The Bank of New York Mellon

ANNUAL REPORT 2024
UNLOCKING
OPPORTUNITY

DEAR FELLOW 
SHAREHOLDERS,
ROBIN VINCE
President and Chief Executive Officer

Two years ago, near the start of my tenure as CEO, 
I wrote to you that our company had yet to realize 
its inherent promise and potential. 
We benefited from a legacy handed to us by our 
predecessors: a collection of terrific businesses 
and a client franchise that would be the envy of any 
company. But I think it is fair to say that we had not 
played our hand as well as we could have. 
In that same letter, I detailed some of the reasons: 
We had largely operated in silos, particularly following 
a series of mergers over several decades. We had not 
taken advantage of the complementary, adjacent 
nature of our businesses. We had not shown our 
clients the breadth of what we could do for them. 
And importantly, partly due to how we operated 
and partly due to cultural factors, our people had 
yet to experience what we could be as one truly 
unified company.
The leadership team has been determined to address 
these challenges and make more of the opportunity 
provided by our clients, our business and our culture.
Those three things, coupled with our central role in 
global financial markets and the trust in our brand, 
created the underpinnings for our future.
One important additional insight that came from 
our strategy work was that we have several 
businesses that are more akin to a true financial 
platforms company. This became a guide for both 
our approach to delivering client solutions and 
organizing ourselves. We have started to become 
more for our clients by reimagining how we serve 
them and found initial opportunities to run our 
company better through the beginnings of an 
operating model evolution.
We are humble about the work ahead, and I consider 
complacency the enemy of progress. Still, there’s an 
increasingly noticeable difference in the pace and 
determination of the company when I enter our offices 
each day, and I hear that same sentiment from our 
people, clients and many of you, too. 
There has been no single silver bullet; rather, we’ve 
committed to our strategic pillars — to be more for 
our clients, run our company better and power our 
culture, each derived from our early strategy work 
and the thesis that evolved from it. We’ve continued 
to lay the foundation and execute against that 
strategy with an increasing pace. Underscoring all 
of this has been a cultural transformation as we have 
increasingly come together as one BNY. 
Each of these factors is essential to our progress 
and our improved financial performance to date. I will 
share specifics of how we’ve done this in 2024 — and 
intend to continue to do so in the future — in the 
sections that follow. 
        	
BNY ANNUAL REPORT 2024	
I
Last year, BNY’s 240th anniversary in business, was an exciting moment where 
we doubled down on execution. Building on the solid foundation we laid in 
2023, we accelerated the pace of our ongoing transformation and closed out 
2024 with a strong performance, delivering record net income of $4.3 billion 
on record revenue of $18.6 billion and generating a return on tangible common 
equity of 23% for the year.1
1	Return on common equity was 11.9% for the year. Return on tangible common equity is a non-GAAP measure.  
	 See “Supplemental information – Explanation of GAAP and Non-GAAP financial measures” beginning on page 115 for a reconciliation. 

92% 94%
95%
BREADTH OF OUR  CLIENT FRANCHISE
of Fortune 
100 companies
of the Top 
100 investment 
managers 
of the Top 
100 banks
Our teams recognize that it’s all about 
our clients. The health of any business 
depends first and foremost on providing 
consistent and excellent service that 
enables client acquisition, client retention 
and ultimately business growth. 
When we defined our strategy, we knew client obsession 
needed to be central to our DNA. Given the important role 
we play in the global financial system, we have long had the 
privilege and responsibility of working with a significant 
majority of the leading financial institutions, pension funds, 
governments, insurance providers and more. These clients 
often tell us that they trust us immensely, which is evident in 
the fact that many have been in business with us for decades. 
We realized that even with this great starting advantage, we 
were not doing enough to deliver our platforms holistically to 
our clients. It became our mission to determine how to unlock 
growth by doing more business with existing clients. We see 
this as our biggest opportunity for growth, and our value 
proposition is simple: With industry-leading positions across 
most of our business lines, our platforms enable us to 
support clients as a comprehensive solutions provider.  
II        	
BNY ANNUAL REPORT 2024
BE MORE 
FOR OUR
CLIENTS
LOOKING 
BACK
ON 2024
Sources: Fortune 100: For 2024, Fortune, Time Inc. ©2024; Investment Managers: Pensions & Investments, 
worldwide institutional assets under management as of December 31, 2023, P&I Crain Communications Inc. 
©2024; Banks: S&P Global, world’s largest banks by assets* as of December 31, 2023, ©2024 S&P Global; client 
penetration assessment based on positive 2024 revenue with client company or parent/holding company.
*According to S&P Global, company assets were adjusted on a best-efforts basis for pending mergers, 
acquisitions and divestitures as well as M&A deals that closed after the end of the reporting period through 
March 31, 2024. To be eligible for inclusion in pro forma adjustments, the amount of assets being transferred 
had to be at least $1 billion, unless otherwise noted. Assets reported by non-U.S. dollar filers were converted 
to dollars using period-end exchange rates. Total assets were taken on an “as-reported” basis, and no 
adjustments were made to account for differing accounting standards. The majority of the banks were ranked 
by total assets as of December 31, 2023, and the data was compiled April 5, 2024.

        	
BNY ANNUAL REPORT 2024	
III
That led us to the creation of our Commercial Office, 
and subsequently, to update our commercial model. 
Last year we developed a streamlined approach to 
client service that centralizes account planning and 
management and ultimately encourages our teams to be 
more front-footed and proactive about connecting the 
dots across the enterprise to deliver the power of one 
BNY to our clients. Accountability and innovation are 
important elements to this reimagining of our approach 
to client coverage. 
Our commercial model is designed to deliver 
companywide solutions to clients at an accelerated 
pace, improve the client experience and ultimately 
deepen relationships. We remain focused on fueling 
growth by deepening our relationships with existing 
clients while also winning business with new clients 
and increasing our market share. This is an ongoing 
evolution, and while we are in the early days of the new 
model, we are beginning to see green shoots as we 
capitalize on synergies across businesses. The number 
of strategic multi-line-of-business enterprise clients 
has grown by over 20% over the past two years, and 
sales with clients who bought from three or more lines 
of business have grown more than 30% year-over-year.
At the same time, we want to improve how we adapt
and innovate to ensure our products and services 
anticipate client needs, bridging gaps where necessary. 
Delivering and bundling solutions that leverage the 
power of our capabilities is an important way for us 
to drive top-line growth. 
Our acquisition of Archer last fall is a good example 
of BNY becoming an end-to-end provider — in this 
case, across the entire managed account ecosystem, 
be it manufacturing in BNY Investments, distribution 
1	 Ranking based on latest available peer group company filings. Peer group included in ranking analysis: State Street, JPMorgan Chase, Citigroup, BNP Paribas, HSBC, Northern Trust and RBC.
2 	Full-year 2024 figures by deal volume and count referenced herein include long-term program and stand-alone bond issuance in markets where BNY actively participates and for which public 
trustee and/or paying agent data is available. Sources include: Refinitiv, Dealogic, Asset-Backed Alert, Concept ABS and Artemis. Depositary Receipts ranked #1 based on market share sourced 
from BNY internal analysis.
3 	LaRoche Research Partners, “Clearing Firm Customer Composition 2024,” based on number of broker-dealer clients. Registered Investment Advisor rankings sourced from “The Cerulli Report, U.S. 
RIA Marketplace 2024,” Cerulli Associates.
4 	Finadium market analysis as of July 2024.
5 	The Clearing House. Based on CHIPS volumes for the year ended December 31, 2024.
6 	Pensions & Investments, October 21, 2024. Ranked by total assets under management as of December 31, 2023.
7 	Based on company filings and “The Cerulli Report, U.S. Private Banks & Trust Companies 2024.”
Ranked by Wealth Management assets under management as of December 31, 2023.
#1
Global 
Custodian1
#1
Global provider 
of Issuer Services2
#1
Global provider 
of Clearance and 
Collateral Management4
TOP 5
Global U.S. dollar 
payments clearer5
#1
Clearing firm for 
broker-dealers and 
Top 3 RIA Custodian3
TOP 10
U.S. Private Bank7
TOP 15
Global Asset Manager6
MARKET POSITIONS
SECURITIES SERVICES
MARKET AND WEALTH SERVICES
INVESTMENT AND 
WEALTH MANAGEMENT

IV       	
BNY ANNUAL REPORT 2024
The first two years in our platforms journey, 2022 and 
2023, were centered on design and testing. This is 
something we should do only once. In 2024, we began 
execution in earnest and transitioned approximately 
one-quarter of the company into the new model. 
As we progressed, we learned and adjusted, and in 
2025 we will transition the majority of the company 
into our new way of working. 
The Platforms Operating Model is a significant 
initiative, but it is a means to an end, aimed at 
simplification and increased velocity; a contributor 
to top-line revenue growth as well as expenses and 
efficiency. It is, however, just one change, albeit 
an important one. Beyond the operating evolution, 
we recognize that we must also invest in growth, 
scalability and further efficiency. Over the course of 
2024, we increased our investments in new client 
solutions, technology and our people, and we generated 
approximately half a billion dollars of efficiency savings 
by continuing to digitize workflows and leveraging the 
initial benefits of artificial intelligence (AI). 
AI is a catalyst for transformational change — 
maybe as profound as the first commercialization 
of electricity. We see enormous potential in AI across all 
three of our strategic pillars. New solutions for clients, 
significant step-function changes in efficiency and 
more machine-leverage for our people.  
We are early in the journey, despite the investment 
so far. In 2023, we launched an AI Hub, and spent the 
past year building and refining our capabilities. The 
platform is designed to be general-intelligence-model 
agnostic, supports multi-agentic functionality and 
serves as a foundation for our digital employees of the 
future. Of the hundreds of use cases our employees 
have generated, we now have over 40 AI solutions in 
production, touching almost every part of what 
we do at our company. 
As we took stock of our company 
two years ago, it became apparent 
that BNY was not operating as 
efficiently or effectively as it could. 
We took inspiration from other 
industries, and though there is 
no perfect solution, we realized that any organizational 
model should be aligned with the inherent nature of 
the business that it serves.
From this mentality arose the Platforms 
Operating Model, a carefully sequenced, multiyear 
transformation initiative. We decided to unite 
capabilities and better organize ourselves around 
the products and services we deliver to the market, 
so we could do things in one place, and do them 
well. By simplifying, streamlining and collaborating 
through cross-functional teams, we’re able to create 
more intuitive client journeys, improve our ability to 
anticipate unmet needs and accelerate speed 
to market across the firm. 
RUN OUR 
COMPANY 
BETTER
through BNY Pershing or servicing through Archer. 
It also ensured we could be full-service across the 
three wrappers of mutual funds, ETFs and separately 
managed accounts. The transaction also represented 
an important test for our new operating model: 
onboarding Archer as a platform would provide 
capabilities across Asset Servicing, Investments and 
Pershing. Buying it once to serve the whole company, 
shedding the historical silo mentality. 
Throughout 2024, we also developed numerous new 
client solutions, such as CollateralOne, AltsBridge, 
Virtual Account-Based Solutions and three new 
products on our Wove platform for wealth advisors. 
Continued product innovation will be an important 
investment in the years to come.

        	
BNY ANNUAL REPORT 2024	
V
POWER 
OUR 
CULTURE
Underscoring everything else,
we have started to foster a 
high-performing culture that 
thrives on client obsession and 
ownership, centered around our 
updated company principles.
Celebrating our company’s 240th anniversary in 
2024 with colleagues, clients and many other 
stakeholders around the world felt even more special 
at a moment when our people could start to see 
their hard work leaving a positive mark on this iconic 
institution. Considering the transformation underway 
at our company, we decided that the time was right 
last summer to simplify and modernize our brand 
and logo to “BNY” to improve the market’s familiarity 
with who we are and what we do.  
The benefits of our improved visibility in the market 
have also supported our recruiting efforts to attract 
top talent at every level. We see early-career 
recruitment as essential to the future of our company 
and have taken an intentional approach to attracting 
the best and brightest people from around the world. 
Three years ago, we had a minimal presence on 
campuses. Today we have a highly competitive, 
award-winning intern and analyst program. In 2024, 
we doubled the number of interns and analysts at 
BNY for the second consecutive year.
In parallel, we significantly raised the bar on 
what leadership looks like at BNY. At the top of 
the house, we further rounded out our executive 
leadership team and introduced a more rigorous 
selection process and expectations for managing 
directors, who act as force multipliers for our strategy. 
And throughout the company, we’ve reinforced the 
fact that everyone, regardless of role or level, has 
the potential to lead by role-modeling our company 
principles and working to bring their teams and 
colleagues along on the journey. 
To support our ability to recruit and retain the 
very best talent, the targeted investments we’ve 
been making in the employee experience across 
development opportunities, benefits and facilities 
are being recognized and valued by our people. 
These range from our technology-enabled learning 
and feedback platforms to our industry-leading 
suite of mental health and well-being benefits.
Today, our AI Hub is promoting a capability-driven 
approach, creating AI-enabled solutions, deploying 
them across the company and educating our people 
on how to use them thoughtfully and responsibly so 
they can experience tangible outcomes. It’s worth 
repeating the premise here: It is early, but we 
see great opportunity.

	
FINANCIAL
RESULTS
Our progress against each strategic pillar helped us improve our overall 
performance throughout the year. We were pleased that in 2024, we delivered 
strong performance against our financial goals for the year. Taken together, 
significant positive operating leverage resulted in pre-tax margin expansion 
and improved profitability, and we delivered attractive capital returns to our 
shareholders, all of which underscored the execution of a reinvigorated BNY. 
1	 As of December 31, 2024. Consists of assets under custody and/or administration (“AUC/A”) primarily from the Asset Servicing line of 
business and, to a lesser extent, the Clearance and Collateral Management, Issuer Services, Pershing and Wealth Management lines of 
business. Includes the AUC/A of CIBC Mellon Trust Company, a joint venture with the Canadian Imperial Bank of Commerce, of $1.8 trillion 
at December 31, 2024.
2 	As of December 31, 2024. Represents assets managed in the Investment and Wealth Management business segment.
3 	Average for the year ended December 31, 2024.
4 	As of December 31, 2024. Includes AUM and AUC/A in the Wealth Management line of business.
VI        	 BNY ANNUAL REPORT 2024
$2.4 T
$16.3 T
$327 B
$5.4 T
$52.1 T
$2.0 T
Assets under custody 
and/or administration1
Assets under 
management2
Average daily 
clearance value3
Average triparty 
balances3
Average daily U.S. 
dollar payment value3
Wealth Management 
client assets4
GLOBAL REACH AND SCALE

Last year, we communicated a strong value 
proposition for our clients, our shareholders and 
our people. We set medium-term financial targets 
to improve pre-tax margin and expand profitability 
and made solid progress against them in 2024. 
We believe we are on the right path toward our goal 
of consistently meeting or exceeding our targets 
through the cycle, both firmwide and for each of 
our three business segments:
Securities Services: We made progress over the
past year in going after inefficient processes and 
reducing the cost to serve, driving down unit costs 
by roughly 5% per custody trade and by roughly 
15% per NAV in traditional fund services over the year, 
for example. We have also invested in uplifting our 
platforms and deepening client relationships to drive 
top-line growth. This combination has resulted in an 
improvement in pre-tax margin for the segment from 
25% in 2023 to 29% in 2024, representing solid 
progress as we aim to generate equal to or greater
than 30% pre-tax margin in this segment over 
the medium term. 
Market and Wealth Services: Our fastest-growing 
and highest-margin business segment, including our 
BNY Pershing, Treasury Services and Clearance and 
Collateral Management businesses, has grown to 
represent approximately half of BNY’s profits. 
We most recently reported a 46% pre-tax margin 
last year, in line with our medium-term target of 
roughly 45% pre-tax margin for this segment. Here, we 
are focused on accelerating growth through deliberate 
investments, including in wealth technology, real-time 
payments and the future of collateral and liquidity, 
while not compromising on profitability.
Investment and Wealth Management: Our focus over 
the past year, in a combination of growth and efficiency 
initiatives, led to an improvement in pre-tax margin 
from 12% in 2023 to 18% in 2024. We recognize we have 
more work to do to reach our pre-tax margin target of 
equal to or greater than 25% over the medium term, 
but we remain excited about the opportunity to unlock 
distribution capabilities from across BNY and expand 
products and solutions, including integrated solutions 
from across our lines of business. 
        	
BNY ANNUAL REPORT 2024	
VII
FEE REVENUE GROWTH
PRE-TAX MARGIN EXPANSION
6%
6%
9%
2%
SECURITIES SERVICES
MARKET AND WEALTH SERVICES
INVESTMENT AND 
WEALTH MANAGEMENT
BNY
31%
29%
46%
18%
SECURITIES SERVICES
MARKET AND WEALTH SERVICES
INVESTMENT AND 
WEALTH MANAGEMENT
BNY
2024 vs. 2023
2024
Note: Medium term refers to a 3-5 year time horizon.

VIII      	 BNY ANNUAL REPORT 2024
MACROECONOMIC
OUTLOOK 
Looking ahead, it’s more apparent than ever that economic growth 
matters. Growth is essential for progress; it fuels prosperity, and 
it pays for the choices and services that define the identities of 
nations. A vibrant capital market, supported by a strong financial 
sector, is the foundation of a robust economy, and enabling it is a 
very solid investment for any country to make. 
The United States entered 2025 in a position of relative strength. 
The U.S. benefits from a resilient consumer base, a robust labor 
force, energy independence and burgeoning technological leadership. 
Its economy has outpaced other regions over the past decade and 
the new administration seems determined to accelerate the 
progress already made. 
Growth is, however, a competitive sport. Globally, there are early 
signs of economic recovery in parts of Asia and a renewed focus on 
growth in the United Kingdom and European nations. But it is still 
early days. This path of divergence is likely to persist in the near term, 
but there is plenty of global opportunity for broad economic success. 
Nearly 40% of our business is international, and we are in the 
import-export business of financial services: serving our global 
clients, helping U.S. clients succeed internationally and helping 
international clients bring business and investment to the U.S. 
As we navigate a changing economic landscape under new 
leadership in the U.S. and in many other nations around the world, 
this elevation of the growth agenda across both the public and 
private sectors should serve as a constructive operating backdrop 
for global financial services companies like BNY, and it is one we 
welcome. While I am cautiously optimistic about the outlook for the 
U.S. economy and capital markets, we must remain humble and 
acknowledge risks, including ongoing uncertainties and headwinds, 
continued growing fiscal challenges, geopolitical conflicts, the 
lingering effects of inflation and the complexities surrounding 
prospective policy actions. 

2025 AND FORWARD
BNY has proudly stood at the heart of the 
American financial system since its inception, and 
our international footprint has played an important 
role in global capital markets for over a hundred years. 
Today, overseeing more than $50 trillion in assets ­— 
the first bank in history to do so — BNY stands ready 
to assist clients in navigating and benefiting from the 
next phases of growth around the world, while also 
helping them prepare for a range of outcomes.
As a company, we are positioning ourselves to 
capitalize on several megatrends in the industry 
while remaining equally focused on continued 
execution against our strategic initiatives and, 
ultimately, driving results.
In 2025, with our strategy set, we intend to 
accelerate the pace of execution across each of 
our priorities. This is not a trivial undertaking, but
we can see the path. 
Effectively cross-selling and leveraging the breadth 
of our business platforms is the single most 
compelling growth opportunity for the company. This 
year will be the first full year of our new commercial 
model, and we need to seize the moment to do more 
business with existing clients, gain new ones and 
continue to strengthen product offerings. 
Through the combination of increasing the scope 
and value of client relationships, both existing and 
new, while also scaling growth investments and 
finding opportunities to fill gaps in the market, 
        	
BNY ANNUAL REPORT 2024	
IX
we are showing up differently for clients, with 
opportunities for fee growth and revenue generation 
guiding our path forward.
We will also continue to build momentum toward 
simplifying how we run our company. By year-end, 
around 80% of our people around the world will work 
in our Platforms Operating Model, representing an 
important milestone. We believe that our transition 
will have a meaningful impact on BNY over the years 
to come — both financially and culturally — as will 
the growing adoption and investment into AI.
Our people remain the key to advancing our 
ambitions. This year is about leaning into 
teamwork — while continuing to raise the bar on 
talent and performance. We are pushing ourselves 
to be nimble and faster while working to make 
BNY feel smaller, special and human. 
We can do more when we work together, and we 
want to build a culture where teams can collaborate 
more seamlessly each day with fewer barriers 
across businesses and regions. Where appropriately 
questioning the status quo is encouraged to spark 
progress. Where we accept that no one has all the 
answers, and we all remain on a continuous learning 
journey. Where people are proud and excited to come 
to work each day because they feel a real sense 
of community and belonging. And where we see 
ourselves truly pulling together as one BNY.

MEGATRENDS  
Private market assets under management (AUM) 
is projected to grow at more than double the rate 
of public assets over the next several years, which 
is being driven by a few catalysts: the trend for 
companies to stay private for longer and public 
companies opting to privatize, as well as regulatory 
trends. We are a leading service provider for fund 
management and administration in public markets, 
and the logical next step for us is to support our 
clients with these same capabilities with a private-
market wrapper. We see significant opportunities 
to support our clients end-to-end — from servicing 
to distribution, cash investment, FX hedging and 
lending — and across traditional and alternative 
asset classes. The integration of public and private 
markets is a related trend, and we believe this may 
favor large more integrated players who can service 
across the spectrum of asset types, irrespective 
of the form or type of wrapper.
CONTINUED SHIFT TOWARD 
PRIVATE MARKETS
Amid rapid technological advancements, investors 
are increasingly seeking out new asset classes, 
additional transparency and more personalized 
solutions at lower cost. Digital assets are just one 
example of a new investment vehicle in which 
we see significant long-term potential. As early 
adopters, we have focused on digital assets and 
tokenization, emphasizing regulatory clarity for 
innovation and client safety. Last year, we saw 
the mass adoption of digital asset exchange-
traded products in the U.S., which grew to more 
than $100B in AUM in less than a year. We now 
provide fund services for the vast majority of these 
products in the U.S. and Canada.
NEW INVESTMENT VEHICLES
We’re optimistic that policy in the U.S. and greater 
collaboration across the public and private 
sectors will help drive more investment, loans 
and growth — resulting in higher trading volumes, 
enhanced investment opportunities as well as 
more equity, debt and activity in the system. Across 
our company, we create, administer, distribute, 
optimize, manage and transact assets, and so 
this changing environment presents tailwinds 
for our revenue and fee growth. Some of our 
fastest-growing businesses — Treasury Services, 
Clearance and Collateral Management, and 
Corporate Trust — demonstrate our gearing 
toward higher activity and greater volumes. 
CAPITAL MARKETS ACTIVITY
The U.S. wealth market is one of the fastest-
growing segments in financial services. With 
the growth of the market also comes increased 
complexity as clients seek to navigate the often 
confusing regulatory and compliance environment. 
Through our Pershing and Wealth businesses, 
we’re a leader in serving this growing segment. Our 
Wealth business is focused on the faster-growing 
ultra-high-net-worth space while our Pershing 
business leverages the size and scale of our 
platforms to power advisors’ businesses, helping 
them navigate evolving client needs. 
GROWTH IN THE U.S. WEALTH MARKET 
Twenty years ago, a company might have seriously 
considered building a proprietary email or 
operating system in-house. Today, they prefer 
using established technology suites and scaled 
platforms rather than expending capital on their 
own systems, so they can focus on revenue-
generating solutions and client benefits. We each 
choose partners to allow us to focus on what 
makes us special. As global markets evolve and 
become ever more complex, both buy-side and 
sell-side firms are looking to outsource certain 
functions and consolidate providers to gain scale 
and reduce risk, and the strength and connectivity 
of our platforms are true differentiators.
SCALING WITH TRUSTED PROVIDERS
X     

To summarize our company’s trajectory: 2023 was about 
foundation-setting, 2024 was about accelerating the pace 
and 2025 represents the moment where we really begin 
to unlock the opportunity.
We are still early in our journey and much of our work 
today is for the future. As we look ahead, we will continue 
to work hard to deliver for our clients, our people and all of 
you, our valued shareholders, guided by our strategy and 
with a laser-focus on consistent execution. 
Thank you for your ongoing support and conviction 
in all we can be as a company.  
We look forward to taking the next steps of this 
journey together. We’re just getting started. 
ONWARD,
Robin Vince,
President and Chief Executive Officer
UNLOCKING 
OPPORTUNITY
        	
BNY ANNUAL REPORT 2024	
XI

SELECTED INCOME STATEMENT INFORMATION
Fee and other revenue (a)
$
14,307
$
13,352
Net interest income
4,312
4,345
Total revenue (a)
18,619
17,697
Provision for credit losses
70
119
Total noninterest expense
12,701
13,295
Income before income taxes (a)
5,848
4,283
Net income applicable to common shareholders of 
     The Bank of New York Mellon Corporation (a)
$
  4,336
$
  3,067
Earnings per common share – diluted (a)
$
 5.80
$
 3.89
Cash dividends per common share
$
1.78
$
1.58
FINANCIAL RATIOS (a)
Pre-tax operating margin
31%
24
Return on common equity
11.9%
8.6
Return on tangible common equity – Non-GAAP (b)
22.8%
16.8
NON-GAAP MEASURES, EXCLUDING NOTABLE ITEMS (c)
Adjusted total revenue (a)
$
18,619
$
17,847
Adjusted total expenses
12,480
12,302
Adjusted earnings per common share – diluted (a)
6.03
5.07
Adjusted pre-tax operating margin (a)
33%
30
Adjusted return on common equity (a)
12.4%
11.2
Adjusted return on tangible common equity (a) (b)
23.8%
21.8
KEY METRICS AT DECEMBER 31
Assets under custody and/or administration (“AUC/A”) (in trillions) (d)
$
52.1
$
47.8
Assets under management (in trillions) (e)
$
2.0
$
2.0
BALANCE SHEET AT DECEMBER 31
Total assets (a) 
$
416,064
$
409,877
Total deposits
289,524
283,669
Total The Bank of New York Mellon Corporation common shareholders’ equity (a)
36,975
36,427
REGULATORY CAPITAL RATIOS AT DECEMBER 31
Common Equity Tier 1 (“CET1”) ratio (f)
11.2%
11.5
Tier 1 capital ratio (f)
13.7%
14.2
Total capital ratio (f)
14.8%
14.9
Tier 1 leverage ratio
5.7%
6.0
Supplementary leverage ratio (“SLR”)
6.5%
7.3
MARKET INFORMATION AT DECEMBER 31
Closing stock price per common share 
$
76.83
$
52.05
Market capitalization
$
55,139
$
39,524
Common shares outstanding (in thousands)
717,680
759,344
FINANCIAL HIGHLIGHTS
The Bank of New York Mellon Corporation (and its subsidiaries) 
(dollars in millions, except per common share amounts or unless otherwise noted)
2024
2023
(a)	Results for the year ended and balances at Dec. 31, 2023 were restated to reflect the retrospective application of adopting new 
		
accounting guidance in 2024 related to our investments in renewable energy projects (ASU 2023-02).
(b)	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 115 for a reconciliation.
(c)	Adjusted (Non-GAAP) measures exclude notable items.
		
