

3,168

$

3,210

$

3,270

$

2,860

$

3,167

$

3,120

$

3,018

(24)

885

4,007

—

2,987

1,020

150

870

11

881

(49)

$

$

$

$

832

0.84

0.84

10

891

4,069

(3)

2,738

1,334

220

1,114

12

916

4,138

(3)

2,747

1,394

286

1,108

(11)

919

4,178

(5)

2,739

1,444

282

1,162

17

851

3,728

(6)

3,006

728

(453)

1,181

(3)

(5)

9

(6)

(2)

1,111

(36)

1,075

1.07

1.06

$

$

1,103

(48)

1,055

1.04

1.03

$

$

1,171

(36)

1,135

1.11

1.10

1,175

(49)

1,126

1.09
1.08

$

$

$

$

$

$

983

0.94
0.94

$

$

926

0.88
0.88

10

839

10

826

33

792

4,016

3,956

3,843

(6)

(7)

(5)

2,654

1,368

348

1,020

1,018

(35)

2,655

1,308

332

976

(1)

975

(49)

2,642

1,206

269

937

(15)

922

(42)

880

0.83
0.83

$ 78,582
118,904

$ 75,907
118,505

$ 85,424
117,761

$ 92,918
118,459

5,543
53,834

285,706
338,591

220,635
28,201

3,542

4,261
53,807

279,218
332,341

209,313
28,074

3,542

3,784
57,066

292,086
346,328

217,567
28,349

3,542

4,183
58,606

302,069
358,175

226,709
28,407

3,542

$ 89,029

$ 86,329

$ 84,148

$ 80,757

120,225
2,723

56,772
297,166

350,786
216,874

28,245
3,542

119,089
2,359

55,944
291,841

345,709
212,658

28,138
3,542

117,227
2,455

58,793
289,496

342,515
216,222

27,398
3,542

114,786
2,254

60,312
283,421

336,200
213,375

25,882
3,542

37,886

38,036

37,750

37,593

36,952

36,780

35,862

34,965

1.24%

8.7%
25%

1.27%

11.2%
33%

1.26%

11.2%
34%

1.22%

12.2%
35%

1.14%
12.1%

20%

1.15%
10.6%

34%

1.14%
10.4%

33%

1.13%
10.2%

31%

$

47.07

$

50.99

$

53.93

$

51.53

$

0.28
45,207

0.28
50,418

0.24
53,927

0.24
52,080

$

53.86
0.24

53.02
0.24

$

51.02
0.19

$

47.23
0.19

54,584

54,294

52,712

49,113

(a)  At Dec. 31, 2018, there were 27,805 shareholders registered with our stock transfer agent, compared with 29,472 at Dec. 31, 2017 and 28,015 at Dec. 31, 
2016.  In addition, there were 45,395 of BNY Mellon’s current and former employees at Dec. 31, 2018 who participate in BNY Mellon’s 401(k) Retirement 
Savings Plan.  All shares of BNY Mellon’s common stock held by the Plan for its participants are registered in the name of The Bank of New York Mellon, 
as trustee.  
(b)  At period end.  

 108 BNY Mellon

Forward-looking Statements

Some statements in this document are forward-
looking.  These include all statements about the 
usefulness of Non-GAAP measures, the future results 
of BNY Mellon, our businesses, financial, liquidity 
and capital condition, results of operations, liquidity, 
risk and capital management and processes, goals, 
strategies, outlook, objectives, expectations 
(including those regarding our performance results, 
expenses, nonperforming assets, seasonality in our 
businesses, impacts of currency fluctuations, impacts 
of trends on our businesses, regulatory, technology, 
market, economic or accounting developments, legal 
proceedings and other contingencies), effective tax 
rate, estimates (including those regarding expenses, 
losses inherent in our credit portfolios, capital ratios 
and the tax benefit related to U.S. tax legislation), 
intentions (including those regarding our capital 
returns and investment in technology), targets, 
opportunities, growth and initiatives. 

In this report, any other report, any press release or 
any written or oral statement that BNY Mellon or its 
executives may make, words, such as “estimate,” 
“forecast,” “project,” “anticipate,” “likely,” “target,” 
“expect,” “intend,” “continue,” “seek,” “believe,” 
“plan,” “goal,” “could,” “should,” “would,” “may,” 
“might,” “will,” “strategy,” “synergies,” 
“opportunities,” “trends,” “future” and words of 
similar meaning, may signify forward-looking 
statements.

Actual results may differ materially from those 
expressed or implied as a result of a number of 
factors, including those discussed in “Risk Factors,” 
such as:  

• 

• 

a communications or technology disruption or 
failure that results in a loss of information, delays 
our ability to access information or impacts our 
ability to provide services to our clients may 
materially adversely affect our business, financial 
condition and results of operations; 
a cybersecurity incident, or a failure to protect 
our computer systems, networks and information 
and our clients’ information against cybersecurity 
threats, could result in the theft, loss, 
unauthorized access to, disclosure, use or 
alteration of information, system or network 
failures, or loss of access to information; any 
such incident or failure could adversely impact 
our ability to conduct our businesses, damage our 
reputation and cause losses; 

• 

• 

our business may be materially adversely affected 
by operational risk; 
our risk management framework may not be 
effective in mitigating risk and reducing the 
potential for losses; 

•  we are subject to extensive government 

• 

• 

• 

rulemaking, regulation and supervision; these 
rules and regulations have, and in the future may, 
compel us to change how we manage our 
businesses, which could have a material adverse 
effect on our business, financial condition and 
results of operations; in addition, these rules and 
regulations have increased our compliance and 
operational risk and costs; 
regulatory or enforcement actions or litigation 
could materially adversely affect our results of 
operations or harm our businesses or reputation; 
our businesses may be negatively affected by 
adverse events, publicity, government scrutiny or 
other reputational harm; 
failure to satisfy regulatory standards, including 
“well capitalized” and “well managed” status or 
capital adequacy and liquidity rules more 
generally, could result in limitations on our 
activities and adversely affect our business and 
financial condition;
a failure or circumvention of our controls and 
procedures could have a material adverse effect 
on our business, reputation, results of operations 
and financial condition; 
the application of our Title I preferred resolution 
strategy or resolution under the Title II orderly 
liquidation authority could adversely affect the 
Parent’s liquidity and financial condition and the 
Parent’s security holders; 
if our resolution plan is determined not to be 
credible or not to facilitate an orderly resolution 
under the U.S. Bankruptcy Code, our business, 
reputation, results of operations and financial 
condition could be materially negatively 
impacted; 
acts of terrorism, impacts from climate change, 
natural disasters, pandemics, global conflicts and 
other geopolitical events may have a negative 
impact on our business and operations; 
•  we are dependent on fee-based business for a 

• 

• 

• 

• 

substantial majority of our revenue and our fee-
based revenues could be adversely affected by 
slowing in market activity, weak financial 
markets, underperformance and/or negative 
trends in savings rates or in investment 
preferences; 

BNY Mellon 109 

Forward-looking Statements (continued)

• 

•  weakness and volatility in financial markets and 
the economy generally may materially adversely 
affect our business, results of operations and 
financial condition; 
transitions away from, or changes in the 
calculation of, LIBOR and other benchmark rates 
could adversely impact our business and results 
of operations; 
the United Kingdom’s referendum decision to 
leave the EU has had and may continue to have 
negative effects on global economic conditions, 
global financial markets, and our business and 
results of operations; 
changes in interest rates and yield curves could 
have a material adverse effect on our 
profitability; 

• 

• 

• 

• 

•  we may experience write-downs of securities that 
we own and other losses related to volatile and 
illiquid market conditions, reducing our earnings 
and impacting our financial condition; 
our FX revenue may be adversely affected by 
decreases in market volatility and the cross-
border investment activity of our clients; 
the failure or perceived weakness of any of our 
significant counterparties, many of whom are 
major financial institutions and sovereign entities, 
and our assumption of credit and counterparty 
risk, could expose us to loss and adversely affect 
our business; 
our business, financial condition and results of 
operations could be adversely affected if we do 
not effectively manage our liquidity; 

• 

• 

•  we could incur losses if our allowance for credit 
losses, including loan and lending-related 
commitments reserves, is inadequate; 
any material reduction in our credit ratings or the 
credit ratings of our principal bank subsidiaries, 
The Bank of New York Mellon or BNY Mellon, 
N.A., could increase the cost of funding and 
borrowing to us and our rated subsidiaries and 
have a material adverse effect on our results of 
operations and financial condition and on the 
value of the securities we issue; 
new lines of business, new products and services 
or transformational or strategic project initiatives 
may subject us to additional risks, and the failure 
to implement these initiatives could affect our 
results of operations; 

• 

 110 BNY Mellon

• 

• 

• 

• 

•  we are subject to competition in all aspects of our 
business, which could negatively affect our 
ability to maintain or increase our profitability; 
our business may be adversely affected if we are 
unable to attract and retain employees; 
our strategic transactions present risks and 
uncertainties and could have an adverse effect on 
our business, results of operations and financial 
condition; 
tax law changes or challenges to our tax positions 
with respect to historical transactions may 
adversely affect our net income, effective tax rate 
and our overall results of operations and financial 
condition; 
our ability to return capital to shareholders is 
subject to the discretion of our Board of Directors 
and may be limited by U.S. banking laws and 
regulations, including those governing capital and 
the approval of our capital plan, applicable 
provisions of Delaware law or our failure to pay 
full and timely dividends on our preferred stock; 
the Parent is a non-operating holding company, 
and as a result, is dependent on dividends from its 
subsidiaries and extensions of credit from its IHC 
to meet its obligations, including with respect to 
its securities, and to provide funds for share 
repurchases and payment of dividends to its 
stockholders; and
changes in accounting standards governing the 
preparation of our financial statements and future 
events could have a material impact on our 
reported financial condition, results of operations, 
cash flows and other financial data.

• 

• 

Investors should consider all risk factors discussed in 
our 2018 Annual Report and any subsequent reports 
filed with the SEC by BNY Mellon pursuant to the 
Securities Exchange Act of 1934, as amended (the 
“Exchange Act”).  All forward-looking statements 
speak only as of the date on which such statements 
are made, and BNY Mellon undertakes no obligation 
to update any statement to reflect events or 
circumstances after the date on which such forward-
looking statement is made or to reflect the occurrence 
of unanticipated events.  The contents of BNY 
Mellon’s website or any other websites referenced 
herein are not part of this report.

Acronyms

ABS
Asset-backed security
APAC
Asia-Pacific region
ASC
Accounting Standards Codification
ASU
Accounting Standards Update
AUC/A Assets under custody and/or administration
AUM
BCBS
BHCs
bps
CCAR
CDs
CET1
CFTC
CLO
CVA
DVA
EMEA
ERISA

Assets under management
Basel Committee on Banking Supervision
Bank holding companies
basis points
Comprehensive Capital Analysis and Review
Certificates of deposit
Common Equity Tier 1 capital
Commodity Futures Trading Commission
Collateralized loan obligation
Credit valuation adjustment
Debit valuation adjustment
Europe, the Middle East and Africa
Employee Retirement Income Security Act of
1974
Employee Stock Ownership Plan
Economic value of equity
Financial Accounting Standards Board
Financial Conduct Authority
Federal Deposit Insurance Corporation
Financial holding company

ESOP
EVE
FASB
FCA
FDIC
FHC
FINRA Financial Industry Regulatory Authority, Inc.
FTE
FX
GAAP
G-SIBs
HQLA
IDI
IHC

Fully taxable equivalent
Foreign exchange
Generally accepted accounting principles
Global systemically important banks
High-quality liquid assets
Insured depository institution
Intermediate holding company

Liquidity coverage ratio

LCR
LIBOR London Interbank Offered Rate
LTD
External eligible long-term debt
M&I
Merger and integration
MBS
Mortgage-backed security
MMF
Money market funds
N/A
Not applicable or Not available
NAV
Net asset value
N/M
Not meaningful
NSFR
Net stable funding ratio
NYSE
New York Stock Exchange
OCC
Office of the Comptroller of the Currency
OCI
Other comprehensive income
OTC
Over-the-counter
OTTI
Other-than-temporary impairment
PRA
Prudential Regulation Authority
PSUs
Performance share units
REIT
Real estate investment trust
RMBS
Residential mortgage-backed security
RSUs
Restricted stock units
RWAs
Risk-weighted assets
S&P
Standard & Poor’s
SBIC
Small business investment company
SBLC
Standby letters of credit
SEC
Securities and Exchange Commission
SIFIs
Systemically important financial institutions
SLR
Supplementary Leverage Ratio
TDR
Troubled debt restructuring
TLAC
Total loss-absorbing capacity
VaR
Value-at-risk
VIE
Variable interest entity
VME
Voting model entity

BNY Mellon 111 

Glossary

Accumulated benefit obligation - The actuarial 
present value of benefits (vested and non-vested) 
attributed to employee services rendered.

Alternative investments - Usually refers to 
investments in hedge funds, leveraged loans, 
subordinated and distressed debt, real estate and 
foreign currency overlay.  Examples of alternative 
investment strategies are:  long-short equity, event-
driven, statistical arbitrage, fixed-income arbitrage, 
convertible arbitrage, short bias, global macro and 
equity market neutral.

Asset-backed security (“ABS”) - A financial 
security backed by a loan, lease or receivables against 
assets other than real estate and mortgage-backed 
securities.

Assets under custody and/or administration 
(“AUC/A”) - Assets that we hold directly or 
indirectly on behalf of clients under a safekeeping or 
custody arrangement or for which we provide 
administrative services for clients.  The following 
types of assets under administration are not and 
historically have not been included in AUC/A: 
performance and risk analytics, transfer agency and 
asset aggregation services.  To the extent that we 
provide more than one AUC/A service for a client’s 
assets, the value of the asset is only counted once in 
the total amount of AUC/A.

Assets under management (“AUM”) - Includes 
assets beneficially owned by our clients or customers 
which we hold in various capacities that are either 
actively or passively managed, as well as the value of 
hedges supporting customer liabilities.  These assets 
and liabilities are not on our balance sheet.

Book value per share - The per share value of a 
company based on common shareholders’ equity.

CAMELS - An international bank-rating system 
where bank supervisory authorities rate institutions 
according to six factors.  The six factors are Capital 
adequacy, Asset quality, Management quality, 
Earnings, Liquidity and Sensitivity to Market Risk.

Collateral management - A comprehensive program 
designed to simplify collateralization and expedite 
securities transfers for buyers and sellers.  

Collateralized loan obligation (“CLO”) - A debt 
security backed by a pool of commercial loans.

 112 BNY Mellon

Collective trust fund - An investment fund formed 
from the pooling of investments by investors.

Common Equity Tier 1 capital (“CET1”) - The 
sum of surplus (net of treasury stock), retained 
earnings, accumulated other comprehensive income 
(loss), and common equity Tier 1 minority interest 
subject to certain limitations, minus certain regulatory 
adjustments and deductions.

Counterparty risk (default risk) - The risk that a 
counterparty will not pay as obligated on a contract, 
trade or transaction.

Credit derivatives - Contractual agreements that 
provide insurance against a credit event of one or 
more referenced credits.  Such events include 
bankruptcy, insolvency and failure to meet payment 
obligations when due.  

Credit risk - The risk of loss due to borrower or 
counterparty default.

Credit valuation adjustment (“CVA”) - The market 
value of counterparty credit risk on OTC derivative 
transactions.  

Currency swaps - An agreement to exchange 
stipulated amounts of one currency for another 
currency.

Debit valuation adjustment (“DVA”) - The market 
value of our credit risk on OTC derivative 
transactions.  

Depositary Receipts - A negotiable security that 
generally represents a non-U.S. company’s publicly 
traded equity.  

Derivative - A contract or agreement whose value is 
derived from changes in interest rates, foreign 
exchange rates, prices of securities or commodities, 
credit worthiness for credit default swaps or financial 
or commodity indices.

Earnings allocated to participating securities - 
Amount of undistributed earnings, after payment of 
taxes, preferred stock dividends and the required 
adjustment for common stock dividends declared, 
that is allocated to securities that are eligible to 
receive a portion of the Company’s earnings.

Glossary (continued)

Economic capital - The amount of capital required to 
absorb potential losses and reflects the probability of 
remaining solvent with a target debt rating over a 
one-year time horizon.

Economic value of equity (“EVE”) - An 
aggregation of discounted future cash flows of assets 
and liabilities over a long-term horizon.

Eurozone - Formed by European Union Member 
States whose currency is the euro (€) and in which a 
single monetary policy is conducted under the 
responsibility of the Governing Council of the 
European Central Bank.  The Eurozone currently 
includes Germany, France, Belgium, the Netherlands, 
Luxembourg, Austria, Finland, Italy, Ireland, Spain, 
Portugal, Greece, Estonia, Cyprus, Malta, Slovenia, 
Slovakia, Latvia and Lithuania.

Fiduciary risk - The risk arising from our role as 
trustee, executor, investment agent or guardian in 
accordance with governing documents, prudent 
person principles and applicable laws, rules and 
regulations.

Fixed Income Clearing Corporation (“FICC”) - 
An agency that deals with the confirmation, 
settlement and delivery of fixed-income assets in the 
U.S.  The agency ensures the systematic and efficient 
settlement of U.S. government securities and 
mortgage-backed security transactions in the market.

Foreign currency options - Similar to interest rate 
options except they are based on foreign exchange 
rates.  Also, see interest rate options in this glossary.

Foreign currency swaps - An agreement to exchange 
stipulated amounts of one currency for another 
currency at one or more future dates.

Foreign exchange contracts - Contracts that provide 
for the future receipt or delivery of foreign currency 
at previously agreed-upon terms.

Forward rate agreements - Contracts to exchange 
payments on a specified future date, based on a 
market change in interest rates from trade date to 
contract settlement date.

Fully taxable equivalent (“FTE”) - Basis for 
comparison of yields on assets having ordinary 
taxability with assets for which special tax 
exemptions apply.  The FTE adjustment reflects an 
increase in the interest yield or return on a tax-exempt 
asset to a level that would be comparable had the 
asset been fully taxable. 

Generally accepted accounting principles 
(“GAAP”) - Accounting rules and conventions 
defining acceptable practices in preparing financial 
statements in the U.S.  The FASB is the primary 
source of accounting rules.

Global systemically important bank (“G-SIB”) - A 
financial institution whose distress or disorderly 
failure, because of its size, complexity and systemic 
interconnectedness, would cause significant 
disruption to the wider financial system and 
economic activity.

Grantor Trust - A legal, passive entity through 
which pass-through securities are sold to investors.

Hedge fund - A fund which is allowed to use diverse 
strategies that are unavailable to mutual funds, 
including selling short, leverage, program trading, 
swaps, arbitrage and derivatives.  

High-quality liquid assets (“HQLA”) - 
Unencumbered assets of the types identified in the 
U.S. LCR rule, which the U.S. banking agencies 
describe as able to be convertible into cash with little 
or no expected loss of value during a period of 
liquidity stress.

Impairment - When an asset’s market value is less 
than its carrying value.

Interest rate options - Contracts to modify interest 
rate risk in exchange for the payment of a premium 
when the contract is initiated.  As a writer of interest 
rate options, we receive a premium in exchange for 
bearing the risk of unfavorable changes in interest 
rates.  Conversely, as a purchaser of an option, we 
pay a premium for the right, but not the obligation, to 
buy or sell a financial instrument or currency at 
predetermined terms in the future.

BNY Mellon 113 

Glossary (continued)

Interest rate sensitivity - The exposure of net 
interest revenue to interest rate movements.

Interest rate swaps - Contracts in which a series of 
interest rate flows in a single currency are exchanged 
over a prescribed period.  Interest rate swaps are the 
most common type of derivative contract that we use 
in our asset/liability management activities.  

Investment grade - Represents Moody’s long-term 
rating of Baa3 or better; and/or a Standard & Poor’s, 
Fitch or DBRS long-term rating of BBB- or better; or 
if unrated, an equivalent rating using our internal risk 
ratings.  Instruments that fall below these levels are 
considered to be non-investment grade.

Joint venture - A company or entity owned and 
operated by a group of companies for a specific 
business purpose, no one of which has a majority 
interest.

Liquidity coverage ratio (“LCR”) - A Basel III 
framework requirement for banks and BHCs to 
measure liquidity.  It is designed to ensure that certain 
banking organizations, including BNY Mellon, 
maintain a minimum amount of unencumbered 
HQLA sufficient to withstand the net cash outflow 
under a hypothetical standardized acute liquidity 
stress scenario for a 30-day time horizon. 

Litigation risk - Arises when, in the ordinary course 
of business, we are named as defendants or made 
parties to legal actions.

Master netting agreement - An agreement between 
two counterparties that have multiple contracts with 
each other that provides for the net settlement of all 
contracts through a single payment in the event of 
default or termination of any one contract.

Mortgage-backed security (“MBS”) - An asset-
backed security whose cash flows are backed by the 
principal and interest payments of a set of mortgage 
loans.

Net interest margin - The result of dividing net 
interest revenue by average interest-earning assets.

Other-than-temporary impairment (“OTTI”) - An 
impairment charge taken on a security whose fair 
value has fallen below the carrying value on the 
balance sheet and its value is not expected to recover 
through the holding period of the security. 

 114 BNY Mellon

Performance fees - Fees received by an investment 
advisor based upon the fund’s performance for the 
period relative to various predetermined benchmarks.

Pre-tax operating margin - Income before taxes for 
a period divided by total revenue for that period.

Private equity/venture capital - Investment in start-
up companies or those in the early processes of 
developing products and services with perceived, 
long-term growth potential.

Projected benefit obligation - The actuarial present 
value of all benefits accrued on employee service 
rendered prior to the calculation date, including 
allowance for future salary increases if the pension 
benefit is based on future compensation levels.

Rating agency - An independent agency that assesses 
the credit quality and likelihood of default of an issue 
or issuer and assigns a rating to that issue or issuer. 

Real estate investment trust (“REIT”) - An 
investor-owned corporation, trust or association that 
sells shares to investors and invests in income-
producing property.

Repurchase agreement (“Repo”) - An instrument 
used to raise short-term funds whereby securities are 
sold with an agreement for the seller to buy back the 
securities at a later date. 

Reputational risk - Arises when events or actions 
that negatively impact our reputation lead to a loss of 
existing clients and could make it more challenging to 
acquire new business.

Residential mortgage-backed security (“RMBS”) - 
An asset-backed security whose cash flows are 
backed by principal and interest payments of a set of 
residential mortgage loans.

Restricted cash and/or securities - Cash and/or 
securities that are segregated under federal and other 
regulatory requirements and consists of excess client 
funds held by our broker-dealer entities.

Return on average assets - Net income applicable to 
common shareholders divided by average assets.

Return on common equity - Net income applicable 
to common shareholders divided by average common 
shareholders’ equity.

Glossary (continued)

Return on tangible common equity - Net income 
applicable to common shareholders, excluding 
amortization of intangible assets, divided by average 
tangible common shareholders’ equity.

Reverse repurchase agreement - The purchase of 
securities with the agreement to sell them at a higher 
price at a specific future date.

Securities lending transaction - A fully 
collateralized transaction in which the owner of a 
security agrees to lend the security typically through 
an agent (such as The Bank of New York Mellon) to a 
borrower, usually a broker-dealer or bank, on an 
open, overnight or term basis, under the terms of a 
prearranged contract.

Sub-custodian - A local provider (e.g., a bank) 
contracted to provide specific custodial-related 
services in a selected country or geographic area.  

Supplementary Leverage Ratio (“SLR”) - An 
Advanced Approach banking organization’s Basel III 
SLR is the simple arithmetic mean of the ratio of its 
Tier 1 capital to total leverage exposure (which is 
broadly defined to capture both on- and off-balance 
sheet exposures). 

Tangible book value per share - Amount per share 
that common shareholders can expect to receive if the 
company goes bankrupt and all of its tangible assets 
are liquidated at their book value.

Tangible common shareholders’ equity - Common 
equity less goodwill and intangible assets adjusted for 
deferred tax liabilities associated with non-tax 
deductible intangible assets and tax deductible 
goodwill.

Tier 1 leverage ratio - Tier 1 capital divided by 
quarterly average total assets, as defined by the 
regulators.

Unfunded commitments - Legally binding 
agreements to provide a defined level of financing 
until a specified future date.

Value-at-risk (“VaR”) - A measure of the dollar 
amount of potential loss in value due to adverse 
market movements over a defined time horizon with a 
specified confidence level.

Variable interest entity (“VIE”) - An entity that:  
(1) lacks enough equity investment at risk to permit 
the entity to finance its activities without additional 
financial support from other parties; (2) has equity 
owners that lack the right to make significant 
decisions affecting the entity’s operations; and/or (3) 
has equity owners that do not have an obligation to 
absorb, or the right to receive, the entity’s losses or 
returns.

BNY Mellon 115 

Report of Management on Internal Control Over Financial Reporting

Management of BNY Mellon is responsible for 
establishing and maintaining adequate internal 
control over financial reporting for BNY Mellon, as 
such term is defined in Rule 13a-15(f) under the 
Exchange Act.

BNY Mellon’s management, including its principal 
executive officer and principal financial officer, has 
assessed the effectiveness of BNY Mellon’s internal 
control over financial reporting as of December 31, 
2018.  In making this assessment, management used 
the criteria set forth by the Committee of Sponsoring 
Organizations of the Treadway Commission in 
Internal Control - Integrated Framework (2013).  
Based upon such assessment, management believes 
that, as of December 31, 2018, BNY Mellon’s 
internal control over financial reporting is effective 
based upon those criteria.

KPMG LLP, the independent registered public 
accounting firm that audited BNY Mellon’s 2018 
financial statements included in this Annual Report 
under “Financial Statements” and “Notes to 
Consolidated Financial Statements,” has issued a 
report with respect to the effectiveness of BNY 
Mellon’s internal control over financial reporting.  
This report appears on page 117.

 116 BNY Mellon

Report of Independent Registered Public Accounting Firm

To the Stockholders and Board of Directors
The Bank of New York Mellon Corporation:

Opinion on Internal Control Over Financial Reporting 

We have audited The Bank of New York Mellon Corporation and subsidiaries’ (BNY Mellon) internal control over 
financial reporting as of December 31, 2018, based on criteria established in Internal Control - Integrated 
Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission. In our 
opinion, BNY Mellon maintained, in all material respects, effective internal control over financial reporting as of 
December 31, 2018, based on criteria established in Internal Control - Integrated Framework (2013) issued by the 
Committee of Sponsoring Organizations of the Treadway Commission. 

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United 
States) (PCAOB), the consolidated balance sheets of BNY Mellon as of December 31, 2018 and 2017, the related 
consolidated statements of income, comprehensive income, changes in equity, and cash flows for each of the years 
in the three-year period ended December 31, 2018, and the related notes (collectively, the consolidated financial 
statements), and our report dated February 27, 2019 expressed an unqualified opinion on those consolidated 
financial statements. 

Basis for Opinion 

BNY Mellon’s management is responsible for maintaining effective internal control over financial reporting and for 
its assessment of the effectiveness of internal control over financial reporting, included in the accompanying Report 
of Management on Internal Control over Financial Reporting. Our responsibility is to express an opinion on BNY 
Mellon’s internal control over financial reporting based on our audit. We are a public accounting firm registered 
with the PCAOB and are required to be independent with respect to BNY Mellon in accordance with the U.S. 
federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the 
PCAOB. 

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and 
perform the audit to obtain reasonable assurance about whether effective internal control over financial reporting 
was maintained in all material respects. Our audit of internal control over financial reporting included obtaining an 
understanding of internal control over financial reporting, assessing the risk that a material weakness exists, and 
testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. Our 
audit also included performing such other procedures as we considered necessary in the circumstances. We believe 
that our audit provides a reasonable basis for our opinion. 

Definition and Limitations of Internal Control Over Financial Reporting 

A company’s internal control over financial reporting is a process designed to provide reasonable assurance 
regarding the reliability of financial reporting and the preparation of financial statements for external purposes in 
accordance with generally accepted accounting principles. A company’s internal control over financial reporting 
includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, 
accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable 
assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance 
with generally accepted accounting principles, and that receipts and expenditures of the company are being made 
only in accordance with authorizations of management and directors of the company; and (3) provide reasonable 
assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the company’s 
assets that could have a material effect on the financial statements. 

BNY Mellon 117 

Report of Independent Registered Public Accounting Firm (continued)

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. 
Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may 
become inadequate because of changes in conditions, or that the degree of compliance with the policies or 
procedures may deteriorate. 

New York, New York 
February 27, 2019 

 118 BNY Mellon

 
The Bank of New York Mellon Corporation (and its subsidiaries)

Consolidated Income Statement

(in millions)
Fee and other revenue
Investment services fees:

Asset servicing
Clearing services
Issuer services
Treasury services

Total investment services fees

Investment management and performance fees
Foreign exchange and other trading revenue
Financing-related fees
Distribution and servicing
Investment and other income
Total fee revenue

Net securities (losses) gains — including other-than-temporary impairment
Noncredit-related portion of other-than-temporary impairment (recognized in other comprehensive income)

Net securities (losses) gains
Total fee and other revenue

Operations of consolidated investment management funds
Investment (loss) income
Interest of investment management fund note holders

(Loss) income from consolidated investment management funds

Net interest revenue
Interest revenue
Interest expense

Net interest revenue
Total revenue

Provision for credit losses
Noninterest expense
Staff (a)
Professional, legal and other purchased services
Software
Net occupancy
Sub-custodian and clearing (b)
Distribution and servicing
Furniture and equipment
Business development
Bank assessment charges
Amortization of intangible assets
Other (a)(b)(c)

Total noninterest expense

Income
Income before income taxes
Provision for income taxes

Net income

Year ended Dec. 31,

2018

2017

2016

$

4,608 $
1,578
1,099
554
7,839
3,685
732
207
139
240
12,842
(47)
1
(48)
12,794

4,383 $
1,553
977
557
7,470
3,584
668
216
160
64
12,162
6
3
3
12,165

(12)
1
(13)

6,432
2,821
3,611
16,392
(11)

6,145
1,334
772
630
450
406
290
228
170
180
606
11,211

5,192
938
4,254

74
4
70

4,382
1,074
3,308
15,543
(24)

6,033
1,276
744
570
414
419
241
229
220
209
602
10,957

4,610
496
4,114

4,244
1,404
1,026
547
7,221
3,350
701
219
166
341
11,998
79
4
75
12,073

35
9
26

3,575
437
3,138
15,237
(11)

5,809
1,186
647
592
400
405
247
245
219
237
536
10,523

4,725
1,177
3,548

Net loss (income) attributable to noncontrolling interests (includes $12, $(33) and $(10) related to

Preferred stock dividends

consolidated investment management funds, respectively)

Net income applicable to shareholders of The Bank of New York Mellon Corporation

(1)
3,547
(122)
Net income applicable to common shareholders of The Bank of New York Mellon Corporation
3,425
In 2018, we adopted new accounting guidance included in ASU 2017-07, Compensation-Retirement Benefits: Improving the Presentation of Net 
Periodic Pension Cost and Net Periodic Postretirement Benefit Cost, which required the reclassification of the components of pension and other 
postretirement costs, other than the service cost component.  As a result, staff expense increased and other expense decreased.  Prior periods 
have been reclassified.  See Note 2 of the Notes to Consolidated Financial Statements for additional information.

(24)
4,090
(175)
3,915 $

12
4,266
(169)
4,097 $

$

(a) 

(b)  Beginning in 2018, clearing expense, which was previously included in other expense, was included with sub-custodian expense.  Prior periods 

have been reclassified. 

(c)  Beginning in 2018, M&I, litigation and restructuring charges are no longer separately disclosed.  Expenses previously reported in this line have 

been reclassified to existing expense categories, primarily other expense.

BNY Mellon 119 

The Bank of New York Mellon Corporation (and its subsidiaries)

Consolidated Income Statement (continued) 

Net income applicable to common shareholders of The Bank of New York Mellon Corporation used

for the earnings per share calculation

(in millions)
Net income applicable to common shareholders of The Bank of New York Mellon Corporation
Less:  Earnings allocated to participating securities

Net income applicable to common shareholders of The Bank of New York Mellon Corporation after

required adjustment for the calculation of basic and diluted earnings per common share

Year ended Dec. 31,

2018
4,097 $
27

2017
3,915 $
43

2016
3,425
52

4,070 $

3,872 $

3,373

$

$

Average common shares and equivalents outstanding of The Bank of New York Mellon Corporation
(in thousands)
Basic
Common stock equivalents
Less: Participating securities
Diluted

Year ended Dec. 31,

2018
1,002,922
6,801
(2,582)
1,007,141

2017
1,034,281
13,030
(7,021)
1,040,290

2016
1,066,286
15,672
(9,945)
1,072,013

Anti-dilutive securities (a)

6,804

12,383

31,695

Earnings per share applicable to common shareholders of The Bank of New York Mellon Corporation
(in dollars)
Basic
Diluted
(a)  Represents stock options, restricted stock, restricted stock units and participating securities outstanding but not included in the computation of 

2018
4.06 $
4.04 $

2017
3.74 $
3.72 $

Year ended Dec. 31,

2016
3.16
3.15

$
$

diluted average common shares because their effect would be anti-dilutive.

See accompanying Notes to Consolidated Financial Statements.

 120 BNY Mellon

The Bank of New York Mellon Corporation (and its subsidiaries)

Consolidated Comprehensive Income Statement

(in millions)
Net income
Other comprehensive income, net of tax:

Foreign currency translation adjustments
Unrealized (loss) gain on assets available-for-sale:
Unrealized (loss) gain arising during the period
Reclassification adjustment

Total unrealized (loss) gain on assets available-for-sale

Defined benefit plans:

Net (loss) gain arising during the period
Foreign exchange adjustment
Amortization of prior service credit, net loss and initial obligation included in net periodic

benefit cost
Total defined benefit plans

Net unrealized (loss) gain on cash flow hedges

Total other comprehensive (loss) income, net of tax (a)
Total comprehensive income

Net loss (income) attributable to noncontrolling interests
Other comprehensive loss (income) attributable to noncontrolling interests

Year ended Dec. 31,

2018
4,254 $

2017
4,114 $

2016
3,548

$

(313)

(416)
36
(380)

(189)
—

69
(120)
(10)
(823)
3,431
12
11

853

153
(3)
150

342
1

68
411
9
1,423
5,537
(24)
(15)

(850)

(242)
(49)
(291)

(108)
—

57
(51)
(4)
(1,196)
2,352
(1)
31

Comprehensive income applicable to shareholders of The Bank of New York Mellon

Corporation

$

3,454 $

5,498 $

2,382

(a)  Other comprehensive (loss) income attributable to The Bank of New York Mellon Corporation shareholders was $(812) million for the 
year ended Dec. 31, 2018, $1,408 million for the year ended Dec. 31, 2017 and $(1,165) million for the year ended Dec. 31, 2016.

See accompanying Notes to Consolidated Financial Statements.

BNY Mellon 121 

The Bank of New York Mellon Corporation (and its subsidiaries)

Consolidated Balance Sheet

(dollars in millions, except per share amounts)
Assets
Cash and due from:

Banks
Interest-bearing deposits with the Federal Reserve and other central banks

Interest-bearing deposits with banks ($2,394 and $1,751 is restricted)
Federal funds sold and securities purchased under resale agreements
Securities:

Held-to-maturity (fair value of $33,302 and $40,512)
Available-for-sale
Total securities

Trading assets
Loans
Allowance for loan losses

Net loans

Premises and equipment
Accrued interest receivable
Goodwill
Intangible assets
Other assets (includes $742 and $791, at fair value)

Subtotal assets of operations

Assets of consolidated investment management funds, at fair value

Total assets

Liabilities
Deposits:

Noninterest-bearing (principally U.S. offices)
Interest-bearing deposits in U.S. offices
Interest-bearing deposits in non-U.S. offices

Total deposits

Federal funds purchased and securities sold under repurchase agreements
Trading liabilities
Payables to customers and broker-dealers
Commercial paper
Other borrowed funds
Accrued taxes and other expenses 
Other liabilities (including allowance for lending-related commitments of $106 and $102, also includes $88

and $800, at fair value)

Long-term debt (includes $371 and $367, at fair value)

Subtotal liabilities of operations

Liabilities of consolidated investment management funds, at fair value

Total liabilities
Temporary equity
Redeemable noncontrolling interests
Permanent equity
Preferred stock – par value $0.01 per share; authorized 100,000,000 shares; issued 35,826 and 35,826 shares
Common stock – par value $0.01 per share; authorized 3,500,000,000 shares; issued 1,364,877,915 and

1,354,163,581 shares
Additional paid-in capital
Retained earnings
Accumulated other comprehensive loss, net of tax
Less: Treasury stock of 404,452,246 and 340,721,136 common shares, at cost
Total The Bank of New York Mellon Corporation shareholders’ equity

Nonredeemable noncontrolling interests of consolidated investment management funds

Total permanent equity
Total liabilities, temporary equity and permanent equity

See accompanying Notes to Consolidated Financial Statements.

 122 BNY Mellon

Dec. 31,

2018

2017

5,864 $
67,988
14,148
46,795

33,982
85,809
119,791
7,035
56,564
(146)
56,418
1,832
671
17,350
3,220
21,298
362,410
463
362,873 $

70,783 $
74,904
93,091
238,778
14,243
3,479
19,731
1,939
3,227
5,669

5,774
29,163
322,003
2
322,005

5,382
91,510
11,979
28,135

40,827
79,543
120,370
6,022
61,540
(159)
61,381
1,634
610
17,564
3,411
23,029
371,027
731
371,758

82,716
52,294
109,312
244,322
15,163
3,984
20,184
3,075
3,028
6,225

6,050
27,979
330,010
2
330,012

129

179

3,542

3,542

14
27,118
28,652
(3,171)
(15,517)
40,638
101
40,739
362,873 $

14
26,665
25,635
(2,357)
(12,248)
41,251
316
41,567
371,758

$

$

$

$

The Bank of New York Mellon Corporation (and its subsidiaries)

Consolidated Statement of Cash Flows

(in millions)
Operating activities
Net income
Net loss (income) attributable to noncontrolling interests
Net income applicable to shareholders of The Bank of New York Mellon Corporation
Adjustments to reconcile net income to net cash provided by operating activities:

Provision for credit losses
Pension plan contributions
Depreciation and amortization
Deferred tax (benefit) expense
Net securities losses (gains)

Change in trading assets and liabilities
Originations of loans held-for-sale
Proceeds from the sales of loans originated for sale
Change in accruals and other, net (a)

Net cash provided by operating activities (a)

Investing activities

Change in interest-bearing deposits with banks (a)
Change in interest-bearing deposits with the Federal Reserve and other central banks
Purchases of securities held-to-maturity
Paydowns of securities held-to-maturity
Maturities of securities held-to-maturity
Purchases of securities available-for-sale
Sales of securities available-for-sale
Paydowns of securities available-for-sale
Maturities of securities available-for-sale
Net change in loans
Sales of loans and other real estate
Change in federal funds sold and securities purchased under resale agreements (a)
Net change in seed capital investments
Purchases of premises and equipment/capitalized software
Proceeds from the sale of premises and equipment
Acquisitions, net of cash
Dispositions, net of cash
Other, net (a)

Net cash provided by (used for) investing activities (a)

Financing activities

Change in deposits
Change in federal funds purchased and securities sold under repurchase agreements
Change in payables to customers and broker-dealers
Change in other borrowed funds
Change in commercial paper
Net proceeds from the issuance of long-term debt
Repayments of long-term debt
Proceeds from the exercise of stock options
Issuance of common stock
Issuance of preferred stock
Treasury stock acquired
Common cash dividends paid
Preferred cash dividends paid
Other, net

Net cash (used for) provided by financing activities

Effect of exchange rate changes on cash
Change in cash and due from banks and restricted cash (a)
Change in cash and due from banks and restricted cash
Cash and due from banks and restricted cash at beginning of period
Cash and due from banks and restricted cash at end of period

Cash and due from banks and restricted cash: (a)

Cash and due from banks at end of period (unrestricted cash)
Restricted cash at end of period

Cash and due from banks and restricted cash at end of period

Supplemental disclosures

Interest paid
Income taxes paid
Income taxes refunded

Year ended Dec. 31,

2018

2017

2016

$

4,254 $
12
4,266

4,114 $
(24)
4,090

(11)
(55)
1,339
(525)
48
(574)
—
—
1,508
5,996

(2,011)
21,954
(5,055)
4,346
6,317
(32,404)
8,247
7,716
9,063
4,620
263
(18,662)
59
(1,108)
23
—
84
(153)
3,299

(2,874)
(920)
(433)
164
(1,136)
5,143
(3,650)
80
40
—
(3,269)
(1,052)
(169)
(22)
(8,098)
(72)

(24)
(114)
1,474
133
(3)
(694)
—
—
(195)
4,667

2,199
(29,613)
(8,329)
4,448
3,992
(26,151)
6,001
9,129
6,319
2,794
392
(2,334)
(124)
(1,197)
—
—
—
(231)
(32,705)

17,069
5,174
(813)
1,852
3,075
4,738
(1,046)
431
34
—
(2,686)
(901)
(175)
26
26,778
189

3,548
(1)
3,547

(11)
(108)
1,502
(126)
(75)
1,522
(350)
831
(465)
6,267

(1,225)
53,347
(6,673)
4,907
3,738
(27,470)
7,580
8,826
11,347
(1,483)
173
(1,407)
(114)
(825)
65
(42)
1
(461)
50,284

(54,738)
(5,013)
(911)
225
—
6,229
(2,953)
438
27
990
(2,398)
(778)
(122)
(46)
(59,050)
(114)

$

$

$

$

1,125
7,133
8,258 $

5,864 $
2,394
8,258 $

2,711 $
983
175

(1,071)
8,204
7,133 $

(2,613)
10,817
8,204

5,382 $
1,751
7,133 $

1,033 $
498
20

4,822
3,382
8,204

406
1,010
307

(a)  Reflects the impact of adopting new accounting guidance included in ASU 2016-15 and ASU 2016-18.  Prior periods have been restated.  See Note 2 of 

the Notes to Consolidated Financial Statements for additional information.

See accompanying Notes to Consolidated Financial Statements.

BNY Mellon 123 

The Bank of New York Mellon Corporation (and its subsidiaries)

Consolidated Statement of Changes in Equity

The Bank of New York Mellon Corporation shareholders

(in millions, except per
share amount)

Preferred
stock

Common
stock

Additional
paid-in
capital

Retained
earnings

Accumulated 
other 
comprehensive 
(loss), net 
of tax

Treasury
stock

Non-redeemable
noncontrolling
interests of
consolidated
investment
management
funds

Total
permanent
equity

Redeemable
non-
controlling
interests/
temporary
equity

$

3,542 $

14 $

26,665 $ 25,635 $

(2,357) $(12,248) $

316 $

41,567 (a) $

179

—

—

—

(55)

—

—

(55)

—

Balance at Dec. 31, 2017
Adjustment for the cumulative

effect of applying ASU
2014-09 for contract revenue
Adjustment for the cumulative

effect of applying ASU
2017-12 for derivatives and
hedging

Adjusted balance at Jan. 1,

2018

Shares issued to shareholders of

noncontrolling interests

Redemption of subsidiary shares
from noncontrolling interests

Other net changes in

noncontrolling interests

Net income (loss)
Other comprehensive (loss)
Dividends:

Common stock at $1.04 per
  share
Preferred stock

Repurchase of common stock
Common stock issued under:
Employee benefit plans
Direct stock purchase and

dividend reinvestment plan

Stock awards and options

exercised

—

—

—

3,542

—

—

—

—
—

—

—
—

—

—

—

—

14

—

—

—

—
—

—

—
—

—

—

—

—

27

(2)

—

25

26,665

25,607

(2,359)

(12,248)

316

41,537

—

—

12

—
—

—

—

—

4,266
—

—

—

—

—
(812)

— (1,052)

—

—

—

—

—
—

—

—
—

31

30

380

(169)
—

—

—

—

—
—
— (3,269)

—

—

—

—

—

—

—

—

(203)

(12)
—

—

—
—

—

—

—

—

—

(191)

4,254
(812)

(1,052)

(169)
(3,269)

31

30

380

Balance at Dec. 31, 2018

$

3,542 $

14 $

27,118 $ 28,652 $

(3,171) $(15,517) $

101 $

40,739 (a) $

(a) 

Includes total The Bank of New York Mellon Corporation common shareholders’ equity of $37,709 million at Dec. 31, 2017 and $37,096 million at Dec. 
31, 2018.

 124 BNY Mellon

—

179

61

(92)

(8)

—
(11)

—

—
—

—

—

—

129

The Bank of New York Mellon Corporation (and its subsidiaries)

Consolidated Statement of Changes in Equity (continued) 

The Bank of New York Mellon Corporation shareholders

(in millions, except per
share amount)

Preferred
stock

Common
stock

Additional
paid-in
capital

Retained
earnings

Accumulated
other
comprehensive
(loss) income,
net of tax

Treasury
stock

Non-redeemable
noncontrolling
interests of
consolidated
investment
management
funds

Total
permanent
equity

Redeemable
non-
controlling
interests/
temporary
equity

Balance at Dec. 31, 2016
Shares issued to shareholders of

noncontrolling interests

Redemption of subsidiary shares
from noncontrolling interests

Other net changes in

noncontrolling interests

Net income (loss)
Other comprehensive income
Dividends:

Common stock at $0.86 per
  share
Preferred stock

Repurchase of common stock
Common stock issued under:
Employee benefit plans
Direct stock purchase and

dividend reinvestment plan

Stock awards and options

exercised

$

3,542 $

13 $

25,962 $ 22,621 $

(3,765) $ (9,562) $

618 $

39,429 (a) $

—

—

—

—
—

—

—
—

—

—

—

—

—

—

—
—

—

—
—

—

—

1

—

—

(35)

—
—

—

—
—

28

26

684

—

—

—

4,090
—

(901)

(175)
—

—

—

—

—

—

—

—
1,408

—

—

—

—

—
—

—

—
—
— (2,686)

—

—

—

—

—

—

—

—

—   

—   

(335)

(370)

33
—

—

—
—

—

—

—

4,123   
1,408

(901)

(175)
(2,686)

28

26

685

Balance at Dec. 31, 2017

$

3,542 $

14 $

26,665 $ 25,635 $

(2,357) $(12,248) $

316 $

41,567 (a) $

151

56

(70)

36

(9)
15

—

—
—

—

—

—

179

(a) 

Includes total The Bank of New York Mellon Corporation common shareholders’ equity of $35,269 million at Dec. 31, 2016 and $37,709 million at Dec. 
31, 2017.

The Bank of New York Mellon Corporation shareholders

(in millions, except per
share amounts)

Preferred
stock

Common
stock

Additional
paid-in
capital

Retained
earnings

Accumulated
other
comprehensive
(loss) income,
net of tax

Treasury
stock

Non-redeemable
noncontrolling
interests of
consolidated
investment
management
funds

Total
permanent
equity

Redeemable
non-
controlling
interests/
temporary
equity

Balance at Dec. 31, 2015
Shares issued to shareholders of

noncontrolling interests

Redemption of subsidiary shares
from noncontrolling interests

Other net changes in

noncontrolling interests

Net income (loss)
Other comprehensive (loss)
Dividends:

Common stock at $0.72 per
  share
Preferred stock

Repurchase of common stock
Common stock issued under:
Employee benefit plans
Direct stock purchase and

dividend reinvestment plan

Preferred stock issued
Stock awards and options

exercised

$

2,552 $

13 $

25,262 $ 19,974 $

(2,600) $ (7,164) $

738 $

38,775 (a) $

—

—

—

—
—

—

—
—

—

—

990

—

—

—

—

—
—

—

—
—

—

—

—

—

—

—

(24)

—
—

—

—
—

27

21

—

676

—

—

—

3,547
—

(778)

(122)
—

—

—

—

—

—

—

—

—
(1,165)

—

—

—

—

—
—

—

—
—
— (2,398)

—

—

—

—

—

—

—

—

—

—

(130)

10
—

—

—
—

—

—

—

—

—

—

(154)

3,557
(1,165)

(778)

(122)
(2,398)

27

21

990

676

200

55

(102)

38

(9)
(31)

—

—
—

—

—

—

—

Balance at Dec. 31, 2016

$

3,542 $

13 $

25,962 $ 22,621 $

(3,765) $ (9,562) $

618 $

39,429 (a) $

151

(a) 

Includes total The Bank of New York Mellon Corporation common shareholders’ equity of $35,485 million at Dec. 31, 2015 and $35,269 million at Dec. 
31, 2016.

See accompanying unaudited Notes to Consolidated Financial Statements.

BNY Mellon 125 

Notes to Consolidated Financial Statements

Note 1–Summary of significant accounting 
and reporting policies

Use of estimates

Nature of operations

BNY Mellon is a global leader in providing a broad 
range of financial products and services in domestic 
and international markets.  Through our two principal 
businesses, Investment Management and Investment 
Services, we serve the following major classes of 
customers - institutions, corporations and high net 
worth individuals.  For institutions and corporations, 
we provide the following services:

• 
• 
• 
• 
• 
• 
• 
• 
• 
• 
• 
• 
• 

investment management;
custody;
foreign exchange;
fund services;
broker-dealer services;
securities finance;
collateral and liquidity services;
clearing services;
depositary receipts;
corporate trust;
global payments;
trade finance; and
cash management.

For individuals, we provide mutual funds, separate 
accounts, wealth management and private banking 
services.  BNY Mellon’s investment management 
businesses provide investment products in many asset 
classes and investment styles on a global basis.

Basis of presentation

The accounting and financial reporting policies of 
BNY Mellon, a global financial services company, 
conform to U.S. GAAP and prevailing industry 
practices.  

In the opinion of management, all adjustments 
necessary for a fair presentation of financial position, 
results of operations and cash flows for the periods 
presented have been made.  Certain immaterial 
reclassifications have been made to prior periods to 
place them on a basis comparable with current period 
presentation.

 126 BNY Mellon

The preparation of financial statements in conformity 
with U.S. GAAP requires management to make 
estimates based upon assumptions about future 
economic and market conditions which affect 
reported amounts and related disclosures in our 
financial statements.  Although our current estimates 
contemplate current conditions and how we expect 
them to change in the future, it is reasonably possible 
that actual conditions could be worse than anticipated 
in those estimates, which could materially affect our 
results of operations and financial condition.  
Amounts subject to estimates are items such as 
allowance for loan losses and lending-related 
commitments, fair value of financial instruments and 
derivatives, goodwill and other intangibles and 
litigation and regulatory contingencies.  Among other 
effects, such changes in estimates could result in 
future impairments of investment securities, goodwill 
and intangible assets and establishment of allowances 
for loan losses and lending-related commitments as 
well as accruals for litigation and regulatory 
contingencies.

Changes in accounting

See Note 2 for the new accounting standards adopted 
in 2018.

Effective Oct. 1, 2016, we changed the accounting 
method for the amortization of premiums and 
accretion of discounts on mortgage-backed securities 
from the prepayment method (also referred to as the 
retrospective method) to the contractual method, 
which are both acceptable methods under ASC 310, 
Receivables.  The calculation performed under the 
prepayment method was based on estimating 
principal prepayment assumptions, principally driven 
by interest rates, and estimating the remaining lives 
of securities.  This method resulted in retrospective 
adjustments each period to reflect changes in those 
estimates as if the updated estimated lives had been 
applied since the acquisition of the securities.  Under 
the contractual method, no assumption is made 
concerning prepayments.  As principal prepayments 
occur, a portion of the unamortized premium or 
discount is recorded in interest revenue such that the 
effective yield of a security remains constant 
throughout the life of the security.  

Notes to Consolidated Financial Statements (continued)

We have determined that the contractual method is 
the preferable method of accounting as it is more 
aligned with our approach to asset/liability 
management, it reduces reliance on complex 
estimates and judgments, and it is consistent with the 
method predominantly used by our peers.  The impact 
of this change was not considered material to prior 
periods and, as a result, the cumulative effect of the 
change of approximately $15 million was reflected as 
a positive adjustment to net interest revenue in the 
fourth quarter of 2016.  We estimate that net interest 
revenue for 2016 would have been higher had we 
continued to use the prepayment method, but have 
not specifically quantified the impact subsequent to 
the effective date, as the estimated amortization is 
also immaterial. 

Parent financial statements

The Parent financial statements in Note 18 include 
the accounts of the Parent; those of a wholly owned 
financing subsidiary that functions as a financing 
entity for BNY Mellon and its subsidiaries; and 
MIPA, LLC, a single-member limited liability 
company, created to hold and administer corporate-
owned life insurance.  Financial data for the Parent, 
the financing subsidiary and the single-member 
limited liability company are combined for financial 
reporting purposes because of the limited function of 
these entities and the unconditional guarantee by 
BNY Mellon of their obligations.

Acquired businesses

The income statement and balance sheet include 
results of acquired businesses accounted for under the 
acquisition method of accounting pursuant to ASC 
805, Business Combinations and equity investments 
from the dates of acquisition.  Contingent purchase 
consideration was measured at its fair value and 
recorded on the purchase date.  Any subsequent 
changes in the fair value of a contingent consideration 
liability are recorded through the income statement.

Equity method investments, including renewable 
energy investments

The consolidated financial statements include the 
accounts of BNY Mellon and its subsidiaries.  Equity 
investments of less than a majority but at least 20% 
ownership are accounted for by the equity method 
and classified as other assets.  Earnings on these 
investments are reflected in fee and other revenue as 

investment services fees, investment management and 
performance fees or investment and other income, as 
appropriate, in the period earned.  

A loss in value of an equity investment that is 
determined to be other-than-temporary is recognized 
by reducing the carrying value of the equity 
investment down to its fair value.  

Renewable energy investment projects through 
limited liability companies are accounted for using 
the equity method of accounting.  The hypothetical 
liquidation at book value (“HLBV”) methodology is 
used to determine the loss that is recognized in each 
quarter.  HLBV estimates the liquidation value at the 
beginning and end of each quarter, with the difference 
recognized as the amount of loss under the equity 
method. 

The pre-tax losses are reported in investment and 
other income section of the income statement.  The 
corresponding tax benefits and credits are recorded as 
a reduction to provision for income taxes on the 
income statement.  The pre-tax losses, tax benefits 
and credits are included in our projected annual 
effective tax rate.

See Note 7 for the amount of our renewable energy 
investments.  Below are our most significant equity 
method investments, other than the investments in 
renewable energy.

Equity method investments at Dec. 31, 2018

(dollars in millions)
CIBC Mellon
Siguler Guff

Percentage
ownership Book value
548
244

50.0% $
20.0% $

Variable interest and voting model entities

We evaluate an entity for possible consolidation in 
accordance with ASC 810, Consolidation.  We first 
determine whether or not we have variable interests 
in the entity, which are investments or other interests 
that absorb portions of an entity’s expected losses or 
receive portions of the entity’s expected returns.  Our 
variable interests may include decision-maker or 
service provider fees, direct and indirect investments 
and investments made by related parties, including 
related parties under common control.  If it is 
determined that we do not have a variable interest in 

BNY Mellon 127 

Notes to Consolidated Financial Statements (continued)

the entity, no further analysis is required and the 
entity is not consolidated. 

Restricted cash and securities

If we hold a variable interest in the entity, further 
analysis is performed to determine if the entity is a 
VIE or a voting model entity (“VME”). 

We consider the underlying facts and circumstances 
of individual entities when assessing whether or not 
an entity is a VIE.  An entity is determined to be a 
VIE if the equity investors:  

• 

• 

do not have sufficient equity at risk for the entity 
to finance its activities without additional 
subordinated financial support; or
lack one or more of the following characteristics 
of a controlling financial interest: 
• 

the power, through voting rights or similar 
rights, to direct the activities of an entity that 
most significantly impact the entity’s 
economic performance;
the obligation to absorb the expected losses 
of the entity; and
the right to receive the expected residual 
returns of the entity.

• 

• 

We reconsider and reassess whether or not we are the 
primary beneficiary of a VIE when governing 
documents or contractual arrangements are changed 
that would reallocate the obligation to absorb 
expected losses or receive expected residual returns 
between BNY Mellon and the other investors.  This 
could occur when BNY Mellon disposes of its 
variable interests in the fund, when additional 
variable interests are issued to other investors or 
when we acquire additional variable interests in the 
VIE.  

We consolidate a VIE if it is determined that we have 
a controlling financial interest in the entity.  We have 
a controlling financial interest in a VIE when we have 
both (1) the power to direct the activities of the VIE 
that most significantly impact the VIE’s economic 
performance and (2) the obligation to absorb losses or 
the right to receive benefits of the VIE that could 
potentially be significant to that VIE. 

For entities that do not meet the definition of a VIE, 
the entity is considered a VME.  We consolidate these 
entities if we can exert control over the financial and 
operating policies of an investee, which can occur if 
we have a 50% or more voting interest in the entity.

 128 BNY Mellon

Cash and securities may be segregated under federal 
and other regulatory requirements and consists of 
excess client funds held by our broker-dealer entities.  
Restricted cash is included in interest-bearing 
deposits with banks on the consolidated balance sheet 
and with cash and due from banks when reconciling 
the beginning and end-of-period balances on the 
consolidated statement of cash flows. 

Securities purchased under resale agreements and 
securities sold under repurchase agreements

Securities purchased under resale agreements and 
securities sold under repurchase agreements are 
accounted for as collateralized financings.  Generally, 
these agreements are recorded at the amounts at 
which the securities will be subsequently resold or 
repurchased, plus accrued interest.  

Securities purchased under resale agreements are 
fully collateralized with high-quality liquid securities.  
Collateral requirements are monitored and additional 
collateral is received or provided, as required.  As 
such, these transactions carry minimal credit risk and 
are not allocated an allowance for credit losses.

Where an enforceable netting agreement exists, resale 
and repurchase agreements executed with the same 
counterparty and the same maturity date are reported 
on a net basis.

Available-for-sale securities and held-to-maturity 
securities and trading securities

Securities are classified as trading, available-for-sale 
or held-to-maturity securities when they are 
purchased.  Securities are classified as available-for-
sale securities when we intend to hold the securities 
for an indefinite period of time or when the securities 
may be used for tactical asset/liability purposes and 
may be sold from time to time to effectively manage 
interest rate exposure, prepayment risk and liquidity 
needs.  Securities are classified as held-to-maturity 
securities when we intend and have the ability to hold 
them until maturity.  Securities are classified as 
trading securities when our intention is to resell the 
securities.  

Trading securities are measured at fair value and 
included in trading assets on the balance sheet.  
Trading revenue includes both realized and unrealized 

Notes to Consolidated Financial Statements (continued)

gains and losses.  The liability incurred on short-sale 
transactions, representing the obligation to deliver 
securities, is included in trading liabilities at fair 
value.

Available-for-sale securities are measured at fair 
value.  The difference between fair value and 
amortized cost representing unrealized gains or losses 
on assets classified as available-for-sale, are recorded 
net of tax as an addition to or deduction from OCI, 
unless a security is deemed to have other-than-
temporary impairment (“OTTI”).  Gains and losses 
on sales of available-for-sale securities are reported in 
the income statement.  The cost of debt and equity 
securities sold is determined on a specific 
identification and average cost method, respectively.  
Held-to-maturity securities are measured at amortized 
cost.

Income on securities purchased is adjusted for 
amortization of premium and accretion of discount on 
a level yield basis, generally over their contractual 
life.  

We routinely conduct periodic reviews to identify and 
evaluate each security to determine whether OTTI 
has occurred.  We examine various factors when 
determining whether an impairment, representing the 
fair value of a security being below its amortized 
cost, is other-than-temporary.  The following are 
examples of factors that we consider:

•  The length of time and the extent to which the 
fair value has been less than the amortized cost 
basis;

•  Whether management has an intent to sell the 

security;

•  Whether the decline in fair value is attributable to 
specific conditions, such as conditions in an 
industry or in a geographic area, affecting a 
particular investment;

•  Whether a debt security has been downgraded by 

a rating agency; 

•  Whether a debt security exhibits cash flow 

deterioration; and

•  For each non-agency RMBS, we compare the 

remaining credit enhancement that protects the 
individual security from losses against the 
projected losses of principal and/or interest 
expected to come from the underlying mortgage 
collateral, to determine whether such credit losses 
might directly impact the relevant security.

When we do not intend to sell the security and it is 
more likely than not that we will not be required to 
sell the security prior to recovery of its cost basis, the 
credit component of an OTTI of a debt security is 
recognized in earnings and the non-credit component 
is recognized in OCI.

The determination of whether a credit loss exists is 
based on the best estimate of the present value of cash 
flows to be collected from the debt security.  
Generally, cash flows are discounted at the effective 
interest rate implicit in the debt security at the time of 
acquisition.  For debt securities that are beneficial 
interests in securitized financial assets and are not 
high credit quality, ASC 325, Investments - Other, 
provides that cash flows be discounted at the current 
yield used to accrete the beneficial interest.

If we intend to sell the security or it is more likely 
than not that we will be required to sell the security 
prior to recovery of its cost basis, the non-credit 
component of OTTI is recognized in earnings and 
subsequently accreted to interest income on an 
effective yield basis over the life of the security.

For held-to-maturity debt securities, the amount of 
OTTI recorded in OCI for the non-credit portion of a 
previous OTTI is amortized prospectively, as an 
increase to the carrying amount of the security, over 
the remaining life of the security on the basis of the 
timing of future estimated cash flows of the 
securities. 

The accounting policy for the determination of the 
fair value of financial instruments has been identified 
as a “critical accounting estimate” as it requires us to 
make numerous assumptions based on available 
market data.  See Note 4 for these disclosures.

Loans and leases

Loans are reported net of any unearned income and 
deferred fees and costs.  Certain loan origination and 
upfront commitment fees, as well as certain direct 
loan origination and commitment costs, are deferred 
and amortized as a yield adjustment over the lives of 
the related loans.  Loans held for sale are carried at 
the lower of cost or fair value.

Unearned revenue on direct financing leases is 
accreted over the lives of the leases in decreasing 
amounts to provide a constant rate of return on the net 
investment in the leases.  Revenue on leveraged 

BNY Mellon 129 

Notes to Consolidated Financial Statements (continued)

leases is recognized on a basis to achieve a constant 
yield on the outstanding investment in the lease, net 
of the related deferred tax liability, in the years in 
which the net investment is positive.  Gains and 
losses on residual values of leased equipment sold are 
included in investment and other income.  
Impairment of leveraged lease residual values is 
reflected in net interest revenue.  Considering the 
nature of these leases and the number of significant 
assumptions, there is risk associated with the income 
recognition on these leases should any of the 
assumptions change materially in future periods.

A modified loan is considered a troubled debt 
restructuring (“TDR”) if the debtor is experiencing 
financial difficulties and the creditor grants a 
concession to the debtor that would not otherwise be 
considered.  A TDR may include a transfer of real 
estate or other assets from the debtor to the creditor, 
or a modification of the term of the loan.  TDRs are 
accounted for as impaired loans (see the 
Nonperforming assets policy).

Nonperforming assets

Commercial loans are placed on nonaccrual status 
when principal or interest is past due 90 days or 
more, or when there is reasonable doubt that interest 
or principal will be collected. 

When a first lien residential mortgage loan reaches 90 
days delinquent, it is subject to an impairment test 
and may be placed on nonaccrual status.  At 180 days 
delinquent, the loan is subject to further impairment 
testing.  The loan will remain on accrual status if the 
realizable value of the collateral exceeds the unpaid 
principal balance plus accrued interest.  If the loan is 
impaired, a charge-off is taken and the loan is placed 
on nonaccrual status.  At 270 days delinquent, all first 
lien mortgages are placed on nonaccrual status.  
Second lien mortgages are automatically placed on 
nonaccrual status when they reach 90 days 
delinquent.  

When a loan is placed on nonaccrual status, 
previously accrued and uncollected interest is 
reversed against current period interest revenue.  
Interest receipts on nonaccrual and impaired loans are 
recognized as interest revenue or are applied to 
principal when we believe the ultimate collectability 
of principal is in doubt.  Nonaccrual loans generally 
are restored to an accrual basis when principal and 

 130 BNY Mellon

interest become current and remain current for a 
specified period. 

A loan is considered to be impaired when it is 
probable that we will be unable to collect all principal 
and interest amounts due according to the contractual 
terms of the loan agreement.  An impairment 
allowance is measured based upon the loan’s market 
value, the present value of expected future cash 
flows, discounted at the loan’s initial effective interest 
rate, or at fair value of the collateral if the loan is 
collateral dependent.  If the loan valuation is less than 
the recorded value of the loan, an impairment 
allowance is established by a provision for credit loss.  
Impairment allowances are not needed when the 
recorded investment in an impaired loan is less than 
the loan valuation.  

Allowance for loan losses and allowance for lending-
related commitments

The allowance for loan losses, shown as a valuation 
allowance to loans, and the allowance for lending-
related commitments recorded in other liabilities, are 
referred to as BNY Mellon’s allowance for credit 
losses.  The accounting policy for the determination 
of the adequacy of the allowances has been identified 
as a “critical accounting estimate” as it requires us to 
make numerous complex and subjective estimates 
and assumptions relating to amounts which are 
inherently uncertain. 

The allowance for loan losses is maintained to absorb 
losses inherent in the loan portfolio as of the balance 
sheet date based on our judgment.  The allowance 
determination methodology is designed to provide 
procedural discipline in assessing the appropriateness 
of the allowance.  Credit losses are charged against 
the allowance.  Recoveries are added to the 
allowance. 

The methodology for determining the allowance for 
lending-related commitments considers the same 
factors as the allowance for loan losses, as well as an 
estimate of the probability of drawdown at default.  
We utilize a quantitative methodology and qualitative 
framework for determining the allowance for loan 
losses and the allowance for lending-related 
commitments.  Within this qualitative framework, 
management applies judgment when assessing 
internal risk factors and environmental factors to 
compute an additional allowance for each component 
of the loan portfolio.

Notes to Consolidated Financial Statements (continued)

The components of the allowance for loan losses and 
the allowance for lending-related commitments are 
inclusive of the qualitative allowance framework and 
consist of the following three elements: 

• 

• 

• 

an allowance for impaired credits of $1 million or 
greater;
an allowance for higher risk-rated credits and 
pass-rated credits; and 
an allowance for residential mortgage loans.

Our lending is primarily to institutional customers.  
As a result, our loans are generally larger than $1 
million.  Therefore, the first element, impaired 
credits, is based on individual analysis of all impaired 
loans of $1 million and greater.  The allowance is 
measured by the difference between the recorded 
value of impaired loans and their impaired value.  
Impaired value is either the present value of the 
expected future cash flows from the borrower, the 
market value of the loan, or the fair value of the 
collateral, if the loan is collateral dependent.

The second element, higher risk-rated credits and 
pass-rated credits, is based on our incurred loss 
model.  Individual credit analyses are performed on 
such loans before being assigned a credit rating.  All 
borrowers are collectively evaluated based on their 
credit rating.  The loss inherent in each loan 
incorporates the borrower’s credit rating, facility 
rating and maturity.  The loss given default, derived 
from the facility rating, incorporates a recovery 
expectation and an estimate of the use of the facility 
at default (usage given default).  The borrower’s 
probability of default is derived from the associated 
credit rating.  Borrower ratings are reviewed at least 
annually and are periodically mapped to third-party 
databases, including rating agency and default and 
recovery databases, to ensure ongoing consistency 
and validity.  Higher risk-rated credits are reviewed 
quarterly.

The third element, the allowance for residential 
mortgage loans, is determined by segregating six 
mortgage pools into delinquency periods ranging 
from current through foreclosure.  Each of these 
delinquency periods is assigned a probability of 
default.  A specific loss given default is assigned for 
each mortgage pool.  BNY Mellon assigns all 
residential mortgage pools, except home equity lines 
of credit, a probability of default and loss given 
default based on default and loss data derived from 
internal historical data related to our residential 

mortgage portfolio.  The resulting incurred loss factor 
(the probability of default multiplied by the loss given 
default) is applied against the loan balance to 
determine the allowance held for each pool.  For 
home equity lines of credit, probability of default and 
loss given default are based on external data from 
third-party databases due to the small size of the 
portfolio and insufficient internal data.

The qualitative framework is used to determine an 
additional allowance for each portfolio based on the 
factors below:

Internal risk factors:

•  Ratio of nonperforming loans to total non-margin 

loans; 

•  Ratio of criticized assets to total loans and 

lending-related commitments; 

•  Borrower concentration; and 
•  Significant concentrations in high risk industries 

and countries.

Environmental risk factors:

•  U.S. non-investment grade default rate; 
•  Unemployment rate; and 
•  Change in real gross domestic product.

The objective of the qualitative framework is to 
capture incurred losses that may not have been fully 
captured in the quantitative reserve, which is based 
primarily on historical data.  Management determines 
the qualitative allowance for each period based on 
judgment informed by consideration of internal and 
external risk factors and other considerations that 
may be deemed relevant during the period.  Once 
determined in the aggregate, our qualitative 
allowance is then allocated to each of our loan classes 
based on the respective classes’ quantitative 
allowance balances with the allocations adjusted, 
when necessary, for class specific risk factors.  

For each risk factor, we calculate the minimum and 
maximum values, and percentiles in-between, to 
evaluate the distribution of our historical experience.  
The distribution of historical experience is compared 
to the risk factor’s current quarter observed 
experience to assess the current risk inherent in the 
portfolio and overall direction/trend of a risk factor 
relative to our historical experience.  

Based on this analysis, we assign a risk level - no 
impact, low, moderate, high and elevated - to each 

BNY Mellon 131 

Notes to Consolidated Financial Statements (continued)

risk factor for the current quarter.  Management 
assesses the impact of each risk factor to determine 
an aggregate risk level.  We do not quantify the 
impact of any particular risk factor.  Management’s 
assessment of the risk factors, as well as the trend in 
the quantitative allowance, supports management’s 
judgment for the overall required qualitative 
allowance.  A smaller qualitative allowance may be 
required when our quantitative allowance has 
reflected incurred losses associated with the 
aggregate risk level.  A greater qualitative allowance 
may be required if our quantitative allowance does 
not yet reflect the incurred losses associated with the 
aggregate risk level.

The allocation of the allowance for credit losses is 
inherently judgmental, and the entire allowance for 
credit losses is available to absorb credit losses 
regardless of the nature of the loss. 

Premises and equipment

Premises and equipment are carried at cost less 
accumulated depreciation and amortization.  
Depreciation and amortization is computed using the 
straight-line method over the estimated useful life of 
the owned asset and, for leasehold improvements, 
over the lesser of the remaining term of the leased 
facility or the estimated economic life of the 
improvement.  For owned and capitalized assets, 
estimated useful lives range from 2 to 40 years.  
Maintenance and repairs are charged to expense as 
incurred, while major improvements are capitalized 
and amortized to operating expense over their 
identified useful lives. 

Software

BNY Mellon capitalizes costs relating to acquired 
software and internal-use software development 
projects that provide new or significantly improved 
functionality.  We capitalize projects that are expected 
to result in longer-term operational benefits, such as 
replacement systems or new applications that result in 
significantly increased operational efficiencies or 
functionality.  All other costs incurred in connection 
with an internal-use software project are expensed as 
incurred.  Capitalized software is recorded in other 
assets.

 132 BNY Mellon

Identified intangible assets and goodwill

Identified intangible assets with estimable lives are 
amortized in a pattern consistent with the assets’ 
identifiable cash flows or using a straight-line method 
over their remaining estimated benefit periods if the 
pattern of cash flows is not estimable.  Intangible 
assets with estimable lives are reviewed for possible 
impairment when events or changed circumstances 
may affect the underlying basis of the asset.  
Goodwill and intangibles with indefinite lives are not 
amortized, but are assessed annually for impairment, 
or more often if events and circumstances indicate it 
is more likely than not they may be impaired and to 
determine if the lives are no longer indefinite and 
should be amortized.  The amount of goodwill 
impairment is determined by the excess of the 
carrying value of the reporting unit over its fair value.  
The accounting policy for valuing and impairment 
testing of identified intangible assets and goodwill 
has been identified as a “critical accounting estimate” 
as it requires us to make numerous complex and 
subjective estimates.  See Note 6 for additional 
disclosures related to goodwill and intangible assets.

Investments in qualified affordable housing projects

Investments in qualified affordable housing projects 
through a limited liability entity are accounted for 
utilizing the proportional amortization method.  
Under the proportional amortization method, the 
initial cost of the investment is amortized to the 
provision for income taxes in proportion to the tax 
credits and other tax benefits received.  The net 
investment performance, including tax credits and 
other benefits received, is recognized in the income 
statement as a component of income tax expense.  
Additionally, the value of the commitments to fund 
qualified affordable housing projects is included in 
other assets on the balance sheet and a liability is 
recorded for the unfunded portion.

Seed capital

Seed capital investments are generally classified as 
other assets and carried at fair value.  Unrealized 
gains and losses on seed capital investments are 
recorded in investment and other income.  Certain 
risk retention investments in our collateralized loan 
obligations (“CLOs”) are classified as available-for-
sale securities.  Any unrealized gains and losses are 
recorded net of tax as an addition to or deduction 

Notes to Consolidated Financial Statements (continued)

from other comprehensive income, unless the 
investment is deemed to have OTTI.

Noncontrolling interests

Noncontrolling interests included in permanent equity 
are adjusted for the income or (loss) attributable to 
the noncontrolling interest holders and any 
distributions to those shareholders.  Redeemable 
noncontrolling interests are reported as temporary 
equity.  BNY Mellon recognizes changes in the 
redemption value of the redeemable noncontrolling 
interests as they occur and adjusts the carrying value 
to be equal to the redemption value.

Fee revenue

Investment Services and Investment Management 
revenue is based on terms specified in a contract with 
a customer, and excludes any amounts collected on 
behalf of third parties.  Revenue is recognized when, 
or as, a performance obligation is satisfied by 
transferring control of a good or service to a 
customer.  A performance obligation may be satisfied 
over time or at a point in time.  Revenue from a 
performance obligation satisfied over time is 
recognized by measuring our progress in satisfying 
the performance obligation in a manner that reflects 
the transfer of goods and services to the customer.  
Revenue from a performance obligation satisfied at a 
point in time is recognized at the point in time the 
customer obtains control of the promised good or 
service.  The amount of revenue recognized reflects 
the consideration we expect to be entitled to in 
exchange for the promised goods and services.  Taxes 
assessed by a governmental authority, that are both 
imposed on, and concurrent with, a specific revenue-
producing transaction, are collected from a customer 
and are excluded from revenue. 

Performance fees are recognized in the period in 
which the performance fees are earned and become 
determinable.  Performance fees are constrained until 
all uncertainties are resolved and reversal of 
previously recorded amounts is not probable.  
Performance fees are generally calculated as a 
percentage of the applicable portfolio’s performance 
in excess of a benchmark index or a peer group’s 
performance.  When a portfolio underperforms its 
benchmark or fails to generate positive performance, 
subsequent years’ performance must generally exceed 
this shortfall prior to fees being earned.  Amounts 
billable, which are subject to a clawback if future 

performance thresholds in current or future years are 
not met, are not recognized since the fees are 
potentially uncollectible.  These fees are recognized 
when it is determined that they will be collected.  
When a multi-year performance contract provides 
that fees earned are billed ratably over the 
performance period, only the portion of the fees 
earned that are non-refundable are recognized.

Additionally, we recognize revenue from non-
refundable, implementation fees under outsourcing 
contracts using a straight-line method, commencing 
in the period the ongoing services are performed 
through the expected term of the contractual 
relationship.  Incremental direct set-up costs of 
implementation, up to the related customer margin or 
minimum fee revenue amount, are deferred and 
amortized over the same period that the related 
implementation fees are recognized.  If a client 
terminates an outsourcing contract prematurely, the 
unamortized deferred incremental direct set-up costs 
and the unamortized deferred implementation fees 
related to that contract are recognized in the period 
the contract is terminated.

We record foreign exchange and other trading 
revenue, financing-related fees and other revenue 
when the services are provided and earned based on 
contractual terms, when amounts are determined and 
collectability is reasonably assured.

Net interest revenue

Revenue on interest-earning assets and expense on 
interest-bearing liabilities are recognized based on the 
effective yield of the related financial instrument.  
The amortization of premiums and accretion of 
discounts are included in interest revenue and are 
adjusted for prepayments when they occur, such that, 
the effective yield remains constant throughout the 
contractual life of the security.  Negative interest 
incurred on assets or charged on liabilities is 
presented as contra interest income and contra 
expense, respectively.

Foreign currency translation

Assets and liabilities denominated in foreign 
currencies are translated to U.S. dollars at the rate of 
exchange on the balance sheet date.  Transaction 
gains and losses are included in the income statement.  
Translation gains and losses on investments in foreign 
entities with functional currencies that are not the 

BNY Mellon 133 

Notes to Consolidated Financial Statements (continued)

U.S. dollar are recorded as foreign currency 
translation adjustments in OCI.  Revenue and expense 
transactions are translated at the applicable daily rate 
or the weighted average monthly exchange rate when 
applying the daily rate is not practical.  

Pension

The measurement date for BNY Mellon’s pension 
plans is December 31.  Plan assets are determined 
based on fair value generally representing observable 
market prices.  The projected benefit obligation is 
determined based on the present value of projected 
benefit distributions at an assumed discount rate.  The 
discount rate utilized is based on the yield curves of 
high-quality corporate bonds available in the 
marketplace.  The net periodic pension expense or 
credit includes service costs (if applicable), interest 
costs based on an assumed discount rate, an expected 
return on plan assets based on an actuarially derived 
market-related value, amortization of prior service 
cost and amortization of prior years’ actuarial gains 
and losses.