See “Supplemental information – Explanation of GAAP and Non-GAAP financial measures” beginning on page 115.
(d)	Consists of AUC/A primarily from the Asset Servicing line of business and, to a lesser extent, the Clearance and Collateral Management, 
		
Issuer Services, Pershing and Wealth Management lines of business. Includes the AUC/A of CIBC Mellon Trust Company, a joint venture.
(e)	Represents assets managed in the Investment and Wealth Management business segment.
(f)	 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 December 31, 2024 was the Standardized Approach, 
		
and for December 31, 2023 was the Advanced Approaches.
XII      	 BNY ANNUAL REPORT 2024
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THE BANK OF NEW YORK MELLON CORPORATION
2024 Annual Report
Table of Contents 
Page
Financial Summary
2
Management’s Discussion and Analysis of 
Financial Condition and Results of Operations:
Results of Operations:
General
3
Overview
3
Summary of financial highlights
3
Fee and other revenue
5
Net interest income
8
Noninterest expense
11
Income taxes
11
Review of business segments
11
International operations
20
Critical accounting estimates
22
Consolidated balance sheet review
26
Liquidity and dividends
35
Capital
39
Trading activities and risk management
44
Asset/liability management
46
Risk Management
48
Cybersecurity
56
Supervision and Regulation
58
Risk Factors
79
Recent Accounting Developments
114
Supplemental Information (unaudited):
Explanation of GAAP and Non-GAAP financial 
measures (unaudited)
115
Rate/volume analysis (unaudited)
119
Forward-looking Statements
120
Glossary
123
Report of Management on Internal Control Over 
Financial Reporting
124
Report of Independent Registered Public 
Accounting Firm
125
Page
Financial Statements:
Consolidated Income Statement
127
Consolidated Comprehensive Income Statement
129
Consolidated Balance Sheet
130
Consolidated Statement of Cash Flows
131
Consolidated Statement of Changes in Equity
132
Notes to Consolidated Financial Statements:
Note 1 – Summary of significant accounting and 
reporting policies
135
Note 2 – Accounting changes and new accounting 
guidance
147
Note 3 – Acquisitions and dispositions
148
Note 4 – Securities
149
Note 5 – Loans and asset quality
154
Note 6 – Leasing
160
Note 7 – Goodwill and intangible assets
161
Note 8 – Other assets
163
Note 9 – Deposits
164
Note 10 – Contract revenue
164
Note 11 – Net interest income
167
Note 12 – Income taxes
167
Note 13 – Long-term debt
169
Note 14 – Variable interest entities 
169
Note 15 – Shareholders’ equity
170
Note 16 – Other comprehensive income (loss)
174
Note 17 – Stock-based compensation
175
Note 18 – Employee benefit plans
176
Note 19 – Company financial information (Parent 
Corporation)
182
Note 20 – Fair value measurement
185
Note 21 – Fair value option
192
Note 22 – Commitments and contingent liabilities
192
Note 23 – Derivative instruments
198
Note 24 – Business segments
204
Note 25 – International operations
208
Note 26 – Supplemental information to the 
Consolidated Statement of Cash Flows
209
Report of Independent Registered Public 
Accounting Firm
210
Directors, Executive Committee and Other 
Executive Officers
215
Performance Graph
216
FINANCIAL SECTION

(dollars in millions, except per share amounts and unless otherwise noted)
2024
2023
2022
Selected income statement information:
Fee and other revenue (a)
$ 14,307 
$ 13,352 
$ 13,025 
Net interest income
4,312 
4,345 
3,504 
Total revenue (a)
18,619 
17,697 
16,529 
Provision for credit losses
70 
119 
39 
Noninterest expense
12,701 
13,295 
13,010 
Income before income taxes (a)
5,848 
4,283 
3,480 
Provision for income taxes
1,305 
979 
937 
Net income (a)
4,543 
3,304 
2,543 
Net (income) loss attributable to noncontrolling interests related to consolidated investment
management funds
(13)
(2)
13 
Preferred stock dividends
(194)
(235)
(211) 
Net income applicable to common shareholders of The Bank of New York 
Mellon Corporation (a)
$ 4,336 
$ 
3,067 
$ 
2,345 
Earnings per share applicable to common shareholders of The Bank of New York 
Mellon Corporation: (a)
Basic
$ 
5.84 
$ 
3.91 
$ 
2.89 
Diluted
$ 
5.80 
$ 
3.89 
$ 
2.88 
Average common shares and equivalents outstanding (in thousands):
Basic 
742,588 
784,069 
811,068 
Diluted
748,101 
787,798 
814,795 
At Dec. 31
Assets under custody and/or administration (“AUC/A”) (in trillions) (b)
$ 
52.1 
$ 
47.8 
$ 
44.3 
Assets under management (“AUM”) (in trillions) (c)
2.0 
2.0 
1.8 
Selected ratios:
Return on common equity (a)
 11.9% 
 8.6% 
 6.5% 
Return on tangible common equity – Non-GAAP (a)(d)
 22.8 
 16.8 
 13.4 
Pre-tax operating margin (a)
 31 
 24 
 21 
Net interest margin
 1.22 
 1.25 
 0.97 
Cash dividends per common share
$ 
1.78 
$ 
1.58 
$ 
1.42 
Common dividend payout ratio (a)
 31% 
 41% 
 50% 
Common dividend yield
 2.3% 
 3.0% 
 3.1% 
At Dec. 31
Closing stock price per common share
$ 76.83 
$ 
52.05 
$ 
45.52 
Market capitalization
$ 55,139 
$ 39,524 
$ 36,800 
Book value per common share (a)
$ 51.52 
$ 
47.97 
$ 
44.25 
Tangible book value per common share – Non-GAAP (a)(d)
$ 27.05 
$ 
25.25 
$ 
22.96 
Full-time employees (e)
51,800 
53,400 
51,700 
Common shares outstanding (in thousands)
717,680 
759,344 
808,445 
Regulatory capital ratios (f)
Common Equity Tier 1 (“CET1”) ratio
 11.2% 
 11.5% 
 11.1% 
Tier 1 capital ratio
 13.7 
 14.2 
 14.1 
Total capital ratio
 14.8 
 14.9 
 14.9 
Tier 1 leverage ratio
 5.7 
 6.0 
 5.7 
Supplementary leverage ratio (“SLR”)
 6.5 
 7.3 
 6.8 
(a)
Results for the year ended Dec. 31, 2023 and Dec. 31, 2022 were restated to reflect the retrospective application of adopting new
accounting guidance in 2024 related to our investments in renewable energy projects using the proportional amortization method
(Accounting Standards Update (“ASU”) 2023-02).  See Note 2 of the Notes to Consolidated Financial Statements for additional
information.
(b)
Consists of AUC/A primarily from the Asset Servicing line of business and, to a lesser extent, the Clearance and Collateral Management,
Issuer Services, Pershing and Wealth Management lines of business.  Includes the AUC/A of CIBC Mellon Trust Company (“CIBC
Mellon”), a joint venture with the Canadian Imperial Bank of Commerce, of $1.8 trillion at Dec. 31, 2024, $1.7 trillion at Dec. 31, 2023
and $1.5 trillion at Dec. 31, 2022.
(c)
Represents assets managed in the Investment and Wealth Management business segment.
(d)
Return on tangible common equity and tangible book value per common share, both Non-GAAP measures, exclude goodwill and
intangible assets, net of deferred tax liabilities.  See “Supplemental Information – Explanation of GAAP and Non-GAAP financial
measures” beginning on page 115 for the reconciliation of these Non-GAAP measures.
(e)
Beginning in 2024, the number of full-time employees excludes interns.
(f)
For our 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.  For additional information on our regulatory capital ratios, see
“Capital” beginning on page 39.
The Bank of New York Mellon Corporation (and its subsidiaries)
Financial Summary
2 BNY

General
In this Annual Report, references to “our,” “we,” 
“us,” “BNY,” 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.
The following should be read in conjunction with the 
Consolidated Financial Statements included in this 
report.  BNY’s actual results of future operations may 
differ from those estimated or anticipated in certain 
forward-looking statements contained herein due to 
the factors described under the headings “Forward-
looking Statements” and “Risk Factors,” both of 
which investors should read.
Certain business terms used in this Annual Report are 
defined in the Glossary.
This Annual Report generally discusses 2024 and 
2023 items and comparisons between 2024 and 2023.  
Discussions of 2022 items and comparisons between 
2023 and 2022 that are not included in this Annual 
Report can be found in our 2023 Annual Report, 
which was filed as an exhibit to our Form 10-K for 
the year ended Dec. 31, 2023.
Overview
BNY is a global financial services company that 
helps make money work for the world – managing it, 
moving it and keeping it safe.  For more than 240 
years BNY has partnered alongside clients, putting its 
expertise and platforms to work to help them achieve 
their ambitions.  Today BNY helps over 90% of 
Fortune 100 companies and nearly all the top 100 
banks globally to access the money they need.  BNY 
supports governments in funding local projects and 
works with over 90% of the top 100 pension plans to 
safeguard investments for millions of individuals, and 
so much more.  As of Dec. 31, 2024, BNY oversees 
$52.1 trillion in assets under custody and/or 
administration and $2.0 trillion in assets under 
management.
BNY is the corporate brand of The Bank of New 
York Mellon Corporation (NYSE: BK).  
Headquartered in New York City, BNY employs over 
50,000 people globally and has been named among 
Fortune’s World’s Most Admired Companies and 
Fast Company’s Best Workplaces for Innovators.  
Additional information is available on www.bny.com.  
Follow on LinkedIn or visit the BNY Newsroom for 
the latest company news.
BNY has three business segments, Securities 
Services, Market and Wealth Services and Investment 
and Wealth Management, which offer a 
comprehensive set of capabilities and deep expertise 
across the investment life cycle, enabling the 
Company to provide solutions to buy-side and sell-
side market participants, as well as leading 
institutional and wealth management clients globally.
The diagram below presents our three business 
segments and lines of business, with the remaining 
operations in the Other segment.
The Bank of New 
York Mellon 
Corporation
Securities
Services
Market and Wealth 
Services
Investment and 
Wealth Management
Asset
Servicing
Pershing
Investment
Management
Issuer
Services
Treasury
Services
Wealth
Management
Clearance and 
Collateral 
Management
For additional information on our business segments, 
see “Review of business segments” and Note 24 of 
the Notes to Consolidated Financial Statements.
Summary of financial highlights
We reported net income applicable to common 
shareholders of $4.3 billion, or $5.80 per diluted 
common share, in 2024, including the negative 
impact of notable items.  Notable items in 2024 
include severance expense, litigation reserves and the 
net impact of adjustments for the Federal Deposit 
Insurance Corporation (“FDIC”) special assessment.  
Excluding notable items, net income applicable to 
common shareholders was $4.5 billion (Non-GAAP), 
or $6.03 (Non-GAAP) per diluted common share, in 
2024.  In 2023, net income applicable to common 
shareholders was $3.1 billion, or $3.89 per diluted 
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations
BNY 3

common share, including the negative impact of 
notable items.  Notable items in 2023 include the 
initial estimate for the FDIC special assessment, 
severance expense, the reduction in the fair value of a 
contingent consideration receivable, litigation 
reserves and net losses on disposals.  Excluding 
notable items, net income applicable to common 
shareholders was $4.0 billion (Non-GAAP), or $5.07 
(Non-GAAP) per diluted common share, in 2023.
The highlights below are based on 2024 compared 
with 2023, unless otherwise noted.
•
Total revenue increased 5%, primarily reflecting:
•
Fee revenue increased 6%, primarily 
reflecting higher market values, net new 
business, higher client activity and foreign 
exchange revenue, partially offset by the mix 
of AUM flows.  (See “Fee and other revenue” 
beginning on page 5.)
•
Investment and other revenue increased 
primarily reflecting the reduction in the fair 
value of a contingent consideration receivable 
in 2023 and higher client activity in our fixed 
income and equity trading business.  (See 
“Fee and other revenue” beginning on page 
5.)
•
Net interest income decreased 1%, primarily 
reflecting changes in deposit mix, partially 
offset by higher investment securities 
portfolio yields and balance sheet growth.  
(See “Net interest income” beginning on page 
8.)
•
The provision for credit losses was $70 million, 
primarily driven by reserve increases related to 
commercial real estate exposure and changes in 
the macroeconomic forecast.  (See “Consolidated 
balance sheet review – Allowance for credit 
losses” beginning on page 33.)
•
Noninterest expense decreased 4%, primarily 
reflecting the net impact of adjustments for the 
FDIC special assessment and efficiency savings, 
partially offset by higher investments, employee 
merit increases and revenue-related expenses.  
Excluding notable items, noninterest expense 
increased 1% (Non-GAAP).  (See “Noninterest 
expense” on page 11.)
•
Effective tax rate of 22.3% in 2024.  (See 
“Income taxes” on page 11.)
•
Return on common equity (“ROE”) was 11.9% 
for 2024.  Excluding notable items, the adjusted 
ROE was 12.4% (Non-GAAP) for 2024. 
•
Return on tangible common equity (“ROTCE”) 
was 22.8% (Non-GAAP) for 2024.  Excluding 
notable items, the adjusted ROTCE was 23.8% 
(Non-GAAP) for 2024.
See “Supplemental Information – Explanation of 
GAAP and Non-GAAP financial measures” 
beginning on page 115 for reconciliations of the Non-
GAAP measures.
Metrics
•
AUC/A totaled $52.1 trillion at Dec. 31, 2024 
compared with $47.8 trillion at Dec. 31, 2023.  
The 9% increase primarily reflects higher market 
values, client inflows and net new business, 
partially offset by the unfavorable impact of a 
stronger U.S. dollar.  (See “Fee and other 
revenue” beginning on page 5.)
•
AUM totaled $2.03 trillion at Dec. 31, 2024 
compared with $1.97 trillion at Dec. 31, 2023.  
The 3% increase primarily reflects higher market 
values, partially offset by the unfavorable impact 
of a stronger U.S. dollar.  (See “Review of 
business segments – Investment and Wealth 
Management business segment” beginning on 
page 17.)
Capital and liquidity
•
Our CET1 ratio calculated under the Standardized 
Approach was 11.2% at Dec. 31, 2024 and 11.5% 
at Dec. 31, 2023 under the Advanced 
Approaches.  The decrease was primarily driven 
by capital returned through common stock 
repurchases and dividends and higher risk-
weighted assets (“RWAs”), partially offset by 
capital generated through earnings.  (See 
“Capital” beginning on page 39.)
•
Our Tier 1 leverage ratio was 5.7% at Dec. 31, 
2024, compared with 6.0% at Dec. 31, 2023.  The 
decrease was driven by higher average assets, 
partially offset by an increase in capital.  (See 
“Capital” beginning on page 39.)
Results of Operations (continued)
4 BNY

Fee and other revenue
Fee and other revenue
2024 vs.
2023 vs.
(dollars in millions, unless otherwise noted)
2024
2023
2022
2023
2022
Investment services fees
$ 9,419 
$ 8,843 
$ 8,529 
 7% 
 4% 
Investment management and performance fees (a)
 
3,139 
 
3,058 
 
3,299 
 3 
 (7) 
Foreign exchange revenue
 
688 
 
631 
 
822 
 9 
 (23) 
Financing-related fees
 
216 
 
192 
 
175 
 13 
 10 
Distribution and servicing fees
 
158 
 
148 
 
130 
 7 
 14 
Total fee revenue
 13,620 
 12,872 
 12,955 
 6 
 (1) 
Investment and other revenue (b)
 
687 
 
480 
 
70 
N/M
N/M
Total fee and other revenue (b)
$ 14,307 
$ 13,352 
$ 13,025 
 7% 
 3% 
Fee revenue as a percentage of total revenue 
 73% 
 73% 
 78% 
AUC/A at period end (in trillions) (c)
$ 
52.1 
$ 
47.8 
$ 
44.3 
 9% 
 8% 
AUM at period end (in billions) (d)
$ 2,029 
$ 1,974 
$ 1,836 
 3% 
 8% 
(a) Excludes seed capital gains (losses) related to consolidated investment management funds.
(b) Results for the years ended Dec. 31, 2023 and Dec. 31, 2022 were restated to reflect the retrospective application of adopting new 
accounting guidance in 2024 related to our investments in renewable energy projects using the proportional amortization method (ASU 
2023-02).  See Note 2 of the Notes to Consolidated Financial Statements for additional information.
(c) Consists of AUC/A primarily from the Asset Servicing line of business and, to a lesser extent, the Clearance and Collateral Management, 
Issuer Services, Pershing and Wealth Management lines of business.  Includes the AUC/A of CIBC Mellon of $1.8 trillion at Dec. 31, 
2024, $1.7 trillion at Dec. 31, 2023 and $1.5 trillion at Dec. 31, 2022.
(d) Represents assets managed in the Investment and Wealth Management business segment. 
N/M – Not meaningful.
Fee revenue increased 6% compared with 2023, 
primarily reflecting higher investment services fees, 
investment management and performance fees and 
foreign exchange revenue.  
Investment and other revenue increased $207 million 
in 2024 compared with 2023, primarily reflecting the 
reduction in the fair value of a contingent 
consideration receivable in 2023 and higher client 
activity in our fixed income and equity trading 
business. 
Investment services fees
Investment services fees increased 7% compared with 
2023, primarily reflecting higher market values, net 
new business and higher client activity.  
AUC/A totaled $52.1 trillion at Dec. 31, 2024, an 
increase of 9% compared with Dec. 31, 2023, 
primarily reflecting higher market values, client 
inflows and net new business, partially offset by the 
unfavorable impact of a stronger U.S. dollar.  AUC/A 
consisted of 37% equity securities and 63% fixed-
income securities at Dec. 31, 2024 and 35% equity 
securities and 65% fixed-income securities at Dec. 
31, 2023.
See “Securities Services business segment” and 
“Market and Wealth Services business segment” in 
“Review of business segments” for additional details.
Investment management and performance fees 
Investment management and performance fees 
increased 3% compared with 2023, primarily 
reflecting higher market values, partially offset by the 
mix of AUM flows and lower performance fees.  
Performance fees were $51 million in 2024 and $81 
million in 2023.  On a constant currency basis (Non-
GAAP), investment management and performance 
fees increased 2% compared with 2023.  See 
“Supplemental Information – Explanation of GAAP 
and Non-GAAP financial measures” beginning on 
page 115 for the reconciliation of Non-GAAP 
measures.
AUM was $2.0 trillion at Dec. 31, 2024, an increase 
of 3% compared with Dec. 31, 2023, primarily 
reflecting higher market values, partially offset by the 
unfavorable impact of a stronger U.S. dollar. 
See “Investment and Wealth Management business 
segment” in “Review of business segments” for 
additional details regarding the drivers of investment 
management and performance fees, AUM and AUM 
flows.
Results of Operations (continued)
BNY 5

Foreign exchange revenue
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, the impact of foreign currency 
hedging activities and foreign currency 
remeasurement gain (loss).  In 2024, foreign 
exchange revenue increased 9% compared with 2023, 
primarily reflecting higher volumes.  Foreign 
exchange revenue is primarily reported in the 
Securities Services business segment and, to a lesser 
extent, the Market and Wealth Services and 
Investment and Wealth Management business 
segments and the Other segment. 
Financing-related fees
Financing-related fees, which are primarily reported 
in the Market and Wealth Services and Securities 
Services business segments, include capital market 
fees, loan commitment fees and credit-related fees.  
Financing-related fees increased 13% in 2024 
compared with 2023, primarily reflecting higher 
underwriting fees.
Distribution and servicing fees
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 line of 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 $158 million in 
2024 compared with $148 million in 2023, driven by 
higher money market balances.  The impact of 
distribution and servicing fees on income in any one 
period is partially offset by distribution and servicing 
expense paid to other financial intermediaries to 
cover their costs for distribution and servicing of 
mutual funds.  Distribution and servicing expense is 
recorded as noninterest expense on the income 
statement.
Investment and other revenue
Investment and other revenue includes income or loss 
from consolidated investment management funds, 
seed capital gains or losses, other trading revenue or 
loss, renewable energy investments gains or losses, 
income from corporate and bank-owned life 
insurance contracts, other investment gains or losses, 
gains or losses from disposals, expense 
reimbursements from our CIBC Mellon joint venture, 
other income or loss and net securities gains or losses.  
The income or loss from consolidated investment 
management funds should be considered together 
with the net income or loss attributable to 
noncontrolling interests, which reflects the portion of 
the consolidated funds for which we do not have an 
economic interest and is reflected below net income 
as a separate line item on the consolidated income 
statement.  Other trading revenue or loss primarily 
includes the impact of market-risk hedging activity 
related to our seed capital investments in investment 
management funds, non-foreign currency derivative 
and fixed income trading, and other hedging activity.  
Other investment gains or losses includes fair value 
changes of non-readily marketable strategic equity, 
private equity and other investments.  Expense 
reimbursements from our CIBC Mellon joint venture 
relate to expenses incurred by BNY on behalf of the 
CIBC Mellon joint venture.  Other income includes 
various miscellaneous revenues. 
Results of Operations (continued)
6 BNY

The following table provides the components of investment and other revenue.
Investment and other revenue 
(dollars in millions)
2024
2023
2022
Income (loss) from consolidated investment management funds
$ 
46 
$ 
30 
$ 
(42) 
Seed capital gains (losses) (a)
 
20 
 
29 
 
(37) 
Other trading revenue
 
314 
 
231 
 
149 
Renewable energy investment gains (losses) (b)
 
25 
 
28 
 
(12) 
Corporate/bank-owned life insurance
 
137 
 
118 
 
128 
Other investment gains (c)
 
67 
 
47 
 
159 
Disposal (losses) gains
 
— 
 
(6) 
 
26 
Expense reimbursements from joint venture
 
118 
 
117 
 
108 
Other income (loss)
 
45 
 
(46) 
 
34 
Net securities (losses)
 
(85) 
 
(68) 
 
(443) (d)
Total investment and other revenue (b)
$ 
687 
$ 
480 
$ 
70 
(a) Includes gains (losses) on investments in BNY funds which hedge deferred incentive awards.
(b) Results for the years ended Dec. 31, 2023 and Dec. 31, 2022 were restated to reflect the retrospective application of adopting new 
accounting guidance in 2024 related to our investments in renewable energy projects using the proportional amortization method (ASU 
2023-02).  See Note 2 of the Notes to Consolidated Financial Statements for additional information.
(c) Includes strategic equity, private equity and other investments.
(d) Includes a net loss of $449 million related to the repositioning of the securities portfolio.
Investment and other revenue was $687 million in 
2024 compared with $480 million in 2023.  The 
increase primarily reflects the reduction in the fair 
value of a contingent consideration receivable in 2023 
and higher client activity in our fixed income and 
equity trading business.
Results of Operations (continued)
BNY 7

Net interest income
Net interest income
2024 vs.
2023 vs.
(dollars in millions)
2024
2023
2022
2023
2022
Net interest income
$ 
4,312 
$ 
4,345 
$ 
3,504 
 (1) %
 24 %
Add: Tax equivalent adjustment
 
2 
 
2 
 
11 
N/M
N/M
Net interest income on a fully taxable equivalent (“FTE”) basis – Non-
GAAP (a)
$ 
4,314 
$ 
4,347 
$ 
3,515 
 (1) %
 24 %
Average interest-earning assets
$ 353,744 
$ 348,160 
$ 362,180 
 2% 
 (4) %
Net interest margin
 1.22% 
 1.25% 
 0.97%  
(3) bps  28 bps 
Net interest margin (FTE) – Non-GAAP (a)
 1.22% 
 1.25% 
 0.97%  
(3) bps  28 bps 
(a) Net interest income (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.
N/M – Not meaningful.
bps – basis points.
Net interest income decreased 1% compared with 
2023, primarily reflecting changes in deposit mix, 
partially offset by higher investment securities 
portfolio yields and balance sheet growth.  
Net interest margin decreased 3 basis points 
compared with 2023.  The decrease primarily reflects 
the factors mentioned above.
Average interest-earning assets increased 2% 
compared with 2023.  The increase primarily reflects 
higher federal funds sold and securities purchased 
under resale agreements, loan balances and securities, 
partially offset by lower interest-bearing deposits 
with the Federal Reserve and other central banks and 
interest-bearing deposits with banks.
Average non-U.S. dollar deposits comprised 
approximately 25% of our average total deposits in 
2024 and 2023.  Approximately 50% of the average 
non-U.S. dollar deposits in 2024 and 45% in 2023 
were euro-denominated.
Net interest income in 2025 will largely depend on 
the level and mix of client deposits and investment 
securities portfolio reinvestment yields.  Based on 
market implied forward interest rates as of Dec. 31, 
2024, we expect net interest income for 2025 to 
increase when compared with 2024. 
Results of Operations (continued)
8 BNY

Average balances and interest rates
2024
2023
(dollars in millions)
Average 
balance Interest
Average 
rate
Average 
balance
Interest
Average 
rate
Assets
Interest-earning assets:
Interest-bearing deposits with the Federal Reserve and other central banks:
Domestic offices
$ 59,432 
$ 3,148 
 5.30% 
$ 59,492 
$ 3,085 
 5.19% 
Foreign offices
 
40,554 
 
1,467 
 3.62 
 
44,412 
 1,456 
 3.28 
Total interest-bearing deposits with the Federal Reserve and other central banks
 
99,986 
 
4,615 
 4.62 
 103,904 
 4,541 
 4.37 
Interest-bearing deposits with banks
 
10,991 
 
434 
 3.94 
 
13,620 
 
523 
 3.84 
Federal funds sold and securities purchased under resale agreements (a)
 
31,306 
 10,915  34.86 
 
26,077 
 7,141  27.38 
Loans:
Domestic offices
 
63,108 
 
4,107 
 6.51 
 
59,487 
 3,663 
 6.16 
Foreign offices
 
5,033 
 
287 
 5.70 
 
4,609 
 
253 
 5.49 
Total loans (b)
 
68,141 
 
4,394 
 6.45 
 
64,096 
 3,916 
 6.11 
Securities:
U.S. government obligations
 
27,826 
 
1,022 
 3.67 
 
33,434 
 1,021 
 3.05 
U.S. government agency obligations
 
62,855 
 
2,058 
 3.27 
 
60,586 
 1,695 
 2.80 
Other securities:
Domestic offices
 
17,560 
 
951 
 5.42 
 
17,168 
 
803 
 4.68 
Foreign offices
 
29,620 
 
911 
 3.07 
 
23,505 
 
695 
 2.96 
Total other securities
 
47,180 
 
1,862 
 3.95 
 
40,673 
 1,498 
 3.68 
Total investment securities
 137,861 
 
4,942 
 3.58 
 134,693 
 4,214 
 3.13 
Trading securities (primarily domestic) (c)
 
5,459 
 
309 
 5.66 
 
5,770 
 
315 
 5.46 
Total securities (c)
 143,320 
 
5,251 
 3.66 
 140,463 
 4,529 
 3.22 
Total interest-earning assets (c)
$ 353,744 
$ 25,609 
 7.24% 
$ 348,160 
$ 20,650 
 5.93% 
Noninterest-earning assets
 
59,590 
 
58,582 
Total assets
$ 413,334 
$ 406,742 
Liabilities and equity
Interest-bearing liabilities:
Interest-bearing deposits:
Domestic offices
$ 141,279 
$ 5,791 
 4.10% 
$ 123,513 
$ 4,703 
 3.81% 
Foreign offices
 
92,926 
 
2,856 
 3.07 
 
88,829 
 2,421 
 2.73 
Total interest-bearing deposits
 234,205 
 
8,647 
 3.69 
 212,342 
 7,124 
 3.35 
Federal funds purchased and securities sold under repurchase agreements (a)
 
17,007 
 
9,974  58.64 
 
20,540 
 6,699  32.62 
Trading liabilities
 
1,768 
 
88 
 4.98 
 
3,396 
 
156 
 4.60 
Other borrowed funds:
Domestic offices
 
136 
 
13 
 9.32 
 
676 
 
44 
 6.49 
Foreign offices
 
303 
 
5 
 1.77 
 
426 
 
3 
 0.74 
Total other borrowed funds
 
439 
 
18 
 4.10 
 
1,102 
 
47 
 4.27 
Commercial paper
 
1,197 
 
62 
 5.18 
 
5 
 
— 
 4.81 
Payables to customers and broker-dealers
 
12,726 
 
640 
 5.03 
 
14,449 
 
566 
 3.91 
Long-term debt
 
31,816 
 
1,866 
 5.87 
 
31,021 
 1,711 
 5.51 
Total interest-bearing liabilities
$ 299,158 
$ 21,295 
 7.12% 
$ 282,855 
$ 16,303 
 5.76% 
Total noninterest-bearing deposits
 
49,521 
 
59,227 
Other noninterest-bearing liabilities
 
23,694 
 
24,011 
Total liabilities
 372,373 
 366,093 
Total The Bank of New York Mellon Corporation shareholders’ equity
 
40,756 
 
40,588 
Noncontrolling interests
 
205 
 
61 
Total liabilities and equity
$ 413,334 
$ 406,742 
Net interest income (FTE) – Non-GAAP (c)(d)
$ 4,314 
$ 4,347 
Net interest margin (FTE) – Non-GAAP (c)(d)
 1.22% 
 1.25% 
Less: Tax equivalent adjustment
 
2 
 
2 
Net interest income – GAAP
$ 4,312 
$ 4,345 
Net interest margin – GAAP
 1.22% 
 1.25% 
Percentage of assets attributable to foreign offices
 23% 
 24% 
Percentage of liabilities attributable to foreign offices
 28% 
 27% 
(a)
Includes the average impact of offsetting under enforceable netting agreements of approximately $176 billion in 2024 and $111 billion in 2023.  On a 
Non-GAAP basis, excluding the impact of offsetting, the yield on federal funds sold and securities purchased under resale agreements would have been 
5.28% for 2024 and 5.22% for 2023, and the rate on federal funds purchased and securities sold under repurchase agreements would have been 5.18% 
for 2024 and 5.10% for 2023.  We believe providing the rates excluding the impact of netting is useful to investors as it is more reflective of the actual 
rates earned and paid.
(b) 
Interest income includes fees of $3 million in 2024 and $1 million in 2023.  Nonaccrual loans are included in average loans; the associated income, 
which was recognized on a cash basis, is included in interest income.
(c) 
Average rates were calculated on an FTE basis, at tax rates of approximately 21% for both 2024 and 2023.
(d)
See “Net interest income” on page 8 for the reconciliation of this Non-GAAP measure.
Results of Operations (continued)
BNY 9

Average balances and interest rates
2022
(dollars in millions)
Average 
balance
Interest
Average 
rate
Assets
Interest-earning assets:
Interest-bearing deposits with the Federal Reserve and other central banks:
Domestic offices
$ 46,270 
$ 
810 
 1.75% 
Foreign offices
 
51,172 
 
209 
 0.41 
Total interest-bearing deposits with the Federal Reserve and other central banks
 
97,442 
 
1,019 
 1.05 
Interest-bearing deposits with banks
 
16,826 
 
221 
 1.31 
Federal funds sold and securities purchased under resale agreements (a)
 
24,953 
 
1,200 
 4.81 
Loans:
Domestic offices
 
62,640 
 
1,878 
 3.00 
Foreign offices
 
5,185 
 
121 
 2.33 
Total loans (b)
 
67,825 
 
1,999 
 2.95 
Securities:
U.S. government obligations
 
40,583 
 
607 
 1.49 
U.S. government agency obligations
 
64,041 
 
1,157 
 1.81 
Other securities:
Domestic offices (c)
 
18,979 
 
629 
 3.31 
Foreign offices 
 
26,283 
 
154 
 0.59 
Total other securities (c)
 
45,262 
 
783 
 1.73 
Total investment securities (c)
 149,886 
 
2,547 
 1.70 
Trading securities (primarily domestic) (c)
 
5,248 
 
143 
 2.73 
Total securities (c)
 155,134 
 
2,690 
 1.73 
Total interest-earning assets (c)
$ 362,180 
$ 
7,129 
 1.97% 
Noninterest-earning assets
 
64,507 
Total assets
$ 426,687 
Liabilities and equity
Interest-bearing liabilities:
Interest-bearing deposits:
Domestic offices
$ 111,491 
$ 
980 
 0.88% 
Foreign offices
 101,916 
 
607 
 0.60 
Total interest-bearing deposits
 213,407 
 
1,587 
 0.74 
Federal funds purchased and securities sold under repurchase agreements (a)
 
12,940 
 
934 
 7.21 
Trading liabilities
 
3,432 
 
68 
 1.98 
Other borrowed funds:
Domestic offices
 
181 
 
7 
 4.12 
Foreign offices
 
324 
 
2 
 0.51 
Total other borrowed funds
 
505 
 
9 
 1.80 
Commercial paper
 
5 
 
— 
 2.06 
Payables to customers and broker-dealers
 
17,111 
 
156 
 0.91 
Long-term debt
 
27,448 
 
860 
 3.13 
Total interest-bearing liabilities
$ 274,848 
$ 
3,614 
 1.31% 
Total noninterest-bearing deposits
 
85,652 
Other noninterest-bearing liabilities
 
25,172 
Total liabilities
 385,672 
Total The Bank of New York Mellon Corporation shareholders’ equity
 
40,905 
Noncontrolling interests
 
110 
Total liabilities and equity
$ 426,687 
Net interest income (FTE) – Non-GAAP (c)(d)
$ 
3,515 
Net interest margin (FTE) – Non-GAAP (c)(d)
 0.97% 
Less: Tax equivalent adjustment
 
11 
Net interest income – GAAP
$ 
3,504 
Net interest margin – GAAP
 0.97% 
Percentage of assets attributable to foreign offices
 26% 
Percentage of liabilities attributable to foreign offices
 30% 
(a) 
Includes the average impact of offsetting under enforceable netting agreements of approximately $43 billion in 2022.  On a Non-GAAP basis, excluding 
the impact of offsetting, the yield on federal funds sold and securities purchased under resale agreements would have been 1.77%, and the rate on federal 
funds purchased and securities sold under repurchase agreements would have been 1.67% for 2022.  We believe providing the rates excluding the impact 
of netting is useful to investors as it is more reflective of the actual rates earned and paid.
(b) 
Interest income includes fees of $2 million in 2022.  Nonaccrual loans are included in average loans; the associated income, which was recognized on a 
cash basis, is included in interest income.
(c)
Average rates were calculated on an FTE basis, at tax rates of approximately 21% in 2022.
(d)
See “Net interest income” on page 8 for the reconciliation of this Non-GAAP measure.
Results of Operations (continued)
10 BNY