Actuarial gains and losses include gains or losses 
related to changes in the amount of the projected 
benefit obligation or plan assets resulting from 
demographic or investment experience different than 
assumed, changes in the discount rate or other 
assumptions.  To the extent an actuarial gain or loss 
exceeds 10% of the greater of the projected benefit 
obligation or the market-related value of plan assets, 
the excess is generally recognized over the future 
service periods of active employees.  Benefit accruals 
under the U.S. pension plans are frozen.  Future 
unrecognized actuarial gains and losses for the U.S. 
plans that exceed a threshold amount are amortized 
over the average future life expectancy of plan 
participants with a maximum of 15 years.

Our expected long-term rate of return on plan assets 
is based on anticipated returns for each applicable 
asset class.  Anticipated returns are weighted for the 
expected allocation for each asset class and are based 
on forecasts for prospective returns in the equity and 
fixed-income markets, which should track the long-
term historical returns for these markets.  We also 
consider the growth outlook for U.S. and global 
economies, as well as current and prospective interest 
rates.

value of plan assets adjusted for the difference 
between expected returns and actual performance of 
plan assets.  The difference between actual experience 
and expected returns on plan assets is included as an 
adjustment in the market-related value over a five-
year period.

See Note 17 for additional disclosures related to 
pensions.

Severance

BNY Mellon provides separation benefits for U.S.-
based employees through The Bank of New York 
Mellon Corporation Supplemental Unemployment 
Benefit Plan.  These benefits are provided to eligible 
employees separated from their jobs for business 
reasons not related to individual performance.  Basic 
separation benefits are generally based on the 
employee’s years of continuous benefited service.  
Severance for employees based outside of the U.S. is 
determined in accordance with local agreements and 
legal requirements.  Severance expense is recorded 
when management commits to an action that will 
result in separation and the amount of the liability can 
be reasonably estimated.

Income taxes

We record current tax liabilities or assets through 
charges or credits to the current tax provision for the 
estimated taxes payable or refundable for the current 
year.  Deferred tax assets and liabilities are recorded 
for future tax consequences attributable to differences 
between the financial statement carrying amounts of 
assets and liabilities and their respective tax bases.  
Deferred tax assets and liabilities are measured using 
enacted tax rates expected to apply to taxable income 
in the years in which those temporary differences are 
expected to be recovered or settled.  A deferred tax 
valuation allowance is established if it is more likely 
than not that all or a portion of the deferred tax assets 
will not be realized.  A tax position that fails to meet a 
more-likely-than-not recognition threshold will result 
in either reduction of current or deferred tax assets, 
and/or recording of current or deferred tax liabilities.  
Interest and penalties related to income taxes are 
recorded as income tax expense.  

Derivative financial instruments

The market-related value utilized to determine the 
expected return on plan assets is based on the fair 

Derivatives are recorded on the balance sheet at fair 
value and include futures, forwards, interest rate 

 134 BNY Mellon

Notes to Consolidated Financial Statements (continued)

swaps, foreign currency swaps and options and 
similar products.  Derivatives in an unrealized gain 
position are recognized as assets while derivatives in 
unrealized loss position are recognized as liabilities.  
Derivatives are reported net by counterparty and after 
consideration of cash collateral, to the extent subject 
to legally enforceable netting agreements.  
Derivatives designated and effective in qualifying 
hedging relationships are classified in other assets or 
other liabilities on the balance sheet.  All other 
derivatives are classified within trading assets or 
trading liabilities on the balance sheet.  Gains and 
losses on trading derivatives are generally included in 
foreign exchange and other trading revenue.

We enter into various derivative financial instruments 
for non-trading purposes primarily as part of our 
asset/liability management process.  These 
derivatives are designated as either fair value or cash 
flow hedges of certain assets and liabilities or 
forecasted transactions when we enter into the 
derivative contracts.  Gains and losses associated with 
fair value hedges are recorded in income as well as 
any change in the value of the related hedged item 
associated with the designated risks being hedged.  
Gains and losses on cash flow hedges are recorded in 
OCI, until reclassified into earnings in the same 
period the hedged item impacts earnings.  Foreign 
currency transaction gains and losses related to a 
hedged net investment in a foreign operation, net of 
their tax effect, are recorded with cumulative foreign 
currency translation adjustments within OCI.

To qualify for hedge accounting each hedge 
relationship is required to be highly effective at 
reducing the risk associated with the exposure being 
hedged, both prospectively and retrospectively.  We 
formally document all relationships between hedging 
instruments and hedged items, as well as our risk-
management objectives and strategy for undertaking 
various hedging transactions.  At inception, the 
potential cause of ineffectiveness related to each of 
our hedges is assessed to determine if we can expect 
the hedge to be highly effective over the life of the 
transaction.  At hedge inception, we document the 
methodology to be utilized for evaluating 
effectiveness on an ongoing basis, and we monitor 
ongoing hedge effectiveness at least quarterly.

For qualifying fair value hedges, changes in the fair 
value of the derivative, and changes in the value of 
the hedged item associated with the designated risks 
being hedged, are recognized in earnings.  Certain 

amounts excluded from the assessment of 
effectiveness are recorded in OCI and recognized in 
earnings through an amortization approach over the 
life of the derivative.  We discontinue hedge 
accounting prospectively when we determine that the 
hedge is no longer effective or the derivative expires, 
is sold, or management discontinues the derivative’s 
hedge designation.  Subsequent gains and losses on 
these derivatives are included in foreign exchange 
and other trading revenue.  For discontinued fair 
value hedges, the accumulated gain or loss on the 
hedged item is amortized on a yield basis over the 
remaining life of the hedged item. 

For qualifying cash flow hedges, changes in the fair 
value of the derivative are recorded in OCI, until 
reclassified into earnings in the same period the 
hedged item impacts earnings.  If the hedge 
relationship is terminated, then the change in value 
will be reclassified from OCI to earnings when the 
cash flows that were previously hedged affect 
earnings.  If cash flow hedge accounting is 
discontinued as a result of a forecasted transaction no 
longer being probable to occur, then the amount 
reported in OCI is immediately reclassified to current 
earnings.

Derivative amounts affecting earnings are recognized 
in the same income statement line as the hedged item 
affects earnings, principally interest income, interest 
expense and other revenue.  

Foreign currency transaction gains and losses related 
to qualifying hedges of net investments in a foreign 
operation are recorded with cumulative foreign 
currency translation adjustments within OCI net of 
their tax effect.  The Company evaluates effectiveness 
of its foreign currency derivatives designated as 
hedges of its net investments utilizing the forward 
rate method.

The determination of fair value of derivative financial 
instruments has been identified as a “critical 
accounting estimate.”  See Note 22 for additional 
disclosures related to derivative financial instruments.

Earnings per common share

Earnings per common share is calculated using the 
two-class method under which earnings are allocated 
to common shareholders and holders of participating 
securities.  Unvested stock-based compensation 
awards that contain non-forfeitable rights to 

BNY Mellon 135 

Notes to Consolidated Financial Statements (continued)

dividends or dividend equivalents are considered 
participating securities under the two-class method. 

Note 2–Accounting changes and new 
accounting guidance

The following accounting changes and new 
accounting guidance were adopted in 2018.  

ASU 2017-12, Derivatives and Hedging: Targeted 
Improvements to Accounting for Hedging Activities 

In August 2017, the FASB issued an ASU, 
Derivatives and Hedging: Targeted Improvements to 
Accounting for Hedging Activities.  The objective of 
this ASU is to improve the financial reporting of 
hedging relationships to better portray the economic 
results of an entity’s risk management activities and 
to simplify the application of hedge accounting 
guidance. 

The most significant impact of the new guidance to 
the Company relates to the new accounting 
alternatives for fair value hedges of interest rate risk, 
specifically, the ability to hedge only the benchmark 
component of the contractual cash flows and partial-
term hedging.  The guidance also changed 
presentation and disclosure requirements and made 
changes to how the shortcut method is applied, which 
resulted in the Company using that method going 
forward for certain hedging relationships. 

BNY Mellon elected to early adopt this ASU on Jan. 
31, 2018, which is the “as of” date for which the 
Company was permitted to make certain elections 
and the measurement date for recording the adoption 
impact for certain hedge modifications.  As part of the 
adoption, we elected to reclassify approximately $1.1 
billion of debt securities from held-to-maturity to 
available-for-sale which resulted in a decrease of $47 
million pre-tax to accumulated other comprehensive 
income.  The Company also elected to modify certain 
hedge relationships as of the adoption date primarily 
to utilize the benchmark component method of 
measuring hedge effectiveness, as such method is 
deemed to more closely match risk management 
objectives with accounting results.  The Company 
recognized a $27 million after-tax increase in retained 
earnings as of Jan. 1, 2018 associated with the 
adoption impact of these hedge modifications.

Basic earnings per share is calculated by dividing net 
income allocated to common shareholders of BNY 
Mellon by the average number of common shares 
outstanding and vested stock-based compensation 
awards where recipients have satisfied either the 
explicit vesting terms or retirement-eligibility 
requirements.

Diluted earnings per common share is computed 
under the more dilutive of either the treasury stock 
method or the two-class method.  We increase the 
average number of shares of common stock 
outstanding by the assumed number of shares of 
common stock that would be issued assuming the 
exercise of stock options and the issuance of shares 
related to stock-based compensation awards using the 
treasury stock method, if dilutive.  Diluted earnings 
per share is calculated by dividing net income 
allocated to common shareholders of BNY Mellon by 
the adjusted average number of common shares 
outstanding.

Statement of cash flows

We have defined cash as cash and due from banks.  
Cash flows from hedging activities are classified in 
the same category as the items hedged.  Distributions 
received from equity method investees are classified 
as cash inflows from operating activities on the 
consolidated statement of cash flows.  Excess returns 
on investments of equity method investments are 
classified as cash flows from investing activities on 
the consolidated statement of cash flows. 

Stock-based compensation

Compensation expense relating to share-based 
payments is recognized in the income statement, on a 
straight-line basis, over the applicable vesting period.

Certain of our stock compensation grants vest when 
the employee retires.  New grants with this feature are 
expensed by the first date the employee is eligible to 
retire.  We estimate forfeitures when recording 
compensation cost related to share-based payment 
awards.

 136 BNY Mellon

Notes to Consolidated Financial Statements (continued)

ASU 2017-07, Compensation - Retirement Benefits: 
Improving the Presentation of Net Periodic Pension 
Cost and Net Periodic Postretirement Benefit Cost 

ASU 2016-15, Statement of Cash Flows: 
Classification of Certain Cash Receipts and Cash 
Payments 

In March 2017, the FASB issued an ASU, 
Compensation - Retirement Benefits: Improving the 
Presentation of Net Periodic Pension Cost and Net 
Periodic Postretirement Benefit Cost.  This ASU 
requires the disaggregation of the service cost 
component from the other components of the net 
benefit cost in the consolidated income statement.  
This ASU also permits only the service cost 
component of net benefit cost to be eligible for 
capitalization.  BNY Mellon adopted this ASU in the 
first quarter of 2018, and applied the guidance 
retrospectively for the presentation of the service cost 
component and the other components in the 
consolidated income statement, and prospectively for 
the capitalization of the service cost component in 
assets.  The adoption of this standard increased staff 
expense and decreased other expense by $62 million 
in 2017 and $75 million in 2016.

ASU 2016-18, Statement of Cash Flows: Restricted 
Cash 

In November 2016, the FASB issued an ASU, 
Statement of Cash Flows: Restricted Cash.  This ASU 
provides guidance on the presentation of restricted 
cash or restricted cash equivalents in the consolidated 
statement of cash flows.  Restricted cash consists of 
excess client funds held by our broker-dealer business 
and totaled $2.4 billion at Dec. 31, 2018 and $1.8 
billion at Dec. 31, 2017.  Restricted cash is included 
in interest-bearing deposits with banks on the 
consolidated balance sheet and with cash and due 
from banks when reconciling the beginning and end-
of-period balances on the consolidated statement of 
cash flows.  

We adopted the guidance in this ASU retrospectively.  
As a result, the change in interest-bearing deposits 
with banks, which is included in investing activities 
on the consolidated statement of cash flows, was 
restated to reflect the decrease in restricted cash of 
$1,631 million in 2017 and $898 million in 2016.  
The increase in restricted cash was $643 million in 
2018.

In August 2016, the FASB issued an ASU, Statement 
of Cash Flows: Classification of Certain Cash 
Receipts and Cash Payments.  This ASU provides 
guidance on eight specific cash flow presentation 
issues.  The most significant impact for BNY Mellon 
relates to distributions received from equity method 
investees.  For equity method investments, BNY 
Mellon elected to report distributions received from 
equity method investees using the cumulative 
earnings approach.  Distributions received are 
considered returns on investment and classified as 
cash inflows from operating activities on the 
consolidated statement of cash flows.  To the extent 
the returns on investment exceeded the cumulative 
equity in earnings recognized, the excess would be 
considered a return of investment and classified as 
cash inflows from investing activities on the 
consolidated statement of cash flows.  We adopted the 
guidance in this ASU retrospectively.  As a result, the 
change in accruals and other, net, which is included in 
operating activities on the consolidated statement of 
cash flows, was restated to reflect distributions 
received of $24 million in 2017 and $17 million in 
2016.  The distributions were previously included in 
other, net in investing activities on the consolidated 
statement of cash flows.  Distributions received in 
2018 were $24 million.  The remaining seven specific 
cash flow presentation issues do not materially 
impact BNY Mellon.

ASU 2014-09, Revenue from Contracts with 
Customers 

In May 2014, the FASB issued an ASU, Revenue 
from Contracts with Customers.  This ASU, as 
amended, provides guidance on the recognition of 
revenue related to the transfer of promised goods or 
services to customers and guidance on accounting for 
certain contract costs.  The standard provides a single 
revenue model to be applied by reporting companies 
under U.S. GAAP and supersedes most existing 
revenue recognition guidance.  

The Company adopted the guidance on Jan. 1, 2018 
using the cumulative effect transition method applied 
to contracts not completed as of Dec. 31, 2017, which 
resulted in a $55 million after-tax reduction to 
retained earnings.  The comparative financial 
information for 2017 and 2016 has not been restated 

BNY Mellon 137 

Notes to Consolidated Financial Statements (continued)

and continues to be reported under the accounting 
standards in effect for that period.  

Although the impact of the adoption of this ASU was 
not material, the most significant changes and 
quantitative impact of the changes are disclosed 
below.

Payments to customers

The timing of recognizing the reduction in revenue 
for certain payments made to depositary receipts 
customers has changed.  Prior to adoption, annual 
payments to customers were capitalized and 
amortized as contra revenue over the remaining 
contract period, subject to impairment reviews.  

Under the new guidance, annual payments are 
recorded as a reduction in revenue in proportion to 
the expected annual revenue generated from the 
related customer contract.  

Costs to obtain a customer contract

Prior to adoption, costs to obtain a customer contract, 
primarily sales incentives, were expensed as incurred.  
Under the new guidance, an asset is recognized for 
the incremental sales incentives that are considered 
costs of obtaining a contract with a customer, if those 
costs are expected to be recovered.

The table below presents the cumulative effect of the 
adoption of the new guidance on the consolidated 
balance sheet as of Dec. 31, 2017.

Impact on the consolidated balance sheet

(in millions)
Assets
Other assets

Liabilities
Accrued tax and other
expenses
Other liabilities

Equity
Retained earnings

Dec. 31,
2017

Impact of 
adoption

Jan. 1,
2018

$

23,029 $

(9) $

23,020

$

6,225 $
6,050

(18) $
64

6,207
6,114

$

25,635 $

(55) $

25,580

The impact of the new guidance on the consolidated 
income statement for 2018 and the consolidated 
balance sheet as of Dec. 31, 2018 was de minimis.  
See Note 9 for additional revenue and contract costs 
disclosures.

 138 BNY Mellon

ASU 2016-01, Financial Instruments - Overall: 
Recognition and Measurement of Financial Assets 
and Financial Liabilities 

In January 2016, the FASB issued an ASU, Financial 
Instruments—Overall: Recognition and Measurement 
of Financial Assets and Financial Liabilities.  This 
ASU requires investments in equity securities that do 
not result in consolidation and are not accounted for 
under the equity method to be measured at fair value 
with changes in the fair value recognized through net 
income, unless one of two available exceptions 
applies.  The first exception, a scope exception, 
allows Federal Reserve Bank stock, FHLB stock and 
exchange memberships to remain accounted for at 
cost, less impairment.  The second practicability 
exception is an election available for equity 
investments that do not have readily determinable fair 
values.  For certain investments where the Company 
has chosen the practicability exception, such 
investments are accounted for at cost adjusted for 
impairment, if any, plus or minus observable price 
changes.

The Company adopted this guidance in the first 
quarter of 2018 using the cumulative effect method of 
adoption, with a de minimis impact to retained 
earnings.  As part of the adoption, we reclassified 
money market fund investments of approximately $1 
billion to trading assets, primarily from available-for-
sale securities. 

We have non-readily marketable equity securities 
where we are utilizing the practicability exception of 
$55 million at Dec. 31, 2018.  We recognized $27 
million of net upward adjustments on these securities 
in 2018, driven by activity that resulted in observable 
price changes. 

ASU 2018-13, Fair Value Measurement: Disclosure 
Framework - Changes to the Disclosure 
Requirements for Fair Value Measurement 

In August 2018, the FASB issued an ASU, Fair Value 
Measurement: Disclosure Framework - Changes to 
the Disclosure Requirements for Fair Value 
Measurement.  This ASU requires disclosure of the 
changes in unrealized gains or losses included in OCI 
for Level 3 assets or liabilities held at the end of the 
period and the range and weighted-average of the 
significant unobservable inputs used in determining 
the fair value of Level 3 assets and liabilities.  This 
ASU removes the requirement to disclose the 

Notes to Consolidated Financial Statements (continued)

transfers between Level 1 and Level 2 of the fair 
value hierarchy and the valuation process for 
determining Level 3 fair value measurements.  BNY 
Mellon adopted this ASU in the third quarter of 2018 
and applied the guidance prospectively for the new 
disclosure requirements and retrospectively for 
disclosure requirements that have been removed. 

ASU 2018-14, Compensation - Retirement Benefits - 
Defined Benefit Plans - General: Disclosure 
Framework - Changes to the Disclosure 
Requirements for Defined Benefit Plans

In August 2018, the FASB issued an ASU, 
Compensation - Retirement Benefits - Defined Benefit 
Plans - General: Disclosure Framework - Changes to 
the Disclosure Requirements for Defined Benefit 
Plans.  This ASU added the requirement to disclose 
the weighted-average interest crediting rates for cash 
balance plans and an explanation of the reasons for 
significant gains and losses related to changes in the 
benefit obligation for the period.  This ASU clarified 
the requirement to disclose the projected benefit 
obligation (“PBO”) and fair value of plan assets for 
plans with PBOs in excess of plan assets, and the 
accumulated benefit obligation (“ABO”) and fair 
value of plan assets for plans with ABOs in excess of 
plan assets.  Additionally, this ASU removed the 
requirement to disclose the amounts in accumulated 
OCI expected to be recognized as components of net 
periodic benefit cost over the next year and the 
sensitivity analysis of changes in the assumed health 
care cost trend rate.  BNY Mellon early adopted this 
ASU in the fourth quarter of 2018 and applied the 
guidance retrospectively. 

Note 3–Acquisitions and dispositions

We sometimes structure our acquisitions with both an 
initial payment and later contingent payments tied to 
post-closing revenue or income growth.  There were 
no contingent payments in 2018.

At Dec. 31, 2018, we are potentially obligated to pay 
additional consideration which, using reasonable 
assumptions, could range from $4 million to $21 
million over the next three years, but could be higher 
as certain of the arrangements do not contain a 
contractual maximum.  

The transactions described below did not have a 
material impact on BNY Mellon’s results of 
operations. 

Transactions in 2018

On Jan. 2, 2018, BNY Mellon completed the sale of 
CenterSquare, one of our Investment Management 
boutiques, and recorded a gain on this transaction.  
CenterSquare had approximately $10 billion in AUM 
in U.S. and global real estate and infrastructure 
investments.  In addition, goodwill of $52 million 
was removed from the consolidated balance sheet as a 
result of this sale. 

On June 29, 2018, BNY Mellon completed the 
exchange of its majority equity interest in Amherst 
Capital Management LLC for a minority equity stake 
in Amherst Holdings LLC.  Goodwill of $13 million 
was removed from the consolidated balance sheet and 
a gain was recorded as a result of this sale. 

Transactions in 2016

On April 1, 2016, BNY Mellon acquired the assets of 
Atherton Lane Advisers, LLC, a U.S.-based 
investment manager with approximately $2.45 billion 
in AUM and servicer for approximately 700 high-net-
worth clients, for cash of $38 million, plus contingent 
payments measured at $22 million.  Goodwill related 
to this acquisition totaled $29 million and is included 
in the Investment Management business.  The 
customer relationship intangible asset related to this 
acquisition is included in the Investment Management 
business, with an estimated life of 14 years, and 
totaled $30 million at acquisition.

BNY Mellon 139 

Notes to Consolidated Financial Statements (continued)

Note 4–Securities

Securities at Dec. 31, 2017

Amortized
cost

Gross
unrealized

Gains Losses

Fair
value

$

$

$

24,002 $ 108 $ 291 $ 23,819
15,263
15,159

160

264

12,405

8,793

2,949

2,898
2,520
2,085
1,265

1,360

1,249
1,040
917
152
1,409
963

175

36

31

12
18
5
317

6

17
3
1
3
4
—

23

67

23

1
9
11
4

6

11
—
10
6
1
—

12,557

8,762

2,957

2,909
2,529
2,079
1,578

1,360

1,255
1,043
908
149
1,412
963

79,166 $1,000 $ 623 $ 79,543

26,208 $
9,792
1,653

1,593

1,324
84
65
57
28

17

6

51 $ 332 $ 25,927
9,742
1,641

56
12

6
—

30

2
2
—
5
—

—

—

—

9
—
1
—
—

1

—

1,623

1,317
86
64
62
28

16

6

(in millions)
Available-for-sale:
Agency RMBS
U.S. Treasury
Sovereign debt/sovereign

guaranteed

Agency commercial MBS
State and political

subdivisions

CLOs
Foreign covered bonds
Supranational
Non-agency RMBS (a)
Non-agency commercial

MBS

Corporate bonds
Other ABS
U.S. government agencies
Other RMBS
Other debt securities
Money market funds
Total securities 

available-for-sale (b)

Held-to-maturity:
Agency RMBS
U.S. Treasury
U.S. government agencies
Sovereign debt/sovereign

guaranteed

Agency commercial MBS
Foreign covered bonds
Other RMBS
Non-agency RMBS
Supranational
State and political

subdivisions

Non-agency commercial

MBS
Total securities held-to-

(a) 

(b) 

$

40,827 $

96 $ 411 $ 40,512

maturity
Total securities
$ 119,993 $1,096 $1,034 $ 120,055
Includes $1,091 million that was included in the former Grantor 
Trust. 
Includes gross unrealized gains of $50 million and gross 
unrealized losses of $144 million recorded in accumulated other 
comprehensive income related to securities that were transferred 
from available-for-sale to held-to-maturity.  The unrealized 
gains and losses are primarily related to Agency RMBS and will 
be amortized into net interest revenue over the contractual lives 
of the securities.

The following tables present the amortized cost, the 
gross unrealized gains and losses and the fair value of 
securities at Dec. 31, 2018, Dec. 31, 2017 and Dec. 
31, 2016, respectively.

Securities at Dec. 31, 2018

(in millions)
Available-for-sale:
Agency RMBS
U.S. Treasury
Sovereign debt/sovereign

guaranteed

Agency commercial MBS
CLOs
Supranational
Foreign covered bonds
State and political

subdivisions

Other ABS
U.S. government

agencies

Non-agency commercial

MBS

Non-agency RMBS (a)
Corporate bonds
Other debt securities
Total securities 

available-for-sale (b)

Held-to-maturity:
Agency RMBS
U.S. Treasury
U.S. government

agencies

Agency commercial MBS
Sovereign debt/sovereign

guaranteed

Non-agency RMBS
Foreign covered bonds
Supranational
State and political

subdivisions
Total securities held-to-

Amortized
cost

Gross
unrealized

Gains Losses

Fair
value

$

25,594 $
20,190

83 $ 369 $ 25,308
20,076
96

210

10,663
9,836
3,410
2,985
2,890

2,251
1,776

1,676

1,491
1,095
1,074
1,236

108
16
—
7
7

18
1

5

1
241
6
6

21
161
46
8
19

22
4

24

28
11
26
4

10,750
9,691
3,364
2,984
2,878

2,247
1,773

1,657

1,464
1,325
1,054
1,238

86,167 $ 595 $ 953 $ 85,809

25,507 $
4,727

1,497
1,195

833
100
80
26

17

32 $ 632 $ 24,907
4,653

77

3

—
—

26
4
1
1

—

10
26

—
2
—
—

—

1,487
1,169

859
102
81
27

17

$

$

(a) 

(b) 

33,982 $

$
67 $ 747 $ 33,302
maturity
$ 120,149 $ 662 $1,700 $ 119,111
Total securities
Includes $832 million that was included in the former Grantor 
Trust.
Includes gross unrealized gains of $39 million and gross 
unrealized losses of $87 million recorded in accumulated other 
comprehensive income related to securities that were transferred 
from available-for-sale to held-to-maturity.  The unrealized 
gains and losses are primarily related to Agency RMBS and will 
be amortized into net interest revenue over the contractual lives 
of the securities.

 140 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Amortized
cost

Gross
unrealized

Gains Losses

Fair
value

The following table presents the realized gains, losses 
and impairments, on a gross basis.

Securities at Dec. 31, 2016

(in millions)
Available-for-sale:
Agency RMBS
U.S. Treasury
Sovereign debt/sovereign

guaranteed

Agency commercial MBS
State and political

subdivisions

CLOs
Foreign covered bonds
Non-agency RMBS (a)
Other ABS
Corporate bonds
Non-agency commercial

MBS

Other RMBS
U.S. government agencies
Other debt securities
Equity securities
Money market funds
Total securities 

available-for-sale (b)

Held-to-maturity:
Agency RMBS
U.S. Treasury
Sovereign debt/sovereign

guaranteed

U.S. government agencies
Agency commercial MBS
Other RMBS
Non-agency RMBS
Foreign covered bonds
State and political

subdivisions

Non-agency commercial

MBS

Other debt securities

Total securities held-to-

maturity
Total securities

$

$

$

22,929 $ 148 $ 341 $ 22,736
14,307
14,373

181

115

12,248

6,505

3,392

2,593
2,126
1,700
1,729
1,391

931

517
366
1,952
2
842

261

28

38

6
24
317
4
22

8

4
2
19
1
—

20

84

52

1
9
22
6
17

11

8
9
10
—
—

12,489

6,449

3,378

2,598
2,141
1,995
1,727
1,396

928

513
359
1,961
3
842

73,596 $ 997 $ 771 $ 73,822

25,221 $
11,117

57 $ 299 $ 24,979
11,098
22

41

1,911

1,589
721
142
78
74

19

7

26

42

—
1
—
4
1

—

—

—

—

6
10
4
2
—

1

—

—

1,953

1,583
712
138
80
75

18

7

26

$

40,905 $ 127 $ 363 $ 40,669

$ 114,501 $1,124 $1,134 $ 114,491
(a)   Includes $1,357 million that was included in the former Grantor 

(b) 

Trust. 
Includes gross unrealized gains of $62 million and gross 
unrealized losses of $190 million recorded in accumulated other 
comprehensive income related to investment securities that were 
transferred from available-for-sale to held-to-maturity.  The 
unrealized gains and losses are primarily related to Agency 
RMBS and will be amortized into net interest revenue over the 
contractual lives of the securities.

Net securities (losses) gains
(in millions)
Realized gross gains
Realized gross losses
Recognized gross impairments

$

Total net securities (losses) gains

$

2018

2017

8 $

(55)
(1)
(48) $

47 $
(40)
(4)
3 $

2016
86
(4)
(7)
75

In 2018, we adopted the new accounting guidance 
included in ASU 2016-01, Financial Instruments—
Overall: Recognition and Measurement of Financial 
Assets and Financial Liabilities.  As a result, money 
market fund investments were reclassified to trading 
assets, primarily from available-for-sale securities.

In 2018, certain debt securities with an aggregate 
amortized cost of $1,117 million and fair value of 
$1,070 million were transferred from held-to-maturity 
securities to available-for-sale securities as part of the 
adoption of ASU 2017-12, Derivatives and Hedging: 
Targeted Improvements to Accounting for Hedging 
Activities.

In 2017, other RMBS with an aggregate amortized 
cost of $74 million and fair value of $76 million were 
transferred from held-to-maturity securities to 
available-for-sale securities.  Due to ratings 
downgrades, the Company no longer intends to hold 
these securities to maturity.

BNY Mellon 141 

Notes to Consolidated Financial Statements (continued)

Temporarily impaired securities

At Dec. 31, 2018, the unrealized losses on the 
securities portfolio were primarily attributable to an 
increase in interest rates from date of purchase, and 
for certain securities that were transferred from 
available-for-sale to held-to-maturity, an increase in 
interest rates through the date they were transferred.  
Specifically, $87 million of the unrealized losses at 
Dec. 31, 2018 and $144 million at Dec. 31, 2017 
reflected in the available-for-sale sections of the 
tables below relate to certain securities (primarily 

Agency RMBS) that were transferred in prior periods 
from available-for-sale to held-to-maturity.  The 
unrealized losses will be amortized into net interest 
revenue over the contractual lives of the securities.  
The transfer created a new cost basis for the 
securities.  As a result, if these securities have 
experienced unrealized losses since the date of 
transfer, the corresponding fair value and unrealized 
losses would be reflected in the held-to-maturity 
sections of the following tables.  We do not intend to 
sell these securities, and it is not more likely than not 
that we will have to sell these securities.

The following tables show the aggregate fair value of securities with a continuous unrealized loss position for less 
than 12 months and those that have been in a continuous unrealized loss position for 12 months or more.

Temporarily impaired securities at Dec. 31, 2018

Less than 12 months

12 months or more

Total

$

(in millions)
Available-for-sale:
Agency RMBS
U.S. Treasury
Sovereign debt/sovereign guaranteed
Agency commercial MBS
CLOs
Supranational
Foreign covered bonds
State and political subdivisions
Other ABS
U.S. government agencies
Non-agency commercial MBS
Non-agency RMBS (a)
Corporate bonds
Other debt securities

Total securities available-for-sale (b)

$

Fair
value

Unrealized
losses

Fair
value

Unrealized
losses

Fair
value

Unrealized
losses

6,678 $
6,126
2,185
4,505
3,280
974
1,058
316
1,289
513
1,015
94
685
397
29,115 $

30
23
8
50
46
2
7
1
4
4
14
1
24
1
215

$

$

9,250 $
6,880
988
3,082
2
481
736
668
23
673
362
157
50
256
23,608 $

339
187
13
111
—
6
12
21
—
20
14
10
2
3
738

$

$

15,928 $
13,006
3,173
7,587
3,282
1,455
1,794
984
1,312
1,186
1,377
251
735
653
52,723 $

369
210
21
161
46
8
19
22
4
24
28
11
26
4
953

Held-to-maturity:
Agency RMBS
U.S. Treasury
U.S. government agencies
Agency commercial MBS
Non-agency RMBS

632
77
10
26
2
747
1,700
(a)  Includes $22 million with an unrealized loss of less than $1 million for less than 12 months and $3 million with an unrealized loss of less 

Total securities held-to-maturity
Total temporarily impaired securities

17,107 $
4,343
1,111
654
31
23,246 $
46,854 $

4,602 $
157
—
477
22
5,258 $
34,373 $

21,709 $
4,500
1,111
1,131
53
28,504 $
81,227 $

576
75
10
19
1
681
1,419

56
2
—
7
1
66
281

$
$

$
$

$
$

$

$

$

than $1 million for 12 months or more that were included in the former Grantor Trust. 

(b)  Includes gross unrealized losses of $87 million for 12 months or more recorded in accumulated other comprehensive income related to 

securities that were transferred from available-for-sale to held-to-maturity.  The unrealized losses are primarily related to Agency RMBS 
and will be amortized into net interest revenue over the contractual lives of the securities.  There were no gross unrealized losses for less 
than 12 months.

 142 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Temporarily impaired securities at Dec. 31, 2017

Less than 12 months

12 months or more

Total

$

(in millions)
Available-for-sale:
Agency RMBS
U.S. Treasury
Sovereign debt/sovereign guaranteed
Agency commercial MBS
State and political subdivisions
CLOs
Foreign covered bonds
Supranational
Non-agency RMBS (a)
Non-agency commercial MBS
Corporate bonds
U.S. government agencies
Other RMBS
Other debt securities

Total securities available-for-sale (b)

$

Fair
value

Unrealized
losses

Fair
value

Unrealized
losses

Fair
value

Unrealized
losses

8,567 $
7,429
1,880
3,077
732
260
953
700
20
476
274
588
71
1,155
26,182 $

66
131
12
28
3
1
7
6
—
3
2
6
4
1
270

$

$

5,834 $
2,175
559
1,332
518
—
116
333
149
122
288
160
45
35
11,666 $

225
29
11
39
20
—
2
5
4
3
9
4
2
—
353

$

$

14,401 $
9,604
2,439
4,409
1,250
260
1,069
1,033
169
598
562
748
116
1,190
37,848 $

291
160
23
67
23
1
9
11
4
6
11
10
6
1
623

$

Held-to-maturity:
Agency RMBS
U.S. Treasury
U.S. government agencies
Agency commercial MBS
Other RMBS
State and political subdivisions

9,458 $
6,389
791
737
—
—
17,375 $
43,557 $
(a)  Includes $7 million with an unrealized loss of less than $1 million for less than 12 months and $12 million with an unrealized loss of $1 

Total securities held-to-maturity
Total temporarily impaired securities

12,305 $
2,909
850
60
50
4

21,763 $
9,298
1,641
797
50
4

251
15
8
2
1
1
278
631

81
41
4
7
—
—
133
403

16,178 $
27,844 $

33,553 $
71,401 $

332
56
12
9
1
1
411
1,034

$
$

$
$

$
$

$

$

million for 12 months or more that were included in the former Grantor Trust. 

(b)  Includes gross unrealized losses of $144 million for 12 months or more recorded in accumulated other comprehensive income related to 
securities that were transferred from available-for-sale to held-to-maturity.  The unrealized losses are primarily related to Agency RMBS 
and will be amortized into net interest revenue over the contractual lives of the securities.  There were no gross unrealized losses for less 
than 12 months.

The following table shows the maturity distribution by carrying amount and yield (on a tax equivalent basis) of our 
securities portfolio.

Maturity distribution and yields
on securities at Dec. 31, 2018

(dollars in millions)
Securities available-for-sale:

One year or less
Over 1 through 5 years
Over 5 through 10 years
Over 10 years
Mortgage-backed securities
Asset-backed securities

Total

Securities held-to-maturity:

One year or less
Over 1 through 5 years
Over 5 through 10 years
Over 10 years
Mortgage-backed securities

Total

U.S. Treasury

State and political
subdivisions
Amount Yield (a) Amount Yield (a) Amount Yield (a) Amount Yield (a) Amount Yield (a)

Other bonds, notes
and debentures

U.S. government
agencies

Mortgage/
asset-backed

Total

$ 7,682
6,753
2,460
3,181
—
—
$ 20,076

$

936
3,480
311
—
—
$ 4,727

2.14% $
2.07
2.25
3.12
—
—

245
317
1,095
—
—
—
2.28% $ 1,657

1.41% $
1.83
2.18
—
—

597
900
—
—
—
1.77% $ 1,497

1.88% $
2.54
2.78
—
—
—

402
1,121
531
193
—
—
2.60% $ 2,247

1.26% $ —
3
2.52
—
—
14
—
—
—
17

2.01% $

2.54% $ 6,032
10,761
2.97
1,930
2.23
181
3.06
—
—
—
—
2.73% $ 18,904

—% $

5.66
—
4.76
—

4.95% $

57
373
509
—
—
939

1.50% $ —
—
1.29
—
0.88
—
1.68
37,788
—
5,137
—
1.32% $ 42,925

0.38% $ —
—
0.47
—
0.85
—
—
26,802
—
0.67% $ 26,802

—% $ 14,361
18,952
—
6,016
—
3,555
—
37,788
3.23
5,137
3.35
3.25% $ 85,809

—% $ 1,590
4,756
—
820
—
14
—
26,802
2.92
2.92% $ 33,982

(a)  Yields are based upon the amortized cost of securities.

BNY Mellon 143 

Notes to Consolidated Financial Statements (continued)

Other-than-temporary impairment

For each security in the securities portfolio, a 
quarterly review is conducted to determine if an 
OTTI has occurred.  See Note 1 for a discussion of 
the determination of OTTI. 

The following table reflects securities credit losses 
recorded in earnings.  The beginning balance 
represents the credit loss component for which OTTI 
occurred on debt securities in the prior year.  The 
additions represent the first time a debt security was 
credit impaired or when subsequent credit 
impairments have occurred.  The deductions represent 
credit losses on securities that have been sold, are 
required to be sold, or for which it is our intention to 
sell.

Debt securities credit loss roll forward
(in millions)
Beginning balance as of Dec. 31
Add: Subsequent OTTI credit losses
Less: Realized losses for securities sold
Ending balance as of Dec. 31

2018

84 $
1
7
78 $

2017
88
4
8
84

$

$

The following table presents pre-tax net securities 
(losses) gains by type.

Net securities (losses) gains
(in millions)
Agency RMBS
U.S. Treasury
Foreign covered bonds
Non-agency RMBS
Other

$

Total net securities (losses) gains

$

2018

2017

(42) $
(4)
(1)
—
(1)
(48) $

(12) $
(16)
—
4
27

3 $

2016
22
4
10
8
31
75

Pledged assets

At Dec. 31, 2018, BNY Mellon had pledged assets of 
$120 billion, including $96 billion pledged as 
collateral for potential borrowings at the Federal 
Reserve Discount Window and $7 billion pledged as 
collateral for borrowing at the FHLB.  The 
components of the assets pledged at Dec. 31, 2018 
included $100 billion of securities, $15 billion of 
loans, $4 billion of trading assets and $1 billion of 
interest-bearing deposits with banks.

 144 BNY Mellon

If there has been no borrowing at the Federal Reserve 
Discount Window, the Federal Reserve generally 
allows banks to freely move assets in and out of their 
pledged assets account to sell or repledge the assets 
for other purposes.  BNY Mellon regularly moves 
assets in and out of its pledged assets account at the 
Federal Reserve.

At Dec. 31, 2017, BNY Mellon had pledged assets of 
$111 billion, including $92 billion pledged as 
collateral for potential borrowing at the Federal 
Reserve Discount Window and $5 billion pledged as 
collateral for borrowing at the FHLB.  The 
components of the assets pledged at Dec. 31, 2017 
included $96 billion of securities, $13 billion of loans 
and $2 billion of trading assets.  

At Dec. 31, 2018 and Dec. 31, 2017, pledged assets 
included $13 billion and $10 billion, respectively, for 
which the recipients were permitted to sell or 
repledge the assets delivered.