Noninterest expense
Noninterest expense
2024 vs.
2023 vs.
(dollars in millions)
2024
2023
2022
2023
2022
Staff
$ 
7,130 $ 
7,095 $ 
6,800 
 —% 
 4% 
Software and equipment
 
1,962  
1,817  
1,657 
 8 
 10 
Professional, legal and other purchased services 
 
1,503  
1,527  
1,527 
 (2) 
 — 
Net occupancy
 
537  
542  
514 
 (1) 
 5 
Sub-custodian and clearing
 
498  
475  
485 
 5 
 (2) 
Distribution and servicing
 
361  
353  
343 
 2 
 3 
Business development
 
188  
183  
152 
 3 
 20 
Bank assessment charges 
 
36  
788  
126 
N/M
N/M
Goodwill impairment
 
—  
—  
680 
N/M
N/M
Amortization of intangible assets
 
50  
57  
67 
 (12) 
 (15) 
Other
 
436  
458  
659 
 (5) 
 (31) 
Total noninterest expense
$ 
12,701 $ 
13,295 $ 
13,010 
 (4) %
 2% 
Full-time employees at year-end (a)
 
51,800  
53,400  
51,700 
 (3) %
 3% 
(a) Beginning in 2024, the number of full-time employees excludes interns.
N/M – Not meaningful.
Total noninterest expense decreased 4% compared 
with 2023, primarily reflecting the net impact of 
adjustments for the FDIC special assessment and 
efficiency savings, partially offset by higher 
investments, employee merit increases and revenue-
related expenses.  Excluding notable items, 
noninterest expense increased 1% (Non-GAAP).  See 
“Supervision and Regulation – FDIC Deposit 
Insurance” beginning on page 67 for information on 
the FDIC special assessment.  See “Supplemental 
Information – Explanation of GAAP and Non-GAAP 
financial measures” beginning on page 115 for the 
reconciliation of the Non-GAAP measure.
We expect total noninterest expense for 2025 to 
increase slightly compared with 2024, primarily 
reflecting incremental investments and higher 
revenue-related expenses, partially offset by the 
benefit of efficiency savings.
Income taxes
BNY recorded an income tax provision of $1.3 billion 
(22.3% effective tax rate) in 2024.  The income tax 
provision was $979 million (22.9% effective tax rate) 
in 2023. 
On Jan. 1, 2024, we adopted ASU 2023-02, 
Investments—Equity Method and Joint Ventures 
(Topic 323): Accounting for Investments in Tax 
Credit Structures Using the Proportional 
Amortization Method, on a retrospective basis.  See 
Note 2 of the Notes to Consolidated Financial 
Statements for additional information on the new 
accounting guidance.
For additional information on income taxes, see Note 
12 of the Notes to Consolidated Financial Statements.
Review of business segments
We have an internal information system that produces 
performance data along product and service lines for 
our three principal business segments: Securities 
Services, Market and Wealth Services and Investment 
and Wealth Management, and the Other segment. 
Business segment accounting principles
Our business segment data has been determined on an 
internal management basis of accounting, rather than 
the generally accepted accounting principles 
(“GAAP”) used for consolidated financial reporting.  
These measurement principles are designed so that 
reported results of the businesses will track their 
economic performance. 
Our business segments are consistent with the 
structure used by the President and Chief Executive 
Officer, our Chief Operating Decision Maker 
(“CODM”), to make key operating decisions and 
assess performance.  Our CODM evaluates the 
business segments’ operating performance primarily 
based on fee and other revenue, total revenue, income 
before income taxes, and pre-tax operating margin.  
The significant expense information regularly 
Results of Operations (continued)
BNY 11

provided to and reviewed by the CODM is total 
noninterest expense.  The CODM considers this 
information when evaluating the performance of each 
business segment and making decisions about 
allocating capital and other resources to each business 
segment.  
For information on the accounting principles of our 
business segments, the primary products and services 
in each line of business, the primary types of revenue 
by line of business and how our business segments 
are presented and analyzed, see Note 24 of the Notes 
to Consolidated Financial Statements.
Business segment results are subject to 
reclassification when organizational changes are 
made, or for refinements in revenue and expense 
allocation methodologies.  Refinements are typically 
reflected on a prospective basis.  In 2024, we made 
certain realignments of similar products and services 
within our lines of business consistent with the firm’s 
ongoing transition to a platforms operating model 
uniting related capabilities and enabling streamlining 
of internal processes to drive growth, efficiency, 
resiliency, and enhanced risk management.  The 
largest change was the movement of Institutional 
Solutions from Pershing to Clearance and Collateral 
Management, both in the Market and Wealth Services 
business segment.  We made other smaller changes 
that moved activity from Asset Servicing in the 
Securities Services business segment to Treasury 
Services in the Market and Wealth Services business 
segment, and from Wealth Management in the 
Investment and Wealth Management business 
segment and Pershing in the Market and Wealth 
Services business segment to Investment 
Management in the Investment and Wealth 
Management business segment.  The Other segment 
was not impacted by the changes.  Business segment 
results for 2023 and 2022 have been revised to reflect 
these changes.  
The results of our business segments may be 
influenced by client and other activities that vary by 
quarter.  In the first quarter, staff expense typically 
increases, reflecting the vesting of long-term stock 
awards for retirement-eligible employees.  The timing 
of our annual employee merit increases also impacts 
staff expense.  In 2024, the merit increase was 
effective in March and in 2023, the merit increase 
was effective in April, thus partially impacting the 
full-year staff expense variances.  In the third quarter, 
volume-related fees may decline due to reduced client 
activity.  In the fourth quarter, we typically incur 
higher business development and marketing 
expenses.  In our Investment and Wealth 
Management business segment, performance fees are 
typically higher in the fourth and first quarters, as 
those quarters represent the end of the measurement 
period for many of the performance fee-eligible 
relationships.  
The results of our business segments 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 Securities Services and Market and 
Wealth Services business segments, we typically have 
more foreign currency-denominated expenses than 
revenues.  However, our Investment and Wealth 
Management business segment typically has more 
foreign currency-denominated revenues than 
expenses.  Overall, currency fluctuations impact the 
year-over-year growth rate in the Investment and 
Wealth Management business segment more than the 
Securities Services and Market and Wealth Services 
business segments.  However, currency fluctuations, 
in isolation, are not expected to significantly impact 
net income on a consolidated basis.
Fee revenue in the Investment and Wealth 
Management business segment, and to a lesser extent, 
the Securities Services and Market and Wealth 
Services business segments, is impacted by global 
market fluctuations.  At Dec. 31, 2024, we estimated 
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 $0.05 to $0.08. 
See Note 24 of the Notes to Consolidated Financial 
Statements for the consolidating schedules which 
show the contribution of our business segments to our 
overall profitability.
Results of Operations (continued)
12 BNY

Securities Services business segment
2024 vs.
2023 vs.
(dollars in millions, unless otherwise noted)
2024
2023
2022
2023
2022
Revenue:
Investment services fees:
Asset Servicing 
$ 
4,094 
$ 
3,872 
$ 
3,888 
 6% 
 —% 
Issuer Services
 
1,163 
 
1,121 
 
1,009 
 4 
 11 
Total investment services fees
 
5,257 
 
4,993 
 
4,897 
 5 
 2 
Foreign exchange revenue
 
552 
 
488 
 
584 
 13 
 (16) 
Other fees (a)
 
234 
 
215 
 
202 
 9 
 6 
Total fee revenue
 
6,043 
 
5,696 
 
5,683 
 6 
 — 
Investment and other revenue
 
405 
 
333 
 
291 
N/M
N/M
Total fee and other revenue
 
6,448 
 
6,029 
 
5,974 
 7 
 1 
Net interest income
 
2,468 
 
2,569 
 
2,028 
 (4) 
 27 
Total revenue
 
8,916 
 
8,598 
 
8,002 
 4 
 7 
Provision for credit losses
 
38 
 
99 
 
8 
N/M
N/M
Noninterest expense (excluding amortization of intangible assets)
 
6,286 
 
6,327 
 
6,248 
 (1) 
 1 
Amortization of intangible assets
 
28 
 
31 
 
33 
 (10) 
 (6) 
Total noninterest expense
 
6,314 
 
6,358 
 
6,281 
 (1) 
 1 
Income before income taxes
$ 
2,564 
$ 
2,141 
$ 
1,713 
 20% 
 25% 
Pre-tax operating margin
 29% 
 25% 
 21% 
Securities lending revenue (b)
$ 
191 
$ 
189 
$ 
182 
 1% 
 4% 
Total revenue by line of business:
Asset Servicing
$ 
6,872 
$ 
6,612 
$ 
6,293 
 4% 
 5% 
Issuer Services
 
2,044 
 
1,986 
 
1,709 
 3 
 16 
Total revenue by line of business
$ 
8,916 
$ 
8,598 
$ 
8,002 
 4% 
 7% 
Selected average balances:
Average loans
$ 11,235 
$ 11,207 
$ 11,245 
 —% 
 —% 
Average deposits
$ 178,643 
$ 168,411 
$ 183,990 
 6% 
 (8) %
Selected metrics:
AUC/A at period end (in trillions) (c)
$ 
37.7 
$ 
34.2 
$ 
31.4 
 10% 
 9% 
Market value of securities on loan at period end (in billions) (d)
$ 
488 
$ 
450 
$ 
449 
 8% 
 —% 
Issuer Services:
Total debt serviced at period end (in trillions)
$ 
14.1 
$ 
14.0 
$ 
12.6 
 1% 
 11% 
Number of sponsored Depositary Receipts programs at period end
 
499 
 
543 
 
589 
 (8) %
 (8) %
(a) Other fees primarily includes financing-related fees. 
(b) Included in investment services fees reported in the Asset Servicing line of business.
(c) Consists of AUC/A primarily from the Asset Servicing line of business and, to a lesser extent, the Issuer Services line of business.  
Includes the AUC/A of CIBC Mellon of $1.8 trillion at Dec. 31, 2024, $1.7 trillion at Dec. 31, 2023 and $1.5 trillion at Dec. 31, 2022.
(d) Represents the total amount of securities on loan in our agency securities lending program.  Excludes securities for which BNY acts as 
agent on behalf of CIBC Mellon clients, which totaled $60 billion at Dec. 31, 2024, $63 billion at Dec. 31, 2023 and $68 billion at Dec. 
31, 2022.
N/M – Not meaningful.
Results of Operations (continued)
BNY 13

Business segment description
The Securities Services business segment consists of 
two distinct lines of business, Asset Servicing and 
Issuer Services, which provide business solutions 
across the transaction lifecycle to our global asset 
owner and asset manager clients.  We are one of the 
leading global investment services providers with 
$37.7 trillion of AUC/A at Dec. 31, 2024.  For 
information on the drivers of the Securities Services 
fee revenue, see Note 10 of the Notes to Consolidated 
Financial Statements.  
The Asset Servicing business provides a 
comprehensive suite of solutions.  We are one of the 
largest global custody, fund administrator and front-
to-back outsourcing partners.  We offer services for 
the safekeeping of assets in capital markets globally 
as well as fund accounting services, exchange-traded 
funds servicing, transfer agency, trust and depository, 
front-to-back capabilities and data and analytics 
solutions for our clients.  We deliver foreign 
exchange, and securities lending and financing 
solutions, on both an agency and principal basis.  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 $5.4 
trillion in 34 separate markets.  Our market-leading 
liquidity services portal enables cash investments for 
institutional clients and includes fund research and 
analytics.
Our Digital Asset Custody platform offers custody 
and administration services for Bitcoin and Ether for 
select U.S. institutional clients.  Our Digital Assets 
Funds Services provides accounting and 
administration, transfer agency and ETF services to 
digital asset funds.  We continue to develop our 
digital asset capabilities working closely with clients 
to address their evolving digital asset needs.  As of 
and for the year ended Dec. 31, 2024, our Digital 
Asset Custody platform and related initiatives had a 
de minimis impact on our assets, liabilities, revenues 
and expenses.
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.
Review of financial results
AUC/A of $37.7 trillion increased 10% compared 
with Dec. 31, 2023, primarily reflecting higher 
market values, client inflows and net new business, 
partially offset by the unfavorable impact of a 
stronger U.S. dollar.  
Total revenue of $8.9 billion increased 4% compared 
with 2023.  The drivers of total revenue by line of 
business are indicated below.
Asset Servicing revenue of $6.9 billion increased 4% 
compared with 2023, primarily reflecting higher 
market values, net new business, higher client 
activity, including in our fixed income and trading 
business, and higher foreign exchange revenue, 
partially offset by lower net interest income.
Issuer Services revenue of $2.0 billion increased 3% 
compared with 2023, primarily reflecting Corporate 
Trust fees driven by net new business, partially offset 
by lower Depositary Receipts 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 regulations and reduce their operating costs. 
Noninterest expense of $6.3 billion decreased 1% 
compared with 2023, primarily reflecting efficiency 
savings, partially offset by higher investments and 
employee merit increases.
Results of Operations (continued)
14 BNY

Market and Wealth Services business segment
2024 vs.
2023 vs.
(dollars in millions, unless otherwise noted)
2024
2023
2022
2023
2022
Revenue:
Investment services fees:
Pershing
$ 
1,947 
$ 
1,885 
$ 
1,793 
 3% 
 5% 
Treasury Services
 
792 
 
717 
 
719 
 10 
 — 
Clearance and Collateral Management
 
1,385 
 
1,212 
 
1,086 
 14 
 12 
Total investment services fees
 
4,124 
 
3,814 
 
3,598 
 8 
 6 
Foreign exchange revenue
 
97 
 
81 
 
88 
 20 
 (8) 
Other fees (a)
 
235 
 
202 
 
163 
 16 
 24 
Total fee revenue
 
4,456 
 
4,097 
 
3,849 
 9 
 6 
Investment and other revenue
 
79 
 
63 
 
40 
N/M
N/M
Total fee and other revenue
 
4,535 
 
4,160 
 
3,889 
 9 
 7 
Net interest income
 
1,729 
 
1,710 
 
1,410 
 1 
 21 
Total revenue
 
6,264 
 
5,870 
 
5,299 
 7 
 11 
Provision for credit losses
 
19 
 
41 
 
7 
N/M
N/M
Noninterest expense (excluding amortization of intangible assets)
 
3,349 
 
3,199 
 
2,928 
 5 
 9 
Amortization of intangible assets
 
4 
 
6 
 
8 
 (33) 
 (25) 
Total noninterest expense
 
3,353 
 
3,205 
 
2,936 
 5 
 9 
Income before income taxes
$ 
2,892 
$ 
2,624 
$ 
2,356 
 10% 
 11% 
Pre-tax operating margin
 46% 
 45% 
 44% 
Total revenue by line of business:
Pershing
$ 
2,687 
$ 
2,616 
$ 
2,330 
 3% 
 12% 
Treasury Services
 
1,737 
 
1,637 
 
1,514 
 6 
 8 
Clearance and Collateral Management
 
1,840 
 
1,617 
 
1,455 
 14 
 11 
Total revenue by line of business
$ 
6,264 
$ 
5,870 
$ 
5,299 
 7% 
 11% 
Selected average balances:
Average loans
$ 41,533 
$ 37,502 
$ 41,300 
 11% 
 (9) %
Average deposits
$ 90,185 
$ 85,785 
$ 91,749 
 5% 
 (7) %
Selected metrics:
AUC/A at period end (in trillions) (b)
$ 
14.1 
$ 
13.3 
$ 
12.7 
 6% 
 5% 
Pershing:
AUC/A at period end (in trillions) 
$ 
2.7 
$ 
2.5 
$ 
2.3 
 8% 
 9% 
Net new assets (U.S. platform) (in billions) (c)
$ 
(6) 
$ 
22 
$ 
121 
N/M
N/M
Daily average revenue trades (“DARTs”) (U.S. platform) (in thousands)
 
269 
 
234 
 
254 
 15% 
 (8) %
Average active clearing accounts (in thousands)
 
8,098 
 
7,946 
 
7,483 
 2% 
 6% 
Treasury Services:
Average daily U.S. dollar payment volumes
 242,997 
 236,696 
 239,630 
 3% 
 (1) %
Clearance and Collateral Management:
Average tri-party collateral management balances (in billions)
$ 
5,383 
$ 
5,658 
$ 
5,285 
 (5) %
 7% 
(a) Other fees primarily include financing-related fees. 
(b) Consists of AUC/A from the Clearance and Collateral Management and Pershing businesses. 
(c) Net new assets represent net flows of assets (e.g., net cash deposits and net securities transfers, including dividends and interest) in 
customer accounts in Pershing LLC, a U.S. broker-dealer.  
N/M – Not meaningful.
Results of Operations (continued)
BNY 15

Business segment description
The Market and Wealth Services business segment 
consists of three distinct lines of business, Pershing, 
Treasury Services and Clearance and Collateral 
Management, which provide business services and 
technology solutions to entities including financial 
institutions, corporations, foundations and 
endowments, public funds and government agencies.  
For information on the drivers of the Market and 
Wealth Services fee revenue, see Note 10 of the 
Notes to Consolidated Financial Statements.
Pershing provides execution, clearing, custody, 
business and technology solutions, delivering 
operational support to broker-dealers, wealth 
managers and registered investment advisors 
(“RIAs”) globally. 
Our Treasury Services business is a leading 
provider of global payments, liquidity management 
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.  We are the 
primary provider of U.S. government securities 
clearance and a provider of non-U.S. government 
securities clearance.  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 financing, risk 
and balance sheet challenges.  We are a leading 
provider of tri-party collateral management 
services with an average of $5.4 trillion serviced 
globally including approximately $4.2 trillion of 
the U.S. tri-party repo market in 2024. 
Review of financial results
AUC/A of $14.1 trillion increased 6% compared with 
Dec. 31, 2023, primarily reflecting net client inflows 
in the Clearance and Collateral Management business 
and higher market values.
Total revenue of $6.3 billion increased 7% compared 
with 2023.  The drivers of total revenue by line of 
business are indicated below.
Pershing revenue of $2.7 billion increased 3% 
compared with 2023, primarily reflecting higher 
market values and client activity, partially offset by 
lost business in the prior year and lower net interest 
income.  Net new assets of $(6) billion in 2024 
reflects the deconversion of business lost in the prior 
year.
Treasury Services revenue of $1.7 billion increased 
6% compared with 2023, primarily reflecting net new 
business, higher client activity and higher net interest 
income.
Clearance and Collateral Management revenue of 
$1.8 billion increased 14% compared with 2023, 
primarily reflecting higher collateral management 
fees, clearance volumes and net interest income.
Noninterest expense of $3.4 billion increased 5% 
compared with 2023, primarily reflecting higher 
investments, employee merit increases and higher 
revenue-related expenses, partially offset by 
efficiency savings.
Results of Operations (continued)
16 BNY

Investment and Wealth Management business segment
2024 vs.
2023 vs.
(dollars in millions)
2024
2023
2022
2023
2022
Revenue:
Investment management fees
$ 3,093 
$ 2,981 
$ 3,228 
 4% 
 (8) %
Performance fees
 
51 
 
81 
 
75 
N/M
N/M
Investment management and performance fees (a)
 
3,144 
 
3,062 
 
3,303 
 3 
 (7) 
Distribution and servicing fees
 
275 
 
241 
 
192 
 14 
 26 
Other fees (b)
 
(256) 
 
(214) 
 
(133) 
N/M
N/M
Total fee revenue
 
3,163 
 
3,089 
 
3,362 
 2 
 (8) 
Investment and other revenue (c)
 
50 
 
(102) 
 
(27) 
N/M
N/M
Total fee and other revenue (c)
 
3,213 
 
2,987 
 
3,335 
 8 
 (10) 
Net interest income
 
176 
 
168 
 
228 
 5 
 (26) 
Total revenue
 
3,389 
 
3,155 
 
3,563 
 7 
 (11) 
Provision for credit losses
 
4 
 
(4) 
 
1 
N/M
N/M
Noninterest expense (excluding goodwill impairment and 
amortization of intangible assets)
 
2,762 
 
2,756 
 
2,809 
 — 
 (2) 
Goodwill impairment
 
— 
 
— 
 
680 
N/M
N/M
Amortization of intangible assets
 
18 
 
20 
 
26 
 (10) 
 (23) 
Total noninterest expense
 
2,780 
 
2,776 
 
3,515 
 — 
 (21) 
Income before income taxes
$ 
605 
$ 
383 
$ 
47 
 58% (d)
 715% (d)
Pre-tax operating margin
 18% 
 12% 
 1% 
Adjusted pre-tax operating margin – Non-GAAP (e)
 20% 
 14% (f)
 2% (f)
Total revenue by line of business:
Investment Management
$ 2,279 
$ 2,097 
$ 2,423 
 9% 
 (13) %
Wealth Management
 
1,110 
 
1,058 
 
1,140 
 5 
 (7) 
Total revenue by line of business
$ 3,389 
$ 3,155 
$ 3,563 
 7% 
 (11) %
Selected average balances:
Average loans
$ 13,610 
$ 13,718 
$ 14,055 
 (1) %
 (2) %
Average deposits
$ 10,589 
$ 14,280 
$ 19,214 
 (26) %
 (26) %
(a) On a constant currency basis, investment management and performance fees increased 2% (Non-GAAP) compared with 2023.  See 
“Supplemental Information – Explanation of GAAP and Non-GAAP financial measures” beginning on page 115 for the reconciliation of 
this Non-GAAP measure.
(b) Other fees primarily includes investment services fees. 
(c) Investment and other revenue and total fee and other revenue are net of income (loss) attributable to noncontrolling interests related to 
consolidated investment management funds.  
(d) Excluding notable items, income before income taxes increased 14% (Non-GAAP) in 2024 compared with 2023 and decreased 28% 
(Non-GAAP) in 2023 compared with 2022.  See “Supplemental Information – Explanation of GAAP and Non-GAAP financial 
measures” beginning on page 115 for the reconciliation of these Non-GAAP measures.
(e) Net of distribution and servicing expense.  See “Supplemental Information – Explanation of GAAP and Non-GAAP financial measures” 
beginning on page 115 for the reconciliation of these Non-GAAP measures.
(f) 
Excluding notable items and net of distribution and servicing expense, the adjusted pre-tax operating margin was 19% (Non-GAAP) in 
2023 and 23% (Non-GAAP) in 2022.  See “Supplemental Information – Explanation of GAAP and Non-GAAP financial measures” 
beginning on page 115 for the reconciliation of these Non-GAAP measures.
N/M – Not meaningful.
Results of Operations (continued)
BNY 17

AUM trends
(in billions)
2024
2023
2022
AUM by product type (a):
Equity 
$ 
162 $ 
145 $ 
135 
Fixed income 
 
221  
205  
198 
Index 
 
491  
459  
395 
Liability-driven investments
 
548  
605  
570 
Multi-asset and alternative investments  
171  
170  
153 
Cash
 
436  
390  
385 
Total AUM
$ 2,029 $ 1,974 $ 1,836 
Changes in AUM (a):
Beginning balance of AUM
$ 1,974 $ 1,836 $ 2,434 
Net inflows (outflows):
Long-term strategies:
Equity
 
(15)  
(12)  
(18) 
Fixed income
 
18  
(4)  
(21) 
Liability-driven investments
 
2  
12  
78 
Multi-asset and alternative 
investments
 
(15)  
(9)  
(11) 
Total long-term active strategies 
(outflows) inflows
 
(10)  
(13)  
28 
Index
 
(42)  
(12)  
2 
Total long-term strategies 
(outflows) inflows
 
(52)  
(25)  
30 
Short-term strategies:
Cash
 
45  
5  
(12) 
Total net (outflows) inflows
 
(7)  
(20)  
18 
Net market impact
 
69  
121  
(471) 
Net currency impact
 
(25)  
37  
(113) 
Other/Divestiture (b)
 
18  
—  
(32) 
Ending balance of AUM
$ 2,029 $ 1,974 $ 1,836 
Wealth Management client 
assets (c)
$ 
327 $ 
312 $ 
269 
(a) Represents assets managed in the Investment and Wealth 
Management business segment.   
(b) Activity in 2024 reflects the realignment of similar products and 
services within our lines of business.  Activity in 2022 reflects 
the divestiture of BNY Alcentra Group Holdings, Inc.
(c) Includes AUM and AUC/A in the Wealth Management line of  
business.
Business segment description
Our Investment and Wealth Management business 
segment consists of two distinct lines of business, 
Investment Management and Wealth Management, 
which have a combined AUM of $2.0 trillion as of 
Dec. 31, 2024.
Investment Management is a leading global asset 
manager and consists of seven specialist investment 
firms and a global distribution platform to deliver a 
diversified range of investment capabilities to 
institutional and retail clients globally.  
Our Investment Management model provides 
specialist expertise from seven investment firms 
offering solutions across major asset classes, backed 
by the strength, scale and proven stewardship of 
BNY.  Each investment firm has its own individual 
culture, investment philosophy and proprietary 
investment process.  This approach brings our clients 
clear, independent thinking from highly experienced 
investment professionals.
The investment firms offer a broad range of actively 
managed equity, fixed income, multi-asset and 
liability-driven investments, along with passive 
products and cash management.  Our six majority-
owned investment firms are: ARX, Dreyfus, Insight 
Investment, Mellon, Newton Investment Management 
and Walter Scott.  BNY owns a noncontrolling 
interest in Siguler Guff.
Investment Management has multiple global 
distribution entities, which are responsible for 
distributing the investment solutions developed and 
managed by the investment firms, as well as the 
management and distribution of our U.S. mutual 
funds, ETFs and certain offshore money market 
funds.
Wealth Management provides investment 
management, custody, wealth and estate planning, 
private banking services, investment servicing and 
information management.  Wealth Management has 
$327 billion in client assets as of Dec. 31, 2024, and 
more than 30 offices in the U.S. and internationally.  
Wealth Management clients include individuals, 
families and institutions.  Institutions include family 
offices, charitable gift programs and endowments and 
foundations.  We work with clients to build, manage 
and sustain wealth across generations and market 
cycles. 
The wealth business differentiates itself with a 
comprehensive wealth management framework called 
Active Wealth that seeks to empower clients to build 
and sustain long-term wealth.
The results of the Investment and Wealth 
Management business segment are driven by a blend 
of daily, monthly and quarterly AUM by product 
type.  The overall level of AUM for a given period is 
determined by:
•
the beginning level of AUM;
Results of Operations (continued)
18 BNY

•
the net flows of new assets during the period 
resulting from new business wins and existing 
client inflows, reduced by the loss of clients and 
existing client outflows; and
•
the impact of market price appreciation or 
depreciation, foreign exchange rates and 
investment firm acquisitions or divestitures.
The mix of AUM is a result of the historical growth 
rates of equity and fixed income markets and the 
cumulative net flows of our investment firms as a 
result of client asset allocation decisions.  Actively 
managed equity, multi-asset and alternative assets 
typically generate higher percentage fees than fixed-
income and liability-driven investments and cash.  
Also, actively managed assets typically generate 
higher management fees than indexed or passively 
managed assets of the same type.  Market and 
regulatory trends have resulted in increased demand 
for lower fee asset management products and for 
performance-based fees. 
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 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 income 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 and 
Wealth Management business segment are mainly 
driven by staff and distribution and servicing 
expenses.  
Review of financial results
AUM of $2.0 trillion increased 3% compared with 
Dec. 31, 2023, primarily reflecting higher market 
values, partially offset by the unfavorable impact of a 
stronger U.S. dollar. 
Net long-term strategy outflows were $52 billion in 
2024, driven by outflows of index, equity and multi-
asset and alternative investments, partially offset by 
inflows of fixed income and liability-driven 
investments.  Short-term strategy inflows were $45 
billion in 2024.  
Total revenue of $3.4 billion increased 7% compared 
with 2023.  The drivers of total revenue by line of 
business are indicated below.
Investment Management revenue of $2.3 billion 
increased 9% compared with 2023, primarily 
reflecting higher market values and the reduction in 
the fair value of a contingent consideration receivable 
in 2023, partially offset by the mix of AUM flows 
and lower performance fees.
Wealth Management revenue of $1.1 billion 
increased 5% compared with 2023, primarily 
reflecting higher market values, partially offset by 
changes in product mix.
Revenue generated in the Investment and Wealth 
Management business segment included 30% from 
non-U.S. sources in 2024, compared with 32% in 
2023.
Noninterest expense of $2.8 billion was flat compared 
with 2023, primarily reflecting employee merit 
increases and higher investments, offset by efficiency 
savings.
Results of Operations (continued)
BNY 19

Other segment
(in millions)
2024
2023
2022
Fee revenue
$ 
(42) $ 
(10) $ 
61 
Investment and other revenue
 
140  
184  
(221) 
Total fee and other revenue
 
98  
174  
(160) 
Net interest expense
 
(61)  
(102)  
(162) 
Total revenue
 
37  
72  
(322) 
Provision for credit losses
 
9  
(17)  
23 
Noninterest expense
 
254  
956  
278 
(Loss) before income taxes
$ 
(226) $ 
(867) $ 
(623) 
Average loans and leases
$ 
1,763 $ 
1,669 $ 
1,225 
Segment description
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;
•
tax credit investments and other corporate 
investments; and
•
certain business exits.
Revenue primarily reflects:
•
net interest income (expense) and lease-related 
gains (losses) from leasing operations;
•
net interest income (expense) and derivatives and 
other corporate treasury activities;
•
other revenue from certain business exits; 
•
investment and other revenue from corporate and 
bank-owned life insurance, gains (losses) 
associated with investment securities and other 
assets; and
•
fee revenue from the elimination of the results of 
certain services provided between segments, 
which are also provided to third parties.  
Expenses include:
•
direct expenses supporting leasing, investing and 
funding activities; and
•
expenses not directly attributable to Securities 
Services, Market and Wealth Services and 
Investment and Wealth Management operations.  
Review of financial results 
Loss before taxes was $226 million in 2024 compared 
with $867 million in 2023.
Investment and other revenue decreased $44 million 
compared with 2023, primarily reflecting investment 
gains recorded in 2023 and higher net securities 
losses.
Noninterest expense decreased $702 million 
compared with 2023, primarily driven by adjustments 
for the FDIC special assessment. 
International operations
Our primary international activities consist of asset 
servicing in our Securities Services business segment, 
global payment services in our Market and Wealth 
Services business segment and investment 
management in our Investment and Wealth 
Management business segment.  
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, 2024, approximately 60% of our total 
employees (full-time and part-time employees) were 
based outside the U.S., with approximately 10,900 
employees in EMEA, approximately 18,900 
employees in APAC and approximately 800 
employees in other global locations, primarily Brazil. 
We are a leading global asset manager.  Our 
international operations managed 47% of BNY’s 
AUM at Dec. 31, 2024 and 51% at Dec. 31, 2023.
Results of Operations (continued)
20 BNY

In Europe, we maintain capabilities to service 
Undertakings for Collective Investment in 
Transferable Securities and alternative investment 
funds.  We offer a full range of tailored solutions for 
investment companies, financial institutions and 
institutional investors across most European markets.  
We are a provider of non-U.S. government securities, 
fixed income and equities clearance, settling 
securities transactions directly in European markets, 
and using a high-quality and established network of 
local agents in non-European markets.
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.  
In emerging markets, we lead with custody, 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 income, 
noninterest expense and AUC/A and AUM.  
Conversely, if the U.S. dollar appreciates, the 
translated levels of fee revenue, net interest income, 
noninterest expense and AUC/A and AUM will be 
lower.
Foreign exchange rates
vs. U.S. dollar
2024
2023
2022
Spot rate (at Dec. 31):
British pound
$ 1.2516 $ 1.2749 $ 1.2096 
Euro
 1.0347  1.1046  1.0708 
Yearly average rate:
British pound
$ 1.2780 $ 1.2432 $ 1.2375 
Euro
 1.0819  1.0813  1.0550 
International clients accounted for 35% of revenues in 
2024 and 36% in 2023.  Net income from 
international operations was $2.3 billion in 2024, 
compared with $2.0 billion in 2023.
Revenues from EMEA were $4.3 billion in 2024, an 
increase of 4% compared with 2023.  The increase 
was primarily driven by higher net interest income, 
collateral management fees and clearance volumes in 
the Market and Wealth Services business segment.  
The Securities Services, Market and Wealth Services 
and Investment and Wealth Management business 
segments generated 58%, 24% and 18% of EMEA 
revenues, respectively.  Net income from EMEA was 
$1.3 billion in 2024, compared with $1.1 billion in 
2023.
Revenues from APAC were $1.3 billion in 2024, a 
decrease of 1% compared with 2023.  The decrease 
primarily reflects lower revenue in the Market and 
Wealth Services and Investment and Wealth 
Management business segments, partially offset by 
higher revenue in the Securities Services business 
segment.  
The Securities Services, Market and Wealth Services 
and Investment and Wealth Management business 
segments generated 60%, 30% and 10% of APAC 
revenues, respectively.  Net income from APAC was 
$542 million in 2024, compared with $547 million in 
2023.
For additional information regarding our international 
operations, including certain key subjective 
assumptions used in determining the results, see Note 
25 of the Notes to Consolidated Financial Statements.
Results of Operations (continued)
BNY 21

Country risk exposure
The following table presents BNY’s top 10 exposures 
by country (excluding the U.S.) as of Dec. 31, 2024, 
as well as certain countries with higher-risk profiles. 
The exposure is presented on an internal risk 
management basis and has not been reduced by the 
allowance for credit losses.  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 securities is 
generally based on the domicile of the issuer of the 
security.
Country risk exposure at Dec. 31, 2024
Interest-bearing deposits
Total 
exposure
(in billions)
Central banks
Banks
Lending (a)
Securities (b)
Other (c)
Top 10 country exposure:
United Kingdom (“UK”)
$ 
8.0 $ 
0.3 
$ 
1.4 
$ 
5.5 
$ 
2.1 
$ 
17.3 
Germany
 
11.3  
0.3 
 
0.8 
 
3.5 
 
0.4 
 
16.3 
Belgium
 
4.9  
1.0 
 
0.1 
 
1.4 
 
0.1 
 
7.5 
Canada
 
—  
0.9 
 
0.1 
 
3.8 
 
1.7 
 
6.5 
Luxembourg
 
0.1  
0.1 
 
1.5 
 
0.1 
 
2.5 
 
4.3 
Netherlands
 
1.6  
— 
 
0.2 
 
2.1 
 
0.2 
 
4.1 
South Korea
 
0.2  
0.1 
 
2.3 
 
0.2 
 
0.8 
 
3.6 
Ireland
 
0.1  
0.2 
 
0.8 
 
— 
 
2.0 
 
3.1 
Australia
 
—  
1.2 
 
0.3 
 
0.6 
 
0.5 
 
2.6 
France
 
—  
— 
 
0.1 
 
2.1 
 
0.2 
 
2.4 
Total Top 10 country exposure
$ 
26.2 $ 
4.1 
$ 
7.6 
$ 
19.3 
$ 
10.5 
$ 
67.7 (d)
Select country exposure:
Brazil
$ 
— $ 
0.1 
$ 
1.2 
$ 
0.1 
$ 
0.1 
$ 
1.5 
Russia
 
—  
0.6 (e)  
— 
 
— 
 
— 
 
0.6 
(a)
Lending includes loans, acceptances, issued letters of credit, net of participations, and lending-related commitments. 
(b)
Securities include both the available-for-sale and held-to-maturity portfolios.
(c)
Other exposure includes over-the-counter (“OTC”) derivative and securities financing transactions, net of collateral.
(d)
The top 10 country exposure comprises approximately 65% of our total non-U.S. exposure.
(e) Represents cash balances with exposure to Russia.
Events in recent years have resulted in increased 
focus on Brazil.  The country risk 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 war in Ukraine has increased our focus on 
Russia.  The country risk exposure to Russia consists 
of cash balances related to our securities services 
businesses and may increase in the future to the 
extent cash is received for the benefit of our clients 
that is subject to distribution restrictions.  BNY has 
ceased new banking business in Russia and 
suspended investment management purchases of 
Russian securities.  Russian securities included in our 
AUC/A and AUM at Dec. 31, 2024, continue to be 
insignificant as a percentage of the total AUC/A and 
AUM, respectively.  We will continue to work with 
multinational clients that depend on our custody and 
recordkeeping services to manage their exposures.  
We are also monitoring our exposure to Israel as part 
of our internal country risk management process.  At 
Dec. 31, 2024, our total exposure to Israel was $158 
million and primarily consisted of investment grade 
short-term interest-bearing deposits and OTC 
derivatives maturing within six months.
Critical accounting estimates
Our significant accounting policies are described in 
Note 1 of the Notes to Consolidated Financial 
Statements.  Certain of these policies include critical 
accounting estimates which require management to 
make subjective or complex judgments about the 
effect of matters that are inherently uncertain and 
may change in subsequent periods.  Our critical 
accounting estimates are those related to the 
Results of Operations (continued)
22 BNY

allowance for credit losses, goodwill and other 
intangibles and litigation and regulatory 
contingencies.  Management has discussed the 
development and selection of the critical accounting 
estimates with the Company’s Audit Committee.
Allowance for credit losses
The allowance for credit losses covers financial assets 
subject to credit losses and measured at amortized 
cost, including loans and lending-related 
commitments, held-to-maturity securities, certain 
securities financing transactions and deposits with 
banks.  The allowance for credit losses is intended to 
adjust the carrying value of these assets by an 
estimated amount of credit losses that we expect to 
incur over the life of the asset.  Similarly, the 
allowance for credit losses on lending-related 
commitments and other off-balance sheet financial 
instruments is meant to capture the credit losses that 
we expect to recognize in these portfolios as of the 
balance sheet date.
A quantitative methodology and qualitative 
framework is used to estimate the allowance for 
credit losses.  
The quantitative component of our estimate uses 
models and methodologies that categorize financial 
assets based on product type, collateral type, and 
other credit trends and risk characteristics, including 
relevant information about past events, current 
conditions and reasonable and supportable forecasts 
of future economic conditions that affect the 
collectability of the recorded amounts.  For the 
quantitative component, we segment portfolios into 
various major components including commercial 
loans and lease financing, commercial real estate, 
financial institutions, residential mortgages, and 
other.  The segmentation of our debt securities 
portfolios is by major asset class and is influenced by 
whether the security is structured or non-structured 
(i.e., direct obligation), as well as the issuer type.  The 
components of the credit loss calculation for each 
major portfolio or asset class include a probability of 
default, loss given default and exposure at default, as 
applicable, and their values depend on the forecast 
behavior of variables in the macroeconomic 
environment.  We utilize a multi-scenario 
macroeconomic forecast which includes a weighting 
of three scenarios: a baseline and upside and 
downside scenarios and allows us to develop our 
estimate using a wide span of economic variables.  
Our baseline scenario reflects a view on likely 
performance of each global region and the other two 
scenarios are designed relative to the baseline 
scenario.  This approach incorporates a reasonable 
and supportable forecast period spanning the life of 
the asset, and includes both an initial estimated 
economic outlook component as well as a reversion 
component for each economic input variable.  The 
length of each of the two components depends on the 
underlying financial instrument, scenario, and 
underlying economic input variable.  In general, the 
initial economic outlook period for each economic 
input variable under each scenario ranges between 
several months and two years.  The speed at which 
the scenario-specific forecasts revert to long-term 
historical mean is based on observed historical 
patterns of mean reversion at the economic variable 
input level that are reflected in our model parameter 
estimates.  Certain macroeconomic variables such as 
unemployment or home prices take longer to revert 
after a contraction, though specific recovery times are 
scenario-specific.  Reversion will usually take longer 
the further away the scenario-specific forecast is from 
the historical mean.  On a quarterly basis, and within 
a developed governance structure, we update these 
scenarios for current economic conditions and may 
adjust the scenario weighting based on our economic 
outlook.  The Company uses judgment to assess these 
economic conditions and loss data in determining the 
best estimate of the allowance for credit losses and 
these estimates are subject to periodic refinement 
based on changes to underlying external or Company-
specific historical data.
In the quantitative component of our estimate, we 
measure expected credit losses using an individual 
evaluation method if the risk characteristics of the 
asset is no longer consistent with the portfolio or class 
of asset.  For these assets, we do not employ the 
macroeconomic model calculation but consider 
factors such as payment status, collateral value, the 
obligor’s financial condition, guarantor support, the 
probability of collecting scheduled principal and 
interest payments when due, and recovery 
expectations if they can be reasonably estimated.  For 
loans, we measure the expected credit loss as the 
difference between the amortized cost basis of the 
loan and the present value of the expected future cash 
flows from the borrower which is generally 
discounted at the loan’s effective interest rate, or the 
fair value of the collateral, if the loan is collateral-
dependent.  We generally individually evaluate 
Results of Operations (continued)
BNY 23

nonperforming loans as well as loans that have been 
modified given the risk characteristics of such loans. 
Available-for-sale debt securities are recorded at fair 
value.  When an available-for-sale debt security is in 
an unrealized loss position, we employ a 
methodology to identify and estimate the credit loss 
portion of the unrealized loss position.  The 
measurement of expected credit losses is performed at 
the security level and is based on our best single 
estimate of cash flows, on a discounted basis; 
however, we do not specifically employ the 
macroeconomic forecasting models and scenarios 
summarized above. 
The qualitative component of our estimate for the 
allowance for credit losses is intended to capture 
expected losses that may not have been fully captured 
in the quantitative component.  Through an 
established governance structure, management 
determines the qualitative allowance each period 
based on an evaluation of various internal and 
environmental factors that include: scenario 
weighting and sensitivity risk, credit concentration 
risk, economic conditions and other considerations.  
We have made and may continue to make 
adjustments for idiosyncratic risks.
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 
and recoveries.
Our allowance for credit losses is sensitive to a 
number of inputs, most notably the macroeconomic 
forecast assumptions that are incorporated into our 
estimate of credit losses through the expected life of 
the loan portfolio, as well as credit ratings assigned to 
each borrower.  As the macroeconomic environment 
and related forecasts change, the allowance for credit 
losses may change materially.  The following 
sensitivity analyses do not represent management’s 
expectations of the deterioration of our portfolios or 
the economic environment, but are provided as 
hypothetical scenarios to assess the sensitivity of the 
allowance for credit losses to changes in key inputs.  
If commercial real estate property values were 
increased 10% and all other credits were rated one 
grade better, the quantitative allowance would have 
decreased by $47 million, and if commercial real 
estate property values were decreased 10% and all 
other credits were rated one grade worse, the 
quantitative allowance would have increased by $82 
million.  Our multi-scenario macroeconomic forecast 
used in determining the Dec. 31, 2024 allowance for 
credit losses consisted of three scenarios.  The 
baseline scenario reflects positive but slightly 
declining GDP growth through the first quarter of 
2025 before moderating, stable unemployment and 
slightly declining commercial real estate prices 
through the end of 2025.  The upside scenario reflects 
higher GDP growth through the first quarter of 2025 
before moderating, declining unemployment through 
the end of 2025 and increasing commercial real estate 
prices through the end of 2025 compared with the 
baseline.  The downside scenario contemplates 
negative GDP growth through the third quarter of 
2025 before moderating, rapidly increasing 
unemployment through the third quarter of 2025 and 
sharply lower commercial real estate prices through 
the end of 2025 compared with the baseline.  At Dec. 
31, 2024, we placed the most weight on our baseline 
scenario, with the remaining weighting equally placed 
on the upside and downside scenarios.  From a 
sensitivity perspective, at Dec. 31, 2024, if we had 
applied 100% weighting to the downside scenario, the 
quantitative allowance for credit losses would have 
been approximately $130 million higher.
See Notes 1 and 5 of the Notes to Consolidated 
Financial Statements for additional information 
regarding the allowance for credit losses. 
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 Accounting Standards Codification 
(“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 ($16.6 
billion at Dec. 31, 2024) and indefinite-lived 
intangible assets ($2.6 billion at Dec. 31, 2024) 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. 
Results of Operations (continued)
24 BNY

Goodwill
BNY’s business segments include seven reporting 
units for which goodwill impairment testing is 
performed on an annual basis.  An interim goodwill 
impairment test is performed when events or 
circumstances occur that may indicate that it is more 
likely than not that the fair value of any reporting unit 
may be less than its carrying value.
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 for the 
difference.  
In each quarter of 2024, we completed an interim 
goodwill impairment test of the Investment 
Management reporting unit, which had $6.0 billion of 
allocated goodwill as of Dec. 31, 2024.  In all cases, 
we determined the fair value of the Investment 
Management reporting unit exceeded its carrying 
value and no goodwill impairment was recorded.
For the Dec. 31, 2024 test, the fair value of the 
Investment Management reporting unit exceeded its 
carrying value by approximately 11%.  We 
determined the fair value of the Investment 
Management reporting unit using an income approach 
based on management’s projections as of Dec. 31, 
2024.  The discount rate applied to these cash flows 
was 10.5%.
As of Dec. 31, 2024, if the discount rate applied to 
the estimated cash flows was increased or decreased 
by 25 basis points, the fair value of the Investment 
Management reporting unit would decrease or 
increase by 4%, respectively.  Similarly, if the long-
term growth rate was increased or decreased by 10 
basis points, the fair value of the Investment 
Management reporting unit would increase or 
decrease by approximately 1%, respectively.
In the second quarter of 2024, we performed our 
annual goodwill impairment test on the remaining six 
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 April 1, 2024.  The 
discount rate applied to these cash flows was 10%.  
As a result of the annual goodwill impairment test, no 
goodwill impairment was recognized.  The fair values 
of the Company’s remaining six reporting units were 
substantially in excess of the respective reporting 
units’ carrying value.  
Intangible assets
Key judgments in accounting for intangible assets 
include determining the useful life and classification 
between goodwill and indefinite-lived intangible 
assets or other amortizing intangible assets. 
Indefinite-lived intangible assets ($2.6 billion at Dec. 
31, 2024) are evaluated for impairment at least 
annually by comparing their fair values, estimated 
using discounted cash flow analyses, to their carrying 
values.  As a result of the annual evaluation, no 
impairment was recognized.
Other amortizing intangible assets ($275 million at 
Dec. 31, 2024) 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. 
Determining the fair value of a reporting unit or 
indefinite-lived intangible assets is subject to 
uncertainty as it is reliant on estimates of cash flows 
that extend far into the future, and, by their nature, are 
difficult to estimate over such an extended time 
frame.  In the future, changes in the assumptions or 
the discount rate could produce a material non-cash 
goodwill or intangible asset impairment. 
See Notes 1 and 7 of the Notes to Consolidated 
Financial Statements for additional information 
regarding goodwill, intangible assets and the annual 
and interim impairment testing. 
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 22 of 
the Notes to Consolidated Financial Statements.
Results of Operations (continued)
BNY 25

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 undertake overall liquidity risk, 
including intraday liquidity risk, that 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.  
At Dec. 31, 2024, total assets were $416 billion, 
compared with $410 billion at Dec. 31, 2023.  The 
increase in total assets was primarily driven by higher 
federal funds sold and securities purchased under 
resale agreements, securities and loans, partially 
offset by lower interest-bearing deposits with the 
Federal Reserve and other central banks.  Deposits 
totaled $290 billion at Dec. 31, 2024, compared with 
$284 billion at Dec. 31, 2023.  The increase primarily 
reflects higher interest-bearing deposits in U.S. 
offices, partially offset by lower interest-bearing 
deposits in non-U.S. offices.  Total interest-bearing 
deposit liabilities as a percentage of total interest-
earning assets were 65% at Dec. 31, 2024 and 66% at 
Dec. 31, 2023.  
At Dec. 31, 2024, available funds totaled $144 billion 
and include cash and due from banks, interest-bearing 
deposits with the Federal Reserve and other central 
banks, interest-bearing deposits with banks and 
federal funds sold and securities purchased under 
resale agreements.  This compares with available 
funds of $158 billion at Dec. 31, 2023.  Total 
available funds as a percentage of total assets were 
35% at Dec. 31, 2024 and 38% at Dec. 31, 2023.  For 
additional information on our available funds, see 
“Liquidity and dividends.”
Securities were $137 billion, or 33% of total assets, at 
Dec. 31, 2024, compared with $126 billion, or 31% 
of total assets, at Dec. 31, 2023.  The increase 
primarily reflects higher non-U.S. government and 
agency residential mortgage-backed securities 
(“RMBS”), partially offset by lower U.S. Treasury 
and U.S. government agency securities.  For 
additional information on our securities portfolio, see 
“Securities” and Note 4 of the Notes to Consolidated 
Financial Statements.
Loans were $72 billion, or 17% of total assets, at Dec. 
31, 2024, compared with $67 billion, or 16% of total 
assets, at Dec. 31, 2023.  The increase was driven by 
higher loans in the financial institutions and capital 
call financing portfolios and higher margin loans, 
partially offset by lower commercial loans.  For 
additional information on our loan portfolio, see 
“Loans” and Note 5 of the Notes to Consolidated 
Financial Statements.
Long-term debt totaled $30.9 billion at Dec. 31, 2024 
and $31.3 billion at Dec. 31, 2023.  The decrease 
primarily reflects maturities, redemptions and a 
decrease in the fair value of hedged long-term debt, 
partially offset by issuances.  For additional 
information on long-term debt, see “Liquidity and 
dividends” and Note 13 of the Notes to Consolidated 
Financial Statements. 
The Bank of New York Mellon Corporation total 
shareholders’ equity totaled $41 billion at Dec. 31, 
2024 and Dec. 31, 2023.  For additional information, 
see “Capital” and Note 15 of the Notes to 
Consolidated Financial Statements. 
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 could indicate increased credit 
risk for us and could be accompanied by an increase 
in the allowance for credit losses and/or a reduction in 
the fair value of our securities portfolio.  
Results of Operations (continued)
26 BNY

The following table shows the distribution of our total securities portfolio.
Securities portfolio
Dec. 31, 
2023
2024
change in
unrealized
gain (loss)
Dec. 31, 2024
Fair value 
as a % of 
amortized
cost (a)
Unrealized
gain (loss)
% 
Floating
rate (b)
Ratings (c)
BBB+/
BBB-
BB+
and
lower
(dollars in millions)
Fair
value
Amortized
cost (a)
Fair
value
AAA/
AA-
A+/
A-
Not
rated
Agency RMBS
$ 39,359 $ 
(152) $ 
46,199 $ 42,183 
 91% $ 
(4,016) 
 26% 
 100%  —% 
 —% 
 —% 
 —% 
Non-U.S. government (d)
 20,455  
269  
29,521  
29,198 
 99 
 
(323) 
 24 
 95 
 2 
 2 
 1 
 — 
U.S. Treasury
 25,115  
225  
25,408  
24,793 
 98 
 
(615) 
 64 
 100 
 — 
 — 
 — 
 — 
Agency commercial 
mortgage-backed securities 
(“MBS”)
 10,845  
107  
10,862  
10,377 
 96 
 
(485) 
 43 
 100 
 — 
 — 
 — 
 — 
Collateralized loan 
obligations (“CLOs”)
 
7,119  
18  
7,625  
7,637 
 100 
 
12 
 100 
 100 
 — 
 — 
 — 
 — 
Foreign covered bonds (e)
 
6,334  
111  
7,684  
7,623 
 99 
 
(61) 
 40 
 100 
 — 
 — 
 — 
 — 
U.S. government agencies
 
6,646  
82  
5,973  
5,636 
 94 
 
(337) 
 30 
 100 
 — 
 — 
 — 
 — 
Non-agency commercial 
MBS
 
2,935  
94  
2,641  
2,487 
 94 
 
(154) 
 45 
 100 
 — 
 — 
 — 
 — 
Non-agency RMBS
 
1,766  
(10)  
1,645  
1,492 
 91 
 
(153) 
 41 
 98 
 2 
 — 
 — 
 — 
Other asset-backed securities
 
943  
44  
654  
615 
 94 
 
(39) 
 16 
 100 
 — 
 — 
 — 
 — 
Other
 
11  
1  
11  
10 
 91 
 
(1) 
 — 
 — 
 — 
 — 
 — 
 100 
Total securities
$ 121,528 $ 
789 $ 138,223 $ 132,051 
 96% $ 
(6,172) (f)
 40% 
 99% 
 1% 
 —% 
 —% 
 —% 
(a) 
Amortized cost includes the impact of hedged item basis adjustments, which was a net decrease of $1,650 million, and is net of the allowance for credit 
losses.
(b) 
Includes the impact of hedges.
(c) 
Represents ratings by Standard & Poor’s (“S&P”) or the equivalent.
(d) 
Includes supranational securities.  Primarily consists of exposure to UK, Germany, France and Canada.
(e) 
Primarily consists of exposure to Canada, UK, the Netherlands and Germany. 
(f) 
At Dec. 31, 2024, includes pre-tax net unrealized losses of $1,596 million related to available-for-sale securities, net of hedges, and $4,576 million 
related to held-to-maturity securities.  The after-tax unrealized losses, net of hedges, related to available-for-sale securities was $1,207 million and the 
after-tax equivalent related to held-to-maturity securities was $3,490 million.
The fair value of our securities portfolio was $132.1 
billion at Dec. 31, 2024, compared with $121.5 
billion at Dec. 31, 2023.  The increase primarily 
reflects higher non-U.S. government securities and 
agency RMBS, partially offset by lower U.S. 
Treasury and U.S. government agencies securities. 
At Dec. 31, 2024, the securities portfolio had a net 
unrealized loss, including the impact of related 
hedges, of $6.2 billion, compared with $7.0 billion at 
Dec. 31, 2023.  The improvement in the net 
unrealized loss, including the impact of related 
hedges, primarily reflects securities moving closer to 
maturity.
The fair value of the available-for-sale securities 
totaled $88.0 billion at Dec. 31, 2024 or 67% of the 
securities portfolio.  The fair value of the held-to-
maturity securities totaled $44.0 billion at Dec. 31, 
2024, or 33% of the securities portfolio.
The unrealized loss (after-tax) on our available-for-
sale securities portfolio, net of hedges, included in 
accumulated other comprehensive income was $1.2 
billion at Dec. 31, 2024, compared with $1.6 billion 
at Dec. 31, 2023.  The improvement in the net 
unrealized loss, including the impact of hedges, was 
primarily driven by securities moving closer to 
maturity.
At Dec. 31, 2024, 99% of the securities in our 
portfolio were rated AAA/AA-, unchanged compared 
with Dec. 31, 2023. 
See Note 4 of the Notes to Consolidated Financial 
Statements for the pre-tax net securities gains (losses) 
by security type.  See Note 20 of the Notes to 
Consolidated Financial Statements for securities by 
level in the fair value hierarchy.
Results of Operations (continued)
BNY 27

The following table presents the net premium (discount) and net amortization (accretion) related to the securities 
portfolio.
Net premium (discount) and net amortization (accretion) related to the securities portfolio (a)
(in millions)
2024
2023
2022
Net purchase premium (discount) that is amortizable (accretable)
$ 
(57) $ 
821 $ 1,109 
Net amortization (b)
$ 
26 $ 
167 $ 
362 
(a) Amortization of purchase premium decreases net interest income while accretion of discount increases net interest income.  Both are 
recorded on a level yield basis.
(b) Including the impact of the accretion of discontinued hedges, there was a net accretion of $149 million in 2024, net amortization of $104 
million in 2023 and net amortization of $388 million in 2022. 
Equity investments
We have several equity investments recorded in other 
assets.  These include tax credit investments, equity 
method investments, Federal Reserve Bank stock, 
other investments, seed capital and Federal Home 
Loan Bank stock.  The following table presents the 
carrying values at Dec. 31, 2024 and Dec. 31, 2023.
Equity investments
Dec. 31,
(in millions)
2024
2023
Tax credit investments
$ 2,821 $ 2,186 
Equity method investments:
CIBC Mellon
 
583  
607 
Siguler Guff
 
228  
234 
Other
 
41  
32 
Total equity method investments
 
852  
873 
Federal Reserve Bank stock
 
478  
480 
Other equity investments (a)
 
679  
741 
Seed capital (b)
 
196  
232 
Federal Home Loan Bank stock
 
57  
7 
Total equity investments
$ 5,083 $ 4,519 
(a) Includes strategic equity, private equity and other 
investments.
(b) Includes investments in BNY funds that hedge deferred 
incentive awards.
For additional information on certain seed capital 
investments and our private equity investments, see 
“Investments valued using net asset value (“NAV”) 
per share” in Note 8 of the Notes to Consolidated 
Financial Statements.
Tax credit investments
Tax credit investments include affordable housing 
projects and renewable energy investments.  We 
invest in affordable housing projects primarily to 
satisfy the Company’s requirements under the 
Community Reinvestment Act.  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.  
On Jan. 1, 2024, we adopted ASU 2023-02, 
Investments—Equity Method and Joint Ventures 
(Topic 323): Accounting for Investments in Tax 
Credit Structures Using the Proportional 
Amortization Method for our renewable energy 
projects that met the eligibility criteria.  See Note 2 of 
the Notes to Consolidated Financial Statements for 
additional information.
Results of Operations (continued)
28 BNY

Loans 
Total exposure – consolidated
Dec. 31, 2024
Dec. 31, 2023
(in billions)
Loans
Unfunded
commitments
Total
exposure
Loans
Unfunded
commitments
Total
exposure
Financial institutions
$ 
13.2 $ 
35.2 $ 
48.4 
$ 
10.5 $ 
29.2 $ 
39.7 
Commercial
 
1.4  
11.9  
13.3 
 
2.1  
11.4  
13.5 
Wealth management loans
 
8.7  
0.7  
9.4 
 
9.1  
0.5  
9.6 
Wealth management mortgages
 
8.9  
0.2  
9.1 
 
9.1  
0.3  
9.4 
Commercial real estate
 
6.8  
3.1  
9.9 
 
6.8  
3.4  
10.2 
Lease financings
 
0.6  
—  
0.6 
 
0.6  
—  
0.6 
Other residential mortgages
 
1.1  
—  
1.1 
 
1.2  
—  
1.2 
Overdrafts
 
3.5  
—  
3.5 
 
3.1  
—  
3.1 
Capital call financing
 
5.2  
3.1  
8.3 
 
3.7  
3.6  
7.3 
Other
 
3.1  
—  
3.1 
 
2.7  
—  
2.7 
Margin loans
 
19.1  
—  
19.1 
 
18.0  
—  
18.0 
Total
$ 
71.6 $ 
54.2 $ 
125.8 
$ 
66.9 $ 
48.4 $ 
115.3 
At Dec. 31, 2024, our total lending-related exposure 
was $125.8 billion, an increase of 9% compared with 
Dec. 31, 2023, primarily reflecting higher exposure in 
the financial institutions and capital call financing 
portfolios and higher margin loans.  
Our financial institutions and commercial portfolios 
comprise our largest concentrated risk.  These 
portfolios comprised 49% of our total exposure at 
Dec. 31, 2024 and 46% at Dec. 31, 2023.  
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)
Dec. 31, 2024
Dec. 31, 2023
Loans
Unfunded
commitments
Total
exposure
% Inv.
grade
% due
<1 yr.
Loans
Unfunded
commitments
Total
exposure
Securities industry
$ 
2.3 $ 
20.3 $ 
22.6 
 100% 
 99% 
$ 
2.3 $ 
14.8 $ 
17.1 
Banks
 
8.9  
1.4  
10.3 
 85 
 95 
 
6.4  
1.4  
7.8 
Asset managers
 
1.8  
8.4  
10.2 
 96 
 74 
 
1.4  
8.0  
9.4 
Insurance
 
—  
4.2  
4.2 
 100 
 10 
 
0.1  
3.9  
4.0 
Government
 
—  
0.4  
0.4 
 100 
 50 
 
—  
0.2  
0.2 
Other
 
0.2  
0.5  
0.7 
 100 
 65 
 
0.3  
0.9  
1.2 
Total
$ 
13.2 $ 
35.2 $ 
48.4 
 96% 
 84% 
$ 10.5 $ 
29.2 $ 
39.7 
The financial institutions portfolio exposure was 
$48.4 billion at Dec. 31, 2024, an increase of 22% 
compared with Dec. 31, 2023, primarily reflecting 
higher exposure in the securities industry and banks 
portfolios.
Financial institution exposures are high-quality, with 
96% of the exposures meeting the investment grade 
equivalent criteria of our internal credit rating 
classification at Dec. 31, 2024.  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.  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.
The exposure to financial institutions is generally 
short-term, with 84% of the exposures expiring 
within one year.  At Dec. 31, 2024, 18% of the 
exposure to financial institutions had an expiration 
within 90 days, compared with 19% at Dec. 31, 2023.
Results of Operations (continued)
BNY 29