We also obtain securities as collateral, including 
receipts under resale agreements, securities borrowed, 
derivative contracts and custody agreements on terms 
which permit us to sell or repledge the securities to 
others.  At Dec. 31, 2018 and Dec. 31, 2017, the 
market value of the securities received that can be 
sold or repledged was $151 billion and $86 billion, 
respectively.  We routinely sell or repledge these 
securities through delivery to third parties.  As of 
Dec. 31, 2018 and Dec. 31, 2017, the market value of 
securities collateral sold or repledged was $101 
billion and $49 billion, respectively.

Restricted cash and securities

Cash and securities may be segregated under federal 
and other regulations or requirements.  At Dec. 31, 
2018 and Dec. 31, 2017, cash segregated under 
federal and other regulations or requirements was $2 
billion and $2 billion, respectively.  Restricted cash is 
included in interest-bearing deposits with banks on 
the consolidated balance sheet.  Securities segregated 
for these purposes were $2 billion at Dec. 31, 2018 
and $1 billion at Dec. 31, 2017.  Restricted securities 
were sourced from securities purchased under resale 
agreements at Dec. 31, 2018 and Dec. 31, 2017 and 
are included in federal funds sold and securities 
purchased under resale agreements on the 
consolidated balance sheet. 

Notes to Consolidated Financial Statements (continued)

Our loan portfolio consists of three portfolio 
segments: commercial, lease financings and 
mortgages.  We manage our portfolio at the class 
level, which consists of six classes of financing 
receivables: commercial, commercial real estate, 
financial institutions, lease financings, wealth 
management loans and mortgages, and other 
residential mortgages.  

The following tables are presented for each class of 
financing receivable and provide additional 
information about our credit risks and the adequacy 
of our allowance for credit losses.

Note 5–Loans and asset quality

Loans

The table below provides the details of our loan 
portfolio and industry concentrations of credit risk at 
Dec. 31, 2018 and Dec. 31, 2017.

Loans
(in millions)
Domestic:

Commercial
Commercial real estate
Financial institutions
Lease financings
Wealth management loans and

mortgages
Other residential mortgages
Overdrafts
Other
Margin loans

Total domestic

Foreign:

Commercial
Financial institutions
Lease financings
Wealth management loans and

mortgages

Other (primarily overdrafts)
Margin loans

Total foreign
Total loans (a)

Dec. 31,

2018

2017

$

1,949 $
4,787
5,091
706

15,843
594
1,550
1,181
13,343
45,044

183
6,492
551

122
4,031
141
11,520
56,564 $

$

2,744
4,900
5,568
772

16,420
708
963
1,131
15,689
48,895

167
7,483
527

108
4,264
96
12,645
61,540

(a)  Net of unearned income of $358 million at Dec. 31, 2018 
and $394 million at Dec. 31, 2017 primarily related to 
domestic and foreign lease financings.

BNY Mellon 145 

Notes to Consolidated Financial Statements (continued)

Allowance for credit losses

Activity in the allowance for credit losses is summarized as follows.

Allowance for credit losses activity for the year ended Dec. 31, 2018

(in millions)

Beginning balance

Charge-offs
Recoveries

Net recoveries

Provision
Ending balance
Allowance for:
Loan losses
Lending-related commitments

Individually evaluated for

impairment:
Loan balance
Allowance for loan losses

Collectively evaluated for

impairment:
Loan balance
Allowance for loan losses

Commercial

Commercial
real estate

Financial
institutions

Lease
financings

Wealth
management
loans and
mortgages

Other
residential
mortgages

All
other

Foreign

Total

$

$

$

$

$

77 $
—
—
—
4
81 $

24 $
57

— $
—

76 $
—
—
—
(1)
75 $

56 $
19

— $
—

23 $
—
—
—
(1)
22 $

7 $
15

— $
—

8 $

—
—
—
(3)
5 $

5 $

—

— $
—

22 $
—
—
—
(1)
21 $

18 $
3

4 $
—

20 $
(1)
2
1
(5)
16 $

16 $
—

— $
—

—
—
—
—
—
—

—
—

—
—

$

$

$

$

35 $
—
1
1
(4)
32 $

20 $
12

261
(1)
3
2
(11)
252

146
106

— $
—

4
—

1,949 $
24

4,787 $
56

5,091 $
7

706 $
5

15,839 $
18

594 $ 16,074 (a) $ 11,520 $ 56,560
146

20

—

16

(a) 

Includes $1,550 million of domestic overdrafts, $13,343 million of margin loans and $1,181 million of other loans at Dec. 31, 2018.

Allowance for credit losses activity for the year ended Dec. 31, 2017

(in millions)

Beginning balance

Charge-offs
Recoveries

Net recoveries

Provision
Ending balance
Allowance for:
Loan losses
Lending-related commitments

Individually evaluated for

impairment:
Loan balance
Allowance for loan losses

Collectively evaluated for

impairment:
Loan balance
Allowance for loan losses

Commercial

Commercial
real estate

Financial
institutions

Lease
financings

Wealth
management
loans and
mortgages

Other
residential
mortgages

All
other

Foreign

Total

$

$

$

$

$

82 $
—
—
—
(5)
77 $

24 $
53

— $
—

73 $
—
—
—
3
76 $

58 $
18

— $
—

26 $
—
—
—
(3)
23 $

7 $
16

1 $
—

13 $
—
—
—
(5)
8 $

8 $

—

— $
—

23 $
—
—
—
(1)
22 $

18 $
4

28 $
(1)
5
4
(12)
20 $

20 $
—

5 $
1

— $
—

—
—
—
—
—
—

—
—

—
—

$

$

$

$

36 $
—
—
—
(1)
35 $

24 $
11

— $
—

281
(1)
5
4
(24)
261

159
102

6
1

2,744 $
24

4,900 $
58

5,567 $
7

772 $
8

16,415 $
17

708 $ 17,783 (a) $ 12,645 $ 61,534
158

—

24

20

(a) 

Includes $963 million of domestic overdrafts, $15,689 million of margin loans and $1,131 million of other loans at Dec. 31, 2017.

 146 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Allowance for credit losses activity for the year ended Dec. 31, 2016

(in millions)

Beginning balance

Charge-offs
Recoveries

Net recoveries

Provision
Ending balance
Allowance for:
Loans losses
Unfunded commitments
Individually evaluated for

impairment:
Loan balance
Allowance for loan losses

Collectively evaluated for

impairment:
Loan balance
Allowance for loan losses

Commercial

Commercial
real estate

Financial
institutions

Lease
financings

Wealth
management
loans and
mortgages

Other
residential
mortgages

All
other

Foreign

Total

$

$

$

$

$

82 $
—
—
—
—
82 $

25 $
57

— $
—

59 $
—
—
—
14
73 $

52 $
21

— $
—

31 $
—
13
13
(18)
26 $

8 $
18

— $
—

15 $
—
—
—
(2)
13 $

13 $
—

4 $
2

19 $
—
—
—
4
23 $

19 $
4

5 $
3

34 $
(2)
5
3
(9)
28 $

28 $
—

— $
—

—
—
—
—
—
—

—
—

—
—

$

$

$

$

35 $
—
1
1
—
36 $

24 $
12

— $
—

275
(2)
19
17
(11)
281

169
112

9
5

2,286 $
25

4,639 $
52

6,342 $
8

985 $
11

15,550 $
16

854 $ 19,760 (a) $ 14,033 $ 64,449
164

—

28

24

(a) 

Includes $1,055 million of domestic overdrafts, $17,503 million of margin loans and $1,202 million of other loans at Dec. 31, 2016.

Nonperforming assets

Lost interest

The table below presents our nonperforming assets. 

The table below presents the amount of lost interest 
income.

Nonperforming assets
(in millions)
Nonperforming loans:

Other residential mortgages
Wealth management loans and

mortgages

Commercial real estate

Total nonperforming loans

Other assets owned

Total nonperforming assets

Dec. 31,

2018

2017

$

$

67 $

9
—
76
3
79 $

78

7
1
86
4
90

At Dec. 31, 2018, undrawn commitments to 
borrowers whose loans were classified as nonaccrual 
or reduced rate were not material.

Lost interest
(in millions)
Amount by which interest income recognized
on nonperforming loans exceeded reversals

2018

2017

2016

Total
Foreign

Amount by which interest income would have
increased if nonperforming loans at year-
end had been performing for the entire year

$ — $ — $ —
—

—

—

Total
Foreign

$

5 $
—

5 $
—

6
—

BNY Mellon 147 

Notes to Consolidated Financial Statements (continued)

Impaired loans

The tables below present information about our impaired loans.  We use the discounted cash flow method as the 
primary method for valuing impaired loans. 

Impaired loans

(in millions)
Impaired loans with an allowance:

Commercial real estate
Financial institutions
Wealth management loans and mortgages
Lease financings

Total impaired loans with an allowance

Impaired loans without an allowance:

2018

2017

2016

Average
recorded
investment

Interest
income
recognized

Average
recorded
investment

Interest
income
recognized

Average
recorded
investment

Interest
income
recognized

$

— $
—
1
—
1

— $
—
—
—
—

— $
1
2
1
4

— $
—
—
—
—

1 $

—
5
3
9

—
—
—
—
—

Commercial real estate
Financial institutions
Wealth management loans and mortgages

—
—
—
—
4
—
—
4
5 $
—
(a)  When the discounted cash flows, collateral value or market price equals or exceeds the carrying value of the loan, then the loan does not 

Total impaired loans without an allowance (a)
Total impaired loans

1
102
2
105
114 $

—
—
—
—
— $

—
—
—
—
— $

—
—
3
3
7 $

$

require an allowance under the accounting standard related to impaired loans.

Impaired loans

(in millions)
Impaired loans with an allowance:

Commercial real estate
Financial institutions
Wealth management loans and mortgages
Total impaired loans with an allowance

Impaired loans without an allowance:

Wealth management loans and mortgages

Total impaired loans without an allowance (b)
Total impaired loans (c)

Dec. 31, 2018
Unpaid
principal
balance

Related
allowance (a)

Dec. 31, 2017
Unpaid
principal
balance

Related
allowance (a)

Recorded
investment

Recorded
investment

$

$

— $
—
—
—

4
4
4 $

— $
—
—
—

4
4
4 $

— $
—
—
—

N/A
N/A

— $

— $
1
1
2

4
4
6 $

3 $
1
1
5

4
4
9 $

—
—
1
1

N/A
N/A
1

(a)  The allowance for impaired loans is included in the allowance for loan losses.
(b)  When the discounted cash flows, collateral value or market price equals or exceeds the carrying value of the loan, then the loan does not 

require an allowance under the accounting standard related to impaired loans.

(c)  Excludes an aggregate of less than $1 million of impaired loans in amounts individually less than $1 million at both Dec. 31, 2018 and 

Dec. 31, 2017, respectively.  The allowance for loan losses associated with these loans totaled less than $1 million at both Dec. 31, 2018 
and Dec. 31, 2017, respectively.

Past due loans

The table below presents our past due loans. 

Past due loans and still accruing interest

Dec. 31, 2018

(in millions)
Wealth management loans and mortgages
Other residential mortgages
Commercial real estate
Financial institutions

Total past due loans

Days past due

30-59

60-89

22 $
12
1
3
38 $

1 $
6
—
3
10 $

$

$

Total
past due
28
25
1
6
60

5 $
7
—
—
12 $

Dec. 31, 2017

Days past due

30-59

60-89

$

$

39 $
18
44
1
102 $

5 $
5
—
—
10 $

Total
past due
44
28
44
1
117  

— $
5
—
—

5 $

 148 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Troubled debt restructurings

A modified loan is considered a TDR if the debtor is 
experiencing financial difficulties and the creditor 
grants a concession to the debtor that would not 

The following table presents our TDRs.

otherwise be considered.  A TDR may include a 
transfer of real estate or other assets from the debtor 
to the creditor, or a modification of the term of the 
loan.  Not all modified loans are considered TDRs.  

TDRs

2018

2017

(dollars in millions)
Other residential mortgages
Wealth management loans and mortgages

Total TDRs

Number of
contracts

17
—
17

Outstanding recorded investment
Pre-modification Post-modification
4
—
4

4
—
4

$

$

$

$

Number of
contracts

50
2
52

Outstanding recorded investment
Pre-modification Post-modification
14
6
20

13
6
19

$

$

$

$

The modifications of the other residential mortgage 
loans in 2018 and 2017 consisted of reducing the 
stated interest rates and, in certain cases, a 
forbearance of default and extending the maturity 
dates.  The modified loans are primarily collateral 
dependent for which the value is based on the fair 
value of the collateral.  

TDRs that subsequently defaulted

There were six residential mortgage loans and one 
wealth management loan, with an aggregate recorded 
investment of $1 million, which were restructured in 

a TDR during the previous 12 months and 
subsequently defaulted in 2018. 

Credit quality indicators

Our credit strategy is to focus on investment-grade 
clients that are active users of our non-credit services.  
Each customer is assigned an internal credit rating, 
which is mapped to an external rating agency grade 
equivalent, if possible, based upon a number of 
dimensions, which are continually evaluated and may 
change over time.

The following tables present information about credit quality indicators.

Commercial loan portfolio

Commercial loan portfolio – Credit risk profile

by creditworthiness category
(in millions)
Investment grade
Non-investment grade

Total

Commercial
Dec. 31,

2018
2,036 $
96
2,132 $

Commercial real estate
Dec. 31,

Financial institutions
Dec. 31,

2017
2,685
226
2,911

$

$

2018
4,184 $
603
4,787 $

2017
4,277
623
4,900

$

$

2018
9,586 $
1,997
11,583 $

2017
10,021
3,030
13,051

$

$

The commercial loan portfolio is divided into 
investment grade and non-investment grade 
categories based on the assigned internal credit 
ratings, which are generally consistent with those of 
the public rating agencies. 

Customers with ratings consistent with BBB- (S&P)/
Baa3 (Moody’s) or better are considered to be 
investment grade.  Those clients with ratings lower 
than this threshold are considered to be non-
investment grade.

BNY Mellon 149 

Notes to Consolidated Financial Statements (continued)

Wealth management loans and mortgages

Other residential mortgages

Wealth management loans and mortgages – Credit risk

profile by internally assigned grade

(in millions)
Wealth management loans:

Investment grade
Non-investment grade

Wealth management mortgages

Total

Dec. 31,

2018

2017

$

$

6,901 $
106
8,958
15,965 $

7,042
185
9,301
16,528

Wealth management non-mortgage loans are not 
typically rated by external rating agencies.  A 
majority of the wealth management loans are secured 
by the customers’ investment management accounts 
or custody accounts.  Eligible assets pledged for these 
loans are typically investment grade fixed-income 
securities, equities and/or mutual funds.  Internal 
ratings for this portion of the wealth management 
portfolio, therefore, would equate to investment-
grade external ratings.  Wealth management loans are 
provided to select customers based on the pledge of 
other types of assets, including business assets, fixed 
assets or a modest amount of commercial real estate.  
For the loans collateralized by other assets, the credit 
quality of the obligor is carefully analyzed, but we do 
not consider this portfolio of loans to be investment 
grade.

Credit quality indicators for wealth management 
mortgages are not correlated to external ratings.  
Wealth management mortgages are typically loans to 
high-net-worth individuals, which are secured 
primarily by residential property.  These loans are 
primarily interest-only, adjustable rate mortgages 
with a weighted-average loan-to-value ratio of 62% at 
origination.  In the wealth management portfolio, less 
than 1% of the mortgages were past due at Dec. 31, 
2018.

At Dec. 31, 2018, the wealth management mortgage 
portfolio consisted of the following geographic 
concentrations:  California - 24%; New York - 18%; 
Massachusetts - 10%; Florida - 8%; and other - 40%.

The other residential mortgage portfolio primarily 
consists of 1-4 family residential mortgage loans and 
totaled $594 million at Dec. 31, 2018 and $708 
million at Dec. 31, 2017.  These loans are not 
typically correlated to external ratings.  Included in 
this portfolio at Dec. 31, 2018 were $128 million of 
mortgage loans purchased in 2005, 2006 and the first 
quarter of 2007, of which, 11% of the serviced loan 
balance was at least 60 days delinquent. 

Overdrafts

Overdrafts primarily relate to custody and securities 
clearance clients and totaled $5.5 billion at Dec. 31, 
2018 and $5.1 billion at Dec. 31, 2017.  Overdrafts 
occur on a daily basis primarily in the custody and 
securities clearance business and are generally repaid 
within two business days.

Other loans

Other loans primarily include loans to consumers that 
are fully collateralized with equities, mutual funds 
and fixed-income securities.

Margin loans

We had $13.5 billion of secured margin loans on our 
consolidated balance sheet at Dec. 31, 2018 
compared with $15.8 billion at Dec. 31, 2017.  
Margin loans are collateralized with marketable 
securities, and borrowers are required to maintain a 
daily collateral margin in excess of 100% of the value 
of the loan.  We have rarely suffered a loss on these 
types of loans and do not allocate any of our 
allowance for credit losses to margin loans.

Reverse repurchase agreements

Reverse repurchase agreements are transactions fully 
collateralized with high-quality liquid securities.  
These transactions carry minimal credit risk and 
therefore are not allocated an allowance for credit 
losses.

 150 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Note 6–Goodwill and intangible assets

Goodwill

The table below provides a breakdown of goodwill by business.

Goodwill by business
(in millions)
Balance at Dec. 31, 2016
Foreign currency translation
Balance at Dec. 31, 2017

Dispositions
Foreign currency translation
Balance at Dec. 31, 2018

Investment
Services

Investment
Management

Other

$

$

$

8,269 $
120
8,389 $
—
(56)
8,333 $

9,000 $
128
9,128 $
(65)
(93)
8,970 $

47 $
—
47 $
—
—
47 $

Consolidated
17,316
248
17,564
(65)
(149)
17,350

Total goodwill decreased in 2018 compared with 2017 reflecting the impact of foreign exchange translation on non-
U.S. dollar denominated goodwill and dispositions in the Investment Management business.

Intangible assets

The table below provides a breakdown of intangible assets by business. 

Intangible assets – net carrying amount by business
(in millions)
Balance at Dec. 31, 2016
Amortization
Foreign currency translation
Balance at Dec. 31, 2017

Amortization
Foreign currency translation
Balance at Dec. 31, 2018

Investment
Services

Investment
Management

Other

$

$

$

1,032 $
(149)
5
888 $
(129)
(1)
758 $

1,717 $
(60)
17
1,674 $
(51)
(10)
1,613 $

849 $
—
—
849 $
—
—
849 $

Consolidated
3,598
(209)
22
3,411
(180)
(11)
3,220

Intangible assets decreased in 2018 compared with 2017 primarily reflecting amortization. 

The table below provides a breakdown of intangible assets by type.

Intangible assets

Dec. 31, 2018

Dec. 31, 2017

Gross
carrying
amount

Accumulated
amortization

Net
carrying
amount

Remaining
weighted-
average
amortization
period

Gross
carrying
amount

Accumulated
amortization

Net
carrying
amount

(in millions)
Subject to amortization: (a)

Customer contracts—Investment Services
Customer relationships—Investment
Management
Other

Total subject to amortization

Not subject to amortization: (b)

Tradenames
Customer relationships

$

1,572 $

(1,186) $

899
26
2,497

(699)
(12)
(1,897)

1,332
1,288
2,620
5,117 $

N/A
N/A
N/A
(1,897) $

Total not subject to amortization
Total intangible assets

$
(a)  Excludes fully amortized intangible assets.
(b)  Intangible assets not subject to amortization have an indefinite life.

386

200
14
600

1,332
1,288
2,620
3,220

10 years

$

2,260 $

(1,744) $

11 years
4 years
10 years

1,262
42
3,564

(1,015)
(23)
(2,782)

516

247
19
782

N/A
N/A
N/A
N/A $

1,334
1,295
2,629
6,193 $

N/A
N/A
N/A
(2,782) $

1,334
1,295
2,629
3,411

BNY Mellon 151 

Notes to Consolidated Financial Statements (continued)

Qualified affordable housing project investments

We invest in affordable housing projects primarily to 
satisfy the Company’s requirements under the 
Community Reinvestment Act.  Our total investment 
in qualified affordable housing projects totaled $1.0 
billion at Dec. 31, 2018 and $1.0 billion at Dec. 31, 
2017.  Commitments to fund future investments in 
qualified affordable housing projects totaled $479 
million at Dec. 31, 2018 and $486 million at Dec. 31, 
2017 and are recorded in other liabilities.  A summary 
of the commitments to fund future investments is as 
follows: 2019 – $201 million; 2020 – $108 million; 
2021 – $122 million; 2022 – $29 million; 2023 – $1 
million; and 2024 and thereafter – $18 million.

Tax credits and other tax benefits recognized were 
$163 million in 2018, $156 million in 2017 and $155 
million in 2016. 

Amortization expense included in the provision for 
income taxes was $136 million in 2018, $153 million 
in 2017 and $115 million in 2016.

Investments valued using net asset value per share

In our Investment Management business, we manage 
investment assets, including equities, fixed income, 
money market and multi-asset and alternative 
investment funds for institutions and other investors.  
As part of that activity, we make seed capital 
investments in certain funds.  We also hold private 
equity investments, specifically SBICs, which are 
compliant with the Volcker Rule, and certain other 
corporate investments.  Seed capital, private equity 
and other corporate investments are included in other 
assets on the consolidated balance sheet.  The fair 
value of these investments was estimated using the 
net asset value (“NAV”) per share for BNY Mellon’s 
ownership interest in the funds.  

Estimated annual amortization expense for current 
intangibles for the next five years is as follows:

For the year ended
Dec. 31,
2019
2020
2021
2022
2023

Impairment testing

$

Estimated amortization expense
(in millions)
115
102
78
60
50

The goodwill impairment test is performed at least 
annually at the reporting unit level.  Intangible assets 
not subject to amortization are tested for impairment 
annually or more often if events or circumstances 
indicate they may be impaired.

BNY Mellon’s three business segments include seven 
reporting units for which goodwill impairment testing 
is performed on an annual basis.  The Investment 
Services segment is comprised of four reporting 
units; the Investment Management segment is 
comprised of two reporting units and one reporting 
unit is included in the Other segment.  As a result of 
the annual goodwill impairment test of the seven 
reporting units conducted in the second quarter of 
2018, no goodwill impairment was recognized. 

Note 7–Other assets 

The following table provides the components of other 
assets presented on the consolidated balance sheet.

$

Other assets
(in millions)
Corporate/bank-owned life insurance
Accounts receivable
Fails to deliver
Software
Prepaid pension assets
Renewable energy investments
Income taxes receivable
Equity in a joint venture and other
investments
Qualified affordable housing project
investments
Federal Reserve Bank stock
Prepaid expense
Fair value of hedging derivatives
Seed capital
Other (a)

Total other assets

$

Dec. 31,

2018
4,937 $
3,692
2,274
1,652
1,357
1,264
1,125

1,064

999
484
385
289
224
1,552
21,298 $

2017
4,857
4,590
2,817
1,499
1,416
1,368
1,533

1,083

1,014
477
395
323
288
1,369
23,029

(a)  At Dec. 31, 2018 and Dec. 31, 2017, other assets include 

$111 million and $82 million, respectively, of Federal Home 
Loan Bank stock, at cost.

 152 BNY Mellon

Notes to Consolidated Financial Statements (continued)

The table below presents information on our investments valued using NAV.

Other assets valued using NAV

(dollars in millions)

Seed capital

Private equity investments (SBICs) (a)

Other (b)

Total

Dec. 31, 2018

Dec. 31, 2017

Fair
value

Unfunded 
commitments

Redemption 
frequency

Redemption 
notice period

Fair
value

Unfunded
commitments

Redemption 
frequency

Redemption 
notice period

$

54

74

87

$ —

Daily-
quarterly

1-90 days

$

41

—

N/A

N/A

Daily-
quarterly

1-95 days

40

55

59

$ 215

$

41  

$ 154

$

$

1

42

—

43

Daily-
quarterly

N/A

Daily-
quarterly

1-90 days

N/A

1-95 days

(a)  Private equity investments include Volcker Rule-compliant investments in SBICs that invest in various sectors of the economy.  Private equity 
investments do not have redemption rights.  Distributions from such investments will be received as the underlying investments in the private 
equity investments, which have a life of 10 years, are liquidated.

(b)  Primarily relates to investments in funds that relate to deferred compensation arrangements with employees.

Note 8–Deposits

Total time deposits in denominations of $250,000 or 
more were $32.1 billion at Dec. 31, 2018 and $37.3 
billion at Dec. 31, 2017.  At Dec. 31, 2018, the 
scheduled maturities of all time deposits are as 
follows: 2019 – $40.5 billion; 2020 – $47 million; 
2021 – $1 million; 2022 – $- million; 2023 – $- 
million; and 2024 and thereafter – $1 million.

Note 9–Contract revenue

Nature of services and revenue recognition 

Fee revenue in Investment Services and Investment 
Management is primarily variable, based on levels of 
AUC/A, AUM and the level of client-driven 
transactions, as specified in fee schedules.  

Investment Services fees are based primarily on the 
market value of AUC/A; client accounts, balances 
and the volume of transactions; securities lending 
volume and spreads; and fees for other services.  
Certain fees based on the market value of assets are 
calculated in arrears on a monthly or quarterly basis. 

Substantially all services within the Investment 
Services business are provided over time.  Revenue 
on these services is recognized using the time elapsed 
method, equal to the expected invoice amount, which 
typically represents the value provided to the 
customer for our performance completed to date. 

Clearing services revenue includes multiple types of 
fees, some of which are driven by customer actions 

and are delivered at a point-in-time.  These 
transaction-based fees are generally recognized on 
trade date.  Other contractual clearing services fees 
are driven by the amount of AUC/A or the number of 
accounts or securities positions and are billed on a 
monthly or quarterly basis. 

Investment management fees are dependent on the 
overall level and mix of AUM.  The management 
fees, expressed in basis points, are charged for 
managing those assets.  Management fees are 
typically subject to fee schedules based on the overall 
level of assets managed and products in which those 
assets are invested. 

Investment management fee revenue also includes 
transactional- and account-based fees.  These fees 
along with distribution and servicing fees are 
recognized when the services have been completed.  
Clients are generally billed for services performed on 
a monthly or quarterly basis. 

Performance fees are generally calculated as a 
percentage of the applicable portfolio’s performance 
in excess of a benchmark index or a peer group’s 
performance.  Performance fees are recognized at the 
end of the measurement period when they are 
determinable.  

See Note 23 for additional information on our 
principal businesses, Investment Services and 
Investment Management, and the primary services 
provided. 

BNY Mellon 153 

 
Notes to Consolidated Financial Statements (continued)

Disaggregation of contract revenue 

Contract revenue is included in fee revenue on the 
consolidated income statement.  The following table 
presents fee revenue related to contracts with 
customers, disaggregated by type, for each business 
segment.  

Disaggregation of contract revenue by business segment (a)

(in millions)

Fee revenue - contract

revenue:
Investment services

fees:
Asset servicing
Clearing services
Issuer services
Treasury services
Total investment
services fees

Investment

management and
performance fees
Financing-related fees
Distribution and

servicing

Investment and other

income

Total fee revenue -
contract revenue
Fee and other revenue - 

not in scope of 
ASC 606 (b)(c)

Total fee and other

revenue

Year ended Dec. 31, 2018

Investment
Services

Investment

Management Other

Total

$

4,395 $
1,577
1,099
553

88 $
—
—
1

1 $ 4,484
— 1,577
— 1,099
554
—

7,624

89

1

7,714

54

61

(51)

279

3,619

— 3,673

1

191

(202)

(2)

—

2

1

60

140

79

11,666

7,967

3,698

959

83

84

1,126

$

8,926 $

3,781 $

85 $12,792

(a)  Business segment data has been determined on an internal 

management basis of accounting, rather than the generally accepted 
accounting principles used for consolidated financial reporting.
(b)  Primarily includes foreign exchange and other trading revenue, 
investment and other income, financing-related fees and net 
securities losses, all of which are accounted for using other 
accounting guidance. 

(c)  The Investment Management business includes a loss from 

consolidated investment management funds, net of noncontrolling 
interests of $1 million in 2018. 

Contract balances 

Our clients are billed based on fee schedules that are 
agreed upon in each customer contract.  Receivable 
from customers were $3.9 billion at Jan. 1, 2018 and 
$2.5 billion at Dec. 31, 2018.  An allowance is 
maintained for accounts receivables which is 
generally based on the number of days outstanding.  
Adjustments to the allowance are recorded in other 
expense in the consolidated income statement.  A 
provision of $11 million was recorded in 2018.

 154 BNY Mellon

Contract assets represent accrued revenues that have 
not yet been billed to the customers due to certain 
contractual terms other than the passage of time and 
were $30 million at Jan. 1, 2018 and $36 million at 
Dec. 31, 2018.  Accrued revenues recorded as 
contract assets are usually billed on an annual basis.  
There were no impairments recorded on contract 
assets in 2018.  

Both receivables from customers and contract assets 
are included in other assets on the consolidated 
balance sheet.  

Contract liabilities represent payments received in 
advance of providing services under certain contracts 
and were $167 million at Jan. 1, 2018 and $171 
million at Dec. 31, 2018.  Contract liabilities are 
included in other liabilities on the consolidated 
balance sheet.  Revenue recognized in 2018 relating 
to contract liabilities as of Jan. 1, 2018 was $96 
million.

Changes in contract assets and liabilities primarily 
relate to either party’s performance under the 
contracts. 

Contract costs

Incremental costs for obtaining contracts that are 
deemed recoverable are capitalized as contract costs.  
Such costs result from the payment of sales 
incentives, primarily in the Wealth Management 
business, and totaled $98 million at Dec. 31, 2018.  
Capitalized sales incentives are amortized based on 
the transfer of goods or services to which the assets 
relate and typically average nine years.  The 
amortization of capitalized sales incentives, which is 
primarily included in staff expense, totaled $22 
million in 2018. 

Costs to fulfill a contract are capitalized when they 
relate directly to an existing contract or specific 
anticipated contract, generate or enhance resources 
that will be used to fulfill performance obligations 
and are recoverable.  Such costs generally represent 
set-up costs, which include any direct cost incurred at 
inception of a contract which enables the fulfillment 
of the performance obligation and totaled $20 million 
at Dec. 31, 2018.  These capitalized costs are 
amortized on a straight-line basis over the expected 
contract period which generally range from seven to 
nine years.  The amortization is included in other 
expense and totaled $5 million in 2018.  

Notes to Consolidated Financial Statements (continued)

There were no impairments recorded on capitalized 
contract costs in 2018.

Note 11–Income taxes

Unsatisfied performance obligations

We do not have any unsatisfied performance 
obligations other than those that are subject to a 
practical expedient election under ASC 606, Revenue 
From Contracts With Customers.  The practical 
expedient election applies to (i) contracts with an 
original expected length of one year or less, and (ii) 
contracts for which we recognize revenue at the 
amount to which we have the right to invoice for 
services performed.

Note 10–Net interest revenue

The following table provides the components of net 
interest revenue presented on the consolidated income 
statement.

Net interest revenue
(in millions)
Interest revenue
Deposits with banks
Deposits with the Federal

Reserve and other central banks
Federal funds sold and securities

purchased under resale
agreements
Margin loans
Non-margin loans
Securities:
Taxable
Exempt from federal income

taxes
Total securities
Trading securities

Total interest revenue

Interest expense
Deposits in domestic offices
Deposits in foreign offices
Federal funds purchased and
securities sold under repurchase
agreements
Trading liabilities
Other borrowed funds
Commercial paper
Customer payables
Long-term debt

Total interest expense
Net interest revenue
Provision for credit losses

Net interest revenue after

provision for credit losses

Year ended Dec. 31,
2018

2017

2016

$

219 $

120 $

104

531

319

198

1,116
510
1,356

2,520

54
2,574
126
6,432

537
340

758
29
58
51
191
857
2,821
3,611
(11)

423
343
1,077

233
265
873

1,977

1,772

64
2,041
59
4,382

107
55

225
7
26
29
64
561
1,074
3,308
(24)

70
1,842
60
3,575

41
(25)

36
6
8
5
12
354
437
3,138
(11)

$ 3,622 $ 3,332 $ 3,149

The components of the income tax provision are as 
follows:

Provision for income taxes
(in millions)
Current tax expense (benefit):

Federal
Foreign
State and local

Total current tax expense
Deferred tax (benefit) expense:

Federal
Foreign
State and local

Total deferred tax (benefit)

expense:

Provision for income taxes

$

Year ended Dec. 31,
2018

2017

2016

$

902 $
442
119
1,463

(99) $
388
74
363

823
327
153
1,303

(556)
9
22

36
14
83

(75)
(14)
(37)

(525)
938 $

133
(126)
496 $ 1,177

In December 2017, the Tax Cuts and Jobs Act of 2017 
(“U.S. tax legislation”) was signed into law in the 
United States.  U.S. GAAP requires companies to 
recognize the effect of tax law changes on deferred 
tax assets and liabilities and other recognized assets 
in the period of enactment.  Also in December 2017, 
the Securities and Exchange Commission staff issued 
Staff Accounting Bulletin No.118 (“SAB 118”).  SAB 
118 allows the recording of a provisional estimate to 
reflect the income tax impact of the U.S. tax 
legislation and provides a measurement period up to 
one year from the enactment date.  Due to the timing 
of the enactment and the complexity involved in 
applying the provisions of the U.S. tax legislation, we 
recorded a provisional tax benefit of $710 million in 
the fourth quarter of 2017.

In 2018, we completed our analysis of the U.S. tax 
legislation and filed our 2017 income tax returns, 
taking into account new Internal Revenue Service 
(“IRS”) guidance.  Accordingly we recorded an 
additional $70 million tax benefit for remeasurement 
of our net deferred tax liability.

The U.S. tax legislation provided a one-time deemed 
repatriation tax on undistributed foreign earnings and 
profits (“repatriation tax”).  In 2017, we recorded 
$723 million provisional repatriation tax.  In 2018, 
we completed our analysis of foreign earnings taking 
into account new IRS guidance and reduced the 
repatriation tax by $36 million.

BNY Mellon 155 

 
Notes to Consolidated Financial Statements (continued)

The components of U.S. tax legislation are as 
follows:

The statutory federal income tax rate is reconciled to 
our effective income tax rate below:

Income tax (benefit) expense
(estimated in millions)
Remeasurement of net deferred tax

liabilities

Repatriation tax
Other items

Net income tax (benefit)

2018

2017

$

$

(70) $ (1,472)
(36)
723
—
39
(106) $
(710)

The components of income before taxes are as 
follows:

Income before taxes
(in millions)
Domestic
Foreign

Income before taxes

2017

Year ended Dec. 31,
2018

2016
$ 3,008 $ 2,699 $ 3,147
1,578
$ 5,192 $ 4,610 $ 4,725

1,911

2,184

The components of our net deferred tax liability are 
as follows:

Net deferred tax liability
(in millions)
Depreciation and amortization
Pension obligation
Renewable energy investment
Lease financings
Equity investments
Repatriation
Securities valuation
Credit losses on loans
Reserves not deducted for tax
Employee benefits
Other assets
Other liabilities

Net deferred tax liability

Dec. 31,

2018

2017
$ 2,060 $ 1,960
283
278
151
65
617
11
(55)
(103)
(287)
(85)
186
$ 2,496 $ 3,021

300
295
130
65
—
(15)
(54)
(143)
(266)
(65)
189

We believe it is more likely than not that we will fully 
realize our deferred tax assets.  This conclusion is 
based on financial results and profit forecasts.

We have completed our analysis of the U.S. tax 
legislation’s impact to foreign earnings and the 
amount of foreign earnings considered permanently 
reinvested abroad.  As of Dec. 31, 2018, we had 
approximately $250 million of earnings attributable 
to foreign subsidiaries that have been permanently 
reinvested abroad and for which no local distribution 
tax provision has been recorded.  If these earnings 
were to be repatriated, the estimated tax liability as of 
Dec. 31, 2018 would be up to $50 million. 

 156 BNY Mellon

Effective tax rate

Federal rate
State and local income taxes, net of
federal income tax benefit
Foreign operations
Tax credits
Tax-exempt income
Leverage lease adjustment
FDIC Assessment
Stock compensation
U.S. tax legislation
Other – net

Effective tax rate

Year ended Dec. 31,
2018
2016
2017
21.0% 35.0% 35.0%

1.6
1.8
2.1
0.5
(5.6)
(4.2)
(3.3)
(2.2)
(3.7)
(0.8)
(1.8)
(1.9)
—
(0.9)
(1.4)
0.5
—
—
(0.6)
—
(1.1)
(1.7)
—
(13.3)
0.4
(1.2)
(0.4)
18.1% 10.8% 24.9%

Unrecognized tax positions
(in millions)
Beginning balance at Jan. 1, – gross $
Prior period tax positions:

Increases
Decreases

Current period tax positions
Settlements
Statute expiration

Ending balance at Dec. 31, – gross $

2018
128 $

2017
146 $

2016
649

6
(8)
9
(32)
—
103 $

20
(4)
10
(44)
—
128 $

8
(40)
16
(477)
(10)
146

Our total tax reserves as of Dec. 31, 2018 were $103 
million compared with $128 million at Dec. 31, 2017.  
If these tax reserves were unnecessary, $103 million 
would affect the effective tax rate in future periods.  
We recognize accrued interest and penalties, if 
applicable, related to income taxes in income tax 
expense.  Included in the balance sheet at Dec. 31, 
2018 is accrued interest, where applicable, of $22 
million.  The additional tax expense related to interest 
for the year ended Dec. 31, 2018 was $8 million, 
compared with $12 million for the year ended Dec. 
31, 2017.

It is reasonably possible the total reserve for uncertain 
tax positions could decrease within the next 12 
months by approximately $20 million as a result of 
adjustments related to tax years that are still subject 
to examination.

Our federal income tax returns are closed to 
examination through 2013.  Our New York State, 
New York City and UK income tax returns are closed 
to examination through 2012.

Notes to Consolidated Financial Statements (continued)

Note 12–Long-term debt

Long-term debt
(in millions)
Senior debt:
Fixed rate
Floating rate

Subordinated debt (a)

Total

(a)  Fixed rate.

Dec. 31, 2018

Rate

Maturity

Amount

Dec. 31, 2017
Rate

Amount

2.05 - 5.45%
2.61 - 3.86%
3.00 - 7.50%

2019 - 2028 $
2019 - 2038
2021 - 2029

$

24,995
2,628
1,540
29,163

1.30 - 5.45% $
1.49 - 2.74%
3.00 - 7.50%

$

23,329
2,829
1,821
27,979

Total long-term debt maturing during the next five 
years for BNY Mellon is as follows: 2019 – $4.3 
billion, 2020 – $5.0 billion, 2021 – $4.6 billion, 2022 
– $1.3 billion and 2023 – $5.5 billion. 