In addition, 67% of the financial institutions exposure 
is secured at Dec. 31, 2024.  For example, securities 
industry clients and asset managers often borrow 
against marketable securities held in custody.
At Dec. 31, 2024, the secured intraday credit 
provided to dealers in connection with their tri-party 
repo activity totaled $13.4 billion and was 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.  Secured intraday 
credit facilities represent 28% of the exposure in the 
financial institutions portfolio and are reviewed and 
reapproved annually.
The asset managers portfolio exposure is high-
quality, with 96% of the exposures meeting our 
investment grade equivalent ratings criteria as of Dec. 
31, 2024.  These exposures are generally short-term 
liquidity facilities, with the majority to regulated 
mutual funds. 
Our banks portfolio exposure primarily relates to our 
global trade finance.  These exposures are short-term 
in nature, with 95% due in less than one year.  The 
investment grade percentage of our banks exposure 
was 85% at Dec. 31, 2024, compared with 84% at 
Dec. 31, 2023.  Our non-investment grade exposures 
are primarily trade finance loans in Brazil. 
Commercial
The commercial portfolio is presented below.
Commercial portfolio exposure
Dec. 31, 2024
Dec. 31, 2023
(dollars in billions)
Loans
Unfunded
commitments
Total
exposure
% Inv.
grade
% due
<1 yr.
Loans
Unfunded
commitments
Total
exposure
Energy and utilities
$ 
0.2 $ 
4.1 $ 
4.3 
 95% 
 8% 
$ 
0.4 $ 
3.7 $ 
4.1 
Services and other
 
0.7  
3.5  
4.2 
 97 
 23 
 
1.2  
3.4  
4.6 
Manufacturing
 
0.5  
3.5  
4.0 
 99 
 18 
 
0.5  
3.6  
4.1 
Media and telecom
 
—  
0.8  
0.8 
 81 
 — 
 
—  
0.7  
0.7 
Total
$ 
1.4 $ 
11.9 $ 
13.3 
 96% 
 15% 
$ 
2.1 $ 
11.4 $ 
13.5 
The commercial portfolio exposure was $13.3 billion 
at Dec. 31, 2024, a decrease of 1% from Dec. 31, 
2023, primarily driven by lower exposure in the 
services and other portfolio, partially offset by higher 
exposure in the energy and utilities portfolio.
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.
Investment grade percentages
Dec. 31,
2024
2023
2022
Financial institutions
 96% 
 92% 
 95% 
Commercial
 96% 
 94% 
 95% 
Wealth management loans 
Our wealth management loan exposure was $9.4 
billion at Dec. 31, 2024, compared with $9.6 billion 
at Dec. 31, 2023.  Wealth management loans 
primarily consist of loans to high-net-worth 
individuals, a majority of which are secured by the 
customers’ investment management accounts or 
custody accounts.  
Wealth management mortgages
Our wealth management mortgage exposure was $9.1 
billion at Dec. 31, 2024, compared with $9.4 billion 
at Dec. 31, 2023.  Wealth management mortgages 
primarily consist of loans to high-net-worth 
individuals, which are secured by residential 
property.  Wealth management mortgages are 
primarily interest-only, adjustable-rate mortgages 
with a weighted-average loan-to-value ratio of 61% at 
origination.  Less than 1% of the mortgages were past 
due at Dec. 31, 2024.
At Dec. 31, 2024, the wealth management mortgage 
portfolio consisted of the following geographic 
concentrations:  California – 21%; New York – 14%; 
Florida – 11%; Massachusetts – 8%; and other – 
46%.
Results of Operations (continued)
30 BNY

Commercial real estate
The composition of the commercial real estate portfolio by asset class, including percentage secured, is presented 
below.
Composition of commercial real estate portfolio by asset class
Dec. 31, 2024
Dec. 31, 2023
Total
exposure
Percentage
secured (a)
Total
exposure
Percentage
secured (a)
(dollars in billions)
Residential
$ 
4.2 
 88% 
$ 
4.3 
 88% 
Office
 
2.4 
 75 
 
2.6 
 74 
Retail
 
0.7 
 58 
 
0.8 
 63 
Mixed-use
 
0.7 
 32 
 
0.8 
 31 
Hotels
 
0.6 
 33 
 
0.6 
 40 
Healthcare
 
0.7 
 43 
 
0.5 
 57 
Other
 
0.6 
 65 
 
0.6 
 71 
Total commercial real estate
$ 
9.9 
 71% 
$ 
10.2 
 73% 
(a) Represents the percentage of secured exposure in each asset class.
Our commercial real estate exposure totaled $9.9 
billion at Dec. 31, 2024 and $10.2 billion at Dec. 31, 
2023.  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, 2024, the unsecured portfolio consisted 
of real estate investment trusts (“REITs”) and real 
estate operating companies, which are both primarily 
investment grade.
At Dec. 31, 2024, our commercial real estate portfolio 
consisted of the following concentrations: New York 
metro – 34%; REITs and real estate operating 
companies – 29%; and other – 37%.
Lease financings
The lease financings portfolio exposure totaled $603 
million at Dec. 31, 2024 and $599 million at Dec. 31, 
2023.  At Dec. 31, 2024, all of leasing exposure was 
investment grade, or investment grade equivalent, and 
consisted of exposures backed by well-diversified 
assets, primarily real estate and large-ticket 
transportation equipment.  Assets are both domestic 
and foreign-based, with primary concentrations in 
Germany and the U.S.  
Other residential mortgages
The other residential mortgages portfolio primarily 
consists of 1-4 family residential mortgage loans and 
totaled $1.1 billion at Dec. 31, 2024 and $1.2 billion 
at Dec. 31, 2023.  
Overdrafts
Overdrafts primarily relate to custody and securities 
clearance clients and are generally repaid within two 
business days.
Capital call financing
Capital call financing includes loans to private equity 
funds that are secured by the fund investors’ capital 
commitments and the funds’ right to call capital.
Other loans
Other loans primarily include loans to consumers that 
are fully collateralized with equities, mutual funds 
and fixed-income securities.
Margin loans
Margin loan exposure of $19.1 billion at Dec. 31, 
2024 and $18.0 billion at Dec. 31, 2023 was 
collateralized with marketable securities.  Borrowers 
are required to maintain a daily collateral margin in 
excess of 100% of the value of the loan.  Margin 
loans included $8 billion at Dec. 31, 2024 and $7 
billion at Dec. 31, 2023 related to a term loan 
program that offers fully collateralized loans to 
broker-dealers. 
Results of Operations (continued)
BNY 31

Maturity of loan portfolio
The following table shows the maturity structure of our loan portfolio.
Maturity of loan portfolio at Dec. 31, 2024
Within
1 year
Between
1 and 5 years
Between
5 and 15 years
After
15 years
Total
(in millions)
Commercial
$ 
876 $ 
489 $ 
55 $ 
— $ 
1,420 
Commercial real estate
 
1,466  
4,509  
807  
—  
6,782 
Financial institutions
 
11,571  
1,596  
—  
—  
13,167 
Lease financings
 
87  
163  
353  
—  
603 
Wealth management loans
 
8,329  
194  
175  
—  
8,698 
Wealth management mortgages
 
—  
21  
361  
8,568  
8,950 
Other residential mortgages
 
—  
3  
131  
934  
1,068 
Overdrafts
 
3,519  
—  
—  
—  
3,519 
Capital call financing
 
4,025  
1,138  
—  
—  
5,163 
Other
 
3,062  
1  
—  
—  
3,063 
Margin loans
 
18,637  
500  
—  
—  
19,137 
Total
$ 
51,572 $ 
8,614 $ 
1,882 $ 
9,502 $ 
71,570 
Interest rate characteristic
The following table shows the interest rate characteristic of loans maturing after one year.
Interest rate characteristic of loan portfolio maturing > 1 year at Dec. 31, 2024
(in millions)
Fixed rates
Floating rates
Total
Commercial
$ 
56 $ 
488 $ 
544 
Commercial real estate
 
147  
5,169  
5,316 
Financial institutions
 
—  
1,596  
1,596 
Lease financings
 
516  
—  
516 
Wealth management loans
 
110  
259  
369 
Wealth management mortgages
 
3,770  
5,180  
8,950 
Other residential mortgages
 
1,036  
32  
1,068 
Capital call financing
 
—  
1,138  
1,138 
Other
 
—  
1  
1 
Margin Loans
 
—  
500  
500 
Total
$ 
5,635 $ 
14,363 $ 
19,998 
Results of Operations (continued)
32 BNY

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 and overdrafts associated with our custody and securities clearance businesses.  
The following table presents the changes in our allowance for credit losses.
Allowance for credit losses activity
2024
2023
(dollars in millions)
Beginning balance of allowance for credit losses
$ 
414 
$ 
292 
Provision for credit losses
 
70 
 
119 
Charge-offs:
Loans:
Commercial real estate
 
(82) 
 
— 
Wealth management mortgages
 
(1) 
 
— 
Other residential mortgages
 
(1) 
 
(3) 
Other financial instruments
 
(9) 
 
(2) 
Total charge-offs
 
(93) 
 
(5) 
Recoveries:
Loans:
Commercial 
 
— 
 
1 
Other residential mortgages
 
1 
 
2 
Other
 
— 
 
5 
Total recoveries
 
1 
 
8 
Net (charge-offs) recoveries
 
(92) 
 
3 
Ending balance of allowance for credit losses
$ 
392 
$ 
414 
Allowance for loan losses
$ 
294 
$ 
303 
Allowance for lending-related commitments
 
72 
 
87 
Allowance for financial instruments (a)
 
26 
 
24 
Total allowance for credit losses
$ 
392 
$ 
414 
Total loans
$ 
71,570 
$ 
66,879 
Average loans outstanding
$ 
68,141 
$ 
64,096 
Net (charge-offs) recoveries of loans to average loans outstanding
 (0.14) %
 — %
Net (charge-offs) recoveries of loans to total allowance for loan losses and lending-related commitments
 (25.14) 
 0.77 
Allowance for loan losses as a percentage of total loans
 0.41 
 0.45 
Allowance for loan losses and lending-related commitments as a percentage of total loans
 0.51 
 0.58 
Net (charge-offs) to average loans by loan category (b):
Commercial real estate
 (1.19) %
N/A
Net (charge-offs) during the year
$ 
(82) 
N/A
Average loans outstanding
$ 
6,915 
N/A
Wealth management mortgages
 (0.01) %
N/A
Net (charge-offs) during the year
$ 
(1) 
N/A
Average loans outstanding (b)
$ 
9,062 
N/A
Other residential mortgages
N/A
 (0.11) %
Net (charge-offs) during the year
N/A
$ 
(1) 
Average loans outstanding (b)
N/A
$ 
908 
(a) Includes allowance for credit losses on federal funds sold and securities purchased under resale agreements, available-for-sale 
securities, held-to-maturity securities, accounts receivable, cash and due from banks and interest-bearing deposits with banks.
(b) Average loans based on month-end balances.
N/A – Not applicable. 
The provision for credit losses was $70 million in 
2024, primarily driven by reserve increases related to 
commercial real estate exposure and changes in the 
macroeconomic forecast.
The allowance for loan losses and allowance for 
lending-related commitments represent 
management’s estimate of lifetime expected losses in 
our credit portfolio.  This evaluation process is 
subject to numerous estimates and judgments.  To the 
extent actual results differ from forecasts or 
Results of Operations (continued)
BNY 33

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 
loans and lending-related commitments as presented 
below.
Allocation of allowance for loan losses and 
lending-related commitments (a)
Dec. 31,
2024
2023
(dollars in millions)
$
%
$
%
Commercial real estate
$ 315 
 86% $ 325 
 83% 
Commercial
 
20 
 5 
 
27 
 7 
Financial institutions
 
19 
 5 
 
19 
 4 
Wealth management 
mortgages
 
6 
 1 
 
9 
 2 
Other residential mortgages  
2 
 1 
 
4 
 1 
Capital call financing
 
3 
 1 
 
4 
 1 
Wealth management loans
 
1 
 1 
 
1 
 1 
Lease financings
 
— 
 — 
 
1 
 1 
Total
$ 366 
 100% $ 390 
 100% 
(a) The allowance allocated to margins loans, overdrafts and 
other loans was insignificant at both Dec. 31, 2024 and Dec. 
31, 2023.  We have rarely suffered a loss on these types of 
loans.
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. 
Nonperforming assets
The table below presents our nonperforming assets.
Nonperforming assets
Dec. 31,
(dollars in millions)
2024
2023
Nonperforming loans:
Commercial real estate
$ 
143 
$ 
189 
Other residential mortgages
 
19 
 
24 
Wealth management mortgages
 
15 
 
19 
Total nonperforming loans
 
177 
 
232 
Other assets owned
 
2 
 
5 
Total nonperforming assets
$ 
179 
$ 
237 
Nonperforming assets ratio
 0.25% 
 0.35% 
Allowance for loan losses/
nonperforming loans
 166.1 
 130.6 
Allowance for loan losses/
nonperforming assets
 164.2 
 127.8 
Allowance for loan losses and lending-
related commitments/nonperforming 
loans
 206.8 
 168.1 
Allowance for loan losses and lending-
related commitments/nonperforming 
assets
 204.5 
 164.6 
Nonperforming assets decreased $58 million 
compared with Dec. 31, 2023, primarily reflecting the 
impact of nonperforming commercial real estate loans 
that were charged off in 2024.
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 the businesses in 
the Securities Services, Market and Wealth Services 
and Investment and Wealth Management segments 
and we rely on those deposits as a low-cost and stable 
source of funding.
Total deposits were $289.5 billion at Dec. 31, 2024, 
an increase of 2%, compared with $283.7 billion at 
Dec. 31, 2023.  The increase primarily reflects higher 
interest-bearing deposits in U.S. offices, partially 
offset by lower interest-bearing deposits in non-U.S. 
offices.
Noninterest-bearing deposits were $58.3 billion at 
Dec. 31, 2024 and Dec. 31, 2023.  Interest-bearing 
deposits were primarily demand deposits and totaled 
$231.3 billion at Dec. 31, 2024, compared with 
$225.4 billion at Dec. 31, 2023.  
The aggregate amount of deposits by foreign 
customers in domestic offices was $58.8 billion at 
Dec. 31, 2024 and $55.1 billion at Dec. 31, 2023.  
Deposits in non-U.S. offices totaled $95.6 billion at 
Dec. 31, 2024 and $96.6 billion at Dec. 31, 2023.  
These deposits were primarily overnight deposits.
Uninsured deposits are the portion of U.S. office 
deposits accounts that exceed the FDIC insurance 
limit.  Uninsured deposits in U.S. office deposit 
accounts are generally demand deposits and totaled 
$168.9 billion at Dec. 31, 2024 and $168.4 billion at 
Dec. 31, 2023.  Our uninsured U.S. office deposits 
accounts reflect the amounts disclosed in our 
regulatory reports, adjusted to exclude intercompany 
deposit balances.
Results of Operations (continued)
34 BNY

The following table presents the amount of uninsured 
U.S. and Non-U.S. office time deposits disaggregated 
by time remaining until maturity.
Uninsured time deposits at Dec. 31, 2024
(in millions)
U.S.
Non-U.S.
Less than 3 months
$ 
636 $ 
1,062 
3 to 6 months
 
105  
6 
6 to 12 months
 
65  
25 
Over 12 months
 
2  
— 
Total
$ 
808 $ 
1,093 
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 short-term borrowings, for example, 
securities sold under repurchase agreements, require 
the delivery of securities as collateral.
Federal funds purchased and securities sold under 
repurchase agreements include repurchase agreement 
activity with the Fixed Income Clearing Corporation 
(“FICC”), where we record interest expense on a 
gross basis, but the ending and average balances 
reflect the impact of offsetting under enforceable 
netting agreements.  This activity primarily relates to 
government securities collateralized resale and 
repurchase agreements executed with clients that are 
novated to and settle with the FICC. 
Payables to customers and broker-dealers represent 
funds awaiting reinvestment and short sale proceeds 
payable on demand.  Payables to customers and 
broker-dealers are driven by customer trading activity 
and market volatility. 
The Bank of New York Mellon issues commercial 
paper that matures within 397 days from the date of 
issue and is not redeemable prior to maturity or 
subject to voluntary prepayment.  
Other borrowed funds primarily include borrowings 
from the Federal Home Loan Bank, overdrafts of sub-
custodian account balances in our Securities Services 
businesses, and borrowings under lines of credit by 
our Pershing subsidiaries.  Overdrafts typically relate 
to timing differences for settlements.  
Liquidity and dividends
BNY 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 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 into cash, the 
inability to hold or raise cash, low overnight deposits, 
deposit run-off or contingent liquidity events. 
Changes in economic conditions or exposure to 
credit, market, operational, legal and reputational 
risks also can affect BNY’s liquidity risk profile and 
are considered in our liquidity risk framework.  For 
additional information, see “Risk Management – 
Liquidity Risk.”
The Parent’s policy is to have access to sufficient 
unencumbered cash and cash equivalents at each 
quarter-end to cover maturities and other 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.  
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 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 to meet its intraday obligations under 
normal and reasonably severe stressed conditions.
Results of Operations (continued)
BNY 35

We define available funds for internal liquidity management purposes as cash and due from banks, interest-bearing 
deposits with the Federal Reserve and other central banks, interest-bearing deposits with banks and federal funds 
sold and securities purchased under resale agreements.  The following table presents our total available funds at 
period end and on an average basis.  
Available funds
Dec. 31, 
2024
Dec. 31, 
2023
Average
(dollars in millions)
2024
2023
2022
Cash and due from banks
$ 4,178 
$ 
4,922 
$ 5,383 
$ 
5,287 
$ 
5,542 
Interest-bearing deposits with the Federal Reserve and other central 
banks
 89,546 
 111,550 
 99,986 
 103,904 
 
97,442 
Interest-bearing deposits with banks
 
9,612 
 
12,139 
 10,991 
 
13,620 
 
16,826 
Federal funds sold and securities purchased under resale agreements
 41,146 
 
28,900 
 31,306 
 
26,077 
 
24,953 
Total available funds
$ 144,482 
$ 157,511 
$ 147,666 
$ 148,888 
$ 144,763 
Total available funds as a percentage of total assets
 35% 
 38% 
 36% 
 37% 
 34% 
Total available funds were $144.5 billion at Dec. 31, 
2024, compared with $157.5 billion at Dec. 31, 2023.  
The decrease was primarily due to lower interest-
bearing deposits with the Federal Reserve and other 
central banks and interest-bearing deposits with 
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, other borrowed funds 
and commercial paper, were $20.4 billion for 2024 
and $25.0 billion for 2023.  The decrease primarily 
reflects lower federal funds purchased and securities 
sold under repurchase agreements and lower trading 
liabilities partially offset by higher commercial paper.
Average interest-bearing domestic deposits were 
$141.3 billion for 2024 and $123.5 billion for 2023.  
Average foreign deposits, primarily from our 
European-based businesses included in the Securities 
Services and Market and Wealth Services segments, 
were $92.9 billion for 2024, compared with $88.8 
billion for 2023.  The changes primarily reflect client 
activity.
Average payables to customers and broker-dealers 
were $12.7 billion for 2024 and $14.4 billion for 
2023.  Payables to customers and broker-dealers are 
driven by customer trading activity and market 
volatility.
Average long-term debt was $31.8 billion for 2024 
and $31.0 billion for 2023.
Average noninterest-bearing deposits decreased to 
$49.5 billion for 2024 from $59.2 billion for 2023, 
primarily reflecting client activity.
A significant reduction of client activity in our 
Securities Services and Market and Wealth Services 
business segments would reduce our access to 
deposits.  See “Asset/liability management” for 
additional factors that could impact our deposit 
balances.
Sources of liquidity
The Parent’s 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”). 
Results of Operations (continued)
36 BNY

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, 2024
  
Moody’s
S&P
Fitch
DBRS
Parent:
 
Long-term senior debt
Aa3
A
AA-
AA
Subordinated debt
A2
A-
A
AA (low)
Preferred stock
Baa1
BBB
BBB+
A 
Outlook – Parent
Stable
Stable
Stable
Stable
The Bank of New York Mellon:
Long-term senior debt
Aa1
AA-
AA
AA (high)
Subordinated debt
NR
A
NR
NR
Long-term deposits
Aa1
AA-
AA+
AA (high)
Short-term deposits
P-1
A-1+
F1+
R-1 (high)
Commercial paper
P-1
A-1+
F1+
R-1 (high)
BNY Mellon, N.A.:
Long-term senior debt
Aa1 (a)
AA-
AA (a)
AA (high)
Long-term deposits
Aa1
AA-
AA+
AA (high)
Short-term deposits
P-1
A-1+
F1+
R-1 (high)
Outlook – Banks
Stable
(multiple) (b)
Stable
Stable
Stable
(a) Represents senior debt issuer default rating.
(b) Stable outlook on long-term deposits ratings.  Negative outlook on long-term senior debt ratings.  Negative outlook on senior unsecured 
rating for The Bank of New York Mellon.
NR – Not rated.
In November 2024, Moody’s Ratings (“Moody’s”) 
upgraded BNY’s issuer and senior unsecured ratings 
to Aa3 from A1.  The long-term counterparty risk 
ratings were upgraded to Aa1 from Aa2 for The Bank 
of New York Mellon and for BNY Mellon, N.A.  The 
long-term issuer and senior unsecured ratings were 
upgraded to Aa1 from Aa2 for The Bank of New 
York Mellon, and the long-term issuer rating was 
upgraded to Aa1 from Aa2 for BNY Mellon, N.A.  
Moody’s affirmed all other long-term and short-term 
ratings and assessments for BNY, The Bank of New 
York Mellon and BNY Mellon N.A.  The outlooks on 
BNY’s issuer and senior unsecured ratings have been 
changed to stable from positive following the upgrade 
of these ratings. 
Long-term debt totaled $30.9 billion at Dec. 31, 2024 
and $31.3 billion at Dec. 31, 2023.  Maturities and 
redemptions of $6.0 billion and a decrease in the fair 
value of hedged long-term debt were partially offset 
by issuances of $5.8 billion.  The Parent has $3.3 
billion of long-term debt that will mature in 2025.
The following table presents the long-term debt 
issued in 2024.
Debt issuances
(in millions)
2024
5.060% fixed-to-floating callable senior notes due 2032
$ 1,100 
5.188% fixed-to-floating callable senior notes due 2035
 
1,000 
4.975% fixed-to-floating callable senior notes due 2030
 
1,000 
5.225% fixed-to-floating callable senior notes due 2035
 
750 
4.890% fixed-to-floating callable senior notes due 2028
 
600 
5.606% fixed-to-floating callable senior notes due 2039
 
500 
SOFR + 45 bps callable senior bank notes due 2026
 
500 
SOFR + 83 bps callable senior notes due 2028
 
300 
Total debt issuances
$ 5,750 
In February 2025, the Parent issued $1.25 billion of 
fixed-to-floating rate callable senior notes maturing in 
2031.  The annual fixed interest rate is 4.942% from 
issuance to, but excluding, Feb. 11, 2030, and then an 
annual interest rate of the compounded secured 
overnight financing rate (“SOFR”) plus 88.7 basis 
points.  
The Bank of New York Mellon may issue notes and 
CDs.  At Dec. 31, 2024 and Dec. 31, 2023, $1.0 
billion and $1.3 billion, respectively, of notes were 
outstanding.  At Dec. 31, 2024 and Dec. 31, 2023, 
Results of Operations (continued)
BNY 37

$1.1 billion and $397 million of CDs were 
outstanding, respectively.  
The Bank of New York Mellon also issues 
commercial paper that matures within 397 days from 
the date of issue and is not redeemable prior to 
maturity or subject to voluntary prepayment.  There 
was $301 million of commercial paper outstanding at 
Dec. 31, 2024.  There was no commercial paper 
outstanding at Dec. 31, 2023.  The average 
commercial paper outstanding was $1.2 billion and 
$5 million for 2024 and 2023, respectively. 
Subsequent to Dec. 31, 2024, our U.S. bank 
subsidiaries could declare dividends to the Parent of 
approximately $82 million, without the need for a 
regulatory waiver.  In addition, at Dec. 31, 2024, non-
bank subsidiaries of the Parent had liquid assets of 
approximately $3.8 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 19 of the Notes to 
Consolidated Financial Statements.
Pershing LLC has one uncommitted line of credit in 
place for liquidity purposes which is guaranteed by 
the Parent for $300 million.  Average borrowings 
under this line were less than $1 million in 2024.  
Pershing Limited, an indirect UK-based subsidiary of 
BNY, has two separate uncommitted lines of credit 
amounting to $247 million in aggregate.  Average 
borrowings under these lines were less than 
$1 million, in aggregate, in 2024.
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’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 73% of total 
revenue in 2024, and the dividend capacity of our 
banking subsidiaries.  Our double leverage ratio was 
119.7% at Dec. 31, 2024 and 120.5% at Dec. 31, 
2023, and within the range targeted by management.  
Uses of funds
The Parent’s major uses of funds are repurchases of 
common stock, payment of dividends, principal and 
interest payments on its borrowings, acquisitions and 
additional investments in its subsidiaries.
In 2024, we paid $1.5 billion in dividends on our 
common and preferred stock.  Our common stock 
dividend payout ratio was 31% for 2024. 
In 2024, we repurchased 48.9 million common shares 
at an average price of $62.70 per common share for a 
total cost of $3.1 billion.  
Liquidity coverage ratio (“LCR”)
U.S. regulators have established an LCR that requires 
certain banking organizations, including BNY, 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 BNY’s consolidated 
HQLA at Dec. 31, 2024, and the average HQLA and 
average LCR for the fourth quarter of 2024.
Consolidated HQLA and LCR
Dec. 31, 
2024
Sept. 30, 
2024
(dollars in billions)
Cash (a)
$ 
89 
$ 
102 
Securities (b)
 
93 
 
97 
Total consolidated HQLA (c)
$ 182 
$ 
199 
Total consolidated HQLA – average (c) $ 187 
$ 
193 
Average consolidated LCR
 115% 
 116% 
(a) Primarily includes cash on deposit with central banks.
(b) Primarily includes securities of U.S. government-sponsored 
enterprises, U.S. Treasury, sovereigns and U.S. agencies.
(c) Consolidated HQLA presented before adjustments.  After 
haircuts and the impact of trapped liquidity, consolidated 
HQLA totaled $129 billion at Dec. 31, 2024 and $135 billion 
at Sept. 30, 2024, and averaged $128 billion for the fourth 
quarter of 2024 and $131 billion for the third quarter of 
2024.
BNY and each of our affected domestic bank 
subsidiaries were compliant with the U.S. LCR 
requirements of at least 100% throughout 2024. 
Results of Operations (continued)
38 BNY

Net stable funding ratio (“NSFR”)
The NSFR is a liquidity requirement applicable to 
large U.S. banking organizations, including BNY.  
The NSFR is expressed as a ratio of the available 
stable funding to the required stable funding amount 
over a one-year horizon.  Our average consolidated 
NSFR was 132% for the fourth quarter of 2024 and 
third quarter of 2024.  
BNY and each of our affected domestic bank 
subsidiaries were compliant with the NSFR 
requirement of at least 100% throughout the fourth 
quarter of 2024. 
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 $687 
million in 2024, compared with $5.9 billion in 2023.  
In 2024, net cash provided by operating activities 
primarily resulted from earnings, partially offset by 
changes in trading assets and liabilities.  In 2023, net 
cash provided by operating activities primarily 
resulted from earnings and changes in accruals and 
other, net.
Net cash used for investing activities was $9.5 billion 
in 2024, compared with $5.8 billion in 2023.  In 
2024, net cash used for investing activities primarily 
reflects changes in federal funds sold and securities 
purchased under resale agreements, a net increase in 
the securities portfolio and the net change in loans, 
partially offset by changes in interest-bearing deposits 
with the Federal Reserve and other central banks.  In 
2023, net cash used for investing activities primarily 
reflects changes in interest-bearing deposits with the 
Federal Reserve and other central banks and changes 
in federal funds sold and securities purchased under 
resale agreements, partially offset by a net decrease in 
the securities portfolio. 
Net cash provided by financing activities was $6.3 
billion in 2024, compared with net cash used for 
financing activities of $3.5 billion in 2023.  In 2024, 
net cash provided by financing activities primarily 
reflects changes in deposits and issuances of long-
term debt, partially offset by repayments of long-term 
debt and common stock repurchases.  In 2023, net 
cash used for financing activities primarily reflects 
repayments of long-term debt, changes in payables to 
customers and broker-dealers and common stock 
repurchases, partially offset by issuances of long-term 
debt and changes in deposits.
Capital
Capital data
(dollars in millions, except per share amounts; common shares in thousands)
2024
2023
At Dec. 31:
BNY shareholders’ equity to total assets ratio
 9.9% 
 9.9% 
BNY common shareholders’ equity to total assets ratio
 8.9% 
 8.9% 
Total BNY shareholders’ equity
$ 41,318 
$ 40,770 
Total BNY common shareholders’ equity
$ 36,975 
$ 36,427 
BNY tangible common shareholders’ equity – Non-GAAP (a)
$ 19,412 
$ 19,174 
Book value per common share
$ 
51.52 
$ 
47.97 
Tangible book value per common share – Non-GAAP (a)
$ 
27.05 
$ 
25.25 
Closing stock price per common share
$ 
76.83 
$ 
52.05 
Market capitalization
$ 55,139 
$ 39,524 
Common shares outstanding
 717,680 
 759,344 
Full-year:
Cash dividends per common share
$ 
1.78 
$ 
1.58 
Common dividend payout ratio 
 31% 
 41% 
Common dividend yield
 2.3% 
 3.0% 
(a) See “Supplemental Information – Explanation of GAAP and Non-GAAP financial measures” beginning on page 115 for the 
reconciliation of these Non-GAAP measures.
Results of Operations (continued)
BNY 39

The Bank of New York Mellon Corporation’s total 
shareholders’ equity increased to $41.3 billion at Dec. 
31, 2024 from $40.8 billion at Dec. 31, 2023.  The 
increase primarily reflects earnings and an increase in 
additional paid-in capital, partially offset by common 
stock repurchases and dividend payments.
The unrealized loss (after-tax) on our available-for-
sale securities portfolio, net of hedges, included in 
accumulated other comprehensive income was $1.2 
billion at Dec. 31, 2024, compared with $1.6 billion 
at Dec. 31, 2023.  The improvement in the net 
unrealized loss, including the impact of related 
hedges, primarily reflects securities moving closer to 
maturity.
We repurchased 48.9 million common shares at an 
average price of $62.70 per common share for a total 
of $3.1 billion in 2024.  
In January 2023, we announced a share repurchase 
program approved by our Board of Directors 
providing for the repurchase of up to $5.0 billion of 
common shares beginning Jan. 1, 2023.  This new 
share repurchase plan replaced all previously 
authorized share repurchase plans.
In April 2024, we announced a new authorization 
providing for the repurchase of $6.0 billion of 
common shares in addition to any remaining capacity 
under the existing January 2023 authorization.
In July 2024, our Board of Directors approved a 12% 
increase in the quarterly cash dividend on common 
stock, from $0.42 to $0.47 per share.  We began 
paying the increased quarterly cash dividend in the 
third quarter of 2024. 
Capital adequacy
Regulators establish certain levels of capital for bank 
holding companies (“BHCs”) and banks, including 
BNY and our bank subsidiaries, in accordance with 
established quantitative measurements.  For the 
Parent to maintain its status as a financial holding 
company (“FHC”), our U.S. bank subsidiaries and 
BNY must, among other things, qualify as “well 
capitalized.”  As of Dec. 31, 2024 and Dec. 31, 2023, 
BNY 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 and Ancillary Regulatory 
Requirements” and “Risk Factors – Capital and 
Liquidity 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.”  
Results of Operations (continued)
40 BNY