Note 13–Variable interest entities and 
securitization

BNY Mellon has variable interests in VIEs, which 
include investments in retail, institutional and 
alternative investment funds, including CLO 
structures in which we provide asset management 
services, some of which are consolidated.  The 
investment funds are offered to our retail and 
institutional clients to provide them with access to 
investment vehicles with specific investment 
objectives and strategies that address the client’s 
investment needs.  

BNY Mellon earns management fees from these 
funds as well as performance fees in certain funds 

and may also provide start-up capital for its new 
funds.  The funds are primarily financed by our 
customers’ investments in the funds’ equity or debt.  

Additionally, BNY Mellon invests in qualified 
affordable housing and renewable energy projects, 
which are designed to generate a return primarily 
through the realization of tax credits by the Company.  
The projects, which are structured as limited 
partnerships and LLCs, are also VIEs, but are not 
consolidated.  

The following table presents the incremental assets 
and liabilities included in BNY Mellon’s consolidated 
financial statements as of Dec. 31, 2018 and Dec. 31, 
2017.  The net assets of any consolidated VIE are 
solely available to settle the liabilities of the VIE and 
to settle any investors’ ownership liquidation 
requests, including any seed capital invested in the 
VIE by BNY Mellon.  

Consolidated investments

(in millions)
Securities - Available-for-sale
Trading assets
Other assets

Total assets
Other liabilities
Total liabilities

Investment
Management
funds

—
243
220
463 (a) $
2
$
2 (a) $
101 (a) $

$

$
$
$
$

Dec. 31, 2018

Dec. 31, 2017

Total
consolidated
investments

Investment
Management
funds

Securitization

Securitization
$

— $

400
—
400 $
371 $
371 $
— $

— $
643
220
863
373
373
101

$
$
$
$

$

—
516
215
731 (b) $
2
$
2 (b) $
316 (b) $

Total
consolidated
investments
400
516
215
1,131
369
369
316  

400 $
—
—
400 $
367 $
367 $
— $

Nonredeemable noncontrolling interests
(a) 
(b) 

Includes VMEs with assets of $253 million, liabilities of $2 million and nonredeemable noncontrolling interests of less than $1 million.
Includes VMEs with assets of $84 million, liabilities of $1 million and nonredeemable noncontrolling interests of $1 million.

BNY Mellon has not provided financial or other 
support that was not otherwise contractually required 
to be provided to our VIEs.  Additionally, creditors of 
any consolidated VIEs do not have any recourse to 
the general credit of BNY Mellon.  

BNY Mellon 157 

Notes to Consolidated Financial Statements (continued)

Non-consolidated VIEs

As of Dec. 31, 2018 and Dec. 31, 2017, the following 
assets and liabilities related to the VIEs where BNY 
Mellon is not the primary beneficiary are included in 
our consolidated financial statements and primarily 

relate to accounting for our investments in qualified 
affordable housing and renewable energy projects.  

The maximum loss exposure indicated in the table 
below relates solely to BNY Mellon’s investments in, 
and unfunded commitments to, the VIEs.

Non-consolidated VIEs

(in millions)
Securities - Available-for-sale (a)
2,450
Other
(a)  Includes investments in the Company’s sponsored CLOs.

Assets

$

214 $

Dec. 31, 2018

Liabilities

Maximum
loss exposure
214
2,929

— $
479

Dec. 31, 2017

Assets

Liabilities

Maximum
loss exposure

$

203 $

2,592

— $

486

203
3,078

Note 14–Shareholders’ equity

Common stock

BNY Mellon has 3.5 billion authorized shares of 
common stock with a par value of $0.01 per share.  
At Dec. 31, 2018, 960,425,669 shares of common 
stock were outstanding.  

Common stock repurchase program

In June 2017, in connection with the Federal 
Reserve’s non-objection to our 2017 capital plan, 
BNY Mellon announced a share repurchase plan 
providing for the repurchase of up to $2.6 billion of 
common stock.  The 2017 capital plan began in the 
third quarter of 2017 and continued through the 
second quarter of 2018.  In June 2018, in connection 
with the Federal Reserve’s non-objection to our 2018 
capital plan, BNY Mellon announced a share 
repurchase plan providing for the repurchase of up to 
$2.4 billion of common stock starting in the third 
quarter of 2018 and continuing through the second 
quarter of 2019.  This new share repurchase plan 
replaces all previously authorized share repurchase 
plans. 

In December 2018, BNY Mellon announced that the 
Federal Reserve approved the repurchase of $830 

million of additional common stock.  Our Board of 
Directors approved the additional share repurchases, 
which were completed in the fourth quarter of 2018.  
These repurchases were in addition to the Company’s 
repurchase of $2.4 billion of common stock 
previously approved by the Board and announced in 
June 2018.

Share repurchases may be executed through open 
market repurchases, in privately negotiated 
transactions or by other means, including through 
repurchase plans designed to comply with Rule 
10b5-1 and other derivative, accelerated share 
repurchase and other structured transactions.  In 
2018, we repurchased 63.7 million common shares at 
an average price of $51.29 per common share for a 
total of $3.3 billion.  At Dec. 31, 2018, the maximum 
dollar value of shares that may yet be purchased 
under the June 2018 program, including employee 
benefit plan repurchases, totaled $1.3 billion.

Preferred stock

BNY Mellon has 100 million authorized shares of 
preferred stock with a par value of $0.01 per share.  
The following table summarizes BNY Mellon’s 
preferred stock issued and outstanding at Dec. 31, 
2018 and Dec. 31, 2017.

 158 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Preferred stock summary (a)

Per annum dividend rate
Greater of (i) three-month LIBOR plus 0.565% for the related
distribution period; or (ii) 4.000%
5.2%
4.50% to but excluding June 20, 2023, then a floating rate equal to the
three-month LIBOR plus 2.46%
4.95% to and including June 20, 2020, then a floating rate equal to the
three-month LIBOR plus 3.42%
4.625% to and including Sept. 20, 2026, then a floating rate equal to
the three-month LIBOR plus 3.131%

Series A

Series C
Series D

Series E

Series F

Total

Total shares issued and
outstanding
Dec. 31,

2018

5,001
5,825

5,000

$

2017

5,001
5,825

5,000

10,000

10,000

Carrying value (b)
(in millions)
Dec. 31,

2018

2017

500 $
568

494

990

500
568

494

990

10,000
35,826

10,000
35,826

$

990
3,542 $

990
3,542

(a)  All outstanding preferred stock is noncumulative perpetual preferred stock with a liquidation preference of $100,000 per share.
(b)  The carrying value of the Series C, Series D, Series E and Series F preferred stock is recorded net of issuance costs.

Holders of both the Series A and Series C preferred 
stock are entitled to receive dividends on each 
dividend payment date (March 20, June 20, 
September 20 and December 20 of each year), if 
declared by BNY Mellon’s Board of Directors.  
Holders of the Series D preferred stock are entitled to 
receive dividends, if declared by BNY Mellon’s 
Board of Directors, on each June 20 and December 
20, to but excluding June 20, 2023; and on each 
March 20, June 20, September 20 and December 20, 
from and including June 20, 2023.  Holders of the 
Series E preferred stock are entitled to receive 
dividends, if declared by BNY Mellon’s Board of 
Directors, on each June 20 and December 20, to and 
including June 20, 2020; and on each March 20, June 
20, September 20 and December 20, from and 
including Sept. 20, 2020.  Holders of the Series F 
preferred stock are entitled to receive dividends, if 
declared by BNY Mellon’s Board of Directors, on 
each March 20 and September 20, commencing 
March 20, 2017, to and including Sept. 20, 2026; and 
on each March 20, June 20, September 20 and 
December 20, commencing Dec. 20, 2026.  BNY 
Mellon’s ability to declare or pay dividends on, or 

purchase, redeem or otherwise acquire, shares of our 
common stock or any of our shares that rank junior to 
the preferred stock as to the payment of dividends 
and/or the distribution of any assets on any 
liquidation, dissolution or winding-up of BNY 
Mellon will be prohibited, subject to certain 
restrictions, in the event that we do not declare and 
pay in full preferred dividends for the then current 
dividend period of the Series A preferred stock or the 
last preceding dividend period of the Series C, Series 
D, Series E and Series F preferred stock.

All of the outstanding shares of the Series A preferred 
stock are owned by Mellon Capital IV, which will 
pass through any dividend on the Series A preferred 
stock to the holders of its Normal Preferred Capital 
Securities.  All of the outstanding shares of the Series 
C, Series D, Series E and Series F preferred stock are 
held by the depositary of the depositary shares, which 
will pass through the applicable portion of any 
dividend on the Series C, Series D, Series E and 
Series F preferred stock to the holders of record of 
their respective depositary shares.  

The table below presents the dividends paid on our preferred stock.

Dividend paid per preferred share

Series A
Series C
Series D
Series E
Series F

Depositary 
shares 
per share

100 (a)

$

4,000
100
100
100

(a)  Represents Normal Preferred Capital Securities.

Total

2018

2017

2016

$

per share
4,055.55 $
5,200.00
4,500.00
4,950.00
4,625.00

in millions
20
31
22
50
46
169

$

per share
4,055.55 $
5,200.00
4,500.00
4,950.00
5,254.51

in millions
20
31
22
50
52
175

$

$

per share
4,055.55 $
5,200.00
4,500.00
4,950.00
N/A

in millions
20
30
22
50
—
122

$

BNY Mellon 159 

Notes to Consolidated Financial Statements (continued)

The preferred stock is not subject to the operation of a 
sinking fund and is not convertible into, or 
exchangeable for, shares of our common stock or any 
other class or series of our other securities.  We may 
redeem the Series A or Series C preferred stock, in 
whole or in part, at our option.  We may also, at our 
option, redeem the shares of the Series D preferred 
stock, in whole or in part, on or after the dividend 
payment date in June 2023, the Series E preferred 
stock, in whole or in part, on or after the dividend 
payment date in June 2020, and the Series F preferred 
stock, in whole or in part, on or after the dividend 
payment date in September 2026.  The Series C, 
Series D, Series E or Series F preferred stock can be 
redeemed, in whole but not in part, at any time within 
90 days following a regulatory capital treatment event 
(as defined in each of the Series C, Series D, Series E 
and Series F’s Certificates of Designation).  
Redemption of the preferred stock is subject to the 
prior approval of the Federal Reserve.

Terms of the Series A, Series C, Series D, Series E 
and Series F preferred stock are more fully described 
in each of their Certificates of Designations, each of 
which is filed as an Exhibit to BNY Mellon’s Annual 
Report on Form 10-K for the year ended Dec. 31, 
2018.

Temporary equity

Temporary equity was $129 million at Dec. 31, 2018 
and $179 million at Dec. 31, 2017.  Temporary equity 
represents the redemption value recorded for 
redeemable noncontrolling interests resulting from 
equity-classified share-based payment arrangements 
that are currently redeemable or are expected to 
become redeemable. 

Capital adequacy

Regulators establish certain levels of capital for 
BHCs and banks, including BNY Mellon and our 
bank subsidiaries, in accordance with established 
quantitative measurements.  For the Parent to 
maintain its status as a FHC, our bank subsidiaries 
and BNY Mellon must, among other things, qualify 
as “well capitalized.” 

 160 BNY Mellon

As of Dec. 31, 2018 and Dec. 31, 2017, BNY Mellon 
and our U.S. bank subsidiaries were “well 
capitalized.”

Our consolidated and largest bank subsidiary, The 
Bank of New York Mellon, regulatory capital ratios 
are shown below.

Consolidated and largest bank 
subsidiary regulatory capital 
ratios (a)

Consolidated regulatory capital
ratios:
CET1 ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
SLR (c)

The Bank of New York Mellon
regulatory capital ratios:
CET1 ratio
Tier 1 capital ratio
Total capital ratio
Tier 1 leverage ratio
SLR (c)

Dec. 31,

2018

2017 (b)

10.7% 10.7%
12.8
13.6
6.6
6.0

12.7
13.4
6.6
N/A

14.0% 14.1%
14.3
14.7
7.6
6.8

14.4
14.7
7.6
N/A

(a)  For our CET1, Tier 1 capital and Total capital ratios, our 

effective capital ratios under U.S. capital rules are the lower 
of the ratios as calculated under the Standardized and 
Advanced Approaches, which for the periods noted above 
was the Advanced Approaches.  The Tier 1 leverage ratio is 
based on Tier 1 capital and quarterly average total assets.  
For BNY Mellon to qualify as “well capitalized,” its Tier 1 
capital and Total capital ratios must be at least 6% and 
10%, respectively.  For The Bank of New York Mellon, our 
largest bank subsidiary, to qualify as “well capitalized,” its 
CET1, Tier 1 capital, Total capital and Tier 1 leverage ratios 
must be at least 6.5%, 8%, 10% and 5%, respectively. 
(b)  Reflects transitional adjustments required in 2017 under the 

U.S. capital rules.

(c)  The SLR is based on Tier 1 capital and total leverage 

exposure, which includes certain off-balance sheet exposures 
and became a binding measure on Jan. 1, 2018.  For The 
Bank of New York Mellon to qualify as “well capitalized,” 
its SLR must be at least 6%.

Failure to satisfy regulatory standards, including 
“well capitalized” status or capital adequacy rules 
more generally, could result in limitations on our 
activities and adversely affect our financial condition.  
If a BHC such as BNY Mellon or bank such as The 
Bank of New York Mellon or BNY Mellon, N.A. fails 
to qualify as “adequately capitalized,” regulatory 
sanctions and limitations are imposed.  

Notes to Consolidated Financial Statements (continued)

The following table presents our capital components 
and RWAs determined under the Standardized and 
Advanced Approaches and the average assets used for 
leverage capital purposes.

The following table presents the amount of capital by 
which BNY Mellon and our largest bank subsidiary, 
The Bank of New York Mellon, exceeded the capital 
thresholds determined under U.S. capital rules.

Capital components and risk-

weighted assets

(in millions)
CET1:

Common shareholders’ equity
Adjustments for:

Goodwill and intangible assets (b)
Net pension fund assets
Equity method investments
Deferred tax assets
Other

Total CET1

Other Tier 1 capital:

Preferred stock
Deferred tax assets
Net pension fund assets
Other

Total Tier 1 capital

Tier 2 capital:

Subordinated debt
Allowance for credit losses
Other

Total Tier 2 capital –

Standardized Approach

Excess of expected credit losses
Less: Allowance for credit losses

Dec. 31,

2018

2017 (a)

$ 37,096 $ 37,859

(18,806)
(320)
(361)
(42)
—
17,567

(18,684)
(169)
(372)
(33)
(8)
18,593

3,542
—
—
(65)

3,542
(8)
(42)
(41)
$ 21,044 $ 22,044

$

1,250 $
252
(10)

1,492
65
252

1,250
261
(12)

1,499
31
261

Total Tier 2 capital – Advanced

Approach

$

1,305 $

1,269

Total capital:

Standardized Approach
Advanced Approach

Risk-weighted assets:

Standardized Approach
Advanced Approach:

Credit Risk
Market Risk
Operational Risk

Total Advanced Approach

Average assets for Tier 1 leverage
ratio
Total leverage exposure for SLR 
purposes (c)

$ 22,536 $ 23,543
$ 22,349 $ 23,313

$ 149,618 $ 155,621

$ 92,917 $ 101,681
3,657
68,688
$ 164,671 $ 174,026

3,454
68,300

$ 319,007 $ 331,600

$ 347,943

N/A

(a)  Reflects transitional adjustments to CET1, Tier 1 capital and 

Tier 2 capital required in 2017 under the U.S. capital rules.

(b)  Reduced by deferred tax liabilities associated with intangible 

assets and tax deductible goodwill.

(c)  SLR became a binding measure on Jan. 1, 2018.

Capital above thresholds at Dec. 31, 2018

Consolidated (a)

(in millions)
CET1
Tier 1 capital
Total capital
Tier 1 leverage ratio
SLR (c)
(a)  Based on minimum required standards, with applicable 

5,217 $
6,224
4,235
8,284
3,647

$

The Bank of
New York
Mellon (b)
10,036
8,372
6,273
6,441
2,336

buffers.

(b)  Based on well capitalized standards.
(c)  SLR became a binding measure on Jan. 1, 2018.

BNY Mellon 161 

Notes to Consolidated Financial Statements (continued)

Note 15–Other comprehensive income (loss)

Components of other comprehensive

income (loss)

Year ended Dec. 31,

(in millions)

Foreign currency translation:

Foreign currency translation adjustments arising 

during the period (a)
Total foreign currency translation

Unrealized (loss) gain on assets available-for-sale:

Unrealized (loss) gain arising during period
Reclassification adjustment (b)

Net unrealized (loss) gain on assets available-

for-sale

Defined benefit plans:

Net (loss) gain arising during the period
Foreign exchange adjustment
Amortization of prior service credit, net loss and 

initial obligation included in net periodic 
benefit cost (b)

Total defined benefit plans

Unrealized (loss) gain on cash flow hedges:

Unrealized hedge (loss) gain arising during

period

Reclassification of net (gain) loss to net income:

FX contracts - trading revenue
FX contracts - other revenue
FX contracts - net interest revenue
FX contracts - staff expense

Total reclassifications to net income (b)

Net unrealized (loss) gain on cash flow

hedges

2018

Tax
(expense)
benefit

Pre-tax
amount

After-tax
amount

Pre-tax
amount

2017

Tax
benefit
(expense)

After-tax
amount

Pre-tax
amount

2016

Tax
(expense)
benefit

After-tax
amount

$

(157) $

(156) $

(313) $

659 $

194 $

(157)

(156)

(313)

659

194

(542)
48

(494)

(244)
—

93

(151)

126
(12)

114

55
—

(24)

31

(416)
36

(380)

(189)
—

69

(120)

237
(3)

234

454
1

100

555

(84)
—

(84)

(112)
—

(32)

(144)

853

853

153
(3)

150

342
1

68

411

$

(518) $

(332) $

(518)

(332)

(388)
(75)

(463)

(151)
(1)

88

(64)

146
26

172

43
1

(31)

13

(850)

(850)

(242)
(49)

(291)

(108)
—

57

(51)

(15)

4

(11)

33

(9)

24

(52)

18

(34)

—
(2)
—
4
2

(13)

—
—
—
(1)
(1)

3

—
(2)
—
3
1

(10)

(2)
(8)
—
(10)
(20)

13

1
2
—
2
5

(4)

(1)
(6)
—
(8)
(15)

9

16
—
18
11
45

(7)

(6)
—
(6)
(3)
(15)

3

10
—
12
8
30

(4)

Total other comprehensive (loss) income

$

(815) $

(8) $

(823) $

1,461 $

(38) $

1,423

$ (1,052) $

(144) $ (1,196)

Includes the impact of hedges of net investments in foreign subsidiaries.  See Note 22 for additional information.

(a) 
(b)  The reclassification adjustment related to the unrealized gain (loss) on assets available-for-sale is recorded as net securities gains on the consolidated 

income statement.  The amortization of prior service credit, net loss and initial obligation included in net periodic benefit cost is recorded as staff expense 
on the consolidated income statement.  See Note 22 for the location of the reclassification adjustment related to cash flow hedges on the consolidated 
income statement.

Changes in accumulated other comprehensive income (loss) attributable to The Bank of New York Mellon Corporation shareholders

(in millions)

2015 ending balance
Change in 2016

2016 ending balance

Change in 2017

2017 ending balance

Adjustment for the cumulative effect of applying

ASU 2017-12 for derivatives and hedging

Adjusted balance at Jan. 1, 2018

Change in 2018

2018 ending balance

Foreign
currency
translation

ASC 820 Adjustments

Other post-
retirement
benefits

Pensions

Unrealized gain
(loss) on assets
available-for-
sale

Unrealized
gain (loss) on
cash flow
hedges

Total accumulated
other comprehensive
income (loss), 
net of tax

$

$

$

$

(1,632)
(819)
(2,451)
838
(1,613)

—

(1,613)
(302)
(1,915)

$

$

$

$

(1,250)
(56)
(1,306)
419
(887)

—

(887)
(118)
(1,005)

$

$

$

$

(47)
5
(42)
(8)
(50)

—

(50)
(2)
(52)

$

$

$

$

327
(291)
36
150
186

(2)

184
(380)
(196)

$

$

$

$

2
(4)
(2)
9
7

—

7
(10)
(3)

$

$

$

$

(2,600)
(1,165)
(3,765)
1,408
(2,357)

(2)

(2,359)
(812)
(3,171)

 162 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Note 16–Stock-based compensation

Stock options

Our Long-Term Incentive Plans provide for the 
issuance of stock options, restricted stock, restricted 
stock units (“RSUs”) and other stock-based awards to 
employees and directors of BNY Mellon.  At Dec. 31, 
2018, under the Long-Term Incentive Plan approved 
in April 2014, we may issue 23,524,349 new stock-
based awards.  Of this amount, 8,761,715 shares 
(subject to potential increase as provided in the Long-
Term Incentive Plan) may be issued as restricted 
stock or RSUs.  Stock-based compensation expense 
related to retirement eligibility vesting totaled $93 
million in 2018, $109 million in 2017 and $106 
million in 2016.

Our Long-Term Incentive Plans provide for the 
issuance of stock options at fair market value at the 
date of grant to officers and employees of BNY 
Mellon.  Generally, each option granted is exercisable 
between one and 10 years from the date of grant.  No 
stock options were granted in 2018, 2017 and 2016.

Compensation costs that were charged against income 
were less than $1 million in both 2018 and 2017 and 
$2 million in 2016.  The income tax benefit 
recognized in the consolidated income statement 
related to compensation costs was less than $1 
million in 2018 and 2017 and $1 million in 2016.

A summary of the status of our options as of Dec. 31, 2018, and changes during the year, is presented below:

Stock option activity

Balance at Dec. 31, 2017
Granted
Exercised
Canceled/Expired
Balance at Dec. 31, 2018
Vested and expected to vest at Dec. 31, 2018
Exercisable at Dec. 31, 2018

Stock options outstanding at Dec. 31, 2018

Shares subject
to option
9,302,140 $

—
(2,539,135)
(48,722)
6,714,283 $
6,714,283
6,714,283

Weighted-average
exercise price
27.27
—
31.29
37.56
25.67
25.67
25.67

Weighted-average 
remaining contractual 
term (in years)
2.7

2.0
2.0
2.0  

Options outstanding
Weighted-average 
Weighted-average
remaining contractual 
exercise price
life (in years)
25.67
2.0
(a)  At Dec. 31, 2017 and Dec. 31, 2016, 9,302,140 and 21,241,568 options were exercisable at a weighted-average price per common share 

Weighted-average
exercise price
25.67

Range of exercise prices
$ 18 to 31

Outstanding
6,714,283

Exercisable
6,714,283

Options exercisable (a)

$

$

of $27.27 and $32.57, respectively.

Aggregate intrinsic value of options
(in millions)
Outstanding at Dec. 31,
Exercisable at Dec. 31,

$
$

2018
144 $
144 $

2017

247 $
247 $

2016
315
315

$3 million in 2016.  Consistent with the adoption of 
ASU 2016-09, the tax benefits in 2018 and 2017 were 
recognized in the provision for income taxes and in 
2016 were recorded to additional paid-in capital.

The total intrinsic value of options exercised was $61 
million in 2018, $159 million in 2017 and $122 
million in 2016.

Cash received from option exercises totaled $80 
million in 2018, $431 million in 2017 and $438 
million in 2016.  The actual excess tax benefit 
realized for the tax deductions from options exercised 
totaled $10 million in 2018, $16 million in 2017 and 

Restricted stock, RSUs and Performance share units

Restricted stock and RSUs are granted under our 
long-term incentive plans at no cost to the recipient.  
These awards are subject to forfeiture until certain 
restrictions have lapsed, including continued 
employment, for a specified period.  The recipient of 
a share of restricted stock is entitled to voting rights 
and generally is entitled to dividends on the common 

BNY Mellon 163 

Notes to Consolidated Financial Statements (continued)

stock.  An RSU entitles the recipient to receive a 
share of common stock after the applicable 
restrictions lapse.  The recipient generally is entitled 
to receive cash payments equivalent to any dividends 
paid on the underlying common stock during the 
period the RSU is outstanding but does not receive 
voting rights.

The fair value of restricted stock and RSUs is equal to 
the fair market value of our common stock on the 
date of grant.  The expense is recognized over the 
vesting period, which is generally zero to four years.  
The total compensation expense recognized for 
restricted stock and RSUs was $270 million in 2018, 
$273 million in 2017 and $256 million in 2016.  The 
total income tax benefit recognized in the 
consolidated income statement related to 
compensation costs was $65 million in 2018, $66 
million in 2017 and $91 million in 2016.

BNY Mellon’s Executive Committee members were 
granted a target award of 362,798 performance share 
units (“PSUs”) in 2018, 793,847 in 2017 and 548,391 
in 2016.  The 2018 awards cliff vest in 3 years based 
on average revenue growth and average operating 
margin, both as adjusted.  These awards are classified 
as equity and marked-to-market to earnings as the 
earnout percentages are determined at the discretion 
of the Human Resources Compensation Committee 
based on a payout table.  The 2017 and 2016 awards 
cliff vest in 3 years based on operating earnings per 
share with the potential of a risk modifier based on 
appropriate growth in RWAs.  These awards are 
liability classified as they contain an interest rate 
condition that is not linked to performance or market 
and marked-to-market to earnings as the earnout 
percentages are determined at the discretion of the 
Human Resources Compensation Committee based 
on a payout table.

The following table summarizes our non-vested PSU, 
restricted stock and RSU activity for 2018. 

Non-vested PSU, restricted stock
and RSU activity

Weighted-
average fair
value at grant
date

Number of
shares

Non-vested PSUs, restricted stock

and RSUs at Dec. 31, 2017

Granted
Vested
Forfeited
Non-vested PSUs, restricted
stock and RSUs at Dec. 31, 2018

16,731,332 $
5,125,001
(7,005,313)
(639,308)

14,211,712 $

42.42
57.67
39.06
45.90

49.43

 164 BNY Mellon

As of Dec. 31, 2018, $207 million of total 
unrecognized compensation costs related to non-
vested PSUs, restricted stock and RSUs is expected to 
be recognized over a weighted-average period of 2.1 
years.

The total fair value of restricted stock, RSUs and 
PSUs that vested was $289 million in 2018, $260 
million in 2017 and $236 million in 2016.  The actual 
excess tax benefit realized for the tax deductions from 
shares vested totaled $26 million in 2018, $34 million 
in 2017 and $8 million in 2016.  Consistent with the 
adoption of ASU 2016-09, the tax benefits in 2018 
and 2017 were recognized in the provision for income 
taxes and in 2016 were recorded to additional paid-in 
capital.

Subsidiary Long-Term Incentive Plans

BNY Mellon also has several subsidiary Long-Term 
Incentive Plans which have issued restricted 
subsidiary shares to certain employees.  These share 
awards are subject to forfeiture until certain 
restrictions have lapsed, including continued 
employment for a specified period of time.  The 
shares are non-voting and non-dividend paying.  
Once the restrictions lapse, which generally occurs in 
three to five years, the shares can only be sold, at the 
option of the employee, to BNY Mellon at a price 
based generally on the fair value of the subsidiary at 
the time of repurchase.  In certain instances BNY 
Mellon has an election to call the shares. 

Note 17–Employee benefit plans

BNY Mellon has defined benefit and/or defined 
contribution retirement plans and other post-
retirement plans providing healthcare benefits.

The defined benefit pension plans cover 
approximately 12,400 U.S. employees and 
approximately 14,700 non-U.S. employees.

BNY Mellon has one qualified and several non-
qualified defined benefit pension plans in the U.S. 
and several pension plans overseas.

Effective June 30, 2015, the benefit accruals under 
the U.S. qualified and nonqualified defined benefit 
plans were frozen.  This change resulted in no 
additional benefits being earned by participants in 
those plans based on service or pay after June 30, 
2015.  These plans were previously closed to new 

Notes to Consolidated Financial Statements (continued)

participants effective Dec. 31, 2010, at which time a 
non-elective contribution was added to the 
Company’s defined contribution plan for employees 
not eligible to join the pension plan.  Employees 
previously participating in the pension plan received 
this non-elective contribution starting July 1, 2015.

Effective Dec. 31, 2018, the benefit accruals were 
frozen under our largest foreign plan, which covers 

Pension and post-retirement healthcare plans

certain UK employees.  This change results in no 
additional benefits being earned by participants in 
that plan based on service or pay after Dec. 31, 2018.  
Most UK employees currently earn benefits only on a 
defined contribution basis.  UK employees impacted 
by the pension plan freeze will begin earning benefits 
on a defined contribution basis in 2019.

The following tables report the combined data for our domestic and foreign defined benefit pension and post-
retirement healthcare plans.

(dollar amounts in millions)
Weighted-average assumptions used to determine benefit
obligations

Discount rate
Rate of compensation increase
Cash balance interest crediting rate
Change in benefit obligation (a)
Benefit obligation at beginning of period
Service cost
Interest cost
Employee contributions
Actuarial gain (loss)
Curtailments
Benefits paid
Foreign exchange adjustment

Benefit obligation at end of period
Change in fair value of plan assets
Fair value at beginning of period
Actual return on plan assets
Employer contributions
Employee contributions
Benefit payments
Foreign exchange adjustment
Fair value at end of period
Funded status at end of period

Amounts recognized in accumulated other comprehensive
loss (income) consist of:

Pension Benefits

Healthcare Benefits

Domestic
2018

Foreign

2017

2018

2017

Domestic
2018

Foreign

2017

2018

2017

4.45%
N/A

4.00

3.97%
N/A

4.00

2.95%
2.98

N/A

2.45%
3.02

N/A

4.45%
3.00

N/A

3.97%
3.00

N/A

3.10%
N/A
N/A

2.50%
N/A
N/A

$ (4,405)
—
(169)
—
219
—
232
N/A
(4,123)

$ (4,274)
—
(180)
—
(165)
—
214
N/A
(4,405)

$ (1,322)
(28)
(32)
—
173
11
25
69
(1,104)

5,496
(257)
33
—
(232)
N/A

4,906
783
21
—
(214)
N/A

5,040
917

$

5,496
$ 1,091

$

1,393
1
22
—
(25)
(75)
1,316
212

$ (1,248)
(31)
(33)
(1)
88
—
31
(128)
(1,322)

1,090
128
93
1
(31)
112
1,393
71

$

$ (175)
(1)
(7)
—
22
—
12
N/A
(149)

107
(8)
12
—
(12)
N/A
99
(50)

$

$

$

(169)
(1)
(7)
—
(10)
—
12
N/A
(175)

97
10
12
—
(12)
N/A
107
(68)

$

$

(4)
—
—
—
(1)
—
—
—
(5)

—
—
—
—
—
—
—
(5)

$

$

Net loss (gain)
Prior service cost (credit)
Total (before tax effects)

$ — $
—
$ — $
(a)  The benefit obligation for pension benefits is the projected benefit obligation, and for healthcare benefits, it is the accumulated benefit obligation.

$ 1,294
—
$ 1,294

$ 1,598
—
$ 1,598

84
(40)
44

97
(49)
48

255
1
256

105
1
106

$

$

$

$

$

$

$

$

(2)
—
—
—
(1)
—
—
(1)
(4)

—
—
—
—
—
—
—
(4)

(1)
—
(1)

A number of key assumptions and measurement date 
values determine pension expense.  The key elements 
include the long-term rate of return on plan assets, the 
discount rate, the market-related value of plan assets 
and the price used to value stock in the Employee 
Stock Ownership Plan (“ESOP”). 

The discount rate for U.S. pension plans was 
determined after reviewing equivalent rates obtained 
by discounting the pension plans’ expected cash flows 
using various high-quality, long-term corporate bond 
yield curves.  We also reviewed the results of several 
models that matched bonds to our pension cash flows.  
After reviewing the various indices and models, we 
selected a discount rate of 4.45% as of Dec. 31, 2018.

BNY Mellon 165 

Notes to Consolidated Financial Statements (continued)

The discount rates for foreign pension plans are based 
on high-quality corporate bond rates in countries that 
have an active corporate bond market.  In those 
countries with no active corporate bond market, 
discount rates are based on local government bond 
rates plus a credit spread.  

Actuarial gains (loss) on the benefit obligation for 
both the domestic and foreign pension plans in 2018, 
as well as the domestic pension plans in 2017, were 
primarily attributable to changes in discount rates.  
The actuarial gain on the benefit obligation for 
foreign pension plans in 2017 was primarily 
attributable to a decrease in assumed inflation rates 
for pension plans in the UK.

Net periodic benefit (credit) cost

Pension Benefits

Healthcare Benefits

Domestic
2017

2018

2016

2018

Foreign
2017

2016

2018

Domestic
2017

2016

2018

Foreign
2017

2016

$ 108

$

97

N/A

$ 102

N/A
3.97% 4.35% 4.48% 2.50% 2.60% 3.60%
6.625
N/A
3.00
N/A
N/A

N/A
N/A
N/A

N/A
N/A
N/A

6.625
3.00

7.00
3.00

N/A

N/A

N/A

N/A

$

$

1
7
(8)

(9)
7
—
(2)

$

$

$

1
7
(7)

1
8
(7)

$ — $ — $ —
—
—

—
—

—
—

(10)
8
—

—
(10)
—
—
6
—
—
—
—
(3) $ — $ — $ — $ —

—
—
—

Pension Benefits

Domestic

Foreign

Healthcare Benefits
Domestic

377 $
(73)
—
304 $

(128) $
(22)
—
(150) $

(6) $
(7)
9
(4) $

Foreign
1
—
—
1  

Domestic
2018

Foreign

2017

2018

2017

1,077 $
(160)
917 $

1,282
(191)
1,091

$

$

(50) $
(50) $

(68) $
(68) $

280 $
(68)
212 $

(5) $
(5) $

134
(63)
71

(4)
(4)

(dollar amounts in millions)
Weighted-average assumptions as
of Jan. 1:

Market-related value of plan assets
Discount rate
Expected rate of return on plan assets
Rate of compensation increase
Cash balance interest crediting rate
Components of net periodic benefit
(credit) cost :

Service cost
Interest cost
Expected return on assets
Amortization of:

Prior service cost (credit)
Net actuarial loss

Settlement loss

Net periodic benefit (credit) cost

$

$ 5,238

$ 5,026

$ 4,830

$ 1,266

$ 994

$ 994

3.97% 4.35% 4.48%
6.625

6.625

7.00

N/A

4.00

N/A

4.00

N/A

4.00

$ — $ — $ — $
180
(325)

182
(330)

169
(339)

2.45% 2.53% 3.45%
4.56
4.61
3.02
3.60

5.35
3.51

N/A

N/A

N/A

28
32
(57)

$ 31
33
(50)

$ 29
36
(51)

—
68
5
(97)

$

—
67
2
(76) $

—
69
2
(77)

—
22
—
25

—
35
—
$ 49

1
17
1
$ 33

$

$

$

$

$

$
$

Changes in other comprehensive loss (income) in 2018
(in millions)
Net loss (gain) arising during period
Recognition of prior years’ net (loss)
Recognition of prior years’ service credit

Total recognized in other comprehensive (income) loss (before tax effects)

(in millions)
Pension benefits:
Prepaid benefit cost
Accrued benefit cost

Total pension benefits

Healthcare benefits:
Accrued benefit cost

Total healthcare benefits

 166 BNY Mellon

Notes to Consolidated Financial Statements (continued)

The accumulated benefit obligation for all defined benefit plans was $5.2 billion at Dec. 31, 2018 and $5.7 billion at 
Dec. 31, 2017.

Plans with obligations in excess of plan

Pension Benefits

assets
(in millions)
Projected benefit obligation
Fair value of plan assets
Accumulated benefit obligation
Fair value of plan assets
(a)  Amounts reported in 2017 have been revised based on the clarification provided in ASU 2018-14.

Domestic
2018
160 $
—
160
—

2017
244 (a)
181 (a)
61
25

2018
245 $
177
67
27

2017
191
—
191
—

Foreign

$

$

Healthcare Benefits

Domestic
2018
N/A
N/A
80
—

2017
N/A
N/A
88
—

Foreign

2018
N/A
N/A
5
—

2017
N/A
N/A
4
—

Assumed healthcare cost trend 

Plan contributions

The assumed healthcare cost trend rate used in 
determining domestic benefit expense for 2019 is 
6.00%, decreasing to 4.75% in 2024 for pre-Medicare 
costs and 5.50% decreasing to 4.75% in 2022 for 
Medicare costs.  This projection is based on various 
economic models that forecast a decreasing growth 
rate of healthcare expenses over time.  The 
underlying assumption is that healthcare expense 
growth cannot outpace gross national product growth 
indefinitely, and over time a lower equilibrium 
growth rate will be achieved.  Further, the ultimate 
growth rate of 4.75% bears a reasonable relationship 
to the discount rate.  In addition, 2020 costs are 
assumed to increase beyond the assumed health care 
cost trend rate for 2019 due to the assumed 
reinstatement of the health insurer fee which was 
waived. 

The following benefit payments for BNY Mellon’s 
pension and healthcare plans, which reflect expected 
future service as appropriate, are expected to be paid 
over the next 10 years: 

Expected benefit payments
(in millions)
Pension benefits:
2019
Year
2020
2021
2022
2023
2024-2028

Total pension benefits
Healthcare benefits:
2019
Year
2020
2021
2022
2023
2024-2028
Total healthcare benefits

Domestic

Foreign

$

$

$

$

265
266
264
261
266
1,297
2,619

11
12
12
11
11
50
107

$

$

$

$

19
20
20
22
24
130
235

—
—
—
—
—
1
1

BNY Mellon expects to make cash contributions to 
fund its defined benefit pension plans in 2019 of $14 
million for the domestic plans and $19 million for the 
foreign plans.

BNY Mellon expects to make cash contributions to 
fund its post-retirement healthcare plans in 2019 of 
$11 million for the domestic plans and less than $1 
million for the foreign plans.

Investment strategy and asset allocation

BNY Mellon is responsible for the administration of 
various employee pension and healthcare post-
retirement benefits plans, both domestically and 
internationally.  The domestic plans are administered 
by BNY Mellon’s Benefits Administration 
Committee, a named fiduciary.  Subject to the 
following, at all relevant times, BNY Mellon’s 
Benefits Investment Committee, another named 
fiduciary to the domestic plans, is responsible for the 
investment of plan assets.  The Benefits Investment 
Committee’s responsibilities include the investment 
of all domestic defined benefit plan assets, as well as 
the determination of investment options offered to 
participants in all domestic defined contribution 
plans.  The Benefits Investment Committee conducts 
periodic reviews of investment performance, asset 
allocation and investment manager suitability.  In 
addition, the Benefits Investment Committee has 
oversight of the Regional Governance Committees 
for the foreign defined benefit plans.

Our investment objective for U.S. and foreign plans is 
to maximize total return while maintaining a broadly 
diversified portfolio for the primary purpose of 
satisfying obligations for future benefit payments.  