The table below presents our consolidated and largest bank subsidiary regulatory capital ratios.
Consolidated and largest bank subsidiary regulatory capital ratios
Dec. 31, 2024
Dec. 31, 
2023
Well 
capitalized
Minimum 
required
Capital
ratios
Capital
ratios
(a)
Consolidated regulatory capital ratios: (b)
Advanced Approaches:
CET1 ratio
N/A (c)
 8.5% 
 11.7% 
 11.5% 
Tier 1 capital ratio 
 6% 
 10 
 14.4 
 14.2 
Total capital ratio 
 10 
 12 
 15.3 
 14.9 
Standardized Approach:
CET1 ratio
N/A (c)
 8.5% 
 11.2% 
 11.9% 
Tier 1 capital ratio 
 6% 
 10 
 13.7 
 14.6 
Total capital ratio 
 10 
 12 
 14.8 
 15.6 
Tier 1 leverage ratio
N/A (c)
 4 
 5.7 
 6.0 
SLR (d)
N/A (c)
 5 
 6.5 
 7.3 
The Bank of New York Mellon regulatory capital ratios: (b)(e)
CET1 ratio
 6.5% 
 7% 
 16.1% 
 16.2% 
Tier 1 capital ratio
 8 
 8.5 
 16.1 
 16.2 
Total capital ratio
 10 
 10.5 
 16.3 
 16.3 
Tier 1 leverage ratio
 5 
 4 
 6.3 
 6.6 
SLR (d)
 6 
 3 
 7.6 
 8.5 
(a) Minimum requirements for Dec. 31, 2024 include minimum thresholds plus currently applicable buffers.  The U.S. global systemically 
important banks (“G-SIB”) surcharge of 1.5% is subject to change.  The countercyclical capital buffer is currently set to 0%.  The stress 
capital buffer (“SCB”) requirement is 2.5%, equal to the regulatory minimum for Standardized Approach capital ratios.  
(b) 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.   
(c) The Federal Reserve’s regulations do not establish well capitalized thresholds for these measures for BHCs. 
(d) The SLR is based on Tier 1 capital and total leverage exposure, which includes certain off-balance sheet exposures.  
(e) The Bank of New York Mellon’s 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 Dec. 31, 2024 was the Standardized Approach for the CET1 and Tier 1 capital ratios 
and the Advanced Approaches for the Total capital ratio, and for Dec. 31, 2023 was the Advanced Approaches.
N/A - Not applicable.
Our CET1 ratio determined under the Standardized 
Approach was 11.2% at Dec. 31, 2024 and 11.5% at 
Dec. 31, 2023 under the Advanced Approaches.  The 
decrease was primarily driven by capital returned 
through common stock repurchases and dividends 
and higher RWAs, partially offset by capital 
generated through earnings.  
The Tier 1 leverage ratio was 5.7% at Dec. 31, 2024, 
compared with 6.0% at Dec. 31, 2023.  The decrease 
was driven by higher average assets, partially offset 
by an increase in capital.  
Risk-based capital ratios vary depending on the size 
of the balance sheet at period end and the levels and 
types of investments in assets, and leverage ratios 
vary based on the average size of the balance sheet 
over the quarter.  The balance sheet size fluctuates 
from period to period 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.
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 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.
Under the Advanced Approaches, 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 
Results of Operations (continued)
BNY 41

result external losses have impacted and could in the 
future impact the amount of capital that we are 
required to hold.
The following table presents our capital components 
and RWAs.
Capital components and risk-
weighted assets
Dec. 31,
(in millions)
2024
2023
CET1:
Common shareholders’ equity
$ 36,975 $ 36,427 
Adjustments for:
Goodwill and intangible assets (a)
 
(17,563)  
(17,253) 
Net pension fund assets
 
(333)  
(297) 
Embedded goodwill
 
(254)  
(275) 
Deferred tax assets
 
(62)  
(62) 
Other
 
(4)  
(6) 
Total CET1
 
18,759  
18,534 
Other Tier 1 capital:
Preferred stock
 
4,343  
4,343 
Other
 
(63)  
(14) 
Total Tier 1 capital
$ 23,039 $ 22,863 
Tier 2 capital:
Subordinated debt
$ 
1,398 $ 
1,148 
Allowance for credit losses
 
392  
414 
Other
 
(11)  
(11) 
Total Tier 2 capital – Standardized 
Approach
 
1,779  
1,551 
Excess of expected credit losses
 
109  
85 
Less: Allowance for credit losses
 
392  
414 
Total Tier 2 capital – Advanced 
Approaches
$ 
1,496 $ 
1,222 
Total capital:
Standardized Approach
$ 24,818 $ 24,414 
Advanced Approaches
$ 24,535 $ 24,085 
Risk-weighted assets:
Standardized Approach
$ 167,786 $ 156,178 
Advanced Approaches:
Credit Risk
$ 90,076 $ 87,223 
Market Risk
 
4,808  
3,380 
Operational Risk
 
65,588  
70,925 
Total Advanced Approaches
$ 160,472 $ 161,528 
Average assets for Tier 1 leverage 
ratio
$ 402,069 $ 383,705 
Total leverage exposure for SLR
$ 353,523 $ 313,555 
(a) Reduced by deferred tax liabilities associated with 
intangible assets and tax-deductible goodwill.
The table below presents the factors that impacted 
CET1 capital.
CET1 generation
2024
(in millions)
CET1 – Beginning of period
$ 
18,534 
Net income applicable to common shareholders of 
The Bank of New York Mellon Corporation
 
4,336 
Goodwill and intangible assets, net of related 
deferred tax liabilities
 
(310) 
Gross CET1 generated
 
4,026 
Capital deployed:
Common stock repurchases
 
(3,064) 
Common stock dividends (a)
 
(1,348) 
Total capital returned
 
(4,412) 
Other comprehensive gain (loss):
Unrealized gain on assets available-for-sale
 
429 
Foreign currency translation
 
(189) 
Unrealized (loss) on cash flow hedges
 
(6) 
Defined benefit plans
 
3 
Total other comprehensive gain
 
237 
Additional paid-in capital (b)
 
413 
Other additions (deductions):
Net pension fund assets
 
(36) 
Embedded goodwill
 
21 
Other
 
(24) 
Total other (deductions)
 
(39) 
Net CET1 generated
 
225 
CET1 – End of period
$ 
18,759 
(a) Includes dividend-equivalents on share-based awards. 
(b) Primarily related to stock awards and stock issued for 
employee benefit plans.
The following table shows the impact on the 
consolidated capital ratios at Dec. 31, 2024 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, 2024
Increase or decrease of
(in basis points)
$100 million
in common
equity
$1 billion in RWA, 
quarterly average 
assets or total 
leverage exposure
CET1:
Standardized Approach
6 bps
7 bps
Advanced Approaches
6
7
Tier 1 capital:
Standardized Approach
6
8
Advanced Approaches
6
9
Total capital:
Standardized Approach
6
9
Advanced Approaches
6
10
Tier 1 leverage
2
1
SLR
3
2
Results of Operations (continued)
42 BNY

Stress capital buffer
In July 2023, the Federal Reserve announced that 
BNY’s SCB requirement would remain at 2.5%, 
equal to the regulatory floor, for the period from Oct. 
1, 2023 through Sept. 30, 2024.  The SCB replaced 
the static 2.5% capital conservation buffer for 
Standardized Approach capital ratios for 
Comprehensive Capital Analysis and Review 
(“CCAR”) BHCs.  The SCB does not apply to bank 
subsidiaries, which remain subject to the static 2.5% 
capital conservation buffer.  In August 2024, the 
Federal Reserve announced that BNY’s SCB 
requirement would remain at 2.5%, equal to the 
regulatory floor, for the period from Oct. 1, 2024 
through Sept. 30, 2025.  See “Supervision and 
Regulation” for additional information. 
The SCB final rule generally eliminates the 
requirement for prior approval of common stock 
repurchases in excess of the distributions in a firm’s 
capital plan, provided that such distributions are 
consistent with applicable capital requirements and 
buffers, including the SCB.  
Total Loss-Absorbing Capacity (“TLAC”)
The following summarizes the minimum 
requirements for BNY’s external TLAC and external 
long-term debt (“LTD”) ratios, plus currently 
applicable buffers. 
As a % of RWAs (a)
As a % of total 
leverage 
exposure
Eligible external 
TLAC ratios
Regulatory minimum of 
18% plus a buffer (b) 
equal to the sum of 
2.5%, the method 1
 G-SIB surcharge 
(currently 1%), and the 
countercyclical capital 
buffer, if any
Regulatory 
minimum of 
7.5% plus a 
buffer (c) equal 
to 2%
Eligible external 
LTD ratios
Regulatory minimum of 
6% plus the greater of 
the method 1 or method 
2 G-SIB surcharge 
(currently 1.5%)
4.5%
(a) RWA is the greater of the Standardized Approach and 
Advanced Approaches. 
(b) Buffer to be met using only CET1. 
(c) Buffer to be met using only Tier 1 capital.
External TLAC consists of the Parent’s Tier 1 capital 
and eligible unsecured LTD issued by it that has a 
remaining term to maturity of at least one year and 
satisfies certain other conditions.  Eligible LTD 
consists of the unpaid principal balance of eligible 
unsecured debt securities, subject to haircuts for 
amounts due to be paid within two years, that satisfy 
certain other conditions.  Debt issued prior to Dec. 
31, 2016 has been permanently grandfathered to the 
extent these instruments otherwise would be 
ineligible only due to containing impermissible 
acceleration rights or being governed by foreign law. 
The following table presents our external TLAC and 
external LTD ratios. 
TLAC and LTD ratios
Dec. 31, 2024
Minimum
required
Minimum 
ratios
with buffers
Ratios
Eligible external TLAC:
As a percentage of RWA
 18.0% 
 21.5% 
 30.2% 
As a percentage of total 
leverage exposure
 7.5% 
 9.5% 
 14.3% 
Eligible external LTD:
As a percentage of RWA
 7.5% 
N/A
 15.3% 
As a percentage of total 
leverage exposure
 4.5% 
N/A
 7.3% 
N/A – Not applicable.
If BNY maintains risk-based ratio or leverage TLAC 
measures above the minimum required level, but with 
a risk-based ratio or leverage below the minimum 
level with buffers, we will face constraints on 
dividends, equity repurchases and discretionary 
executive compensation based on the amount of the 
shortfall and eligible retained income.  
Results of Operations (continued)
BNY 43

Issuer purchases of equity securities
Share repurchases – fourth quarter of 2024
Total shares 
repurchased as
 part of a publicly 
announced plan 
or program
Maximum approximate dollar 
value of shares that may yet 
be purchased under the 
publicly announced plans or 
programs at Dec. 31, 2024
(dollars in millions, except per share amounts; 
common shares in thousands)
Total shares
repurchased
Average price
per share
October 2024
 
3,087 
$ 
76.39 
 
3,087 
$ 
5,846 
November 2024
 
4,654 
 
78.11 
 
4,654 
 
5,483 
December 2024
 
1,857 
 
81.16 
 
1,857 
 
5,332 
Fourth quarter of 2024 (a)
 
9,598 
$ 
78.15 
 
9,598 
$ 
5,332 (b)
(a) Includes 40 thousand shares repurchased at a purchase price of $3 million from employees, primarily in connection with the employees’ 
payment of taxes upon the vesting of restricted stock.  The average price of open market share repurchases was $78.15.
(b) Represents the maximum value of the shares to be repurchased under the share repurchase plan and includes shares repurchased in 
connection with employee benefit plans.
In January 2023, we announced a share repurchase 
program approved by our Board of Directors 
providing for the repurchase of up to $5.0 billion of 
common shares beginning Jan. 1, 2023.  This new 
share repurchase plan replaced all previously 
authorized share repurchase plans.
In April 2024, we announced a new authorization 
providing for the repurchase of $6.0 billion of 
common shares in addition to any remaining capacity 
under the existing January 2023 authorization. 
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.  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 limitations and considerations.
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 into account the potential 
variability of market liquidity; and
•
Previous moves in market risk factors may not 
produce accurate predictions of all future market 
moves.
See Note 23 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.  
VaR (a)
2024
Dec. 31, 
2024
(in millions)
Average
Minimum Maximum
Interest rate
$ 
2.7 $ 
1.9 $ 
4.6 $ 
2.6 
Foreign exchange  
2.2  
1.6  
3.0  
2.0 
Equity
 
0.1  
—  
1.0  
0.1 
Credit
 
1.3  
0.9  
1.9  
1.5 
Diversification
 
(4.4) 
N/M
N/M  
(4.8) 
Overall portfolio
 
1.9  
1.4  
3.0  
1.4 
Results of Operations (continued)
44 BNY

VaR (a)
2023
Dec. 31, 
2023
(in millions)
Average
Minimum
Maximum
Interest rate
$ 
3.2 $ 
1.9 $ 
7.6 $ 
2.6 
Foreign exchange  
2.9  
2.0  
5.7  
2.9 
Equity
 
0.2  
—  
1.5  
0.1 
Credit
 
1.5  
0.7  
3.5  
1.3 
Diversification
 
(5.0) 
N/M
N/M  
(4.7) 
Overall portfolio
 
2.8  
1.3  
8.9  
2.2 
(a)
VaR exposure does not include the impact of the Company’s 
consolidated investment management funds and seed capital 
investments.
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 are predominantly driven 
by interest rate levels.  These instruments include, but 
are not limited to, U.S. Treasury securities, 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 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 are predominantly driven by credit 
spread levels, i.e., idiosyncratic default risk.  These 
instruments include, but are not limited to, single 
issuer credit default swaps, and securities with 
exposures from corporate and municipal credit 
spreads.
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.
During 2024, interest rate risk generated 43% of 
average gross VaR, foreign exchange risk generated 
35% of average gross VaR, equity risk generated 1% 
of average gross VaR and credit risk generated 21% 
of average gross VaR.  During 2024, our daily trading 
loss exceeded our calculated VaR amount of the 
overall portfolio on only 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. 
Distribution of trading revenue (loss) (a)
Quarter ended
(dollars in 
millions)
Dec. 31, 
2024
Sept. 30, 
2024
June 30, 
2024
March 31, 
2024
Dec. 31, 
2023
Revenue range:
Number of days
Less than $(2.5)
 
—  
—  
—  
—  
2 
$(2.5) – $0
 
2  
2  
2  
1  
3 
$0 – $2.5
 
12  
18  
8  
19  
18 
$2.5 – $5.0
 
26  
27  
34  
30  
25 
More than $5.0
 
24  
17  
19  
12  
15 
(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 income.
Trading assets include debt and equity instruments 
and derivative assets, primarily foreign exchange and 
interest rate contracts, not designated as hedging 
instruments.  Trading assets were $14.0 billion at 
Dec. 31, 2024 and $10.1 billion at Dec. 31, 2023. 
Trading liabilities include debt and equity instruments 
and derivative liabilities, primarily foreign exchange 
and interest rate contracts, not designated as hedging 
instruments.  Trading liabilities were $4.9 billion at 
Dec. 31, 2024 and $6.2 billion at Dec. 31, 2023.
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. 
Results of Operations (continued)
BNY 45

At Dec. 31, 2024, our OTC derivative assets, 
including those in hedging relationships, of $3.7 
billion included a credit valuation adjustment 
(“CVA”) deduction of $11 million.  Our OTC 
derivative liabilities, including those in hedging 
relationships, of $2.9 billion included a debit 
valuation adjustment (“DVA”) of $7 million related 
to our own credit spread.  Net of hedges, the CVA 
increased by less than $1 million and the DVA 
decreased by less than $1 million in 2024, which 
decreased other trading revenue by $1 million in 
2024.  During 2024, no realized loss was charged off 
against CVA reserves.
At Dec. 31, 2023, our OTC derivative assets, 
including those in hedging relationships, of $2.3 
billion included a CVA deduction of $16 million.  
Our OTC derivative liabilities, including those in 
hedging relationships, of $3.8 billion included a DVA 
of $4 million related to our own credit spread.  Net of 
hedges, the CVA increased by $1 million and the 
DVA increased by $1 million in 2023, which 
increased other trading revenue by less than $1 
million in 2023.  During 2023, no realized loss was 
charged off against CVA reserves.
The table below summarizes our exposure, net of 
collateral related to our derivative counterparties, as 
determined on an internal risk management basis.  
Significant changes in counterparty credit ratings 
could alter the level of credit risk faced by BNY.
Foreign exchange and other trading 
  counterparty risk rating profile
Dec. 31, 2024
Dec. 31, 2023
(dollars in 
millions)
Exposure, 
net of 
collateral
Percentage 
of exposure, 
net of 
collateral
Exposure, 
net of 
collateral
Percentage 
of exposure, 
net of 
collateral
Investment grade
$ 
3,201 
 98% 
$ 
2,062 
 95% 
Non-investment 
grade
 
76 
 2% 
 
103 
 5% 
Total
$ 
3,277 
 100% 
$ 
2,165 
 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 income 
between a baseline scenario and hypothetical interest 
rate scenarios.  Interest rate sensitivity is quantified 
by calculating the change in pre-tax net interest 
income between the scenarios over a 12-month 
measurement period.    
The baseline scenario incorporates the market’s 
forward rate expectations and management’s 
assumptions regarding client deposit rates, credit 
spreads, changes in the prepayment behavior of loans 
and securities and the impact of derivative financial 
instruments used for interest rate risk management 
purposes as of each respective quarter-end.  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.  Client 
deposit levels and mix are key assumptions impacting 
net interest income in the baseline as well as the 
hypothetical interest rate scenarios.  The earnings 
simulation model assumes static deposit levels and 
mix, and it also assumes that no management actions 
will be taken to mitigate the effects of interest rate 
changes.  Typically, the baseline scenario uses the 
average deposit balances of the quarter.
In the table below, we use the earnings simulation 
model to assess the impact of various hypothetical 
interest rate scenarios compared to the baseline 
scenario.  In each of the scenarios, all currencies’ 
interest rates are instantaneously shifted higher or 
lower at the start of the forecast.  Long-term interest 
rates are defined as all tenors equal to or greater than 
three years and short-term interest rates are defined as 
all tenors equal to or less than three months.  Interim 
term points are interpolated where applicable.  The 
impact of interest rate shifts may not be linear.  The 
results of this earnings simulation should therefore 
not be extrapolated for more severe interest rate 
scenarios than those presented in the table below.  
Results of Operations (continued)
46 BNY

The following table shows net interest income 
sensitivity for BNY. 
Up 100 bps rate shock vs. 
baseline
$ 
125 $ 
190 $ 
254 
Long-term up 100 bps, short-
term unchanged
 
88  
130  
71 
Short-term up 100 bps, long-
term unchanged
 
37  
60  
183 
Long-term down 100 bps, 
short-term unchanged 
 
(90)  
(139)  
(73) 
Short-term down 100 bps, 
long-term unchanged
 
(104)  
(124)  
(270) 
Down 100 bps rate shock vs. 
baseline
 
(194)  
(263)  
(343) 
Estimated changes in net 
interest income 
(in millions)
Dec. 31, 
2024
Sept. 30, 
2024
Dec. 31, 
2023
At Dec. 31, 2024, the changes in the impacts of a 100 
basis point upward or downward shift in rates on net 
interest income compared with Sept. 30, 2024 were 
primarily driven by an increase in fixed-rate assets 
and floating rate liabilities.
While the net interest income sensitivity scenario 
calculations assume static deposit balances to 
facilitate consistent period-over-period comparisons, 
net interest income is impacted by changes in deposit 
balances and interest rate trajectory.  Noninterest-
bearing deposits are particularly sensitive to changes 
in short-term rates.  
To illustrate the net interest income sensitivity to non-
interest-bearing deposits, we estimate that a $5 billion 
instantaneous reduction/increase in U.S. dollar-
denominated noninterest-bearing deposits would 
reduce/increase the net interest income sensitivity 
results in the up 100 basis point rate shock scenario in 
the table above by approximately $260 million, and in 
the down 100 basis point rate shock scenario by 
approximately $160 million.  The impact would be 
smaller if the reduction/increase was assumed to be a 
mixture of interest-bearing and noninterest-bearing 
deposits. 
Additionally, during periods of low short-term 
interest rates, money market mutual fund fees and 
other similar fees are typically waived to protect 
investors from negative returns.  
For a discussion of factors impacting the growth or 
contraction of deposits, see “Risk Factors – Capital 
and Liquidity Risk – 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 
EVE would change in response to changes in interest 
rates.  
Estimated changes in EVE
Dec. 31, 
2024
Rate change:
Up 200 bps vs. baseline 
 (1.9) %
Up 100 bps vs. baseline
 —% 
Down 100 bps vs. baseline
 (0.7) %
Down 200 bps vs. baseline
 (2.4) %
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, 2024, net investments 
in foreign operations totaled $14 billion and were 
spread across 19 foreign currencies.  
Results of Operations (continued)
BNY 47

Overview
BNY plays a vital role in the global financial markets, 
and effective risk management is critical to our 
success.  BNY operates under the Enterprise Risk 
Management Framework (“risk management 
framework”) which is the foundation of our risk 
management approach.  Risk management begins 
with a strong risk culture, and we reinforce our 
culture through principle-based policies including the 
Code of Conduct, which are grounded in our core 
values of passion for excellence, integrity, strength in 
diversity and courage to lead.  
These values are critical to our success.  They not 
only explain what we stand for and our shared 
culture, but also help us to think and act globally.  
They serve as a representation of the promises we 
have made to our clients, communities, shareholders 
and each other. 
BNY’s Risk Identification process is a core 
component of BNY’s risk framework and is the 
foundation for understanding and managing risk.  We 
utilize a common risk language, our Risk Taxonomy, 
to identify risks across our six primary risk 
categories: Operational Risk, Market Risk, Credit 
Risk, Liquidity Risk, Model Risk and Strategic Risk.  
Quarterly, the Company engages in a process 
designed to document identification and assessment 
of its risks, and to determine the set of risks material 
to BNY.  Outputs from the Risk Identification process 
inform elements of our risk framework such as our 
Risk Appetite as well as Enterprise-wide Stress 
Testing and Capital Planning.  
BNY’s Risk Appetite expresses the level of risk we 
are willing to tolerate to meet our strategic objectives 
in a manner that balances risk and reward while 
considering our risk capacity and maintaining a 
balance sheet that remains resilient throughout market 
cycles.  This guides BNY’s risk-taking activities and 
informs key decision-making processes, including the 
manner by which we pursue our business strategy and 
the methods by which we manage risk.  The Risk 
Appetite Statement and associated key risk metrics to 
monitor our risk profile are updated and approved by 
the Risk Committee of the Board at least annually.
BNY conducts Enterprise-wide Stress Testing as part 
of its Internal Capital Adequacy Assessment Process 
in accordance with CCAR, and as required by the 
enhanced prudential standards issued pursuant to the 
Dodd-Frank Wall Street Reform and Consumer 
Protection Act (the “Dodd-Frank Act”).  Enterprise-
wide Stress Testing considers the Company’s lines of 
business, products, geographic areas and risk types 
incorporating the results from underlying models and 
projections for a range of stress scenarios.  Additional 
details on Capital Planning and Stress Testing are 
included in “Supervision and Regulation.”
Three Lines of Defense
BNY’s three lines of defense model is a critical 
component of our risk management framework to 
clarify roles and responsibilities across the 
organization.  
BNY’s first line of defense includes senior 
management and business and corporate staff, 
excluding management and employees in Risk 
Management, Compliance and Internal Audit.  Senior 
management in the first line is responsible for 
maintaining and implementing an effective risk 
management framework and appropriately managing 
risk consistent with its strategy and risk tolerance, 
including establishing clear responsibilities and 
accountability for the identification, measurement, 
management and control of risk.
Risk and Compliance is the independent second line 
of defense, reporting to the Chief Risk Officer.  The 
Chief Risk Officer reports to both the Chief 
Executive Officer and the Risk Committee of the 
Company’s Board of Directors.  Risk and 
Compliance is responsible for establishing policies, 
expectations and guidance for managing risk at BNY 
while also independently monitoring, reviewing and 
challenging the first line.  To facilitate the 
comprehensive global application of consistent 
standards for each risk or compliance topic, 
independent oversight is provided by Risk and 
Compliance across three perspectives  – lines of 
business; legal entities; and enterprise-wide risk and 
compliance disciplines.  
Internal Audit is BNY’s third line of defense and 
serves as 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 
Risk Management
48 BNY

includes the review and evaluation of the adequacy, 
effectiveness and sustainability of risk management 
procedures, internal control systems, information 
systems and governance processes.
Governance
BNY’s management is responsible for execution of the Company’s risk management framework and the governance 
structure that supports it, with oversight provided by BNY’s Board of Directors through two key Board committees: 
the Risk Committee and the Audit Committee.  
A summary of the governance structure is provided below.
BNY Board of Directors
Risk Committee
Audit Committee
Senior Risk and Control Committee (“SRCC”)
• Anti-Money Laundering Oversight 
Committee
• Asset Liability Committee
• Balance Sheet Risk Committee
• Business Risk Committees
• Compliance and Ethics Oversight 
Committee
• Contract Management Committee
• Credit Portfolio Management Committees
• Enterprise Insider Threat Steering 
Committee
• Enterprise Risk Committee
• International Senior Risk and Control 
Committee
• Operational Risk Committee
• Product Approval and Review Committee
• Regulatory Oversight Committee
• Resolvability Steering Committee
• Technology Risk 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 Company’s risk management policies 
and practices.  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.bny.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, the Company’s independent 
registered public accountant’s qualifications and 
independence, and the performance of our internal 
audit function and the independent registered public 
accountant.  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.bny.com.
The SRCC is the most senior management level risk 
governance group at the Company and is responsible 
for oversight of all Risk Management, Compliance & 
Ethics activities and processes, including the 
Enterprise Risk Management Framework.  The 
committee is chaired by the Chief Risk Officer and its 
members include the Chief Financial Officer, Chief 
Information Officer, Global Head of Engineering and 
General Counsel.
Subcommittees of the SRCC include: 
•
Anti-Money Laundering Oversight Committee: 
Oversees the systems and controls relating to all 
aspects of anti-money laundering and terrorist 
financing compliance (including Know Your 
Customer, suspicious activity reporting and 
sanctions) within the Company.
•
Asset Liability Committee (“ALCO”): The senior 
management committee responsible for balance 
sheet oversight, including capital, liquidity and 
interest rate risk management. 
Risk Management (continued)
BNY 49

•
Balance Sheet Risk Committee (the “BSRC”): 
Reviews and receives escalation relating to 
balance sheet risk management frameworks 
associated with the assets, liabilities and capital 
of the Company.  There is a focus on treasury risk 
topics, including matters related to liquidity risk, 
capital management, investment portfolio risk, 
and interest rate risk in the banking book. 
•
Business Risk Committees: Review and assess 
risk and control issues observed from existing 
business practices or activities or arising from 
new business practices or activities in our various 
lines of business and supporting operations.
•
Compliance and Ethics Oversight Committee: 
Provides governance and oversight of the 
operations of the Compliance and Ethics function 
and the management and reporting of compliance 
risk-related issues, as well as Compliance and 
Ethics processes, policies, procedures and 
standards. 
•
Contract Management Committee: The 
governance and escalation body for the 
Company’s Customer Contract Management 
policy and determines the client contract 
management policies and infrastructure for the 
Company. 
•
Credit Portfolio Management Committees: Seven 
Portfolio Management Committees, governed by 
the same charter and rules, manage, monitor and 
review each of Credit Risk’s primary portfolio 
segments, including underwriting criteria, 
portfolio limits and composition, risk metrics, 
concentration, credit strategy, quality and 
exposure, stress test outcomes and wrong way 
risk. 
•
Enterprise Insider Threat Steering Committee: 
Provides enterprise-wide governance and 
oversight related to the Enterprise Insider Threat 
Program and related initiatives, as well as 
provides visibility to senior leadership related to 
the enterprise risk profile as it relates to insider 
threat risks.
•
Enterprise Risk Committee: Oversees the 
Enterprise Risk Management Framework and 
related activities, including comprehensive 
discussions, deliberations and collaboration on 
material and emerging risks, limit setting, risk 
reporting, issue management, escalation and 
relevant decision-making.
•
International Senior Risk and Control Committee: 
Provides risk management oversight, and acts as 
a point of convergence for the coordination, 
transparency and communication of material 
issues (live or emerging) across international 
entities. 
•
Operational Risk Committee: Oversees the 
operational risk profile and is responsible for 
monitoring and managing the appropriateness of 
the operational risk framework, policy design, 
adherence tracking and mitigating controls.
•
Product Approval and Review Committee: 
Responsible for reviewing and approving 
proposals to introduce new and modify or retire 
existing products.
•
Regulatory Oversight Committee: Provides 
strategic direction, oversight, challenge, and 
coordination across regulatory remediation 
initiatives.
•
Resolvability Steering Committee: Oversees 
recovery and resolution planning, including but 
not limited to the project governance and 
oversight framework for all recovery and 
resolution planning requirements in relevant 
jurisdictions where BNY operates.  
•
Technology Risk Committee: Oversees the 
review and assessment of technology risk and 
control issues observed from existing business 
practices or activities, or arising from new 
business practices or activities in our various 
lines of business and supporting operations so as 
to assist the Company in managing and 
monitoring technology risk and control issues. 
Risk Management (continued)
50 BNY

Risk Types Overview
The understanding, identification, measurement and mitigation of risk are essential elements for the successful 
management of BNY.  We leverage a comprehensive risk taxonomy to support consistent language for defining and 
understanding risks.  The primary categories in our risk taxonomy are: 
Type of risk
Description
Operational
The risk of loss and/or regulatory, legal or reputational impact resulting from inadequate or failed internal 
processes, people and systems or from external events.  Operational risk includes risks, such as compliance 
and financial crimes, technology risks and third party risks.
Market
The risk of financial loss or adverse change to the economic condition of BNY resulting from movements 
in market risk factors. Market risk factors include, but are not limited to, interest rates, credit spreads, 
foreign exchanges rates, commodity prices, and equity prices.  
Credit
Credit risk denotes a broad category of adverse financial outcomes arising from credit events (default, 
bankruptcy, ratings migration) associated with obligor/counterparty not meeting (inability/unwilling) its 
contractual obligations.  Credit risk is present in the majority of our assets, but primarily concentrated in 
the loan and securities books, as well as foreign exchange and off-balance sheet exposures such as lending 
commitments, letters of credit and securities lending indemnifications.
Liquidity
The risk arising from an inability to access funding, convert assets to cash quickly and efficiently, or to roll 
over or issue new debt, especially during periods of market stress. Liquidity risk includes the inability to 
access funding sources or manage fluctuations in funding levels.  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.
Model
The potential loss arising from incorrectly designing/using a model or stress conditions that invalidate the 
assumptions of a model.
Strategic
The risk arising from the flawed design, decision or implementation of a business strategy, and potential 
disruption to business strategy by external factors and/or internal decisions.  More specifically, the risks 
arising from adverse business decisions, poor implementation of business decisions or lack of 
responsiveness to changes in the financial industry and operating environment.  Strategic risks may also 
arise from the acceptance of new businesses, the introduction or modification of products, strategic finance 
and risk management decisions, business process changes, complex transactions, acquisitions/divestitures/
joint ventures and major capital expenditures/investments.
Operational risk
In providing a comprehensive array of products and 
services, we are exposed to operational risk.  
Operational risk may result from, but is not limited to, 
errors related to transaction processing, failure of 
internal control systems and meeting compliance 
requirements, fraud by employees or persons outside 
BNY or business interruption due to system failures 
or other events.  Operational risk may also include 
breaches of our technology and information systems 
resulting in 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.  
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.  
The organizational framework for operational risk is 
based upon a strong risk culture that incorporates 
both governance and risk management activities 
comprising:
•
Accountability of Businesses – Business 
managers are responsible for maintaining an 
effective system of internal controls 
commensurate with the business risk profiles and 
in accordance with BNY policies and procedures. 
•
Operational Risk Management is the independent 
second line function responsible for developing 
risk management policies and tools for assessing, 
measuring, monitoring and managing operational 
risk for BNY.  The primary objectives of the 
Operational Risk Management Framework are to 
promote effective risk management, identify 
emerging risks and drive improvement in controls 
and to reduce operational risk.  The Operational 
Risk Management (continued)
BNY 51

Risk Management function includes independent 
operational risk oversight of all lines of business 
and functions, as well as specialist oversight of 
areas such as data risk, fraud risk, and third party 
risk.  
•
Technology risk is a subset of operational risk.  
Technology Risk Management is part of the 
second line of defense risk function providing 
oversight over technology risks in an effort to 
improve the likelihood that technology risks are 
identified, considered, and managed effectively 
against the stated risk appetite of the Company.  
Technology Risk Management is responsible for 
developing risk management policies and tools in 
an effort to identify and manage risks across 
cyber, infrastructure, applications, and resiliency 
and is responsible for confirming such policies 
and tools are well understood by the first line of 
defense.  Further, Technology Risk Management 
oversees the risk reporting process through our 
governance and that the risks are managed within 
our defined risk appetite and risk management 
framework.  Technology Risk Management uses 
its expertise in engaging in centralized activities 
and capabilities, and data-driven methodologies.  
Additionally, Technology Risk Management acts 
as a catalyst to drive the development of global 
technology policies, key controls, and methods to 
assess, measure, and monitor information and 
technology risk for BNY.  The function also 
conducts integrated independent assessments on 
multiple cyber and digital initiatives within the 
Company and works to drive better understanding 
and a more accurate assessment of technology 
risks. 
•
Operational resiliency is a strategic priority for 
the Company.  Foundational to our enterprise 
resiliency strategy is the Business Services 
Framework, governed by the first line Enterprise 
Resiliency Office, with second line oversight 
from Resiliency Risk Management.  First line 
business management is accountable for 
maintaining effective resiliency capabilities under 
this framework, while Engineering and 
Operations are responsible for successful 
execution in coordination with the business.  
Elements of the resiliency strategy include the 
Business Services Framework, management of 
technology assets, Incident and Crisis 
Management, as well as Disaster Recovery 
Testing and Business Continuity capabilities.  We 
are also focused on the resiliency capabilities of 
our third-party service providers.  These 
processes are intended to position the Company 
to continuously deliver services to our clients 
through our ability to prevent, respond to and 
recover from business disruptions and threats.
•
Compliance and financial crimes risk is also a 
subset of operational risk with second line 
Compliance and Ethics and Financial Crime 
Compliance teams.  Compliance and financial 
crimes risk is defined as the risk of legal or 
regulatory sanctions, material financial loss, or a 
financial institution’s reputational loss as a result 
of its failure to comply with laws, regulations, 
rules, related self-regulatory organizational 
standards, and codes of conduct or organizational 
standards of practice.  We seek to comply with all 
obligations through a comprehensive, integrated 
Compliance and Ethics Management Framework.
Market risk
Our business activity tends to minimize outright our 
direct exposure to market risk, with such risk 
primarily limited to market volatility from trading 
activity in support of clients.  More significant market 
risk is assumed in the form of interest rate and credit 
spread risk within the investment portfolio as a means 
for asset/liability management and net interest income 
generation, and also through the interest rate risk 
associated with BNY’s balance sheet position which 
is sensitive to adverse movements in interest rates.  
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.  The Markets business monitors its 
market risk through a variety of metrics including 
trading VaR and trading stressed VaR.  Finally, the 
Risk Quantification Review Group reviews back-
testing results for the Company’s VaR model.
Credit risk
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.
Risk Management (continued)
52 BNY

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 exposure at a counterparty, 
industry, country and portfolio level.  Credit risk 
exposure at the counterparty level is managed through 
our credit approval framework 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 proposed by the 
business, as well as the ongoing monitoring of the 
creditworthiness of the counterparty.  In addition, it is 
responsible for challenging and approving the internal 
risk ratings on each exposure.
The calculation of a fundamental credit measure is 
based on a projection of 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.”  Borrowers/counterparties are 
assigned ratings by the business and reviewed, 
challenged and approved by the 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 5-grade scale) that reflect the transactions’ 
structures, including the effects of guarantees, 
collateral and relative seniority of position.
The Risk Modeling and Analytics Group is 
responsible for the calculation methodologies and the 
estimates of the inputs used in those methodologies 
for the determination of expected loss.  These 
methodologies and input estimates are regularly 
evaluated for appropriateness and accuracy.  As new 
techniques and data become available, the Risk 
Modeling and Analytics Group incorporates, where 
appropriate, those techniques or data. 
BNY 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 an independent 
group within Internal Audit, composed of 
experienced loan review officers who perform timely 
reviews of the loan files and credit ratings assigned to 
the loans.
Liquidity risk
Adequate liquidity is vital to BNY’s ability to process 
payments as well as settle and clear transactions on 
behalf of clients.  The Company’s liquidity position 
can be affected by multiple factors, including funding 
mismatches, market conditions that impact our ability 
to convert our investment portfolio to cash, inability 
to issue debt or roll over funding, run-off of core 
deposits, and contingent liquidity events such as 
additional collateral posting requirements.  
Additionally, a downgrade in our credit rating cannot 
only lead to an outflow of deposits, which are a major 
source of our funding, but also increase our margin 
requirements on secured transactions and have a 
broader adverse impact on our overall brand that may 
further impair our ability to refinance maturing 
liabilities.  Changes in economic conditions or 
exposure to other risks can also affect our liquidity.
The Board of Directors approves liquidity risk 
tolerance and is responsible for oversight of liquidity 
risk management of the Company.  ALCO provides 
governance for the appropriate execution of Board-
approved strategies, policies and procedures for 
managing liquidity.  Senior management is 
responsible for executing those Board-approved 
strategies, policies and procedures for managing 
liquidity which ALCO oversees, as well as regularly 
reporting the liquidity position of the Company to the 
Board of Directors.  The BSRC provides governance 
over independent risk oversight of liquidity risks, and 
oversees the establishment of control frameworks.  
BNY actively manages and monitors its cash 
position, quality of the investment portfolio, intraday 
liquidity positions and potential liquidity needs in 
order to support the timely payment and settlement of 
obligations under both normal and stressed 
conditions.  The Company uses a range of stress 
testing measures in connection with its efforts to 
Risk Management (continued)
BNY 53

maintain sufficient liquidity relative to risk appetite, 
including the Liquidity Coverage Ratio and Internal 
Liquidity Stress Testing.  
Model risk
Models support our infrastructure for managing risk.  
Among their functions, models help us value 
securities, rate the quality of an obligor’s credit, 
establish capital needs and monitor liquidity trends.  
Model failure might stem from faulty design, misuse, 
or environmental conditions that invalidate our 
assumptions.  When this happens, the Company could 
be exposed to losses and other adverse consequences 
resulting from operational, market, credit and 
liquidity risk, as well as reputational harm.  We aim 
to maintain a low-risk environment. 
BNY’s processes are designed to identify the 
conditions under which model risk incidents could 
occur and to establish controls that are designed to 
minimize or prevent loss in case of such an event.  
These processes include enforcement of standards for 
developing models, a process to validate new models, 
change controls for existing models, and a monitoring 
system to assess performance throughout a model’s 
life. 
When evaluating the degree of model risk, we 
consider multiple dimensions, including the quality of 
design, the robustness of controls, and indications of 
underperformance.  Based on these measures, we 
create an overall metric that is intended to measure 
the health of the Company’s modeling environment 
and set thresholds around it.  This allows us to 
manage model risk, not only at the level of the 
individual model, but also in aggregate, across all the 
Company’s businesses.
Strategic risk
Our strategy includes, but is not limited to, improving 
organic growth across our businesses, delivering 
quality solutions and evolving our operating model.  
Successful realization of our strategy requires that we 
provide expertise, insight and market-leading and 
technology-enabled products and services that drive 
economies of scale.  Additionally, it requires 
attracting, developing and retaining highly talented 
people capable of executing our strategy, while 
safeguarding our financial profile.  Failure to achieve 
these objectives may negatively impact both our 
growth strategy and our ability to service our existing 
clients, resulting in potential financial loss or 
litigation.
The markets in which we and our clients operate can 
evolve quickly.  The introduction of new or disruptive 
technologies, geopolitical events and economic 
slowdowns are examples of factors that can create 
market uncertainty.  Failure to anticipate or 
participate in transformational change within a given 
market or appropriately and promptly react to market 
conditions or client preferences could result in poor 
strategic positioning and potential negative financial 
impact.  While it is essential that we continue to 
innovate and respond to changing markets and client 
demand, we strive to do so in a manner that does not 
adversely affect our financial position or compromise 
our fundamental business strategy.  
Other Risk Considerations
In addition to the primary risk categories and sub-
categories noted above, we consider risks that have 
significance and may manifest across multiple 
categories of risk.  These risk considerations include 
data risk, fraud risk, third party risk, environmental, 
social and governance risk, reputational risk and 
geopolitical and country risk.  
Data risk
We are exposed to data management risk when we 
fail to consistently manage and control our data assets 
through the entire lifecycle, including managing the 
production, confidentiality, quality, integrity, 
availability, and retention of data information.
Our risk management approach considers data risks 
within our business activities.  Our Data Management 
Framework and supporting policies address 
management of data in key areas of data architecture, 
data governance, data quality management, data 
protection, data usage and ethics.
Emphasis is placed on data quality through data 
policies, regular quality assessments, and continuous 
improvement programs aimed at enhancing data 
integrity.  The data architecture must be resilient and 
scalable to support the complex and evolving needs 
of the business.  Efforts are made to strengthen the 
control environment in mitigating data management 
risks, aiming to achieve a higher data maturity level 
which enables the integration of innovative data 
solutions.
Risk Management (continued)
54 BNY

We also consider data risks in the execution of our 
business objectives and processes, including the 
development of new products and services, including 
AI applications.  We remain committed to increasing 
the effectiveness of our data management practices 
which are designed to enable us to deliver products 
and services to our clients across the investment 
lifecycle.
Fraud risk
Fraud risk, the risk associated with an internal or 
external party deliberately performing an activity that 
relies on deception to achieve financial gain to the 
detriment of BNY or its clients or affiliated or related 
parties, is an inherent risk as part of our business.  As 
part fraud prevention, we utilize tools which include 
culture and awareness campaigns, risk identification, 
risk assessment and risk mitigation which help us 
understand key fraud risks and controls and to 
educate employees about the expectations of 
identifying and reporting fraud attempts in order to 
protect assets of BNY and its clients.   
Third party risk
Third party risk arises from an adverse impact on the 
Company due to reliance on third parties, including 
vendors, that provide goods or perform services or 
other benefits on our behalf or on behalf of our 
clients.  As part of our third-party risk management 
framework, we identify, evaluate, measure, mitigate, 
monitor and re-assess risks in an attempt to reduce the 
likelihood of, and negative impacts from, operational 
failures throughout the lifecycle of an engagement 
with a third party.  
Environmental, social and governance 
We are exposed to environmental, social and 
governance risks factors that may lead to increased 
risk levels across one or more enterprise risk 
categories and may impact our risk management 
frameworks.  For example, climate risks include 
physical risks from acute and chronic weather-related 
effects as well as transition risks from changes such 
as fiscal policy, legislation and regulation, 
technological development, and investor and 
customer preference changes.  Social and governance 
risks could also impact our risk categories and risk 
management frameworks.  
These effects may be wide-ranging with potential 
financial and operational resilience implications that 
could negatively impact the Company’s strategic 
objectives and financial performance, reputation, 
business operations, ability to service clients and 
broad stakeholder relationships.  Potential risk 
outcomes include, but are not limited to, adverse 
publicity, loss of business, financial loss, litigation, 
employee impacts, and other operational impacts.  
For example, climate-related impacts have been 
identified across our credit portfolios, strategic 
positioning, operational resiliency, and the pace and 
volume of regulatory change, with the potential for 
reputational impacts across these areas.  Thus, these 
risk factors are considered when managing risk within 
appetite and limits across the enterprise risk 
categories.    
Reputational risk
We are exposed to Reputational Risk as a result of 
negative stakeholder perception which may result 
from any decision, action, or inaction by BNY, any of 
our employees, or through other associated parties, 
such as clients, strategic partners, and third parties.  
Reputational impacts can result in risks to current or 
anticipated earnings, capital, liquidity, brand, and 
enterprise value, and can stem from any line of 
business, corporate function, legal entity, product, or 
service.  
Geopolitical and country risk
We are exposed to the effects of geopolitical events, 
including tensions between nations and/or regions 
that may disrupt the stability of international 
relations, economies or markets.  Geopolitical event 
risks include wars, trade or territorial disputes, 
sanctions, cybersecurity conflicts, nuclear 
advancements, the imposition of tariffs and retaliatory 
measures, shifts in alliances and government policy 
changes that impact global systems and stakeholders.  
These events can affect macroeconomic factors and 
financial markets which could result in losses to BNY 
or its clients.  We are also exposed to the risks 
associated with maintaining commercial relationships 
within or connected to sovereign jurisdictions which, 
among other things, may not possess: an independent 
judiciary, a history of political pluralism, robust 
protections for private property (including intellectual 
property), traditions of free enterprise or the rule of 
law, or similar attributes.  We monitor geopolitical 
events to assess and measure the potential impact on 
BNY.  
Risk Management (continued)
BNY 55

BNY maintains a broad range of defenses aimed at 
remaining abreast of and responding to evolving 
cybersecurity threats impacting the Company, its 
operations, its clients, its third-party service providers 
and the broader financial services sector.  During 
2024, cybersecurity threats did not have a material 
effect on the Company’s business strategy or 
operations.  However, the financial services sector is 
prone to cybersecurity threats, and there can be no 
assurance that the Company will be able to 
successfully protect its information systems against 
material cybersecurity incidents in the future.  Given 
the increasing prevalence and severity of 
cybersecurity incidents affecting financial 
institutions, other companies and governmental 
agencies as well as the evolving and adaptive nature 
of cybersecurity threats, cybersecurity risk 
management is a priority for the Company that 
impacts its allocation of resources, operations and 
risk management strategy.  For a further discussion of 
the various risks related to cybersecurity threats and 
the potential impact on the Company’s business 
strategy, results of operations or financial condition, 
see “Risk Factors – Operational Risk.”
Risk management strategy and procedures
BNY has implemented policies and procedures 
designed to detect, prevent and respond to malicious 
and accidental disruptions to the delivery of critical 
technology services.  BNY’s cybersecurity risk 
management program is embedded in the Company’s 
three lines of defense model.  
As part of its first line of defense, the Company 
maintains a dedicated Information Security Division 
(“ISD”), led by the Chief Information Security 
Officer (the “CISO”), that is responsible for the day-
to-day management of risks from cybersecurity 
threats.  ISD’s responsibilities include cybersecurity 
threat intelligence, incident response and other 
cybersecurity operations aimed at enabling the 
Company to identify, assess and manage existing and 
emerging cybersecurity threats.  ISD monitors for 
potential threats and communicates relevant risks to 
the CISO and other members of executive 
management.  Additionally, ISD maintains a 
cybersecurity incident response and reporting process 
pursuant to which cybersecurity incidents are 
classified according to their severity based upon an 
assessment of multiple factors.  Certain cybersecurity 
incidents may activate enterprise-wide resiliency 
processes, which include, among other things, 
escalation through the management and Board 
committee structures described below.  In addition, 
the Company maintains a preparedness program 
designed to reinforce cybersecurity risk management 
practices and compliance with the Company’s 
policies and procedures.  The preparedness program 
includes mandatory training for all employees, 
contractors and consultants, enhanced training for 
those in roles presenting higher risk, calibrated 
phishing email simulations, distribution of 
information security awareness materials and 
cybersecurity event simulation exercises.  In addition, 
the Company leverages both internal and external 
assessments and engages with third-party assessors, 
consultants and auditors to evaluate and test its 
cybersecurity controls and provide guidance on 
potential improvements, including design and 
operating effectiveness.  The Company has standing 
arrangements with third parties to assist the Company 
in identifying, assessing and managing cybersecurity 
threats, including in connection with risk 
assessments, penetration testing, legal advice and 
other aspects of the Company’s cybersecurity risk 
management and incident response processes.
BNY has a defined third-party governance framework 
to help manage the risk posed to the Company by the 
use of third-party service providers.  The Company 
evaluates the risk posed by third-party service 
engagements based on multiple factors.  The 
Company has protocols that seek to mitigate 
cybersecurity risks associated with third-party service 
providers based on the risk level assigned to such 
third party, which may include mandatory contractual 
obligations or the implementation of additional 
controls by the Company and/or the applicable 
service provider.
ISD is subject to ongoing review and challenge from 
Technology Risk Management, which is a part of the 
independent second line of defense risk function.  
Technology Risk Management, together with the 
broader Risk & Compliance group, is responsible for 
and manages the Company’s risk management 
framework and establishes guidance for ISD and 
management designed to help identify, assess and 
manage cybersecurity risk.  For more information on 
how we monitor and manage our risk management 
framework, see “Risk Management – Overview.”
Internal Audit serves as the third line of defense and 
provides an independent view on how effectively the 
organization as a whole manages cybersecurity risk.  
Cybersecurity
56 BNY

For a further discussion of BNY’s three lines of 
defense model, see “Risk Management – Three Lines 
of Defense.”
Risk management oversight and governance
The Company’s management is responsible for 
assessing and managing the Company’s material risks 
from cybersecurity threats with oversight provided by 
the Parent’s Board of Directors and the Board 
committees.  The Risk Committee of the Board has 
primary responsibility for oversight of the overall 
operation of the Company’s risk management 
framework, including policies and practices 
addressing cybersecurity risk, and is responsible for 
the oversight of the second line of defense with 
respect to its cybersecurity risk management 
responsibilities.  The Technology Committee of the 
Board and the full Board regularly receive reports and 
briefings from management concerning cybersecurity 
matters, including any significant changes to the 
Company’s cybersecurity program.  The Company 
also has protocols for escalating cybersecurity threats 
and incidents to the Technology Committee of the 
Board and the full Board.  In addition, the Audit 
Committee monitors and oversees the performance of 
Internal Audit, including with respect to its 
cybersecurity risk management responsibilities.
At the management level, the Technology Oversight 
Committee, which is the senior management 
committee responsible for the governance and 
oversight of the Company’s significant technology 
projects and initiatives, reviews reports from 
management concerning ISD and is responsible for, 
among other things, escalating issues, including 
significant cybersecurity threats and incidents, to the 
Technology Committee of the Board.  The 
Technology Oversight Committee is chaired by the 
Chief Information Officer (the “CIO”) and its 
members include the CISO.
The Technology Risk Committee is the most senior 
governance committee primarily focused on 
cybersecurity and technology risk issues and is a part 
of the second line of defense risk function.  It is 
responsible for, among other things, overseeing and 
reviewing emerging cybersecurity risks, significant 
cybersecurity incidents and remediation plans.  The 
Technology Risk Committee receives reports from 
management and has protocols for escalating certain 
issues and risks to the SRCC and the Risk Committee 
of the Board of Directors.  The Technology Risk 
Committee is chaired by the interim Chief 
Technology Risk Officer.  Members include key 
leaders from the first line of defense, including the 
CISO.
BNY’s CIO, CISO and interim Chief Technology 
Risk Officer each have extensive experience in 
assessing and managing risks from cybersecurity 
threats.  The Company’s CISO joined BNY in 2022 
and previously served as head of information security 
at a Fortune 500 biopharmaceutical company and an 
information technology company, as well as the 
Global Chief Technology Officer at a large 
cybersecurity company.  The Company’s CIO joined 
BNY in September 2024 from a large multinational 
company, where she was responsible for overseeing 
information technology and cybersecurity operations.  
The Company’s interim Chief Technology Risk 
Officer joined BNY in November 2024 and has 
previous experience as Global Head of Cyber, 
Technology and Information Security Risk 
Management at a global systemically important 
financial institution and over a decade of experience 
serving the U.S. intelligence community in a variety 
of cybersecurity-related positions.
For a further discussion of BNY’s risk management 
governance structure, see “Risk Management – 
Governance.”
Cybersecurity (continued)
BNY 57

Evolving Regulatory Environment 
BNY engages in banking, investment advisory and 
other financial activities across the globe 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-depositor 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 this 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 15 years 
globally, and this enhanced oversight environment is 
likely to continue in the future.  Our businesses have 
been subject to a significant number of global reform 
measures.  Moreover, political developments have 
resulted and may continue to result in legislative and 
regulatory changes to key aspects of laws and 
regulations affecting large banking and financial 
institutions and in laws or regulations relating to 
sustainability matters.  
Enhanced Prudential Standards
The Federal Reserve has adopted rules (“SIFI Rules”) 
to implement liquidity requirements, capital stress 
testing and overall risk management requirements 
affecting U.S. systemically important financial 
institutions (“SIFIs”).  BNY must comply with 
enhanced liquidity and overall risk management 
standards, which include maintenance of a buffer of 
highly liquid assets based on projected funding needs 
for 30 days.  The liquidity buffer is in addition to the 
rules regarding the LCR and NSFR, discussed below, 
and is described by the Federal Reserve as being 
“complementary” to these liquidity standards.
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 U.S. 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 Federal Reserve, the FDIC and the Office of the 
Comptroller of the Currency (“OCC,” and together, 
the “Agencies”) 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 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.
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, 
Supervision and Regulation
58 BNY

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 U.S. 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 or liquidity 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’s capital distributions are subject to Federal 
Reserve oversight.  The major component of that 
oversight is the Federal Reserve’s CCAR, 
implementing its capital plan rule.  That rule requires 
BNY to submit annually a 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 plan.
On March 4, 2020, the Federal Reserve finalized an 
SCB rule, which made changes to the capital plan 
rule.  The SCB rule eliminated the quantitative 
grounds for objection to a firm’s CCAR capital plan 
and introduced an SCB that became part of quarterly 
capital requirements of CCAR firms on Oct. 1, 2020.  
The final rule replaced the 2.5% capital conservation 
buffer with an SCB requirement for capital ratios 
under the U.S. capital rules’ standardized approach 
risk-weightings framework (“Standardized 
Approach”) that is based on the largest projected 
decrease in a firm’s CET1 ratio in the nine-quarter 
CCAR supervisory severely adverse scenario plus 
four quarters of planned common stock dividends as 
percentage of RWAs.  The SCB is subject to a 2.5% 
floor.  Each CCAR firm, including BNY, will be 
notified of its SCB by August 31, and the SCB will 
become effective on October 1 of the applicable 
calendar year.  In June 2024, the Federal Reserve 
notified BNY that its preliminary SCB requirement 
would remain at 2.5%, which equals the regulatory 
floor.  The SCB requirement was confirmed via an 
announcement from the Federal Reserve in August 
2024.  The SCB rule requires that firms reduce their 
planned capital actions if those distributions would 
cause the firm to fall below applicable buffer 
requirements based on the firm’s own baseline 
scenario projections and allows firms to increase 
certain planned capital distributions if they are 
forecasted to be above capital buffer constraints.  The 
SCB rule also eliminates the requirement for prior 
approval of capital distributions in excess of the 
distributions in a firm’s capital plan, provided that 
such distributions do not cause a breach of the firm’s 
capital ratios, including applicable buffers.  In 
addition, the SCB rule provides that a firm must 
receive prior approval for any dividend, stock 
repurchase or other capital distribution, other than a 
capital distribution on a newly issued capital 
instrument, if a firm is required to resubmit its capital 
plan.  In December 2024 and February 2025, the 
Federal Reserve indicated that it intends to propose 
changes to the stress test framework during 2025 and, 
for the 2025 stress test, take steps to reduce the 
volatility of results and to improve model 
transparency.  See “MD&A – Results of Operations – 
Capital” for information about our share repurchase 
program.
To the extent a banking organization’s capital buffer 
is less than 100% of its applicable buffer 
requirements, its distributions and discretionary 
bonus payments are constrained by the amount of the 
shortfall and its eligible retained income.  Under the 
final rule, eligible retained income is defined as the 
greater of (i) a banking organization’s net income for 
the four preceding calendar quarters, net of any 
distributions and associated tax effects not already 
reflected in net income, and (ii) the average of a 
banking organization’s net income over the preceding 
four quarters.  The Federal Reserve made 
corresponding changes to the definition of “eligible 
retained income” in the TLAC buffer requirements.  
For more information on TLAC, see “Total Loss-
Absorbing Capacity” below.
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 an annual regulatory stress test 
Supervision and Regulation (continued)
BNY 59

conducted by the Federal Reserve.  The BHC is 
required to conduct an annual company-run stress 
test.  In addition, The Bank of New York Mellon is 
required to conduct an annual company-run stress test 
(although the bank is permitted to combine certain 
reporting and disclosure of its stress test results with 
the results of BNY).  Results from our annual 
company-run stress tests are reported to the 
appropriate regulators and published.
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, National Association (“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 
Agencies retain significant discretion to set higher 
capital requirements for categories of BHCs or banks 
or for an individual BHC or bank as warranted.
U.S. Capital Rules – Minimum Risk-Based Capital 
Ratios and Capital Buffers
The U.S. capital rules require banking organizations 
subject to the advanced approaches risk-weighting 
framework (the “Advanced Approaches”), such as 
BNY, to satisfy minimum risk-based capital ratios 
using both the Standardized Approach and the 
Advanced Approaches.  See “MD&A – Results of 
Operations – Capital” for details on these 
requirements.  In addition, for CCAR firms, these 
minimum ratios are supplemented by (i) the SCB 
(which, for BNY, is 2.5%, as noted), in the case of a 
firm’s Standardized Approach capital ratios, and (ii) a 
capital conservation buffer of 2.5%, in the case of a 
firm’s Advanced Approaches capital ratios.  The 
capital conservation buffer can only be satisfied with 
CET1 capital.
When systemic vulnerabilities are meaningfully 
above normal, the SCB and 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, 
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 U.S. will also 
generally be subject to a 12-month phase-in period.
For G-SIBs like BNY, the U.S. capital rules’ buffers 
are also supplemented by a G-SIB risk-based capital 
surcharge, which is the higher of the surcharges 
calculated under two methods (referred to as “method 
1” and “method 2”).  Method 1 is based on the BCBS 
framework and considers a G-SIB’s size, 
interconnectedness, cross-jurisdictional activity, 
substitutability and complexity.  Method 2 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.  The G-SIB surcharge 
applicable to BNY for 2024 was 1.5%.
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 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.
In addition, the Agencies adopted a final rule that 
generally requires certain Advanced Approaches 
banking organizations, including BNY, to deduct 
from Tier 2 capital, subject to certain exceptions, 
direct, indirect and synthetic exposures to covered 
debt instruments, including TLAC instruments.
Supervision and Regulation (continued)
60 BNY