BNY Mellon 167 

Notes to Consolidated Financial Statements (continued)

Equities are the main holding of the plans.  
Alternative investments (including private equities) 
and fixed-income securities provide diversification 
and, in certain cases, lower the volatility of returns.  
In general, equity securities and alternative 
investments within any domestic plan’s portfolio can 
be maintained in the range of 30% to 70% of total 
plan assets, fixed-income securities can range from 
20% to 50% of plan assets and cash equivalents can 
be held in amounts ranging from 0% to 5% of plan 
assets.  Actual asset allocation within the approved 
ranges varies from time to time based on economic 
conditions (both current and forecast) and the advice 
of professional advisors.

Our pension assets were invested as follows at Dec. 
31, 2018 and Dec. 31, 2017:

Asset allocations

Equities
Fixed income
Alternative investment
Private equities
Real estate
Cash

Total pension benefits

Domestic
2018
2017
52% 63%
45
2
1
—
—
100% 100%

33
2
1
—
1

Foreign

2018
2017
48% 51%
36
9
—
4
3

33
9
—
4
3

100% 100%

We held no The Bank of New York Mellon 
Corporation stock in our pension plans at Dec. 31, 
2018 and Dec. 31, 2017.  Assets of the U.S. post-
retirement healthcare plan are invested in an 
insurance contract.  

Fair value measurement of plan assets

In accordance with ASC 715, Compensation - 
Retirement Benefits, BNY Mellon has established a 
three-level hierarchy for fair value measurements of 
its pension plan assets based upon the transparency of 
inputs to the valuation of an asset as of the 
measurement date.  The valuation hierarchy is 
consistent with guidance in ASC 820, Fair Value 
Measurement, which is detailed in Note 19.

The following is a description of the valuation 
methodologies used for assets measured at fair value, 
as well as the general classification of such assets 
pursuant to the valuation hierarchy.  

 168 BNY Mellon

Cash and currency

This category consists primarily of foreign currency 
balances and is included in Level 1 of the valuation 
hierarchy.  Foreign currency is translated monthly 
based on current exchange rates.

Common and preferred stock and mutual funds

These investments include equities and mutual funds 
and are valued at the closing price reported in the 
active market in which the individual securities are 
traded, if available.  Where there are no readily 
available market quotations, we determine fair value 
primarily based on pricing sources with reasonable 
levels of price transparency.  Common and preferred 
stock and mutual funds are included in Level 1 of the 
valuation hierarchy.

Collective trust funds 

Collective trust funds include commingled and U.S. 
equity funds that have no readily available market 
quotations.  The fair value of the funds is based on 
the securities in the portfolio, which typically are the 
amount that the fund might reasonably expect to 
receive for the securities upon a sale.  These funds are 
valued using observable inputs on either a daily or 
monthly basis.  Collective trust funds are included in 
Level 2 of the valuation hierarchy.

Fixed-income investments

Fixed-income investments include U.S. Treasury 
securities, U.S. government agencies, sovereign 
government obligations, U.S. corporate bonds and 
foreign corporate debt funds.  U.S. Treasury securities 
are valued at the closing price reported in the active 
market in which the individual security is traded and 
included as Level 1 of the valuation hierarchy.  U.S. 
government agencies, sovereign government 
obligations, U.S. corporate bonds and foreign 
corporate debt funds are valued based on quoted 
prices for comparable securities with similar yields 
and credit ratings.  When quoted prices are not 
available for identical or similar bonds, the bonds are 
valued using discounted cash flows that maximize 
observable inputs, such as current yields of similar 
instruments, but includes adjustments for certain risks 
that may not be observable, such as credit and 
liquidity risks.  U.S. government agencies, sovereign 
government obligations, U.S. corporate bonds and 

Notes to Consolidated Financial Statements (continued)

foreign corporate debt funds are primarily included in 
Level 2 of the valuation hierarchy.

Other assets measured at NAV

Other assets measured at NAV include funds of funds 
and venture capital and partnership interests, property 
funds and other funds.  There are no readily available 
market quotations for these funds.  The fair value of 
the funds of funds is based on NAVs of the funds in 
the portfolio, which reflects the value of the 
underlying securities.  The fair value of the 
underlying securities is typically the amount that the 
fund might reasonably expect to receive upon selling 
those hard to value or illiquid securities within the 
portfolios.  These funds are either valued on a daily or 
monthly basis.  The fair value of the venture capital 
and partnership interests is based on the pension 
plan’s ownership percentage of the fair value of the 
underlying funds as provided by the fund managers.  
These funds are typically valued on a quarterly basis.  
The pension plan’s venture capital and partnership 
interests are valued at NAV as a practical expedient 
for fair value.  

The following tables present the fair value of each 
major category of plan assets as of Dec. 31, 2018 and 
Dec. 31, 2017, by captions and by ASC 820, Fair 
Value Measurement, valuation hierarchy. 

Plan assets measured at fair value on a recurring basis—

domestic plans at Dec. 31, 2018

(in millions)

Level 1 Level 2 Level 3

Common and preferred stock:

Total fair
value

U.S. equity
Non-U.S. equity
Collective trust funds:

Commingled
U.S. equity
Fixed income:

U.S. Treasury securities
U.S. government agencies
Sovereign government

obligations

U.S. corporate bonds
Other

Mutual funds

Total domestic plan assets in

the fair value hierarchy
Other assets measured at NAV:

Funds of funds
Venture capital and

partnership interests

Total domestic plan assets, at

fair value

$ 1,514 $ — $ — $
—

160

—

—
—

630
—

3

—
—
114

435
934

—
44

5

972
69
—

—
—

—
—

—

—
—
—

1,514
160

435
934

630
44

8

972
69
114

$ 2,421 $ 2,459 $ — $

4,880

130

30

$

5,040  

Total fair
value
194

Plan assets measured at fair value on a recurring basis—

foreign plans at Dec. 31, 2018

(in millions)

Level 1 Level 2 Level 3

Equity funds
Sovereign/government

obligation funds
Corporate debt funds
Cash and currency

Total foreign plan assets in
the fair value hierarchy
Other assets measured at NAV
Total foreign plan assets, at

fair value

$ — $

194 $ — $

—

—
356

126

418
—

—

—
—

126

418
356

$

356 $

738 $ — $

1,094

222

$

1,316  

Plan assets measured at fair value on a recurring basis—

domestic plans at Dec. 31, 2017

(in millions)

Level 1 Level 2 Level 3

Common and preferred stock:

Total fair
value

U.S. equity
Non-U.S. equity
Collective trust funds:

Commingled
U.S. equity
Fixed income:

U.S. Treasury securities
U.S. government agencies
Sovereign government

obligations

U.S. corporate bonds
Other

Mutual funds

Total domestic plan assets in

the fair value hierarchy
Other assets measured at NAV:

Funds of funds
Venture capital and

partnership interests

Total domestic plan assets, at

fair value

$ 1,815 $ — $ — $
—

243

—

193
—
— 1,389

452
—

5

—
—
163

—
48

6

910
100
—

—
—

—
—

—

—
—
—

1,815
243

193
1,389

452
48

11

910
100
163

$ 2,678 $ 2,646 $ — $

5,324

129

43

$

5,496  

Plan assets measured at fair value on a recurring basis—

foreign plans at Dec. 31, 2017

(in millions)

Level 1 Level 2 Level 3

Equity funds
Sovereign/government

obligation funds
Corporate debt funds
Cash and currency

Total foreign plan assets in
the fair value hierarchy
Other assets measured at NAV
Total foreign plan assets, at fair

value

Total fair
value
711

$

434 $

277 $ — $

—

—
41

104

345
—

—

—
—

104

345
41

$

475 $

726 $ — $

1,201

192

$

1,393  

BNY Mellon 169 

Notes to Consolidated Financial Statements (continued)

Changes in Level 3 fair value measurements

Assets valued using NAV at Dec. 31, 2017

The table below presents a rollforward of the plan 
assets, for the year ended Dec. 31, 2017 (including 
the change in fair value), for financial instruments 
classified in Level 3 of the valuation hierarchy.

Fair value measurements using significant unobservable
inputs—foreign plans—for the year ended Dec. 31, 2017

(in millions)
Fair value at Dec. 31, 2016
Transfers out of Level 3
Total gains included in plan assets

Fair value at Dec. 31, 2017

Change in unrealized gains or (losses) for the

period included in earnings for assets held at the
end of the reporting period

Corporate
debt funds
17
$
(20)
3
—

$

$

—

(dollar amounts
in millions)

Fair
value

Unfunded
commitments

Redemption
frequency

$ 152 $

—

Monthly

Redemption
notice
period
30-45 days

Funds of funds (a)
Venture capital and 

partnership 
interests (b)

Property funds (c)
Corporate debt
Other contracts (d)

Total

128

51
20
13
$ 364 $

49

—
—
—
49

N/A

Monthly
N/A
N/A

N/A

0-90 days
N/A
N/A

(a)  Funds of funds include multi-strategy hedge funds that utilize 

investment strategies that invest over both long-term investment and 
short-term investment horizons.

(b)  Venture capital and partnership interests do not have redemption 
rights. Distributions from such funds will be received as the 
underlying investments are liquidated.

(c)  Property funds include funds invested in regional real estate 
vehicles that hold direct interest in real estate properties.
(d)  Other contracts include assets invested in pooled accounts at 

insurance companies that are privately valued by the asset manager.

Funds of funds and venture capital and partnership 
interests valued using NAV per share

Defined contribution plans

BNY Mellon had pension and post-retirement plan 
assets invested in funds of funds, venture capital and 
partnership interests, property funds and other 
contracts valued using NAV.  The funds of funds 
investments are redeemable at NAV under agreements 
with the funds of funds managers.

Assets valued using NAV at Dec. 31, 2018

(dollar amounts
in millions)

Fair
value

Unfunded
commitments

Redemption
frequency

Funds of funds (a)
Venture capital and 

partnership 
interests (b)

Property funds (c)
Corporate debt

Other contracts (d)

Total

$ 147 $

148

52
19

16
$ 382 $

Monthly

N/A

Monthly
N/A

N/A

—

—

—
—

—
—

Redemption
notice
period
30-45 days

N/A

0-90 days
N/A

N/A

 170 BNY Mellon

BNY Mellon sponsors defined contribution plans in 
the U.S. and in certain non-U.S. locations, all of 
which are administered in accordance with local laws.  
The most significant defined contribution plan is The 
Bank of New York Mellon Corporation 401(k) 
Savings Plan sponsored by the Company in the U.S. 
and covers substantially all U.S. employees.  

Under The Bank of New York Mellon Corporation 
401(k) Savings Plan, the Company matched 100% of 
the first 4% of an employee’s eligible base pay plus 
50% of the next 2% of eligible pay contributed by the 
participant for a maximum matching contribution of 
5% for 2018, 2017 and 2016, subject to statutory 
limits. 

The U.S. qualified and nonqualified defined benefit 
plans were closed to new participants effective Dec. 
31, 2010, at which time an annual non-elective 
contribution equal to 2% of eligible base pay was 
added to The Bank of New York Mellon Corporation 
401(k) Savings Plan. 

At Dec. 31, 2018 and Dec. 31, 2017, The Bank of 
New York Mellon Corporation 401(k) Savings Plan 
owned 12.7 million and 13.2 million shares of our 
common stock, respectively.  The fair value of total 
assets was $6.2 billion at Dec. 31, 2018 and $6.6 
billion at Dec. 31, 2017.  We recorded expense of 
$244 million in 2018, $232 million in 2017 and $224 
million in 2016 primarily for contributions to our 
defined contribution plans. 

Notes to Consolidated Financial Statements (continued)

We also have an ESOP covering certain domestic 
full-time employees hired on or before July 1, 2008.  
The ESOP works in conjunction with the defined 
benefit pension plan.  Employees are entitled to the 
higher of their benefit under the ESOP or such 
defined benefit pension plan at retirement.  Benefits 
payable under the defined benefit pension plan are 
offset by the equivalent value of benefits earned 
under the ESOP. 

At Dec. 31, 2018 and Dec. 31, 2017, the ESOP 
owned 5.0 million and 5.4 million shares of our 
common stock, respectively.  The fair value of total 
ESOP assets was $236 million at Dec. 31, 2018 and 
$293 million at Dec. 31, 2017.  The Company is not 
permitted to make contributions to the ESOP.  

The Benefits Investment Committee appointed 
Fiduciary Counselors, Inc. to serve as the 
independent fiduciary to (i) make all fiduciary 
decisions related to the continued prudence of 
offering the common stock of BNY Mellon or its 
affiliates as an investment option under the plans, 
other than plan sponsor decisions, and (ii) select and 
monitor any actively or passively managed 
investments of BNY Mellon or its affiliates to be 
offered to participants as investment options under 
the plans, excluding self-directed accounts.

Note 18–Company financial information 
(Parent Corporation) 

In connection with our single point of entry resolution 
strategy, we have established an IHC to facilitate the 
provision of capital and liquidity resources to certain 
key subsidiaries in the event of material financial 
distress or failure.  In 2017, we entered into a binding 
support agreement with those key subsidiaries and 
other related entities that requires the IHC to provide 
that support.  The support agreement requires the 
Parent to transfer cash and other liquid financial 
assets to the IHC, subject to certain amounts retained 
by the Parent to meet its near-term cash needs.  The 
Parent’s and the IHC’s obligations under the support 
agreement are secured.  The IHC has provided the 
Parent with a committed line of credit that allows the 
Parent to draw funds necessary to service near-term 
obligations.  As a result, during business-as-usual 
circumstances, the Parent is expected to continue to 
have access to the funds necessary to pay dividends, 
repurchase common stock, service its debt and satisfy 
its other obligations.  If our projected liquidity 
resources deteriorate so severely that resolution of the 

Parent becomes imminent, the committed line of 
credit the IHC provided to the Parent will 
automatically terminate, with all amounts outstanding 
becoming due and payable, and the support 
agreement will require the Parent to transfer most of 
its remaining assets (other than stock in subsidiaries 
and a cash reserve to fund bankruptcy expenses) to 
the IHC.  As a result, during a period of severe 
financial stress, the Parent could become unable to 
meet its debt and payment obligations (including with 
respect to its securities), causing the Parent to seek 
protection under bankruptcy laws earlier than it 
otherwise would have.

Our bank subsidiaries are subject to dividend 
limitations under the Federal Reserve Act, as well as 
national and state banking laws.  Under these statutes, 
prior regulatory consent is required for dividends in 
any year that would exceed the bank’s net profits for 
such year combined with retained net profits for the 
prior two years.  Additionally, such bank subsidiaries 
may not declare dividends in excess of net profits on 
hand, as defined, after deducting the amount by 
which the principal amount of all loans, on which 
interest is past due for a period of six months or more, 
exceeds the allowance for credit losses. 

The payment of dividends also is limited by 
minimum capital requirements imposed on banks.  As 
of Dec. 31, 2018, BNY Mellon’s bank subsidiaries 
exceeded these minimum requirements.

Subsequent to Dec. 31, 2018, our U.S. bank 
subsidiaries could declare dividends to the Parent of 
approximately $3.7 billion, without the need for a 
regulatory waiver.  In addition, at Dec. 31, 2018, non-
bank subsidiaries of the Parent had liquid assets of 
approximately $1.7 billion.

The bank subsidiaries declared dividends of $3.8 
billion in 2018, $1.3 billion in 2017 and $160 million 
in 2016.  The Federal Reserve and the OCC have 
issued additional guidelines that require BHCs and 
national banks to continually evaluate the level of 
cash dividends in relation to their respective 
operating income, capital needs, asset quality and 
overall financial condition.

The Federal Reserve policy with respect to the 
payment of cash dividends by BHCs provides that, as 
a matter of prudent banking, a BHC should not 
maintain a rate of cash dividends unless its net 
income available to common shareholders has been 

BNY Mellon 171 

Notes to Consolidated Financial Statements (continued)

sufficient to fully fund the dividends, and the 
prospective rate of earnings retention appears to be 
consistent with the holding company’s capital needs, 
asset quality and overall financial condition.  The 
Federal Reserve can also prohibit a dividend if 
payment would constitute an unsafe or unsound 
banking practice.  Any increase in BNY Mellon’s 
ongoing quarterly dividends would require approval 
from the Federal Reserve. 

BNY Mellon and other affected BHCs may pay 
dividends, repurchase stock, and make other capital 
distributions only in accordance with a capital plan 
that has been reviewed by the Federal Reserve and as 
to which the Federal Reserve has not objected.  The 
Federal Reserve may object to a capital plan if the 
plan does not show that the covered BHC will meet, 
for each quarter throughout the nine-quarter planning 
horizon covered by the capital plan, all minimum 
regulatory capital ratios under applicable capital rules 
as in effect for that quarter on a pro forma basis under 
the base case and stressed scenarios (including a 
severely adverse scenario provided by the Federal 
Reserve).  The capital plan rules also stipulate that a 
covered BHC may not make a capital distribution 
unless after giving effect to the distribution it will 
meet all minimum regulatory capital ratios.  As part 
of this process, BNY Mellon also provides the 
Federal Reserve with estimates of the composition 
and levels of regulatory capital, RWAs and other 
measures under Basel III under an identified scenario.  

In June 2018, in connection with the Federal 
Reserve’s non-objection to our 2018 capital plan, 
BNY Mellon announced a share repurchase plan 
providing for the repurchase of up to $2.4 billion of 
common stock starting in the third quarter of 2018 
and continuing through the second quarter of 2019.  
This new share repurchase plan replaces all 
previously authorized share repurchase plans.  

On Dec. 10, 2018, BNY Mellon announced that the 
Federal Reserve approved the repurchase of up to 
$830 million of additional common stock.  Our Board 
of Directors approved the additional share 
repurchases, all of which were repurchased in the 
fourth quarter of 2018.  These repurchases were in 
addition to the Company’s repurchase of $2.4 billion 
of common stock previously approved by the Board 
and announced in June 2018.

The Federal Reserve Act limits, and requires 
collateral for, extensions of credit by our insured 

 172 BNY Mellon

subsidiary banks to BNY Mellon and certain of its 
non-bank affiliates.  Also, there are restrictions on the 
amounts of investments by such banks in stock and 
other securities of BNY Mellon and such affiliates, 
and restrictions on the acceptance of their securities 
as collateral for loans by such banks.  Extensions of 
credit by the banks to each of our affiliates are limited 
to 10% of such bank’s regulatory capital, and in the 
aggregate for BNY Mellon and all such affiliates to 
20%, and collateral must be between 100% and 130% 
of the amount of the credit, depending on the type of 
collateral. 

Our insured subsidiary banks are required to maintain 
reserve balances with Federal Reserve Banks under 
the Federal Reserve Act and Regulation D.  Required 
balances averaged $6.1 billion and $5.6 billion for the 
years 2018 and 2017, respectively.

In the event of impairment of the capital stock of one 
of the Parent’s national banks or The Bank of New 
York Mellon, the Parent, as the banks’ stockholder, 
could be required to pay such deficiency. 

The Parent guarantees the debt issued by Mellon 
Funding Corporation, a wholly owned financing 
subsidiary of the Company.  The Parent also 
guarantees committed and uncommitted lines of 
credit of Pershing LLC and Pershing Limited 
subsidiaries.  The Parent guarantees described above 
are full and unconditional and contain the standard 
provisions relating to parent guarantees of subsidiary 
debt.  Additionally, the Parent guarantees or 
indemnifies obligations of its consolidated 
subsidiaries as needed.  Generally, there are no stated 
notional amounts included in these indemnifications 
and the contingencies triggering the obligation for 
indemnification are not expected to occur.  As a 
result, we are unable to develop an estimate of the 
maximum payout under these indemnifications.  
However, we believe the possibility is remote that we 
will have to make any material payment under these 
guarantees and indemnifications.

The condensed financial statements of the Parent 
include the accounts of the Parent; Mellon Funding 
Corporation and MIPA, LLC, a single-member 
limited liability company, created to hold and 
administer corporate-owned life insurance.  Financial 
data for the Parent, the financing subsidiary and the 
single-member limited liability company are 
combined for financial reporting purposes because of 
the limited function of these entities and the 

Notes to Consolidated Financial Statements (continued)

unconditional guarantee by BNY Mellon of their 
obligations.

The Parent’s condensed financial statements are as 
follows:

Condensed Income Statement—The Bank of New 
York Mellon Corporation (Parent Corporation)  

(in millions)
Dividends from bank subsidiaries
Dividends from nonbank subsidiaries
Interest revenue from bank subsidiaries
Interest revenue from nonbank

subsidiaries

Gain on securities held for sale
Other revenue

Total revenue

Interest (including, $59, $73, $88, to

subsidiaries, respectively)

Other expense

Total expense

Income before income taxes and equity

in undistributed net income of
subsidiaries

(Benefit) for income taxes
Equity in undistributed net income:

Bank subsidiaries
Nonbank subsidiaries

Net income
Preferred stock dividends
Net income applicable to common

shareholders of The Bank of New York
Mellon Corporation

Year ended Dec. 31,
2018

2017

$ 3,874 $ 1,405 $

1,869
13

200

1
36
5,993

658

439
1,097

382
25

171

—
67
2,050

663

254
917

2016
125
798
70

121

—
39
1,153

427

262
689

4,896

1,133

(165)

(526)

464

(333)

(508)
(287)
4,266
(169)

1,524
907
4,090
(175)

2,474
276
3,547
(122)

$ 4,097 $ 3,915 $ 3,425

Condensed Balance Sheet—The Bank of New 
York Mellon Corporation (Parent Corporation) 

(in millions)
Assets:
Cash and due from banks
Securities
Investment in and advances to subsidiaries and

associated companies:

Banks
Other
Subtotal

Corporate-owned life insurance
Other assets

Total assets

Liabilities:
Deferred compensation
Affiliate borrowings
Other liabilities
Long-term debt

Total liabilities

Shareholders’ equity

Total liabilities and shareholders’ equity

Dec. 31,

2018

2017

$

909 $
27

1,301
40

31,285
37,986
69,271
761
740

32,967
37,660
70,627
756
1,135
$ 71,708 $ 73,859

$

445 $

476
3,177
1,373
27,582
32,608
41,251
$ 71,708 $ 73,859

1,616
1,246
27,763
31,070
40,638

Condensed Statement of Cash Flows—The Bank 
of New York Mellon Corporation (Parent 
Corporation)

(in millions)
Operating activities:
Net income
Adjustments to reconcile net income to

net cash provided by operating activities:

Equity in undistributed net loss (income)

of subsidiaries

Change in accrued interest receivable
Change in accrued interest payable
Change in taxes payable (a)
Other, net

Net cash provided by operating

activities
Investing activities:
Purchases of securities
Proceeds from sales of securities
Change in loans
Acquisitions of, investments in, and 

advances to subsidiaries (b)

Other, net

Net cash (used for) investing activities

Financing activities:
Proceeds from issuance of long-term debt
Repayments of long-term debt
Change in advances from subsidiaries
Issuance of common stock
Treasury stock acquired
Issuance of preferred stock
Cash dividends paid
Tax benefit realized on share-based

payment awards

Net cash (used for) provided by

financing activities

Change in cash and due from banks
Cash and due from banks at beginning of

year

Cash and due from banks at end of year
Supplemental disclosures
Interest paid
Income taxes paid
Income taxes refunded

$

$

Year ended Dec. 31,
2018

2017

2016

$ 4,266 $ 4,090 $ 3,547

795

(2,431)

(2,750)

27
29
224
(257)

(6)
42
(600)
38

2
4
452
(31)

5,084

1,133

1,224

—
13
—

(991)
2,729
7

(1,739)
—
13

(53)

1
(39)

(7,208)

—
(5,463)

(317)

—
(2,043)

4,144
(3,650)
(1,561)
120
(3,269)
—
(1,221)

4,738
(997)
(3,930)
465
(2,686)
—
(1,076)

6,229
(2,700)
(1,136)
465
(2,398)
990
(900)

—

—

3

(5,437)

(3,486)

553

(392)

(7,816)

(266)

1,301

9,117

9,383

909 $ 1,301 $ 9,117

629 $
12
7

705 $
61
15

409
1
12

(a) 

(b) 

Includes payments received from subsidiaries for taxes of $837 
million in 2018, $189 million in 2017 and $189 million in 2016.
Includes $2,807 million of cash outflows, net of $2,754 million of 
cash inflows in 2018 and $10,296 million of cash outflows, net of 
$3,088 million of cash inflows in 2017.

BNY Mellon 173 

  
  
 
Notes to Consolidated Financial Statements (continued)

Note 19–Fair value measurement

Fair value is defined as the price that would be 
received to sell an asset, or paid to transfer a liability, 
in an orderly transaction between market participants 
at the measurement date.  A three-level hierarchy for 
fair value measurements is utilized based upon the 
transparency of inputs to the valuation of an asset or 
liability as of the measurement date.  BNY Mellon’s 
own creditworthiness is considered when valuing 
liabilities. 

Fair value focuses on exit price in an orderly 
transaction (that is, not a forced liquidation or 
distressed sale) between market participants at the 
measurement date under current market conditions.  
If there has been a significant decrease in the volume 
and level of activity for the asset or liability, a change 
in valuation technique or the use of multiple valuation 
techniques may be appropriate.  In such instances, 
determining the price at which willing market 
participants would transact at the measurement date 
under current market conditions depends on the facts 
and circumstances and requires the use of significant 
judgment.  The objective is to determine from 
weighted indicators of fair value a reasonable point 
within the range that is most representative of fair 
value under current market conditions.

Determination of fair value

We have established processes for determining fair 
values.  Fair value is based upon quoted market prices 
in active markets, where available.  For financial 
instruments where quotes from recent exchange 
transactions are not available, we determine fair value 
based on discounted cash flow analysis, comparison 
to similar instruments and the use of financial 
models.  Discounted cash flow analysis is dependent 
upon estimated future cash flows and the level of 
interest rates.  Model-based pricing uses inputs of 
observable prices, where available, for interest rates, 
foreign exchange rates, option volatilities and other 
factors.  Models are benchmarked and validated by an 
independent internal risk management function.  Our 
valuation process takes into consideration factors 
such as counterparty credit quality, liquidity, 
concentration concerns and observability of model 
parameters.  Valuation adjustments may be made to 
record financial instruments at fair value.

Most derivative contracts are valued using internally 
developed models which are calibrated to observable 

 174 BNY Mellon

market data and employ standard market pricing 
theory for their valuations.  Valuation models 
incorporate counterparty credit risk by discounting 
each trade’s expected exposures to the counterparty 
using the counterparty’s credit spreads, as implied by 
the credit default swap market.  We also adjust 
expected liabilities to the counterparty using BNY 
Mellon’s own credit spreads, as implied by the credit 
default swap market.  Accordingly, the valuation of 
our derivative positions is sensitive to the current 
changes in our own credit spreads as well as those of 
our counterparties.

In certain cases, recent prices may not be observable 
for instruments that trade in inactive or less active 
markets.  Upon evaluating the uncertainty in valuing 
financial instruments subject to liquidity issues, we 
make an adjustment to their value.  The determination 
of the liquidity adjustment includes the availability of 
external quotes, the time since the latest available 
quote and the price volatility of the instrument.

Certain parameters in some financial models are not 
directly observable and, therefore, are based on 
management’s estimates and judgments.  These 
financial instruments are normally traded less 
actively.  We apply valuation adjustments to mitigate 
the possibility of error and revision in the model 
based estimate value.  Examples include products 
where parameters such as correlation and recovery 
rates are unobservable.  

The methods described above for instruments that 
trade in inactive or less active markets may produce a 
current fair value calculation that may not be 
indicative of net realizable value or reflective of 
future fair values.  We believe our methods of 
determining fair value are appropriate and consistent 
with other market participants.  However, the use of 
different methodologies or different assumptions to 
value certain financial instruments could result in a 
different estimate of fair value.

Valuation hierarchy

A three-level valuation hierarchy is used for 
disclosure of fair value measurements based upon the 
transparency of inputs to the valuation of an asset or 
liability as of the measurement date.  The three levels 
are described below.

Notes to Consolidated Financial Statements (continued)

Level 1: Inputs to the valuation methodology are 
quoted prices (unadjusted) for identical assets or 
liabilities in active markets.  Level 1 assets and 
liabilities include certain debt and equity securities, 
derivative financial instruments actively traded on 
exchanges and highly liquid government bonds.

Level 2: Observable inputs other than Level 1 prices, 
for example, quoted prices for similar assets and 
liabilities in active markets, quoted prices for 
identical or similar assets or liabilities in markets that 
are not active, and inputs that are observable or can 
be corroborated, either directly or indirectly, for 
substantially the full term of the financial instrument.  
Level 2 assets and liabilities include debt instruments 
that are traded less frequently than exchange-traded 
securities and derivative financial instruments whose 
model inputs are observable in the market or can be 
corroborated by market-observable data.  Examples 
in this category are mortgage-backed securities, 
corporate debt securities and OTC derivative 
contracts.

Level 3: Inputs to the valuation methodology are 
unobservable and significant to the fair value 
measurement. 

A financial instrument’s categorization within the 
valuation hierarchy is based upon the lowest level of 
input that is significant to the fair value measurement.  

Valuation methodology

Following is a description of the valuation 
methodologies used for instruments measured at fair 
value, as well as the general classification of such 
instruments pursuant to the valuation hierarchy.

Securities

We determine fair value primarily based on pricing 
sources with reasonable levels of price transparency.  
Where quoted prices are available in an active 
market, we classify the securities within Level 1 of 
the valuation hierarchy.  Securities include both long 
and short positions.  Level 1 securities include U.S. 
Treasury and certain sovereign debt securities that are 
actively traded in highly liquid OTC markets, money 
market funds and exchange-traded equities.  

If quoted market prices are not available, fair values 
are primarily determined using pricing models using 
observable trade data, market data, quoted prices of 

securities with similar characteristics or discounted 
cash flows.  Examples of such instruments, which 
would generally be classified within Level 2 of the 
valuation hierarchy, include mortgage-backed 
securities, state and political subdivisions, certain 
sovereign debt, corporate bonds and foreign covered 
bonds.

Specifically, the pricing sources obtain recent 
transactions for similar types of securities (e.g., 
vintage, position in the securitization structure) and 
ascertain variables such as discount rate and speed of 
prepayment for the types of transaction and apply 
such variables to similar types of bonds.  We view 
these as observable transactions in the current 
marketplace and classify such securities as Level 2.  
Pricing sources discontinue pricing any specific 
security whenever they determine there is insufficient 
observable data to provide a good faith opinion on 
price.

In certain cases where there is limited activity or less 
transparency around inputs to the valuation, we 
classify those securities in Level 3 of the valuation 
hierarchy.  We have no instruments included in Level 
3 of the valuation hierarchy.  

At Dec. 31, 2018, approximately 99% of our 
securities were valued by pricing sources with 
reasonable levels of price transparency.  Additional 
disclosures of securities are provided in Note 4.

Derivative financial instruments

We classify exchange-traded derivative financial 
instruments valued using quoted prices in Level 1 of 
the valuation hierarchy.  Examples include exchange-
traded equity and foreign exchange options.  Since 
few other classes of derivative contracts are listed on 
an exchange, most of our derivative positions are 
valued using internally developed models that use as 
their basis readily observable market parameters, and 
we classify them in Level 2 of the valuation 
hierarchy.  Such derivative financial instruments 
include swaps and options, foreign exchange spot and 
forward contracts and credit default swaps.  

Derivatives valued using models with significant 
unobservable market parameters in markets that lack 
two-way flow are classified in Level 3 of the 
valuation hierarchy.  Examples may include long-
dated swaps and options, where parameters may be 
unobservable for longer maturities; and certain highly 

BNY Mellon 175 

Notes to Consolidated Financial Statements (continued)

structured products, where correlation risk is 
unobservable.  As of Dec. 31, 2018 we have no Level 
3 derivatives.  Additional disclosures of derivative 
instruments are provided in Note 22.

Seed capital

In our Investment Management business, we manage 
investment assets, including equities, fixed income, 
money market and multi-asset and alternative 
investment funds for institutions and other investors.  
As part of that activity, we make seed capital 
investments in certain funds.  Seed capital is 
generally included in other assets on the consolidated 
balance sheet.  When applicable, we value seed 
capital based on the published NAV of the fund. 

For other types of investments in funds, we consider 
all of the rights and obligations inherent in our 
ownership interest, including the reported NAV as 
well as other factors that affect the fair value of our 
interest in the fund. 

Interests in securitizations

For the interests in securitizations that are classified 
in securities available-for-sale, trading assets and 
long-term debt, we use discounted cash flow models, 
which generally include assumptions of projected 

finance charges related to the securitized assets, 
estimated net credit losses, prepayment assumptions 
and estimates of payments to third-party investors.  
When available, we compare our fair value estimates 
and assumptions to market activity and to the actual 
results of the securitized portfolio.  

Other assets measured at NAV

BNY Mellon holds private equity investments, 
specifically SBICs, which are compliant with the 
Volcker Rule.  There are no readily available market 
quotations for these investment partnerships.  The fair 
value of the SBICs is based on our ownership 
percentage of the fair value of the underlying 
investments as provided by the partnership managers.  
These investments are typically valued on a quarterly 
basis.  Our SBIC private equity investments are 
valued at NAV as a practical expedient for fair value.

The following tables present the financial instruments 
carried at fair value at Dec. 31, 2018 and Dec. 31, 
2017, by caption on the consolidated balance sheet 
and by the three-level valuation hierarchy.  We have 
included credit ratings information in certain of the 
tables because the information indicates the degree of 
credit risk to which we are exposed, and significant 
changes in ratings classifications could result in 
increased risk for us. 

 176 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Assets measured at fair value on a recurring basis at Dec. 31, 2018
(dollars in millions)
Available-for-sale securities:

Level 1

Level 2

Level 3 Netting (a)

Total carrying
value

Agency RMBS
U.S. Treasury
Sovereign debt/sovereign guaranteed
Agency commercial MBS
CLOs
Supranational
Foreign covered bonds
State and political subdivisions
Other asset-backed securities
U.S. government agencies
Non-agency commercial MBS
Non-agency RMBS (b)
Corporate bonds
Other debt securities

Total available-for-sale securities

Trading assets:

Debt instruments
Equity instruments (c)
Derivative assets not designated as hedging:

Interest rate
Foreign exchange
Equity and other contracts

Total derivative assets not designated as hedging
Total trading assets

Other assets:

Derivative assets designated as hedging:

Interest rate
Foreign exchange

Total derivative assets designated as hedging

Other assets (d)
Other assets measured at NAV (d)

Total other assets

Subtotal assets of operations at fair value
Percentage of assets of operations prior to netting
Assets of consolidated investment management funds

Total assets

Percentage of total assets prior to netting

$

$

— $ 25,308
—
4,137
9,691
3,364
2,984
2,878
2,247
1,773
1,657
1,464
1,325
1,054
1,238
59,120

20,076
6,613
—
—
—
—
—
—
—
—
—
—
—
26,689

801
1,114

7
—
9
16
1,931

—
—
—
68

2,594
—

3,583
4,807
59
8,449
11,043

23
266
289
170

— $
—
—
—
—
—
—
—
—
—
—
—
—
—
—

—
—

—
—
—
—
—

—
—
—
—

— $
—
—
—
—
—
—
—
—
—
—
—
—
—
—

—
—

(2,202)
(3,724)
(13)
(5,939)
(5,939)

—
—
—
—

68
28,688

459
70,622

29%

71%

210
$ 28,898

253
$ 70,875

$

29%

71%

—
—
—%
—
— $
—%

—
(5,939)

—
(5,939) $

25,308
20,076
10,750
9,691
3,364
2,984
2,878
2,247
1,773
1,657
1,464
1,325
1,054
1,238
85,809

3,395
1,114

1,388
1,083
55
2,526
7,035

23
266
289
238
215
742
93,586

463
94,049

BNY Mellon 177 

1,124
75

608
1,589
83
2,280
3,479
371

74
14

88
3,938

2
3,940

(2,508)
(3,626)
(36)
(6,170)
(6,170)
—

—
—

—
(6,170)

—
(6,170) $

Notes to Consolidated Financial Statements (continued)

Liabilities measured at fair value on a recurring basis at Dec. 31, 2018
(dollars in millions)
Trading liabilities:
Debt instruments
Equity instruments
Derivative liabilities not designated as hedging:

Interest rate
Foreign exchange
Equity and other contracts

Total derivative liabilities not designated as hedging
Total trading liabilities

Long-term debt (c)
Other liabilities – derivative liabilities designated as hedging:

Interest rate
Foreign exchange

12
—
1
13
1,094
—

—
—

3,104
5,215
118
8,437
8,555
371

74
14

—
—
—
—
—
—

—
—

Level 1

Level 2

Level 3 Netting (a)

Total carrying
value

$

1,006
75

$

$

118
—

— $
—

— $
—

Total other liabilities – derivative liabilities designated as

hedging

Subtotal liabilities of operations at fair value
Percentage of liabilities of operations prior to netting
Liabilities of consolidated investment management funds

Total liabilities

Percentage of total liabilities prior to netting

—
1,094

11%
2
1,096

11%

$

88
9,014

89%
—
9,014

89%

$

$

—
—
—%
—
— $
—%

(a)  ASC 815, Derivatives and Hedging, permits the netting of derivative receivables and derivative payables under legally enforceable 
master netting agreements and permits the netting of cash collateral.  Netting is applicable to derivatives not designated as hedging 
instruments included in trading assets or trading liabilities and derivatives designated as hedging instruments included in other assets or 
other liabilities.  Netting is allocated to the derivative products based on the net fair value of each product.

(b)  Includes $832 million in Level 2 that was included in the former Grantor Trust. 
(c)  Includes certain interests in securitizations.
(d)  Includes seed capital, private equity investments and other assets. 

 178 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Assets measured at fair value on a recurring basis at Dec. 31, 2017
(dollars in millions)
Available-for-sale securities:

Level 1

Level 2

Level 3 Netting (a)

Total carrying
value

Agency RMBS
U.S. Treasury
Sovereign debt/sovereign guaranteed
Agency commercial MBS
State and political subdivisions
CLOs
Foreign covered bonds
Supranational
Non-agency RMBS (b)
Non-agency commercial MBS
Corporate bonds
Other asset-backed securities
U.S. government agencies
Other RMBS
Other debt securities
Money market funds (c)

Total available-for-sale securities

Trading assets:

Debt instruments
Equity instruments (c)
Derivative assets not designated as hedging:

Interest rate
Foreign exchange
Equity and other contracts

Total derivative assets not designated as hedging
Total trading assets

Other assets:

Derivative assets designated as hedging:

Interest rate
Foreign exchange

Total derivative assets designated as hedging

Other assets (d)
Other assets measured at NAV (d)

Total other assets

Subtotal assets of operations at fair value
Percentage of assets of operations prior to netting
Assets of consolidated investment management funds

Total assets

Percentage of total assets prior to netting

$

$

— $ 23,819
—
2,638
8,762
2,957
2,909
2,529
2,079
1,578
1,360
1,255
1,043
908
149
1,412
—
53,398

15,263
9,919
—
—
—
—
—
—
—
—
—
—
—
—
963
26,145

690
654

9
—
—
9
1,353

—
—
—
144

1,910
—

6,430
5,104
70
11,604
13,514

278
45
323
170

— $
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—

—
—

—
—
—
—
—

—
—
—
—

— $
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—

—
—

(5,075)
(3,720)
(50)
(8,845)
(8,845)

—
—
—
—

144
27,642

493
67,405

29%

71%

322
$ 27,964

409
$ 67,814

$

29%

71%

—
—
—%
—
— $
—%

—
(8,845)

—
(8,845) $

23,819
15,263
12,557
8,762
2,957
2,909
2,529
2,079
1,578
1,360
1,255
1,043
908
149
1,412
963
79,543

2,600
654

1,364
1,384
20
2,768
6,022

278
45
323
314
154
791
86,356

731
87,087

BNY Mellon 179 

Notes to Consolidated Financial Statements (continued)

Liabilities measured at fair value on a recurring basis at Dec. 31, 2017
(dollars in millions)
Trading liabilities:
Debt instruments
Equity instruments
Derivative liabilities not designated as hedging:

Interest rate
Foreign exchange
Equity and other contracts

Total derivative liabilities not designated as hedging
Total trading liabilities

Long-term debt (c)
Other liabilities – derivative liabilities designated as hedging:

Interest rate
Foreign exchange

Total other liabilities – derivative liabilities designated as

hedging

Subtotal liabilities of operations at fair value
Percentage of liabilities of operations prior to netting
Liabilities of consolidated investment management funds

Total liabilities

Percentage of total liabilities prior to netting

Level 1

Level 2

Level 3 Netting (a)

Total carrying
value

$

$

979
149

$

80
—

— $
—

— $
—

4
—
—
4
1,132
—

—
—

—
1,132

6,349
5,067
153
11,569
11,649
367

534
266

800
12,816

8%
1
1,133

92%
1
$ 12,817

$

8%

92%

$

—
—
—
—
—
—

—
—

—
—
—%
—
— $
—%

(5,495)
(3,221)
(81)
(8,797)
(8,797)
—

—
—

—
(8,797)

—
(8,797) $

1,059
149

858
1,846
72
2,776
3,984
367

534
266

800
5,151

2
5,153

(a)  ASC 815, Derivatives and Hedging, permits the netting of derivative receivables and derivative payables under legally enforceable 
master netting agreements and permits the netting of cash collateral.  Netting is applicable to derivatives not designated as hedging 
instruments included in trading assets or trading liabilities and derivatives designated as hedging instruments included in other assets or 
other liabilities.  Netting is allocated to the derivative products based on the net fair value of each product.

(b)  Includes $1,091 million in Level 2 that was included in the former Grantor Trust. 
(c)  Includes certain interests in securitizations.
(d)  Includes private equity investments and seed capital.

 180 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Details of certain available-for-sale securities
measured at fair value on a recurring basis

(dollars in millions)
Non-agency RMBS (c), originated in:

2007
2006
2005
2004 and earlier

Total non-agency RMBS

Non-agency commercial MBS, originated in:

2009-2018
2005

Total non-agency commercial MBS

Foreign covered bonds:

Canada
United Kingdom
Australia
Sweden
Other

Total foreign covered bonds
Sovereign debt/sovereign guaranteed:

United Kingdom
Germany
France
Spain
Italy
Netherlands
Ireland
Hong Kong
Canada
Belgium
Other (e)

Dec. 31, 2018

Dec. 31, 2017

Total
carrying
value

AAA/
AA-

(b)

Ratings (a)
BBB+/
BBB-

A+/
A-

BB+ and
lower

Total
carrying 
value

AAA/
AA-

(b)

Ratings (a)
BBB+/
BBB-

A+/
A-

BB+ and
lower

$

$

$

$

$

$

315
363
396
251
1,325

1,464
—
1,464

1,524
529
333
187
305
2,878

15% 2%
—
9
16
9% 11%

19
1
24

3%

—
7
11
5%

96% 4% —%
—
96% 4% —%

—

—

100% —% —%
—
100
—
100
—
100
100
—
100% —% —%

—
—
—
—

80% $
81
83
49
75% $

—% $
—
—% $

—% $
—
—
—
—
—% $

419
467
509
332

1,727 (d)

1,309
51
1,360

1,659
103
265
136
366
2,529

13%
—
6
3
6%

94%
100
94%

3%
17
2
2
6%

6%
—
6%

100% —%
100
100
100
100
100% —%

—
—
—
—

—%
—
6
31
8%

—%
—
—%

—%
—
—
—
—
—%

84%
83
86
64
80%

—%
—
—%

—%
—
—
—
—
—%

$

2,153
1,826
1,548
1,365
939
875
625
450
378
260
331
$ 10,750

100% —% —%
—
100
—
100
—
—
—
—
—
100
— 100
—
—
—
—

100
100
100
68
72% 6% 21%

—
—
100
100
—
—
—
—
—
—

—% $
3,052
—
1,586
—
2,046
—
1,635
—
1,292
—
1,027
—
843
—
—
—
—
—
803
32
273
1% $ 12,557

100% —%
100
100
—
—
100

—
—
—
—
—
— 100
—
—
—
—
—
100
—
50
7%
69%

—%
—
—
100
100
—
—
—
—
—
—
23%

—%
—
—
—
—
—
—
—
—
—
50
1%

Total sovereign debt/sovereign guaranteed
(a)  Represents ratings by S&P or the equivalent.
(b)  At Dec. 31, 2018 and Dec. 31, 2017, sovereign debt/sovereign guaranteed securities were included in Level 1 and Level 2 in the valuation hierarchy.  All 

(c) 
(d) 
(e) 

other assets in the table are Level 2 assets in the valuation hierarchy.
Includes $832 million at Dec. 31, 2018 and $1,091 million at Dec. 31, 2017 that were included in the former Grantor Trust.
Includes other RMBS.
Includes non-investment grade sovereign debt/sovereign guaranteed securities related to Brazil of $107 million at Dec. 31, 2018 and $136 million at Dec. 
31, 2017.

Assets and liabilities measured at fair value on a 
nonrecurring basis

readily marketable equity securities carried at cost 
with upward or downward adjustments.

Under certain circumstances, we make adjustments to 
fair value our assets, liabilities and unfunded lending-
related commitments although they are not measured 
at fair value on an ongoing basis.  Examples would be 
the recording of an impairment of an asset and non-

The following table presents the financial instruments 
carried on the consolidated balance sheet by caption 
and level in the fair value hierarchy as of Dec. 31, 
2018 and Dec. 31, 2017, for which a nonrecurring 
change in fair value has been recorded in the 
respective year.

Assets measured at fair value on a

nonrecurring basis

(in millions)
Loans (a)
Other assets (b)

Total assets at fair value on a nonrecurring

basis

Dec. 31, 2018

Dec. 31, 2017

Level 1

Level 2

Level 3

Total carrying
value

Level 1

Level 2

Level 3

Total carrying
value

$

$

— $
—

64 $
57

4 $

—

$

68
57

— $
—

73 $
4

6 $
—

— $

121 $

4 $

125

$

— $

77 $

6 $

79
4

83  

(a)  The fair value of these loans decreased $1 million in both 2018 and 2017, based on the fair value of the underlying collateral, as required by 

(b) 

guidance in ASC 310, Receivables, with an offset to the allowance for credit losses.
Includes non-readily marketable equity securities carried at cost with upward or downward adjustments and other assets received in satisfaction 
of debt.

BNY Mellon 181 

Notes to Consolidated Financial Statements (continued)

Estimated fair value of financial instruments

The following tables present the estimated fair value and the carrying amount of financial instruments not carried at 
fair value on the consolidated balance sheet at Dec. 31, 2018 and Dec. 31, 2017, by caption on the consolidated 
balance sheet and by the valuation hierarchy. 

Summary of financial instruments

Dec. 31, 2018

(in millions)
Assets:

Interest-bearing deposits with the Federal Reserve and other central banks
Interest-bearing deposits with banks
Federal funds sold and securities purchased under resale agreements
Securities held-to-maturity
Loans (a)
Other financial assets

Total

Liabilities:

Noninterest-bearing deposits
Interest-bearing deposits
Federal funds purchased and securities sold under repurchase agreements
Payables to customers and broker-dealers
Commercial paper
Borrowings
Long-term debt

Total

(a)  Does not include the leasing portfolio.

Summary of financial instruments

(in millions)
Assets:

Interest-bearing deposits with the Federal Reserve and other central banks
Interest-bearing deposits with banks
Federal funds sold and securities purchased under resale agreements
Securities held-to-maturity
Loans (a)
Other financial assets

Total

Liabilities:

Noninterest-bearing deposits
Interest-bearing deposits
Federal funds purchased and securities sold under repurchase agreements
Payables to customers and broker-dealers
Commercial paper
Borrowings
Long-term debt

Total

(a)  Does not include the leasing portfolio.

$

$

$

$

$

$

$

$

Level 1

Level 2

Level 3

Total
estimated
fair value

Carrying
amount

— $
—
—
5,512
—
5,864

67,988 $
14,168
46,795
27,790
55,142
1,383

11,376 $ 213,266 $

70,783 $

— $
— 165,914
14,243
—
19,731
—
1,939
—
3,584
—
—
28,347
— $ 304,541 $

67,988 $
14,168
46,795
33,302
55,142
7,247

67,988
— $
14,148
—
46,795
—
33,982
—
55,161
—
—
7,247
— $ 224,642 $ 225,321

70,783 $

70,783
— $
167,995
— 165,914
14,243
14,243
—
19,731
19,731
—
1,939
1,939
—
3,584
3,584
—
—
28,792
28,347
— $ 304,541 $ 307,067

Dec. 31, 2017

Level 1

Level 2

Level 3

Total
estimated
fair value

Carrying
amount

— $
—
—
11,365
—
5,382
16,747 $ 222,237 $

91,510 $
11,982
28,135
29,147
60,219
1,244

82,716 $

— $
— 160,042
15,163
—
20,184
—
3,075
—
2,931
—
27,789
—
— $ 311,900 $

91,510 $
11,982
28,135
40,512
60,219
6,626

91,510
— $
11,979
—
28,135
—
40,827
—
60,082
—
6,626
—
— $ 238,984 $ 239,159

82,716 $

82,716
— $
161,606
— 160,042
15,163
15,163
—
20,184
20,184
—
3,075
3,075
—
2,931
2,931
—
27,612
27,789
—
— $ 311,900 $ 313,287

 182 BNY Mellon

Notes to Consolidated Financial Statements (continued)

The table below summarizes the carrying amount of the hedged financial instruments, the notional amount of the 
hedge and the unrealized gain (loss) (estimated fair value) of the derivatives.

Hedged financial instruments

(in millions)
Dec. 31, 2018

Securities available-for-sale (b)
Long-term debt

Dec. 31, 2017

Carrying 
amount

Notional
amount of
hedge

Unrealized (a)

Gain

(Loss)

$

19,349 $
16,147

19,437 $
16,600

24 $
—

(74)
—

(301)
(233)

Securities available-for-sale
Long-term debt

102 $
175
(a)  Unrealized gain/loss amounts reflect the fact that certain of the derivatives are cleared and settled through central clearing 

12,365 $
23,950

12,307 $
23,821

$

counterparties where cash collateral received and paid is deemed a settlement of the derivative.

(b)  Includes foreign exchange fair value hedges with a carrying value of $148 million, a notional amount of $147 million and unrealized 

gains of $1 million.

Note 20–Fair value option

We elected fair value as an alternative measurement 
for selected financial assets and liabilities.  The 
following table presents the assets and liabilities of 
consolidated investment management funds, at fair 
value.

Assets and liabilities of consolidated

investment management funds, at fair value

(in millions)
Assets of consolidated investment management

funds:
Trading assets
Other assets

Total assets of consolidated investment

management funds

Liabilities of consolidated investment

management funds:
Other liabilities

Total liabilities of consolidated investment

management funds

Dec. 31,

2018

2017

$

$

$

$

243 $
220

516
215

463 $

731

2 $

2 $

2

2

BNY Mellon values the assets and liabilities of its 
consolidated investment management funds using 
quoted prices for identical assets or liabilities in 
active markets or observable inputs such as quoted 
prices for similar assets or liabilities.  Quoted prices 
for either identical or similar assets or liabilities in 
inactive markets may also be used.  Accordingly, fair 
value best reflects the interests BNY Mellon holds in 
the economic performance of the consolidated 
investment management funds.  Changes in the value 

of the assets and liabilities are recorded in the 
consolidated income statement as investment income 
of consolidated investment management funds and in 
the interest of investment management fund note 
holders, respectively.

We have elected the fair value option on $240 million 
of long-term debt.  The fair value of this long-term 
debt was $371 million at Dec. 31, 2018 and $367 
million at Dec. 31, 2017.  The long-term debt is 
valued using observable market inputs and is 
included in Level 2 of the valuation hierarchy. 

The following table presents the changes in fair value 
of long-term debt and certain loans for which we 
elected the fair value option that we previously held 
in 2016, and the location of the changes in the 
consolidated income statement.  There were no loans 
valued under the fair value option election at Dec. 31, 
2018, Dec. 31, 2017 and Dec. 31, 2016. 

Impact of changes in fair value in the income statement (a)

(in millions)
Loans:

Year ended Dec. 31,
2018

2017

2016

Investment and other income

$ — $ — $

12

Long-term debt:

Foreign exchange and other trading

revenue

$

(4) $

(4) $

(4)

(a)  The changes in fair value of the loans and long-term debt are 
approximately offset by economic hedges included in foreign 
exchange and other trading revenue.

BNY Mellon 183 

Notes to Consolidated Financial Statements (continued)

Note 21–Commitments and contingent 
liabilities

year, $20.3 billion in one to five years and $570 
million over five years.

Off-balance sheet arrangements

In the normal course of business, various 
commitments and contingent liabilities are 
outstanding that are not reflected in the 
accompanying consolidated balance sheets.

Our significant trading and off-balance sheet risks are 
securities, foreign currency and interest rate risk 
management products, commercial lending 
commitments, letters of credit and securities lending 
indemnifications.  We assume these risks to reduce 
interest rate and foreign currency risks, to provide 
customers with the ability to meet credit and liquidity 
needs and to hedge foreign currency and interest rate 
risks.  These items involve, to varying degrees, credit, 
foreign currency and interest rate risks not recognized 
on the balance sheet.  Our off-balance sheet risks are 
managed and monitored in manners similar to those 
used for on-balance sheet risks. 

The following table presents a summary of our off-
balance sheet credit risks.

Dec. 31,

Off-balance sheet credit risks
2017
(in millions)
51,467
Lending commitments
3,531
Standby letters of credit (a)
122
Commercial letters of credit
432,084
Securities lending indemnifications (b)(c)
(a)  Net of participations totaling $163 million at Dec. 31, 2018 

2018
50,631 $
2,817
165
401,504

$

and $672 million at Dec. 31, 2017. 

(b)  Excludes the indemnification for securities for which BNY 
Mellon acts as an agent on behalf of CIBC Mellon clients, 
which totaled $56 billion at Dec. 31, 2018 and $69 billion at 
Dec. 31, 2017. 

(c)  Includes cash collateral, invested in indemnified repurchase 
agreements, held by us as securities lending agent of $35 
billion at Dec. 31, 2018 and $33 billion at Dec. 31, 2017. 

The total potential loss on undrawn lending 
commitments, standby and commercial letters of 
credit, and securities lending indemnifications is 
equal to the total notional amount if drawn upon, 
which does not consider the value of any collateral.

Since many of the lending commitments are expected 
to expire without being drawn upon, the total amount 
does not necessarily represent future cash 
requirements.  A summary of lending commitment 
maturities is as follows: $29.8 billion in less than one 

 184 BNY Mellon

SBLCs principally support obligations of corporate 
clients and were collateralized with cash and 
securities of $223 million at Dec. 31, 2018 and $160 
million at Dec. 31, 2017.  At Dec. 31, 2018, $2.0 
billion of the SBLCs will expire within one year and 
$845 million in one to five years. 

We must recognize, at the inception of an SBLC and 
foreign and other guarantees, a liability for the fair 
value of the obligation undertaken in issuing the 
guarantee.  The fair value of the liability, which was 
recorded with a corresponding asset in other assets, 
was estimated as the present value of contractual 
customer fees.  The estimated liability for losses 
related to SBLCs and foreign and other guarantees, if 
any, is included in the allowance for lending-related 
commitments.  The allowance for lending-related 
commitments was $106 million at Dec. 31, 2018 and 
$102 million at Dec. 31, 2017.

Payment/performance risk of SBLCs is monitored 
using both historical performance and internal ratings 
criteria.  BNY Mellon’s historical experience is that 
SBLCs typically expire without being funded.  
SBLCs below investment grade are monitored closely 
for payment/performance risk.  The table below 
shows SBLCs by investment grade:

Standby letters of credit

Investment grade
Non-investment grade

Dec. 31,
2018
89%
11%

2017
84%
16%

A commercial letter of credit is normally a short-term 
instrument used to finance a commercial contract for 
the shipment of goods from a seller to a buyer.  
Although the commercial letter of credit is contingent 
upon the satisfaction of specified conditions, it 
represents a credit exposure if the buyer defaults on 
the underlying transaction.  As a result, the total 
contractual amounts do not necessarily represent 
future cash requirements.  Commercial letters of 
credit totaled $165 million at Dec. 31, 2018 and $122 
million at Dec. 31, 2017.

We expect many of the lending commitments and 
letters of credit to expire without the need to advance 
any cash.  The revenue associated with guarantees 
frequently depends on the credit rating of the obligor 

Notes to Consolidated Financial Statements (continued)

and the structure of the transaction, including 
collateral, if any.

A securities lending transaction is a fully 
collateralized transaction in which the owner of a 
security agrees to lend the security (typically through 
an agent, in our case, The Bank of New York 
Mellon), to a borrower, usually a broker-dealer or 
bank, on an open, overnight or term basis, under the 
terms of a prearranged contract.  

We typically lend securities with indemnification 
against borrower default.  We generally require the 
borrower to provide collateral with a minimum value 
of 102% of the fair value of the securities borrowed, 
which is monitored on a daily basis, thus reducing 
credit risk.  Market risk can also arise in securities 
lending transactions.  These risks are controlled 
through policies limiting the level of risk that can be 
undertaken.  Securities lending transactions are 
generally entered into only with highly rated 
counterparties.  Securities lending indemnifications 
were secured by collateral of $420 billion at Dec. 31, 
2018 and $451 billion at Dec. 31, 2017.

CIBC Mellon, a joint venture between BNY Mellon 
and the Canadian Imperial Bank of Commerce 
(“CIBC”), engages in securities lending activities.  
CIBC Mellon, BNY Mellon and CIBC jointly and 
severally indemnify securities lenders against specific 
types of borrower default.  At Dec. 31, 2018 and Dec. 
31, 2017, $56 billion and $69 billion, respectively, of 
borrowings at CIBC Mellon, for which BNY Mellon 
acts as agent on behalf of CIBC Mellon clients, were 
secured by collateral of $59 billion and $73 billion, 
respectively.  If, upon a default, a borrower’s 
collateral was not sufficient to cover its related 
obligations, certain losses related to the 
indemnification could be covered by the indemnitors. 

Dec. 31, 2018
Unfunded
commitments

Loans

Financial institutions
portfolio exposure
(in billions)
Securities industry
Banks
Asset managers
Insurance
Government
Other
Total

Commercial portfolio
exposure
(in billions)
Manufacturing
Services and other
Energy and utilities
Media and telecom

Total

$

$

$

$

3.1 $
6.3
1.3
0.1
0.1
0.7
11.6 $

0.8 $
0.7
0.5
0.1
2.1 $

Total
exposure
25.6
7.9
7.4
2.6
0.6
1.5
45.6  

22.5 $
1.6
6.1
2.5
0.5
0.8
34.0 $

Total
exposure
5.9
5.5
4.6
1.3
17.3

5.1 $
4.8
4.1
1.2
15.2 $

Dec. 31, 2018
Unfunded
commitments

Loans

Major concentrations in securities lending are 
primarily to broker-dealers and are generally 
collateralized with cash and/or securities.

Operating leases

Net rent expense for premises and equipment was 
$295 million in 2018, $285 million in 2017 and $301 
million in 2016.

At Dec. 31, 2018, we were obligated under various 
noncancelable lease agreements, some of which 
provide for additional rents based upon real estate 
taxes, insurance and maintenance and for various 
renewal options.  A summary of the future minimum 
rental commitments under noncancelable operating 
leases, net of related sublease revenue, is as follows: 
2019—$264 million; 2020—$244 million; 2021—
$211 million; 2022—$172 million; 2023—$136 
million and 2024 and thereafter—$432 million. 

Industry concentrations

Exposure for certain administrative errors

We have significant industry concentrations related to 
credit exposure at Dec. 31, 2018.  The tables below 
present our credit exposure in the financial 
institutions and commercial portfolios.  

In connection with certain offshore tax-exempt funds 
that we manage, we may be liable to the funds for 
certain administrative errors.  The errors relate to the 
resident status of such funds, potentially exposing the 
Company to a tax liability related to the funds’ 
earnings.  The Company is in discussions with tax 
authorities regarding the funds.  We believe we are 
appropriately accrued and the additional reasonably 
possible exposure is not significant.

BNY Mellon 185 

Notes to Consolidated Financial Statements (continued)

Indemnification arrangements

Legal proceedings

We have provided standard representations for 
underwriting agreements, acquisition and divestiture 
agreements, sales of loans and commitments, and 
other similar types of arrangements and customary 
indemnification for claims and legal proceedings 
related to providing financial services that are not 
otherwise included above.  Insurance has been 
purchased to mitigate certain of these risks.  
Generally, there are no stated or notional amounts 
included in these indemnifications and the 
contingencies triggering the obligation for 
indemnification are not expected to occur.  
Furthermore, often counterparties to these 
transactions provide us with comparable 
indemnifications.  We are unable to develop an 
estimate of the maximum payout under these 
indemnifications for several reasons.  In addition to 
the lack of a stated or notional amount in a majority 
of such indemnifications, we are unable to predict the 
nature of events that would trigger indemnification or 
the level of indemnification for a certain event.  We 
believe, however, that the possibility that we will 
have to make any material payments for these 
indemnifications is remote.  At Dec. 31, 2018 and 
Dec. 31, 2017, we have not recorded any material 
liabilities under these arrangements.

Clearing and settlement exchanges

We are a noncontrolling equity investor in, and/or 
member of, several industry clearing or settlement 
exchanges through which foreign exchange, 
securities, derivatives or other transactions settle.  
Certain of these industry clearing and settlement 
exchanges require their members to guarantee their 
obligations and liabilities and/or to provide liquidity 
support in the event other members do not honor their 
obligations.  We believe the likelihood that a clearing 
or settlement exchange (of which we are a member) 
would become insolvent is remote.  Additionally, 
certain settlement exchanges have implemented loss 
allocation policies that enable the exchange to 
allocate settlement losses to the members of the 
exchange.  It is not possible to quantify such mark-to-
market loss until the loss occurs.  Any ancillary costs 
that occur as a result of any mark-to-market loss 
cannot be quantified.  In addition, we also sponsor 
clients as members on clearing and settlement 
exchanges and guarantee their obligations.  At Dec. 
31, 2018 and Dec. 31, 2017, we have not recorded 
any material liabilities under these arrangements.

 186 BNY Mellon

In the ordinary course of business, BNY Mellon and 
its subsidiaries are routinely named as defendants in 
or made parties to pending and potential legal actions.  
We also are subject to governmental and regulatory 
examinations, information-gathering requests, 
investigations and proceedings (both formal and 
informal).  Claims for significant monetary damages 
are often asserted in many of these legal actions, 
while claims for disgorgement, restitution, penalties 
and/or other remedial actions or sanctions may be 
sought in governmental and regulatory matters.  It is 
inherently difficult to predict the eventual outcomes 
of such matters given their complexity and the 
particular facts and circumstances at issue in each of 
these matters.  However, on the basis of our current 
knowledge and understanding, we do not believe that 
judgments, settlements or orders, if any, arising from 
these matters (either individually or in the aggregate, 
after giving effect to applicable reserves and 
insurance coverage) will have a material adverse 
effect on the consolidated financial position or 
liquidity of BNY Mellon, although they could have a 
material effect on our results of operations in a given 
period.

In view of the inherent unpredictability of outcomes 
in litigation and regulatory matters, particularly 
where (i) the damages sought are substantial or 
indeterminate, (ii) the proceedings are in the early 
stages, or (iii) the matters involve novel legal theories 
or a large number of parties, as a matter of course 
there is considerable uncertainty surrounding the 
timing or ultimate resolution of litigation and 
regulatory matters, including a possible eventual loss, 
fine, penalty or business impact, if any, associated 
with each such matter.  In accordance with applicable 
accounting guidance, BNY Mellon establishes 
accruals for litigation and regulatory matters when 
those matters proceed to a stage where they present 
loss contingencies that are both probable and 
reasonably estimable.  In such cases, there may be a 
possible exposure to loss in excess of any amounts 
accrued.  BNY Mellon regularly monitors such 
matters for developments that could affect the amount 
of the accrual, and will adjust the accrual amount as 
appropriate.  If the loss contingency in question is not 
both probable and reasonably estimable, BNY Mellon 
does not establish an accrual and the matter continues 
to be monitored for any developments that would 
make the loss contingency both probable and 
reasonably estimable.  BNY Mellon believes that its 

Notes to Consolidated Financial Statements (continued)

accruals for legal proceedings are appropriate and, in 
the aggregate, are not material to the consolidated 
financial position of BNY Mellon, although future 
accruals could have a material effect on the results of 
operations in a given period.

For certain of those matters described here for which 
a loss contingency may, in the future, be reasonably 
possible (whether in excess of a related accrued 
liability or where there is no accrued liability), BNY 
Mellon is currently unable to estimate a range of 
reasonably possible loss.  For those matters described 
here where BNY Mellon is able to estimate a 
reasonably possible loss, the aggregate range of such 
reasonably possible loss is up to $900 million in 
excess of the accrued liability (if any) related to those 
matters.  

The following describes certain judicial, regulatory 
and arbitration proceedings involving BNY Mellon:

Mortgage-Securitization Trusts Proceedings
The Bank of New York Mellon has been named as a 
defendant in a number of legal actions brought by 
MBS investors alleging that the trustee has expansive 
duties under the governing agreements, including the 
duty to investigate and pursue breach of 
representation and warranty claims against other 
parties to the MBS transactions.  These actions 
include a lawsuit brought in New York State court on 
June 18, 2014, and later re-filed in federal court, by a 
group of institutional investors who purport to sue on 
behalf of 233 MBS trusts. 

Matters Related to R. Allen Stanford
In late December 2005, Pershing LLC (“Pershing”) 
became a clearing firm for Stanford Group Co. 
(“SGC”), a registered broker-dealer that was part of a 
group of entities ultimately controlled by R. Allen 
Stanford (“Stanford”).  Stanford International Bank 
(“SIB”), also controlled by Stanford, issued 
certificates of deposit (“CDs”).  Some investors 
allegedly wired funds from their SGC accounts to 
purchase CDs.  In 2009, the SEC charged Stanford 
with operating a Ponzi scheme in connection with the 
sale of CDs, and SGC was placed into receivership.  
Alleged purchasers of CDs have filed 15 lawsuits 
against Pershing that are pending in Texas, including 
two putative class actions.  The purchasers allege that 
Pershing, as SGC’s clearing firm, assisted Stanford in 
a fraudulent scheme and assert contractual, statutory 
and common law claims.  On July 12, 2018, a federal 
district court dismissed six of the individual lawsuits 

and those cases are on appeal.  A series of FINRA 
arbitration proceedings also have been initiated by 
alleged purchasers asserting similar claims. 

Brazilian Postalis Litigation
BNY Mellon Servicos Financeiros DTVM S.A. 
(“DTVM”), a subsidiary that provides asset services 
in Brazil, acts as administrator for certain investment 
funds in which a public pension fund for postal 
workers called Postalis-Instituto de Seguridade Social 
dos Correios e Telégrafos (“Postalis”) invested.  On 
Aug. 22, 2014, Postalis sued DTVM in Rio de 
Janeiro, Brazil for losses related to a Postalis fund for 
which DTVM is administrator.  Postalis alleges that 
DTVM failed to properly perform duties, including to 
conduct due diligence of and exert control over the 
manager.  On March 12, 2015, Postalis filed a lawsuit 
in Rio de Janeiro against DTVM and BNY Mellon 
Administração de Ativos Ltda. (“Ativos”) alleging 
failure to properly perform duties relating to another 
fund of which DTVM is administrator and Ativos is 
manager.  On Dec. 14, 2015, Associacão dos 
Profissionais dos Correiros (“ADCAP”), a Brazilian 
postal workers association, filed a lawsuit in São 
Paulo against DTVM and other defendants alleging 
that DTVM improperly contributed to Postalis 
investment losses.  On March 20, 2017, the lawsuit 
was dismissed without prejudice, and ADCAP has 
appealed that decision.  On Dec. 17, 2015, Postalis 
filed three lawsuits in Rio de Janeiro against DTVM 
and Ativos alleging failure to properly perform duties 
with respect to investments in several other funds.  
On Feb. 4, 2016, Postalis filed a lawsuit in Brasilia 
against DTVM, Ativos and BNY Mellon Alocação de 
Patrimônio Ltda., an investment management 
subsidiary, alleging failure to properly perform duties 
and liability for losses with respect to investments in 
various funds of which the defendants were 
administrator and/or manager.  On Jan. 16, 2018, the 
Brazilian Federal Prosecution Service (“MPF”) filed 
a civil lawsuit in São Paulo against DTVM alleging 
liability for Postalis losses based on alleged failures 
to properly perform certain duties as administrator to 
certain funds in which Postalis invested or controller 
of Postalis’s own investment portfolio.  On April 18, 
2018, the court dismissed the lawsuit without 
prejudice, and the MPF has appealed that decision.  
On Oct. 31, 2018, Postalis filed an application in 
federal court in the Southern District of New York 
seeking an order authorizing it to take discovery from 
The Bank of New York Mellon Corporation and its 
U.S. subsidiaries, purportedly for use in the Brazilian 

BNY Mellon 187 

Notes to Consolidated Financial Statements (continued)

proceedings.  On Dec. 20, 2018, the court denied 
Postalis’s application in its entirety.

maker for our customers and facilitating customer 
trades in compliance with the Volcker Rule.

Depositary Receipt Litigation
Between late December 2015 and February 2016, 
four putative class action lawsuits were filed against 
BNY Mellon asserting claims relating to BNY 
Mellon’s foreign exchange pricing when converting 
dividends and other distributions from non-U.S. 
companies in its role as depositary bank to Depositary 
Receipt issuers.  The claims are for breach of contract 
and violations of ERISA.  The lawsuits have been 
consolidated into two suits that are pending in federal 
court in the Southern District of New York.  The 
parties in the lawsuits have entered into settlement 
agreements to resolve the suits, which are subject to 
court approval.

Brazilian Silverado Litigation
DTVM acts as administrator for the Fundo de 
Investimento em Direitos Creditórios Multisetorial 
Silverado Maximum (“Silverado Maximum Fund”), 
which invests in commercial credit receivables.  On 
June 2, 2016, the Silverado Maximum Fund sued 
DTVM in its capacity as administrator, along with 
Deutsche Bank S.A. - Banco Alemão in its capacity 
as custodian and Silverado Gestão e Investimentos 
Ltda. in its capacity as investment manager.  The 
Fund alleges that each of the defendants failed to 
fulfill its respective duty, and caused losses to the 
Fund for which the defendants are jointly and 
severally liable.

Depositary Receipt Pre-Release Inquiry
In March 2014, the Staff of the U.S. Securities and 
Exchange Commission’s Enforcement Division (the 
“Staff”) commenced an investigation into certain 
issuers of American Depositary Receipts (“ADRs”), 
including BNY Mellon, for the period of 2011 to 
2015.  The Staff issued several requests to BNY 
Mellon for information relating to the pre-release of 
ADRs.  BNY Mellon fully cooperated with the 
investigation.  On Dec. 17, 2018, the SEC announced 
that BNY Mellon had settled an administrative 
proceeding to resolve the investigation of BNY 
Mellon’s pre-release activity, in which BNY Mellon 
did not admit or deny the SEC’s findings.

Note 22–Derivative instruments

We use derivatives to manage exposure to market 
risk, including interest rate risk, equity price risk and 
foreign currency risk, as well as credit risk.  Our 
trading activities are focused on acting as a market-

 188 BNY Mellon

The notional amounts for derivative financial 
instruments express the dollar volume of the 
transactions; however, credit risk is much smaller.  
We perform credit reviews and enter into netting 
agreements and collateral arrangements to minimize 
the credit risk of derivative financial instruments.  We 
enter into offsetting positions to reduce exposure to 
foreign currency, interest rate and equity price risk.

Use of derivative financial instruments involves 
reliance on counterparties.  Failure of a counterparty 
to honor its obligation under a derivative contract is a 
risk we assume whenever we engage in a derivative 
contract.  There were no counterparty default losses 
recorded in 2018 or 2017.

Hedging derivatives

We utilize interest rate swap agreements to manage 
our exposure to interest rate fluctuations.  We enter 
into fair value hedges as an interest rate risk 
management strategy to reduce fair value variability 
by converting certain fixed rate interest payments 
associated with available-for-sale securities and long-
term debt to LIBOR.

The available-for-sale securities hedged consist of 
U.S. Treasury bonds, agency and non-agency 
commercial MBS, sovereign debt, corporate bonds 
and covered bonds that had original maturities of 30 
years or less at initial purchase.  At Dec. 31, 2018, 
$19.2 billion face amount of available-for-sale 
securities were hedged with interest rate swaps 
designated as fair value hedges that had notional 
values of $19.3 billion.

The fixed rate long-term debt instruments hedged 
generally have original maturities of five to 30 years.  
We issue both callable and non-callable debt.  The 
debt is hedged with “receive fixed rate, pay variable 
rate” swaps.  At Dec. 31, 2018, $16.6 billion par 
value of debt was hedged with interest rate swaps 
designated as fair value hedges that had notional 
values of $16.6 billion.

In addition, we utilize forward foreign exchange 
contracts as hedges to mitigate foreign exchange 
exposures.  We use forward foreign exchange 
contracts as cash flow hedges to convert certain 
forecasted non-U.S. dollar revenue and expenses into 

Notes to Consolidated Financial Statements (continued)

U.S. dollars.  We use forward foreign exchange 
contracts with maturities of 15 months or less as cash 
flow hedges to hedge our foreign exchange exposure 
to Indian rupee, British pound, Hong Kong dollar, 
Singapore dollar and Polish zloty revenue and 
expense transactions in entities that have the U.S. 
dollar as their functional currency.  As of Dec. 31, 
2018, the hedged forecasted foreign currency 
transactions and designated forward foreign exchange 
contract hedges were $234 million (notional), with a 
pre-tax loss of $1 million recorded in accumulated 
OCI.  This loss will be reclassified to earnings over 
the next 12 months.

We also utilize forward foreign exchange contracts as 
fair value hedges of the foreign exchange risk 
associated with available-for-sale securities.  Forward 
points are designated as an excluded component, and 
amortized into earnings over the hedge period.  The 
unamortized derivative value associated with the 
excluded component is recognized in accumulated 
OCI.  At Dec. 31, 2018, $147 million face amount of 
available-for-sale securities were hedged with foreign 
currency forward contracts that had a notional value 
of $147 million.

Forward foreign exchange contracts are also used to 
hedge the value of our net investments in foreign 
subsidiaries.  These forward foreign exchange 
contracts have maturities of less than one year.  The 
derivatives employed are designated as hedges of 
changes in value of our foreign investments due to 
exchange rates.  Changes in the value of the forward 
foreign exchange contracts offset the changes in value 
of the foreign investments due to changes in foreign 
exchange rates.  The change in fair market value of 
these forward foreign exchange contracts is reported 
within foreign currency translation adjustments in 
shareholders’ equity, net of tax.  At Dec. 31, 2018, 
forward foreign exchange contracts with notional 
amounts totaling $5.9 billion were designated as net 
investment hedges.

In addition to forward foreign exchange contracts, we 
also designate non-derivative financial instruments as 
hedges of our net investments in foreign subsidiaries.  
Those non-derivative financial instruments 
designated as hedges of our net investments in 
foreign subsidiaries were all long-term liabilities of 
BNY Mellon in various currencies, and, at Dec. 31, 
2018, had a combined U.S. dollar equivalent value of 
$175 million.

The following table presents the gains (losses) related to our hedging derivative portfolio recognized in the 
consolidated income statement.

Income statement impact of fair value and cash flow hedges

(in millions)

Interest rate fair value hedges of available-for-sale securities

Derivative
Hedged item

Interest rate fair value hedges of long-term debt

Derivative
Hedged item

Foreign exchange fair value hedges of available-for-sale securities

Derivative (a)
Hedged item

Cash flow hedges of forecasted FX exposures

Gain (loss) reclassified from OCI into income
Gain reclassified from OCI into income
(Loss) reclassified from OCI into income
(Loss) gain reclassified from OCI into income
Gains (losses) recognized in the consolidated income statement due to fair value and

cash flow hedging relationships

Year ended Dec. 31,

Location of 
gains (losses)

2018

2017

2016

Interest income $
Interest income

284 $
(273)

82 $
(97)

Interest expense
Interest expense

(328)
330

(197)
190

Other revenue
Other revenue

Trading revenue
Other revenue
Net interest revenue
Staff expense

(2)
2

—
2
—
(4)

—
—

2
8
—
10

$

11 $

(2) $

49
(50)

(323)
320

—
—

(16)
—
(18)
(11)

(49)

(a) 

Includes $1 million associated with the amortization of the excluded component.  At Dec. 31, 2018, the remaining accumulated OCI balance associated 
with the excluded component was de minimis.

BNY Mellon 189 

Notes to Consolidated Financial Statements (continued)

The following table presents the impact of hedging derivatives used in net investment hedging relationships in the 
consolidated income statement.

Impact of derivative instruments used in net investment hedging relationships in the income statement
(in millions)

Derivatives in net investment hedging
relationships

FX contracts

Gain or (loss) recognized in
accumulated OCI on derivatives
Year ended Dec. 31,

2018

$

535 $

2017
(625) $

2016
652

Location of gain or (loss) reclassified
from accumulated OCI into income

Net interest revenue

Gain or (loss) reclassified from
accumulated OCI into income
Year ended Dec. 31,

2018

2017

$

— $

— $

2016
—

The following table presents information on the hedged items in fair value hedging relationships.

Hedged items in fair value hedging relationships at Dec. 31, 2018
(in millions)
Available-for-sale securities (a)
Long-term debt

Carrying amount of hedged
asset or liability

Hedge accounting basis
adjustment (decrease)

$

19,201
16,147

$

(125)
(453) (b)

(a)  Excludes hedged items where only foreign currency risk is the designated hedged risk, as the basis adjustments related to foreign currency hedges will not 
reverse through the consolidated income statement in future periods.  The carrying amount excluded for available-for-sale securities was $148 million at 
Dec. 31, 2018.
Includes $284 million of basis adjustment on long-term debt associated with terminated hedges.

(b) 

The following table summarizes the notional amount and credit exposure of our total derivative portfolio at Dec. 31, 
2018 and Dec. 31, 2017.

Impact of derivative instruments on the balance sheet

(in millions)
Derivatives designated as hedging instruments: (a)(b)
Interest rate contracts
Foreign exchange contracts

Total derivatives designated as hedging instruments

Derivatives not designated as hedging instruments: (b)(c)
Interest rate contracts
Foreign exchange contracts
Equity contracts
Credit contracts

Total derivatives not designated as hedging instruments
Total derivatives fair value (d)
Effect of master netting agreements (e)

Fair value after effect of master netting agreements

Notional value
Dec. 31,

Asset derivatives
fair value
Dec. 31,

Liability derivatives
fair value
Dec. 31,

2018

2017

2018

2017

2018

2017

$

35,890 $
6,330

36,315
8,923

$ 248,534 $ 267,485
767,999
1,698
180

831,730
927
150

$

$

$

$
$

$

23 $
266
289 $

278
45
323

3,590 $
4,807
68
—
8,465 $
8,754 $
(5,939)
2,815 $

6,439
5,104
70
—
11,613
11,936
(8,845)
3,091

$

$

$

$
$

$

74 $
14
88 $

534
266
800

3,116 $
5,215
118
1
8,450 $
8,538 $
(6,170)
2,368 $

6,353
5,067
149
4
11,573
12,373
(8,797)
3,576

(a)  The fair value of asset derivatives and liability derivatives designated as hedging instruments is recorded as other assets and other 

liabilities, respectively, on the consolidated balance sheet.

(b)  Pursuant to a rule change at a clearing organization in 2018, cash collateral exchanged is deemed a settlement of the derivative each 

day.  The impact of the change reduced the gross fair value of derivative assets and liabilities and a corresponding decrease in effect of 
master netting agreements, with no impact to the consolidated balance sheet.

(c)  The fair value of asset derivatives and liability derivatives not designated as hedging instruments is recorded as trading assets and 

trading liabilities, respectively, on the consolidated balance sheet.

(d)  Fair values are on a gross basis, before consideration of master netting agreements, as required by ASC 815, Derivatives and Hedging.
(e)  Effect of master netting agreements includes cash collateral received and paid of $809 million and $1,040 million, respectively, at Dec. 

31, 2018, and $925 million and $877 million, respectively, at Dec. 31, 2017.

 190 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Trading activities (including trading derivatives)

Our trading activities are focused on acting as a 
market-maker for our customers, facilitating customer 
trades and risk mitigating economic hedging in 
compliance with the Volcker Rule.  The change in the 
fair value of the derivatives utilized in our trading 
activities is recorded in foreign exchange and other 
trading revenue on the consolidated income 
statement.

The following table presents our foreign exchange 
and other trading revenue.

Foreign exchange and other

trading revenue

(in millions)
Foreign exchange
Other trading revenue
Total foreign exchange and other

trading revenue

$

$

Year ended Dec. 31,
2018
663 $
69

638 $
30

2017

2016
687
14

732 $

668 $

701

Foreign exchange revenue includes income from 
purchasing and selling foreign currencies and 
currency forwards, futures and options.  Other trading 
revenue reflects results from trading in cash 
instruments including fixed income and equity 
securities and non-foreign exchange derivatives.

We also use derivative financial instruments as risk 
mitigating economic hedges, which are not formally 
designated as accounting hedges.  This includes 
hedging the foreign currency, interest rate or market 
risks inherent in some of our balance sheet exposures, 
such as seed capital investments and deposits, as well 
as certain investment management fee revenue 
streams.  We also use total return swaps to 
economically hedge obligations arising from the 
company’s deferred compensation plan whereby the 
participants defer compensation and earn a return 
linked to the performance of investments they select.  
The gains or losses on these total return swaps are 
recorded in staff expense on the consolidated income 
statement and was a loss of $20 million in 2018, a 
gain of $26 million in 2017 and a gain of $14 million 
in 2016. 

We manage trading risk through a system of position 
limits, a VaR methodology based on historical 
simulation and other market sensitivity measures.  
Risk is monitored and reported to senior management 
by a separate unit, independent from trading, on a 
daily basis.  Based on certain assumptions, the VaR 
methodology is designed to capture the potential 

overnight pre-tax dollar loss from adverse changes in 
fair values of all trading positions.  The calculation 
assumes a one-day holding period, utilizes a 99% 
confidence level and incorporates non-linear product 
characteristics.  The VaR model is one of several 
statistical models used to develop economic capital 
results, which are allocated to lines of business for 
computing risk-adjusted performance.

VaR methodology does not evaluate risk attributable 
to extraordinary financial, economic or other 
occurrences.  As a result, the risk assessment process 
includes a number of stress scenarios based upon the 
risk factors in the portfolio and management’s 
assessment of market conditions.  Additional stress 
scenarios based upon historical market events are also 
performed.  Stress tests may incorporate the impact of 
reduced market liquidity and the breakdown of 
historically observed correlations and extreme 
scenarios.  VaR and other statistical measures, stress 
testing and sensitivity analysis are incorporated in 
other risk management materials.

Counterparty credit risk and collateral

We assess credit risk of our counterparties through 
regular examination of their financial statements, 
confidential communication with the management of 
those counterparties and regular monitoring of 
publicly available credit rating information.  This and 
other information is used to develop proprietary 
credit rating metrics used to assess credit quality.

Collateral requirements are determined after a 
comprehensive review of the credit quality of each 
counterparty.  Collateral is generally held or pledged 
in the form of cash and/or highly liquid government 
securities.  Collateral requirements are monitored and 
adjusted daily.

Additional disclosures concerning derivative financial 
instruments are provided in Note 19.

Disclosure of contingent features in OTC derivative 
instruments

Certain OTC derivative contracts and/or collateral 
agreements contain credit-risk contingent features 
triggered upon a rating downgrade in which the 
counterparty has the right to request additional 
collateral or the right to terminate the contracts in a 
net liability position.  

BNY Mellon 191 

Notes to Consolidated Financial Statements (continued)

The following table shows the aggregate fair value of 
OTC derivative contracts in net liability positions that 
contained credit-risk contingent features and the 
value of collateral that has been posted.

The following table shows the fair value of contracts 
falling under early termination provisions that were in 
net liability positions for three key ratings triggers.  

(in millions)
Aggregate fair value of OTC derivatives 

in net liability positions (a)
Collateral posted
(a)  Before consideration of cash collateral.

Dec. 31,

2018

$
$

2,877 $
2,801 $

2017

2,393
2,115

The aggregate fair value of OTC derivative contracts 
containing credit-risk contingent features can 
fluctuate from quarter to quarter due to changes in 
market conditions, composition of counterparty 
trades, new business or changes to the contingent 
features.

The Bank of New York Mellon, our largest banking 
subsidiary, enters into the substantial majority of our 
OTC derivative contracts and/or collateral 
agreements.  As such, the contingent features may be 
triggered if The Bank of New York Mellon’s long-
term issuer rating was downgraded.

Offsetting assets and liabilities

Potential close-out exposures (fair value) (a)

(in millions)
If The Bank of New York Mellon’s 
rating changed to: (b)

Dec. 31,
2018

Dec. 31,
2017

A3/A-
Baa2/BBB
Ba1/BB+

92
748
2,007
(a)  The amounts represent potential total close-out values if The 

15 $
116 $
1,041 $

$
$
$

Bank of New York Mellon’s long-term issuer rating were to 
immediately drop to the indicated levels, and do not reflect 
collateral posted.

(b)  Represents rating by Moody’s/S&P.

If The Bank of New York Mellon’s debt rating had 
fallen below investment grade on Dec. 31, 2018 and 
Dec. 31, 2017, existing collateral arrangements would 
have required us to post additional collateral of $100 
million and $102 million, respectively.

The following tables present derivative instruments and financial instruments that are either subject to an 
enforceable netting agreement or offset by collateral arrangements.  There were no derivative instruments or 
financial instruments subject to a legally enforceable netting agreement for which we are not currently netting.

Offsetting of derivative assets and financial assets at Dec. 31, 2018

(in millions)
Derivatives subject to netting arrangements:

Gross
amounts
offset in the
balance
sheet

(a)

Net assets
recognized
in the
balance
sheet

Gross amounts not offset
in the balance sheet

Financial
instruments

Cash
collateral
received

Net
amount

Gross assets
recognized

$

Interest rate contracts
Foreign exchange contracts
Equity and other contracts

Total derivatives subject to netting arrangements
Total derivatives not subject to netting arrangements

319
615
25
959
1,653
2,612
—
302
2,914
(a)  Includes the effect of netting agreements and net cash collateral received.  The offset related to the OTC derivatives was allocated to the 

Total derivatives
Reverse repurchase agreements
Securities borrowing
Total

2,202
3,724
13
5,939
—
5,939
76,040 (b)
—
81,979

2,654 $
4,409
38
7,101
1,653
8,754
112,245
10,588
131,587 $

133 $
70
—
203
—
203
36,205
10,286
46,694 $

452 $
685
25
1,162
1,653
2,815
36,205
10,588
49,608 $

— $
—
—
—
—
—
—
—
— $

$

$

$

various types of derivatives based on the net positions.

(b)  Offsetting of reverse repurchase agreements relates to our involvement in the FICC, where we settle government securities transactions 

on a net basis for payment and delivery through the Fedwire system.

 192 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Offsetting of derivative assets and financial assets at Dec. 31, 2017

(in millions)
Derivatives subject to netting arrangements:

Gross
amounts
offset in the
balance
sheet

(a)

Net assets 
recognized 
in the 
balance 
sheet

Gross amounts not offset
in the balance sheet

Financial
instruments

Cash
collateral
received

Net
amount

Gross assets
recognized

$

Interest rate contracts
Foreign exchange contracts
Equity and other contracts

Total derivatives subject to netting arrangements
Total derivatives not subject to netting arrangements

662
830
17
1,509
1,288
2,797
13
341
3,151
(a)  Includes the effect of netting agreements and net cash collateral received.  The offset related to the OTC derivatives was allocated to the 

Total derivatives
Reverse repurchase agreements
Securities borrowing
Total

5,075
3,720
50
8,845
—
8,845
25,848 (b)
—
34,693

178 $
116
—
294
—
294
16,923
10,858
28,075 $

840 $
946
17
1,803
1,288
3,091
16,936
11,199
31,226 $

5,915 $
4,666
67
10,648
1,288
11,936
42,784
11,199
65,919 $

— $
—
—
—
—
—
—
—
— $

$

$

$

various types of derivatives based on the net positions.

(b)  Offsetting of reverse repurchase agreements relates to our involvement in the FICC, where we settle government securities transactions 

on a net basis for payment and delivery through the Fedwire system.

Offsetting of derivative liabilities and financial liabilities at Dec. 31, 2018

(in millions)
Derivatives subject to netting arrangements:

Interest rate contracts
Foreign exchange contracts
Equity and other contracts

Total derivatives subject to netting arrangements
Total derivatives not subject to netting arrangements

Total derivatives
Repurchase agreements
Securities lending
Total

Gross
amounts
offset in the
balance
sheet

(a)

Gross
liabilities
recognized

Net
liabilities
recognized
in the
balance
sheet

Gross amounts not offset
in the balance sheet

Financial
instruments

Cash
collateral
pledged

$

$

3,144 $
4,747
75
7,966
572
8,538
84,665
997
94,200 $

2,508
3,626
36
6,170
—
6,170
76,040 (b)
—
82,210

$

$

636 $

1,121
39
1,796
572
2,368
8,625
997
11,990 $

547 $
187
37
771
—
771
8,625
937
10,333 $

— $
—
—
—
—
—
—
—
— $

Net
amount

89
934
2
1,025
572
1,597
—
60
1,657

(a)  Includes the effect of netting agreements and net cash collateral paid.  The offset related to the OTC derivatives was allocated to the 

various types of derivatives based on the net positions.

(b)  Offsetting of repurchase agreements relates to our involvement in the FICC, where we settle government securities transactions on a net 

basis for payment and delivery through the Fedwire system.

BNY Mellon 193 

Notes to Consolidated Financial Statements (continued)

Offsetting of derivative liabilities and financial liabilities at Dec. 31, 2017

(in millions)
Derivatives subject to netting arrangements:

Interest rate contracts
Foreign exchange contracts
Equity and other contracts

Total derivatives subject to netting arrangements
Total derivatives not subject to netting arrangements

Total derivatives
Repurchase agreements
Securities lending
Total

Gross
amounts
offset in the
balance
sheet

(a)

Gross
liabilities
recognized

Net 
liabilities 
recognized 
in the 
balance 
sheet

Gross amounts not offset
in the balance sheet

Financial
instruments

Cash
collateral
pledged

$

$

6,810 $
4,765
143
11,718
655
12,373
33,908
2,186
48,467 $

5,495
3,221
81
8,797
—
8,797
25,848 (b)
—
34,645

$

$

1,315 $
1,544
62
2,921
655
3,576
8,060
2,186
13,822 $

1,222 $
177
58
1,457
—
1,457
8,059
2,091
11,607 $

— $
—
—
—
—
—
—
—
— $

Net
amount

93
1,367
4
1,464
655
2,119
1
95
2,215

(a)  Includes the effect of netting agreements and net cash collateral paid.  The offset related to the OTC derivatives was allocated to the 

various types of derivatives based on the net positions.

(b)  Offsetting of repurchase agreements relates to our involvement in the FICC, where we settle government securities transactions on a net 

basis for payment and delivery through the Fedwire system.

Secured borrowings

The following table presents the contract value of repurchase agreements and securities lending transactions 
accounted for as secured borrowings by the type of collateral provided to counterparties.

Repurchase agreements and securities lending transactions accounted for as secured borrowings

(in millions)
Repurchase agreements:

U.S. Treasury
U.S. government agencies
Agency RMBS
Corporate bonds
Other debt securities
Equity securities

Total

Securities lending:

U.S. government agencies
Other debt securities
Equity securities

Total

Total borrowings

Dec. 31, 2018

Remaining contractual maturity

Overnight and
continuous

Up to 30
days

30 days or
more

$

$

$

$
$

76,822 $
759
3,184
416
271
163
81,615 $

7 $

294
696
997 $
82,612 $

— $
—
—
—
—
—
— $

— $
—
—
— $
— $

— $
—
4
1,413
1,106
527
3,050 $

— $
—
—
— $
3,050 $

Total

76,822
759
3,188
1,829
1,377
690
84,665

7
294
696
997
85,662

Dec. 31, 2017

Remaining contractual maturity

Overnight and
continuous

Up to 30
days

30 days or
more

$

$

$

$
$

26,883 $
570
2,574
373
253
655
31,308 $

72 $

316
1,798
2,186 $
33,494 $

11 $

180
109
—
—
—
300 $

— $
—
—
— $
300 $

— $
—
—
1,052
731
517
2,300 $

— $
—
—
— $
2,300 $

Total

26,894
750
2,683
1,425
984
1,172
33,908

72
316
1,798
2,186
36,094

BNY Mellon’s repurchase agreements and securities 
lending transactions primarily encounter risk 
associated with liquidity.  We are required to pledge 
collateral based on predetermined terms within the 
agreements.  If we were to experience a decline in the 
fair value of the collateral pledged for these 
transactions, we could be required to provide 

additional collateral to the counterparty, therefore 
decreasing the amount of assets available for other 
liquidity needs that may arise.  BNY Mellon also 
offers tri-party collateral agency services in the tri-
party repo market where we are exposed to credit 
risk.  In order to mitigate this risk, we require dealers 
to fully secure intraday credit.

 194 BNY Mellon

Notes to Consolidated Financial Statements (continued)

Note 23–Lines of business

We have an internal information system that produces performance data along product and service lines for our two 
principal businesses and the Other segment.  The primary products and services and types of revenue for our 
principal businesses and a description of the Other segment are presented below.

Investment Services business

Line of business
Asset Servicing

Pershing

Issuer Services

Treasury Services

Primary products and services
Custody, accounting, ETF services,
middle-office solutions, transfer agency,
services for private equity and real estate
funds, foreign exchange, securities
lending, liquidity/lending services, prime
brokerage and data analytics

Clearing and custody, investment, wealth
and retirement solutions, technology and
enterprise data management, trading
services and prime brokerage

Corporate Trust (trustee, administration
and agency services and reporting and
transparency) and Depositary Receipts
(issuer services and support for brokers
and investors)

Integrated cash management solutions
including payments, foreign exchange,
liquidity management, receivables
processing and payables management
and trade finance and processing

Primary types of revenue
- Asset servicing fees (includes 
securities lending revenue)
- Foreign exchange revenue
- Net interest revenue
- Financing-related fees

- Clearing services fees
- Net interest revenue

- Issuer services fees
- Net interest revenue
- Foreign exchange revenue

- Treasury services fees
- Net interest revenue

Clearance and Collateral Management

U.S. government clearing, global
collateral management and tri-party repo

- Asset servicing fees
- Net interest revenue

Investment Management business

Line of business
Asset Management

Wealth Management

Other segment

Primary products and services
Diversified investment management
strategies and distribution of investment
products

Primary types of revenue
- Investment management fees
- Performance fees
- Distribution and servicing fees

Investment management, custody, wealth
and estate planning and private banking
services

- Investment management fees
- Net interest revenue

Description
Includes leasing portfolio, corporate
treasury activities, including our
securities portfolio, derivatives and other
trading activity, corporate and bank-
owned life insurance, renewable energy
investments and business exits

Primary types of revenue
- Net interest revenue
- Investment and other income
- Net gain (loss) on securities
- Other trading revenue

BNY Mellon 195 

Notes to Consolidated Financial Statements (continued)

Business accounting principles

Our business data has been determined on an internal 
management basis of accounting, rather than the 
generally accepted accounting principles used for 
consolidated financial reporting.  These measurement 
principles are designed so that reported results of the 
businesses will track their economic performance.

Business results are subject to reclassification when 
organizational changes are made.  There were no 
significant organizational changes in 2018.  The 
results are also subject to refinements in revenue and 
expense allocation methodologies, which are 
typically reflected on a prospective basis.

The accounting policies of the businesses are the 
same as those described in Note 1.

The results of our businesses are presented and 
analyzed on an internal management reporting basis.

•  Revenue amounts reflect fee and other revenue 
generated by each business.  Fee and other 
revenue transferred between businesses under 
revenue transfer agreements is included within 
other revenue in each business.  

•  Revenues and expenses associated with specific 

client bases are included in those businesses.  For 
example, foreign exchange activity associated 
with clients using custody products is included in 
Investment Services.  

•  Net interest revenue is allocated to businesses 
based on the yields on the assets and liabilities 
generated by each business.  We employ a funds 
transfer pricing system that matches funds with 
the specific assets and liabilities of each business 
based on their interest sensitivity and maturity 
characteristics.  

•  The provision for credit losses associated with the 
respective credit portfolios is reflected in each 
business segment.
Incentives expense related to restricted stock is 
allocated to the businesses.  

• 

•  Support and other indirect expenses are allocated 
to businesses based on internally developed 
methodologies.

•  Recurring FDIC expense is allocated to the 

businesses based on average deposits generated 
within each business.  

•  Litigation expense is generally recorded in the 

business in which the charge occurs.  

•  Management of the securities portfolio is a shared 
service contained in the Other segment.  As a 
result, gains and losses associated with the 
valuation of the securities portfolio are included 
in the Other segment.  

•  Client deposits serve as the primary funding 

source for our securities portfolio.  We typically 
allocate all interest revenue to the businesses 
generating the deposits.  Accordingly, accretion 
related to the portion of the securities portfolio 
restructured in 2009 has been included in the 
results of the businesses.

•  Balance sheet assets and liabilities and their 
related income or expense are specifically 
assigned to each business.  Businesses with a net 
liability position have been allocated assets.  
•  Goodwill and intangible assets are reflected 

within individual businesses.  

Total revenue includes approximately $2.6 billion in 
2018, $2.4 billion in 2017 and $2.2 billion in 2016 of 
international operations domiciled in the UK which 
comprised 16%, 15% and 14% of total revenue, 
respectively.

 196 BNY Mellon

Notes to Consolidated Financial Statements (continued)

The following consolidating schedules present the contribution of our businesses to our overall profitability.

For the year ended Dec. 31, 2018
(dollars in millions)
Total fee and other revenue
Net interest revenue (expense)

Total revenue
Provision for credit losses
Noninterest expense

Income (loss) before taxes

Investment
Services
8,926
3,372
12,298
1
8,058
4,239

$

$

Investment
Management
$

3,781
303
4,084
3
2,818
1,263

(a) $

(a)

(a) $

$

Consolidated
$

12,792
3,611
16,403
(11)
11,210
5,204

(a) 

(a) 

(b)
(a)(b)

$

Pre-tax operating margin (c)
Average assets
(a)  Both total fee and other revenue and total revenue include a net loss from consolidated investment management funds of $1 million, 

343,774

262,747

31,446

32%

31%

34%

$

$

$

$

representing $13 million of losses and a loss attributable to noncontrolling interests of $12 million.  Income before taxes is net of a loss 
attributable to noncontrolling interests of $12 million.

(b)  Noninterest expense includes a loss attributable to noncontrolling interests of $1 million related to other consolidated subsidiaries.
(c)  Income before taxes divided by total revenue.

For the year ended Dec. 31, 2017
(dollars in millions)
Total fee and other revenue
Net interest revenue (expense)
Total revenue (loss)
Provision for credit losses
Noninterest expense

Income (loss) before taxes

Investment
Services
8,527
3,058
11,585
(7)
7,747
3,845

$

$

Investment
Management
3,668
329
3,997
2
2,854
1,141

$

$

(a) $

(a)

(a) $

Consolidated

$

$

12,202
3,308
15,510
(24)
10,948
4,586

(a)

(a)

(b)
(a)(b)

Pre-tax operating margin (c)
Average assets
(a)  Both total fee and other revenue and total revenue include net income from consolidated investment management funds of $37 million, 

343,848

254,646

31,450

30%

33%

29%

$

$

$

$

representing $70 million of income and noncontrolling interests of $33 million.  Income before taxes is net of noncontrolling interests of 
$33 million.

(b)  Noninterest expense includes a loss attributable to noncontrolling interest of $9 million related to other consolidated subsidiaries.
(c)  Income before taxes divided by total revenue.

Consolidated

$

12,089
3,138
15,227
(11)
10,514
4,724

(a)

(a)

(b)
(a)(b)

For the year ended Dec. 31, 2016
(dollars in millions)
Total fee and other revenue
Net interest revenue

Total revenue
Provision for credit losses
Noninterest expense

$

Investment
Services
8,299
2,797
11,096
8
7,342
3,746

(a) $

(a)

$

Investment
Management
3,424
327
3,751
6
2,778
967
26%

Income before taxes
Pre-tax operating margin (c)
Average assets
(a)  Both total fee and other revenue and total revenue include net income from consolidated investment management funds of $16 million, 

358,477

273,808

30,169

(a) $

31%

34%

$

$

$

$

$

$

$

representing $26 million of income and noncontrolling interests of $10 million.  Income before taxes is net of noncontrolling interests of 
$10 million.

(b)  Noninterest expense includes a loss attributable to noncontrolling interest of $9 million related to other consolidated subsidiaries.
(c)  Income before taxes divided by total revenue.

BNY Mellon 197 

Other
85
(64)
21
(15)
334
(298)
N/M
49,581

Other
7
(79)
(72)
(19)
347
(400)
N/M
57,752

Other
366
14
380
(25)
394
11
N/M
54,500

Notes to Consolidated Financial Statements (continued)

Note 24–International operations

International activity includes Investment Services 
and Investment Management fee revenue generating 
businesses, foreign exchange trading activity, loans 
and other revenue producing assets and transactions 
in which the customer is domiciled outside of the 
United States and/or the international activity is 
resident at an international entity.  Due to the nature 
of our international and domestic activities, it is not 
possible to precisely distinguish our international 
operations between internationally and domestically 

domiciled customers.  As a result, it is necessary to 
make certain subjective assumptions such as:

• 

Income from international operations is 
determined after internal allocations for interest 
revenue, taxes, expenses and provision for credit 
losses.

•  Expense charges to international operations 

include those directly incurred in connection with 
such activities, as well as an allocable share of 
general support and overhead charges.

Total assets, total revenue, income before income taxes and net income of our international operations are shown in 
the table below.

International operations
(in millions)
2018

2017

2016

Total assets at period end (a)
Total revenue
Income before income taxes
Net income

Total assets at period end (a)
Total revenue
Income before income taxes
Net income

Total assets at period end (a)
Total revenue
Income before income taxes
Net income

International

EMEA

APAC

Other

Total
International

Total
Domestic

$

$

$

74,982 (b) $
4,252 (b)
1,694
1,345

88,490 (b) $
3,982 (b)
1,497
1,186

73,303 (b) $
3,744 (b)
1,263
1,013

23,199 $
1,103
564
448

20,676 $
997
538
426

18,074 $
922
485
389

1,483 $
684
455
361

1,737 $
610
296
234

1,350 $
549
286
229

$

$

$

99,664
6,039
2,713
2,154

110,903
5,589
2,331
1,846

92,727
5,215
2,034
1,631

$

$

$

263,209
10,353
2,479
2,100

260,855
9,954
2,279
2,268

240,742
10,022
2,691
1,917

Total

362,873
16,392
5,192
4,254

371,758
15,543
4,610
4,114

333,469
15,237
4,725
3,548

(a)  Total assets include long-lived assets, which are not considered by management to be significant in relation to total assets.  Long-lived 

assets are primarily located in the United States.

(b)  Includes assets of approximately $30.6 billion, $32.9 billion and $29.6 billion and revenue of approximately $2.6 billion, $2.4 billion and 
$2.2 billion in 2018, 2017 and 2016, respectively, of international operations domiciled in the UK, which is 8%, 9% and 9% of total 
assets and 16%, 15% and 14% of total revenue, respectively.

Note 25–Supplemental information to the Consolidated Statement of Cash Flows

Non-cash investing and financing transactions that, appropriately, are not reflected in the consolidated statement of 
cash flows are listed below.

Non-cash investing and financing transactions
(in millions)
Transfers from loans to other assets for other real estate owned
Change in assets of consolidated VIEs
Change in liabilities of consolidated VIEs
Change in nonredeemable noncontrolling interests of consolidated investment management funds
Securities purchased not settled
Securities sold not settled
Securities matured not settled
Available-for-sale securities transferred to trading assets
Held-to-maturity securities transferred to available-for-sale
Premises and equipment/capitalized software funded by capital lease obligations

Year ended Dec. 31,

2018

2017

$

2 $

3 $

268
—
215
227
187
—
963
1,087
26

500
313
302
112
587
70
—
74
347

2016
4
170
69
120
75
—
—
—
10
13  

 198 BNY Mellon

Report of Independent Registered Public Accounting Firm

To the Stockholders and Board of Directors
The Bank of New York Mellon Corporation:

Opinion on the Consolidated Financial Statements

We have audited the accompanying consolidated balance sheets of The Bank of New York Mellon Corporation and 
subsidiaries (BNY Mellon) as of December 31, 2018 and 2017, the related consolidated statements of income, 
comprehensive income, changes in equity, and cash flows for each of the years in the three-year period ended 
December 31, 2018, and the related notes (collectively, the consolidated financial statements).  In our opinion, the 
consolidated financial statements present fairly, in all material respects, the financial position of BNY Mellon as of 
December 31, 2018 and 2017, and the results of its operations and its cash flows for each of the years in the three-
year period ended December 31, 2018, in conformity with U.S. generally accepted accounting principles.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United 
States) (PCAOB), BNY Mellon’s internal control over financial reporting as of December 31, 2018, based on 
criteria established in Internal Control - Integrated Framework (2013) issued by the Committee of Sponsoring 
Organizations of the Treadway Commission, and our report dated February 27, 2019 expressed an unqualified 
opinion on the effectiveness of BNY Mellon’s internal control over financial reporting.

Basis for Opinion

These consolidated financial statements are the responsibility of BNY Mellon’s management.  Our responsibility is 
to express an opinion on these consolidated financial statements based on our audits.  We are a public accounting 
firm registered with the PCAOB and are required to be independent with respect to BNY Mellon in accordance with 
the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission 
and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB.  Those standards require that we plan and 
perform the audit to obtain reasonable assurance about whether the consolidated financial statements are free of 
material misstatement, whether due to error or fraud. Our audits included performing procedures to assess the risks 
of material misstatement of the consolidated financial statements, whether due to error or fraud, and performing 
procedures that respond to those risks.  Such procedures included examining, on a test basis, evidence regarding the 
amounts and disclosures in the consolidated financial statements.  Our audits also included evaluating the 
accounting principles used and significant estimates made by management, as well as evaluating the overall 
presentation of the consolidated financial statements.  We believe that our audits provide a reasonable basis for our 
opinion.

We have served as BNY Mellon’s auditor since 2007. 

New York, New York 
February 27, 2019

BNY Mellon 199 

 
Directors, Executive Committee and Other Executive Officers

Effective February 27, 2019

Directors

Steven D. Black
Co-Chief Executive Officer
Bregal Investments
Private equity firm

Linda Z. Cook
Partner, Managing Director and Member of the
Executive Committee of EIG Global Energy
Partners, an investment firm, and Chief
Executive Officer of Harbour Energy, Ltd.,
an energy investment vehicle

Joseph J. Echevarria
Retired Chief Executive Officer
Deloitte LLP
Global provider of audit, consulting, financial
advisory, risk management, tax and related
services

Edward P. Garden
Chief Investment Officer and a founding partner,
Trian Fund Management, L.P.
Alternative investment management firm

Jeffrey A. Goldstein
Chairman
SpringHarbor Holding Company LLC and a
Senior Advisor, Hellman & Friedman LLC
Private equity firm

John M. Hinshaw
Former Executive Vice President and
Chief Customer Officer at
Hewlett Packard Enterprise Company
Global provider of IT, technology and enterprise
products and solutions

Mark A. Nordenberg
Chancellor Emeritus,
Chair of the Institute of Politics and
Distinguished Service Professor of Law
University of Pittsburgh
Major public research university

Elizabeth E. Robinson
Former Global Treasurer, Partner and
Managing Director of
The Goldman Sachs Group, Inc.
Global financial services company

Edmund F. (Ted) Kelly
Retired Chairman
Liberty Mutual Group
Multi-line insurance company

Charles W. Scharf
Chairman and Chief Executive Officer
The Bank of New York Mellon Corporation

Jennifer B. Morgan
Executive Board Member of SAP and
President of SAP Americas and Asia Pacific Japan,
Global Customer Operations
Global software company

Samuel C. Scott III
Retired Chairman, President and
Chief Executive Officer
Ingredion Incorporated (formerly Corn
Products International, Inc.)
Global ingredient solutions provider

Executive Committee and Other Executive Officers

Paul Camp
Chief Executive Officer, Treasury Services

Lisa Dolly
Chief Executive Officer, Pershing LLC

Bridget E. Engle *
Chief Information Officer

Thomas P. (Todd) Gibbons *
Chief Executive Officer, Clearing, Markets
and Client Management

Mitchell E. Harris *
Chief Executive Officer, Investment Management

Monique R. Herena *
Chief Human Resources Officer

Hani A. Kablawi *
Chief Executive Officer, Global Asset Servicing
and Chairman, Europe, Middle East and Africa

Roman Regelman *
Head of Digital

Catherine Keating
Chief Executive Officer, BNY Mellon Wealth
Management

Kurtis R. Kurimsky *
Corporate Controller

Francis (Frank) La Salla *
Chief Executive Officer, Issuer Services

J. Kevin McCarthy *
General Counsel

Michelle M. Neal
Chief Executive Officer, BNY Mellon Markets

Lester J. Owens *
Head of Operations

Brian Ruane
Chief Executive Officer, BNY Mellon
Government Securities Services Corp.

Michael P. Santomassimo *
Chief Financial Officer

Charles W. Scharf *
Chairman and Chief Executive Officer

Akash A. Shah *
Head of Strategy

James S. Wiener *
Chief Risk Officer

* 

Designated as an Executive Officer.

 200 BNY Mellon

Performance Graph

Cumulative shareholder returns (a)
(in dollars)
The Bank of New York Mellon Corporation
S&P 500 Financials Index
S&P 500 Index
Peer Group
(a)  Returns are weighted by market capitalization at the beginning of the measurement period.

2013
100.0
100.0
100.0
100.0

2014
118.3
115.2
113.7
115.5

$

$

$

2015
122.2
113.4
115.3
115.3

Dec. 31,

$

$

2016
143.0
139.3
129.1
139.3

2017
165.4
170.2
157.2
168.8

$

2018
147.5
148.0
150.3
141.0

This graph shows The Bank of New York Mellon Corporation’s cumulative total shareholder returns over the five-
year period from Dec. 31, 2013 to Dec. 31, 2018.  Our peer group is composed of financial services companies 
which provide investment management and investment servicing.  We also utilize the S&P 500 Financials Index as a 
benchmark against our performance.  The graph shows the cumulative total returns for the same five-year period of 
the S&P 500 Financials Index, the S&P 500 Index as well as our peer group listed below.  The comparison assumes 
a $100 investment on Dec. 31, 2013 in The Bank of New York Mellon Corporation common stock, in the S&P 500 
Financials Index, in the S&P 500 Index and in the peer group detailed below and assumes that all dividends were 
reinvested.

Peer Group
BlackRock, Inc.
The Charles Schwab Corporation
Franklin Resources, Inc.
JPMorgan Chase & Co.

Morgan Stanley
Northern Trust Corporation
The PNC Financial Services Group, Inc.
Prudential Financial, Inc.

State Street Corporation
U.S. Bancorp
Wells Fargo & Company

BNY Mellon 201 

Corporate Information

BNY Mellon is a global investments company dedicated to helping its clients manage and service their financial assets 
throughout the investment lifecycle. Whether providing financial services for institutions, corporations or individual 
investors, BNY Mellon delivers informed investment services and investment management in 35 countries. As of 
December 31, 2018, BNY Mellon had $33.1 trillion in assets under custody and/or administration, and $1.7 trillion in 
assets under management. BNY Mellon can act as a single point of contact for clients looking to create, trade, hold, 
manage, service, distribute or restructure investments. BNY Mellon is the corporate brand of The Bank of New York 
Mellon Corporation (NYSE: BK). Additional information is available on www.bnymellon.com. Follow us on  
Twitter @BNYMellon or visit our newsroom at www.bnymellon.com/newsroom for the latest company news.

CORPORATE HEADQUARTERS 
240 Greenwich Street, New York, NY 10286 
+ 1 212 495 1784 
www.bnymellon.com 

ANNUAL MEETING 
The Annual Meeting of Shareholders will be held in New York at  
240 Greenwich Street at 9 a.m. on Tuesday, April 9, 2019.

EXCHANGE LISTING 
BNY Mellon’s common stock is traded on the New York Stock Exchange  
under the trading symbol BK. Mellon Capital IV’s 6.244% Fixed-to-Floating 
Rate Normal Preferred Capital Securities fully and unconditionally  
guaranteed by BNY Mellon (symbol BK/P) and depositary shares, each 
representing a 1/4,000th interest in a share of BNY Mellon’s Series C 
Noncumulative Perpetual Preferred Stock (symbol BK PrC), also are listed  
on the New York Stock Exchange.  

STOCK PRICES 
Prices for BNY Mellon’s common stock can be viewed at 
www.bnymellon.com/investorrelations. 

CORPORATE GOVERNANCE 
Corporate governance information is available at  
www.bnymellon.com/governance. 

CORPORATE SOCIAL RESPONSIBILITY
Information about BNY Mellon’s commitment to corporate social 
responsibility is available at www.bnymellon.com/csr. BNY Mellon’s  
Corporate Social Responsibility (CSR) Report, which includes our  
Equal Employment Opportunity/Affirmative Action policies, can be  
viewed and printed at www.bnymellon.com/csr. 

INVESTOR RELATIONS 
Visit www.bnymellon.com/investorrelations or  
call +1 212 635 8529.

COMMON STOCK DIVIDEND PAYMENTS 
Subject to approval of the Board of Directors, dividends are paid  
on BNY Mellon’s common stock quarterly in February, May, August  
and November. 

TRANSFER AGENT AND REGISTRAR  
EQ Shareowner Services

SHAREHOLDER SERVICES 
EQ Shareowner Services maintains the records for our registered  
shareholders and can provide a variety of services such as those involving: 

•  Change of name or address 
•  Consolidation of accounts 
•  Duplicate mailings 
•  Dividend reinvestment enrollment 
•  Direct deposit of dividends 
•  Transfer of stock to another person 

For assistance from EQ Shareowner Services,  
visit www.shareowneronline.com or call +1 800 205 7699. 

DIRECT STOCK PURCHASE AND DIVIDEND  
REINVESTMENT PLAN 
The Direct Stock Purchase and Dividend Reinvestment Plan provides a  
way to purchase shares of common stock directly from BNY Mellon at the 
current market value. Non-shareholders may purchase their first shares of 
BNY Mellon’s common stock through the Plan, and shareholders may increase 
their shareholding by reinvesting cash dividends and through optional cash 
investments. Plan details are in a prospectus, which may be viewed online  
at www.shareowneronline.com, or obtained in printed form by calling  
+1 800 205 7699. 

ELECTRONIC DEPOSIT OF DIVIDENDS 
Registered shareholders may have quarterly dividends paid on  
BNY Mellon’s common stock deposited electronically to their checking  
or savings accounts. To have dividends deposited electronically, go to  
www.shareowneronline.com to set up your account(s) for direct deposit.  
If you prefer, you may also send a request by mail to EQ Shareowner  
Services, Shareholder Relations, P.O. Box 64874, St. Paul, MN 55164-0874.  
For more information, call +1 800 205 7699. 

SHAREHOLDER ACCOUNT ACCESS 

BY INTERNET 
www.shareowneronline.com
Shareholders can register to receive shareholder information electronically. 
To enroll, visit www.shareowneronline.com.

FORM 10-K AND SHAREHOLDER PUBLICATIONS 
For a free copy of BNY Mellon’s Annual Report on Form 10-K, including the 
financial statements and the financial statement schedules, or quarterly 
reports on Form 10-Q as filed with the Securities and Exchange Commission, 
send a request by email to investorrelations@bnymellon.com, or by  
mail to Investor Relations at The Bank of New York Mellon Corporation,  
240 Greenwich Street, New York, NY 10286. The 2018 Annual Report, as well 
as Forms 10-K, 10-Q and 8-K and quarterly earnings and other news releases 
can be found at www.bnymellon.com/investorrelations. 

BY PHONE 
Toll-free in the U.S. +1 800 205 7699
Outside the U.S. +1 651 450 4064  

BY MAIL 
EQ Shareowner Services
P.O. Box 64874
St. Paul, MN 55164-0874

The contents of the listed Internet sites are not incorporated in this Annual Report.

 
The Bank of New York Mellon Corporation
240 Greenwich Street
New York, NY 10286
United States
+1 212 495 1784

bnymellon.com