U.S. Capital Rules – Advanced Approaches Risk-
Based Capital Rules
Under the U.S. capital rules’ Advanced Approaches 
framework, credit 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-
weightings are generally based on supervisory risk-
weightings which vary primarily by counterparty type 
and asset class.  BNY is required to comply with 
Advanced Approaches reporting and public 
disclosures.  For purposes of determining whether we 
meet minimum risk-based capital requirements under 
the U.S. capital rules, our CET1 ratio, Tier 1 capital 
ratio, and total capital ratio is the lower of each ratio 
as calculated under the Standardized Approach and 
under the Advanced Approaches framework (based 
on currently applicable buffers).
U.S. Capital Rules – Standardized Approach
The Standardized Approach calculates 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.
Securities finance transactions, including transactions 
in which we serve as agent and provide securities 
replacement indemnification to a securities lender, are 
treated as repo-style transactions under the U.S. 
capital rules.  The 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 amount and the relevant risk weight for the 
counterparty and collateral posted.
U.S. Capital Rules – Standardized Approach for 
Measuring Counterparty Credit Risk Exposures for 
Derivatives
The Agencies jointly issued the Standardized 
Approach for Counterparty Credit Risk (“SA-CCR”) 
in January 2020 amending the U.S. capital rules to 
implement a modified approach for calculating the 
exposure amount for derivative contracts.  The final 
rule 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.  SA-CCR was 
implemented in the first quarter of 2022.
U.S. Capital Rules – 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.  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 U.S. G-SIBs (including BNY) 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 Agencies adopted a final rule to exclude certain 
central bank deposits from the total leverage 
exposure, the SLR denominator, and related TLAC 
and LTD measures of custody banks, including BNY 
and The Bank of New York Mellon.  Under the final 
rule, qualifying central banks include a Federal 
Reserve Bank, the European Central Bank or a central 
bank of a member country of the Organisation for 
Economic Co-operation and Development (“OECD”), 
provided that an exposure to the OECD member 
country receives a 0% risk-weighting and the 
sovereign debt of such country is not, and has not 
been, in default in the past five years.  The central 
bank deposit exclusion from the SLR denominator 
Supervision and Regulation (continued)
BNY 61

equals the average daily balance over the applicable 
quarter of all deposits placed with a qualifying central 
bank up to an amount equal to the on-balance sheet 
deposit liabilities that are linked to fiduciary or 
custodial and safekeeping accounts.  
BCBS Revisions to Components of Basel III and U.S. 
Implementation
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.  In January 2019, the BCBS released 
revised minimum capital requirements for market 
risk.
On July 27, 2023, the Federal Reserve, the OCC, and 
the FDIC proposed for comment substantial revisions 
to the capital requirements applicable to large 
banking organizations and to banking organizations 
with significant trading activity, including BNY, to 
implement the international capital standards issued 
by the BCBS.  Large banking organizations would be 
required to calculate risk-based capital ratios under 
both a new Expanded Risk-based Approach 
(replacing the current Advanced Approaches 
framework) and the current Standardized Approach.  
The proposal would replace existing models-based 
Advanced Approaches for calculating RWA for credit 
risk and operational risk with new standardized 
approaches that are part of the Expanded Risk-based 
Approach.  The proposed Expanded Risk-based 
Approach also includes a revised approach to market 
risk.  
The proposal would also indirectly impact several 
other regulations, including the requirements for total 
loss-absorbing capacity, long-term debt requirements, 
and the surcharge for G-SIBs.  The Federal Reserve 
has indicated that it expects to work with the OCC 
and FDIC in 2025 on a revised proposal. 
Risk-Based Capital Surcharges for Global 
Systemically Important Bank Holding Companies
On July 27, 2023, the Federal Reserve proposed 
amendments to its rule regarding risk-based capital 
surcharges for G-SIBs, including BNY, to revise 
certain systemic indicators and measures for G-SIB 
surcharges.  We are assessing the potential impact of 
the proposal.
Total Loss-Absorbing Capacity
The Federal Reserve imposes external TLAC and 
related requirements for U.S. G-SIBs, including 
BNY, at the top-tier holding company.  
U.S. G-SIBs are required to maintain a minimum 
eligible external TLAC equal to the greater of (i) 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 (ii) 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 LTD equal to the greater of (i) 6% of 
RWAs plus the G-SIB surcharge (calculated using the 
greater of method 1 and method 2), and (ii) 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, 
and have a maturity of at least one year from the date 
of issuance.  In addition, LTD issued on or after Dec. 
31, 2016 must (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.  
On Aug. 29, 2023, the Federal Reserve proposed for 
comment amendments to the TLAC rule applicable to 
U.S. G-SIBs, including BNY.  The proposal would: 
(i) require a $400,000 minimum denomination for 
newly issued long-term debt of G-SIBs used to satisfy 
TLAC and LTD requirements; (ii) allow only 50% of 
the amount of eligible long-term debt with a maturity 
of one year or more but less than two years to count 
towards TLAC requirements; and (iii) exempt certain 
agreements from the scope of the TLAC rule’s clean 
Supervision and Regulation (continued)
62 BNY

holding company prohibitions with respect to 
qualified financial contracts with third parties.  We 
are evaluating the potential impact of the proposed 
rule.
Certain foreign jurisdictions impose internal TLAC 
requirements on the foreign subsidiaries of U.S. G-
SIBs.  The European Union’s Capital Requirements 
Regulation 2 (“EU CRR2”) requires EU material 
subsidiaries of non-EU G-SIBs (including BNY) to 
maintain a minimum level of internal loss absorbing 
capacity; this requirement will continue under the 
EU’s proposed Capital Requirements Regulation 3 
(“EU CRR3”).  The BNY SA/NV is considered an 
EU material subsidiary for purposes of this regulation 
and is, therefore, subject to an internal TLAC 
requirement.
Prompt Corrective Action Regarding IDI Capital 
Requirements
The FDI Act, as amended by the Federal Deposit 
Insurance Corporation Improvement Act of 1991 
(“FDICIA”), requires the Agencies to take “prompt 
corrective action” in respect of IDIs 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 BHC, such as the Parent, 
based on the undercapitalized 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 Agencies’ prompt corrective action framework 
contains “well capitalized” thresholds for IDIs.  
Under these rules, an IDI must have the capital ratios 
as detailed in the “Capital” disclosure in order to 
satisfy the quantitative ratio requirements to be 
deemed “well capitalized.” 
Liquidity Standards – Basel III and U.S. Rules
BNY is subject to the U.S. LCR Rule, which is 
designed to ensure that BNY 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, 2024, the 
Parent and its domestic bank subsidiaries were in 
compliance with applicable LCR requirements.
The Agencies have issued a final NSFR rule that 
implements a quantitative long-term liquidity 
requirement applicable to large and internationally 
active banking organizations, including BNY.  Under 
the final rule, BNY’s NSFR is expressed as a ratio of 
its available stable funding to its required stable 
funding amount, and BNY is required to maintain an 
NSFR of 1.0.  As of Dec. 31, 2024, BNY was in 
compliance with the NSFR rule.
Separately, as noted above, the SIFI Rules impose 
additional liquidity requirements for BHCs with $100 
billion or more in total assets, including BNY, 
including 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 provisions of the Dodd-Frank Act commonly 
referred to as the “Volcker Rule” prohibit “banking 
entities,” including BNY, from engaging in 
proprietary trading and limit 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 acts as 
both sponsor/manager and custodian).  These 
restrictions are subject to certain exceptions. 
The restrictions concerning proprietary trading 
contain limited exceptions for, among other things, 
bona fide liquidity risk management and risk-
mitigating hedging activities, as well as certain 
Supervision and Regulation (continued)
BNY 63

classes of exempted instruments, including 
government securities.  Ownership interests in 
covered funds 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.  The 
aggregate value of all such ownership interests in 
covered funds is limited to 3% of the banking 
organization’s Tier 1 capital, and such interests are 
subject to a deduction from its Tier 1 capital.  The 
2019 amendments to the Volcker Rule (discussed 
below) remove the requirements that ownership 
interests in third-party covered funds held under the 
underwriting and market-making exemptions be 
subject to the aggregate limit and capital deduction 
but preserve these requirements for ownership 
interests in covered funds sponsored or organized by 
BNY. 
The Volcker Rule regulations also require us to 
develop and maintain a compliance program.  In 
2019, the Agencies, the Commodity Futures Trading 
Commission (“CFTC”) and the SEC modified the 
regulations implementing the Volcker Rule.  The 
most impactful aspects of the revisions with respect 
to BNY concern the compliance requirements 
applicable to institutions with moderate exposure to 
trading assets and trading liabilities, which are 
institutions with less than $20 billion and more than 
$1 billion of trading assets and trading liabilities.  
Specifically, among other revisions, such “moderate 
trading” banks are no longer required to file an annual 
CEO attestation and quantitative metrics.  
Furthermore, the comprehensive six-pillar 
compliance program associated with the Volcker 
Rule no longer applies to “moderate trading” banks; 
rather, such banks are permitted to tailor their 
compliance programs to the size and nature of their 
activities.  BNY is treated as a “moderate trading” 
bank under the revised Volcker Rule.  The final 
revisions also clarified and amended certain 
definitions, requirements and exemptions.  
On June 25, 2020, a second set of amendments to the 
Volcker Rule was released, which is principally 
focused on the restrictions on banking entities’ 
investments in, sponsorship of, and other 
relationships with covered funds.  Generally, the 
changes establish new exclusions from the covered 
fund definition for certain types of investment 
vehicles, modify the eligibility criteria for certain 
existing exclusions, and clarify and modify other 
provisions with respect to investment in, sponsoring 
of and transactions with covered funds.
Derivatives Trading and Margining
Title VII of the Dodd-Frank Act imposes a 
comprehensive regulatory structure on the OTC 
derivatives markets in which BNY 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.  Additionally, Title VII requires 
persons acting as security-based swap dealers to 
register with the SEC.  The Bank of New York 
Mellon is registered as a security-based swap dealer.
In addition, because BNY is subject to supervision by 
the Federal Reserve, we must comply with the U.S. 
prudential margin rules for variation and initial 
margin with respect to its OTC swap transactions.  
Furthermore, various BNY subsidiaries are also 
subject to OTC derivatives regulation by local 
authorities in Europe and Asia.
Single Counterparty Credit Limits
The Federal Reserve adopted a rule in June 2018 
imposing single-counterparty credit limits (“SCCLs”) 
on, among other organizations, domestic BHCs, 
including BNY, that are G-SIBs.  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 rule established two primary credit exposure 
limits: (i) 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 (ii) 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 non-bank 
SIFI).  The rule provides a cure period of 90 days (or, 
with prior notice from the Federal Reserve, a longer 
or shorter period) for breaches of the SCCL rule.  
During the cure period, a company may not engage in 
additional credit transactions with the particular 
counterparty unless the covered company has 
obtained a temporary credit exposure limit increase 
from the Federal Reserve.
Supervision and Regulation (continued)
64 BNY

Recovery and Resolution Planning 
As required by the Dodd-Frank Act, large domestic 
financial institutions, such as BNY, are required to 
submit periodically to the Federal Reserve and the 
FDIC a plan – referred to as the 165(d) resolution 
plan – for their rapid and orderly resolution in the 
event of material financial distress or failure.  In 
addition, certain large IDIs, such as The Bank of New 
York Mellon, are required to submit periodically to 
the FDIC a separate plan for resolution in the event of 
the institution’s failure.  The public portions of these 
resolution plans are available on the Federal 
Reserve’s and FDIC’s websites.  BNY also maintains 
a comprehensive recovery plan, which describes 
actions it could take to seek to avoid failure if faced 
with financial stress.
On June 20, 2024, the FDIC issued a final rule 
amending its resolution planning rule applicable to 
covered IDIs.  The amended rule: (i) adjusts the 
frequency of resolution plan submissions by IDIs 
affiliated with a U.S. G-SIB, including The Bank of 
New York Mellon, from a 3-year cycle to a 2-year 
cycle; (ii) expands resolution plan content 
requirements; (iii) requires IDIs to provide the FDIC 
with notice within 45 days of certain “extraordinary 
events”; and (iv) revises certain definitions to be 
more consistent with similar concepts and approaches 
under the Dodd-Frank Act.  The final rule became 
effective on Oct. 1, 2024.
In 2019, the Federal Reserve and FDIC issued a final 
rule modifying certain requirements for the 165(d) 
resolution plan.  The final rule requires U.S. G-SIBs, 
such as BNY, to file alternating full and more limited, 
targeted resolution plans every two years.  The final 
rule does not materially modify the components or 
informational requirements of full resolution plans.  
BNY submitted a full resolution plan dated July 1, 
2023.  The Federal Reserve and FDIC found no 
deficiencies or shortcomings in BNY’s 2023 
resolution plan submission.
If the Federal Reserve and FDIC jointly determine 
that our 165(d) resolution plan is not credible and we 
fail 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.
The resolution strategy set out in our 165(d) 
resolution plan is a single point of entry strategy, 
whereby certain key operating subsidiaries would be 
provided with sufficient capital and liquidity to 
operate in the event of material financial stress or 
failure, and only our parent holding company would 
file for bankruptcy.  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 
addition, we have a binding support agreement in 
place 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 on an 
ongoing basis.
BNY and the other U.S. G-SIBs are also subject to 
heightened supervisory expectations for recovery and 
resolution preparedness under Federal Reserve rules 
and guidance.  The Federal Reserve incorporates 
reviews of our capabilities in respect of recovery and 
resolution preparedness as part of its ongoing 
supervision of BNY.
In the European Economic Area (“EEA”) and in the 
UK, the Bank Recovery and Resolution Directive, as 
amended by the Bank Resolution and Recovery 
Directive II (“BRRD”), provides the legal framework 
for recovery and resolution planning, including a set 
of harmonized powers to resolve or implement 
recovery of in-scope institutions, such as EEA and 
UK subsidiaries of third country banks.  The UK 
transposed the BRRD into local legislation and 
regulation before the UK exit from the EU on Dec. 
31, 2020.  Existing EU law that was in force and 
applicable in the UK on Dec. 31, 2020, continues to 
be effective under the UK regulatory framework as 
“retained EU law.”
The BRRD, as implemented in local law, gives 
relevant EEA and UK regulators various powers, 
including: (i) powers to intervene pre-resolution to 
require an institution to take remedial steps to avoid 
the need for resolution; (ii) 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); (iii) 
Supervision and Regulation (continued)
BNY 65

the power to require a firm to change its structure to 
remove impediments to resolvability; and (iv) powers 
to require in-scope institutions to prepare recovery 
plans.  Under the BRRD, resolution authorities (rather 
than the institutions themselves) are responsible for 
drawing up resolution plans based on information 
provided by relevant institutions.
Under applicable rules, in-scope institutions are 
required to maintain a minimum requirement for their 
own funds (defined as regulatory capital) and eligible 
liabilities (“MREL”) that can be written down or 
bailed-in to absorb losses.  MREL is set on a case-by-
case basis for each institution and is applicable to 
certain EU and UK domiciled credit institutions and 
certain other firms subject to recovery and resolution 
planning BNY SA/NV is subject to MREL.
Rules on Resolution Stays for Qualified Financial 
Contracts
The Agencies’ regulations require 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.  
The regulations allow these G-SIBs to comply by 
amending covered QFCs (with the consent of relevant 
counterparties) using the International Swaps and 
Derivatives Association (“ISDA”) 2018 U.S. 
Resolution Stay Protocol, ISDA 2015 Universal Stay 
Protocol or by executing appropriate bilateral 
amendments to the covered QFCs.  BNY entities 
which have been confirmed to engage in covered 
QFC activities have adhered to the Protocol and, 
where necessary, have executed bilateral amendments 
to cover QFCs.
Insolvency of an Insured Depository Institution or a 
Bank Holding Company; Orderly Liquidation 
Authority 
Under the FDI Act, if the FDIC is appointed as 
conservator or receiver for an IDI, such as The Bank 
of New York Mellon or 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, including claims of debt holders, in the 
“liquidation or other resolution” of such an institution 
by any receiver.  As a result, regardless of whether 
the FDIC repudiates 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 resolution regime 
(known as the “orderly liquidation authority”) 
applicable to domestic systemically important 
financial companies that are not IDIs, including 
BHCs, such as the Parent, and their non-bank 
affiliates.  Under the orderly liquidation authority, the 
FDIC may be appointed as receiver for the 
systemically important institution, and its failed non-
bank subsidiaries, for purposes of liquidating the 
entity if, among other conditions, it is determined that 
the institution is in default or in danger of default and 
the failure poses a risk to the stability of the U.S. 
financial system.
In liquidations of failing financial institutions where 
the Dodd-Frank orderly liquidation authority applies, 
the orderly liquidation authority supplants the U.S. 
Bankruptcy Code and sets forth the powers of the 
FDIC as receiver and the rights and obligations of 
creditors and other parties who have dealt with the 
financial institution.  The powers of the FDIC as 
receiver under the orderly liquidation authority were 
based on the powers of the FDIC as receiver for IDIs 
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.  
Supervision and Regulation (continued)
66 BNY

Nonetheless, substantial differences in the rights of 
creditors exist 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 in Bank Resolutions
The FDIC applies a priority regime (“depositor 
preference”) for the distribution of receivership assets 
of a failed bank.  Under the depositor preference 
regime, when a U.S. bank fails, the 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.
FDIC 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, 
condition imposed by the FDIC, or written agreement 
between the IDI and the FDIC.
The FDIC’s Deposit Insurance Fund (“DIF”) is 
funded by assessments on IDIs.  The FDIC assesses 
DIF premiums based on an IDI’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 
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.
Following the bank failures in March 2023, the FDIC 
announced that, as required by the FDI Act, any 
losses to the DIF to support uninsured depositors 
would be recovered by a special assessment 
prescribed through regulation.  Under the FDI Act, 
the FDIC has discretion with respect to the design and 
timeframe for any special assessment, which may be 
on IDIs, depository institution holding companies 
(with the concurrence of the Treasury Secretary), or 
both, as the FDIC determines to be appropriate.  The 
FDIC may consider the types of entities that benefit 
from the action taken, economic conditions, the 
effects on the industry, and such other factors as the 
FDIC deems appropriate.
On Nov. 16, 2023, the FDIC adopted a final rule, 
effective April 1, 2024, implementing a special 
assessment on IDIs to recover losses to the DIF 
associated with the 2023 closures of Silicon Valley 
Bank and Signature Bank.  Under the rule, the FDIC 
will collect from each IDI a special assessment, based 
on the IDI’s estimated uninsured deposits (excluding 
the first $5 billion of estimated uninsured deposits 
applied at the banking organization level) as of Dec. 
31, 2022, during an initial special assessment period 
of eight quarters that began in the first quarter of 
2024.  The special assessment is subject to periodic 
adjustment by the FDIC, including early cessation, 
extension or a potential one-time final special 
assessment for any shortfall to the DIF.  We have 
recorded accruals and related adjustments for the 
estimate of the special assessment to noninterest 
expense starting in the fourth quarter of 2023 and 
throughout 2024.
Supervision and Regulation (continued)
BNY 67

BHC as Source of Strength and Liability of 
Commonly Controlled Depository Institutions
The Federal Reserve requires BHCs to act as a source 
of financial and managerial strength to their bank 
subsidiaries.  BNY has a statutory obligation to 
commit resources to its bank subsidiaries in times of 
financial distress.  In addition, any loans by BNY 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 
reorganization under the U.S. Bankruptcy Code, any 
commitment by the BHC to a federal bank regulator 
to maintain the capital of a subsidiary IDI will be 
deemed assumed by the bankruptcy trustee and 
entitled to priority of payment of the unsecured claim 
resulting from such commitment.  Further, in certain 
circumstances, BNY’s IDI subsidiaries could be held 
liable for losses incurred by another BNY IDI 
subsidiary.  In the event of impairment of the capital 
stock of one of BNY’s national bank subsidiaries or 
The Bank of New York Mellon, BNY, as the banks’ 
stockholder, could be required to pay such deficiency.
Bank Transactions with Non-bank Affiliates
Transactions between BNY’s banking subsidiaries, 
on the one hand, and the Parent and its non-bank 
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 in 
good faith, at arm’s-length, and on market terms.  In 
general, extensions of credit by a BNY banking 
subsidiary to any non-bank 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.
Acquisitions/Transactions by Banks or BHCs
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 
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.”
Anti-Money Laundering (“AML”) 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 AML 
requirements for financial institutions that are 
applicable to BNY’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 AML 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.
The Anti-Money Laundering Act of 2020 (“AMLA”), 
which amends the Bank Secrecy Act (“BSA”), was 
enacted to comprehensively reform and modernize 
Supervision and Regulation (continued)
68 BNY

U.S. AML laws.  Among other things, the AMLA 
codifies a risk-based approach to AML compliance 
for financial institutions; requires the development of 
standards by the U.S. Department of the Treasury for 
evaluating technology and internal processes for BSA 
compliance; and expands enforcement- and 
investigation-related authority, including a significant 
expansion in the available sanctions for certain BSA 
violations and instituting BSA whistleblower 
incentives and protections.  The AMLA contains 
many statutory provisions that require additional 
rulemakings, reports and other measures, and the 
rulemaking process has begun for several of these 
provisions.  In June 2021, the first government-wide 
priorities for anti-money laundering and countering 
the financing of terrorism (“AML/CFT Priorities”) 
were published.  These AML/CFT Priorities will need 
to be incorporated into banks’ risk-based BSA 
compliance programs after completion of the 
rulemaking process and on the effective date of the 
final regulations.  The impact of the AMLA will 
depend on, among other things, the completion of the 
rulemaking process and the issuing of implementation 
guidance.
Financial Crimes Enforcement Network (“FinCEN”)
FinCEN, a bureau of the U.S. Department of the 
Treasury, issued rules under the BSA that apply to 
covered financial institutions, including The Bank of 
New York Mellon and BNY Mellon, N.A., setting 
forth five pillars of an effective AML program: 
development of internal policies, procedures and 
related controls; designation of a compliance officer; 
a thorough and ongoing training program; 
independent review for compliance; and customer 
due diligence (“CDD”).  CDD requires a covered 
financial institution 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.
Bank Secrecy Act Extended to Investment Advisers
On Aug. 28, 2024, FinCEN adopted a final rule 
requiring certain investment advisers to establish anti-
money laundering/countering the financing of 
terrorism (“AML/CFT”) programs pursuant to the 
BSA and to monitor for, and report, suspicious 
activity and currency transactions to FinCEN.  
Investment advisers will be required to apply their 
AML/CFT programs to all advisory services provided 
to all customers, except that they will be permitted to 
exclude mutual funds, certain bank- and trust 
company-sponsored collective investment funds, and 
other investment advisers subject to the rule.  Among 
other requirements, the AML/CFT program must (i) 
be risk-based, (ii) be reasonably designed to prevent 
the investment adviser from being used for money 
laundering, terrorist financing, or other illicit finance 
activities and to achieve compliance with applicable 
provisions of the BSA and regulations thereunder, 
(iii) provide for independent compliance testing, and 
(iv) designate responsible persons and ongoing 
training.  Investment advisers must comply with the 
Rule by Jan. 1, 2026.  BNY has evaluated the final 
rule and is implementing a program designed to meet 
the applicable regulatory requirements.
NYSDFS Anti-Money Laundering and Anti-Terrorism 
Regulations
The New York State Department of Financial 
Services (“NYSDFS”) issued regulations requiring 
regulated institutions, including The Bank of New 
York Mellon, to maintain a transaction monitoring 
program to monitor transactions for potential BSA 
and AML violations and suspicious activity reporting, 
and a watch list filtering program to interdict 
transactions prohibited by applicable sanctions 
programs.
The 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 regulations 
also require institutions to submit annually 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, 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”).  The 
Supervision and Regulation (continued)
BNY 69

GDPR contains enhanced compliance obligations and 
penalties for non-compliance.
EU Artificial Intelligence Act
On July 12, 2024, the EU’s Regulation on Artificial 
Intelligence (“AI Act”) was published in the Official 
Journal of the EU and came into force on Aug. 1, 
2024.  The AI Act will apply extraterritorially, 
impacting both EU and non-EU entities, and will 
impact BNY.  The AI Act creates a pan-EU 
regulatory framework to manage the risks associated 
with the use of artificial intelligence, including with 
respect to financial services.  The AI Act requires 
categorization of AI systems into four risk levels 
depending on their potential to harm individuals or 
society (unacceptable risk, high risk, limited risk, and 
minimal risk) and imposes obligations depending on 
the risk categorization, which may include data 
governance, documentation and recordkeeping, 
human oversight, testing, cybersecurity, disclosure, 
regulatory notification or reporting, or training.  In 
addition, the AI Act prohibits AI that pose 
unacceptable risks that are abusive or contradict EU 
values, including AI that may be manipulative, 
exploitive, or discriminatory.  The individual 
provisions of the AI Act apply on a rolling basis from 
Feb. 2, 2025 to Aug. 2, 2027.  BNY has evaluated the 
impact of the AI Act and has established an 
implementation program designed to operationalize 
the regulatory requirements applicable to BNY within 
required time frames.
SEC Conflicts of Interest Rule for Use of Artificial 
Intelligence by Broker-Dealers and Investment 
Advisers
On July 26, 2023, the SEC proposed new rules 
intended to address certain conflicts of interest 
associated with the use of “Covered Technology” by 
broker-dealers and investment advisers (“Firms”) in 
investor interactions (“Proposed AI Rules”).  Covered 
Technology is generally described as applying to 
“artificial intelligence” or “AI” and is broadly defined 
under the Proposed AI Rules to include the use of 
analytical, technological, or computational functions, 
algorithms, models, correlation matrices, or similar 
methods or processes that optimize for, predict, 
guide, forecast, or direct investment-related behaviors 
or outcomes of an investor.  If adopted, the Proposed 
AI Rules would: (i) generally apply when a Firm uses 
a Covered Technology in engaging or communicating 
with an investor, including by exercising discretion 
with respect to an investor’s account, providing an 
investor with information, or soliciting an investor 
and (ii) require Firms to (among other things) identify 
conflicts of interests when using Covered Technology 
in interactions with investors, and adopt policies and 
procedures to eliminate or neutralize those conflicts 
of interest.  We continue to evaluate the potential 
impact of the proposed rules. 
Cybersecurity Regulation
The NYSDFS requires financial institutions regulated 
by NYSDFS, including The Bank of New York 
Mellon, to establish a cybersecurity program, adopt a 
written cybersecurity policy, designate a chief 
information security officer, address artificial 
intelligence risks related to cybersecurity, 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 variety of other requirements to 
protect the confidentiality, integrity and availability 
of information systems, including the annual delivery 
of a certificate of compliance.
The Agencies have adopted a final rule imposing 
notification requirements for significant computer-
security incidents on banking organizations.  Under 
the final rule, a BHC, state member bank or national 
bank, including the Parent, The Bank of New York 
Mellon and BNY Mellon, N.A., is required to notify 
the Federal Reserve or OCC, as applicable, within 36 
hours after a computer-security incident that could: (i) 
result in the banking organization’s inability to 
deliver services to a material portion of its customer 
base, (ii) disrupt the banking organization’s lines of 
businesses the failure of which would result in 
material losses, or (iii) disrupt operations the failure 
of which would threaten the financial stability of the 
U.S.
On July 26, 2023, the SEC adopted rules, effective on 
Sept. 5, 2023, requiring public companies, including 
the Parent, to disclose material cybersecurity 
incidents and details regarding their cybersecurity 
risk management, strategy and governance.  Under 
the rules, public companies must disclose material 
cybersecurity incidents on Form 8-K.  Disclosure of 
material incidents generally is due within four 
business days after a public company determines that 
a cybersecurity incident is material.  On an annual 
basis, public companies must describe in their annual 
report on Form 10-K their processes for assessing, 
Supervision and Regulation (continued)
70 BNY

identifying, and managing, and management’s role 
and expertise in assessing and managing, material 
cybersecurity risks; whether any cybersecurity risks 
have materially affected or are reasonably likely to 
material affect the company; and the board of 
directors’ oversight of cybersecurity risks.
On March 15, 2023, the SEC proposed a new rule 
regarding cybersecurity risk management for entities 
including broker-dealers, security-based swap 
dealers, and transfer agents.  The proposed rule would 
require such entities to maintain written policies and 
procedures to address their cybersecurity risk, 
immediately notify the SEC of significant 
cybersecurity incidents, and publicly disclose 
descriptions of their cybersecurity risks and 
significant cybersecurity incidents.
In addition, on March 15, 2023, the SEC proposed 
amendments to Regulation S-P, including a 
requirement for broker-dealers, investment 
companies, RIAs, and transfer agents to adopt written 
policies and procedures for an incident response 
program with respect to unauthorized access to or use 
of customer information.  The proposal would require 
these entities to notify individuals whose sensitive 
customer information was accessed or used without 
authorization not later than 30 days after becoming 
aware that the information was compromised.  BNY 
is evaluating the potential impact of the proposals.
SEC Amendments to Regulation S-P for Safeguarding 
of Customer Information
On May 16, 2024, the SEC adopted amendments (the 
“S-P Amendments”) to Regulation S-P, which 
governs the safeguarding, treatment and disposal of 
customer records and information by certain financial 
institutions, to enhance the protection of customer 
financial information and establish a federal 
minimum standard for data breach notifications to 
affected individuals by brokers, dealers, investment 
companies, registered investment advisers and 
transfer agents (“S-P covered institutions”).  The S-P 
Amendments: (i) extend certain requirements of 
Regulation S-P to transfer agents registered with the 
SEC or another appropriate regulatory agency; (ii) 
require S-P covered institutions to develop, 
implement, and maintain written policies and 
procedures for an incident response program that is 
reasonably designed to detect, respond to, and recover 
from unauthorized access to or use of customer 
information; (iii) set forth a data breach notification 
requirement that requires S-P covered institutions to 
notify affected individuals whose customer 
information was, or is reasonably likely to have been, 
accessed or used without authorization (subject to 
certain exceptions) within 30 days after the S-P 
covered institution becomes aware that unauthorized 
access to or use of customer information has, or is 
reasonably likely to have, occurred; (iv) broaden the 
group of customers whose information is protected; 
(v) address the use of service providers by S-P 
covered institutions; and (vi) codify an existing 
statutory exemption to the requirement to provide 
annual privacy notices to customers.  The S-P 
Amendments are effective as of Aug. 2, 2024 and 
BNY will have 18 months to come into compliance.  
BNY has evaluated the S-P Amendments and is 
implementing a program designed to meet the 
applicable regulatory requirements.
Sustainability
The SEC adopted a final rule, on March 6, 2024,  
requiring registrants, including BNY, to disclose 
material climate-related information in registration 
statements and periodic reports; however, the final 
rule is currently subject to multiple legal challenges 
and, on April 4, 2024, the SEC voluntarily issued an 
order staying the final rule pending the completion of 
judicial review of the legal challenges.  In addition, 
the SEC’s May 2022 proposed rule and form 
amendments under the Investment Company Act of 
1940, as amended (the “1940 Act”) and the 
Investment Advisers Act of 1940 remains pending 
and would require certain registered investment funds 
and certain investment advisers to provide enhanced 
disclosures regarding environmental, social, and 
governance factors considered.  Implementation of 
the SEC rules is currently uncertain.
A number of states have proposed or enacted laws 
and regulations addressing climate disclosure. For 
example, California enacted three statutes imposing 
extensive new climate-related disclosure obligations 
on certain companies doing business in California, 
which became effective on Jan. 1, 2024, including the 
Climate Corporate Data Accountability Act (as 
updated in 2024, “SB 253”), which requires annual 
disclosure of greenhouse gas emissions beginning in 
2026, and the Climate-Related Financial Risk Act (as 
updated in 2024, “SB 261”), which requires 
publication of biennial reports disclosing climate-
related financial risks and the measures adopted to 
mitigate the disclosed risks beginning on Jan. 1, 
Supervision and Regulation (continued)
BNY 71

2026.  Conversely, certain states have enacted or 
implemented, or have proposed to enact or 
implement, statutes, regulations or policies that 
prohibit financial institutions from denying or 
canceling products or services to a person, or 
otherwise discriminating against a person in making 
available products or services, on the basis of social 
credit scores and certain other sustainability factors. 
In Europe, EU entities in-scope for the Corporate 
Sustainability Reporting Directive (“CSRD”) will 
soon be subject to new requirements to disclose 
information about impacts, risks, and opportunities 
related to sustainability matters.  Five EU subsidiaries 
of BNY are currently subject to these requirements, 
with BNY SA/NV required to report in 2025 and the 
remaining four subsidiaries currently scheduled to 
report in 2026.  However, on Feb. 26, 2025, the 
European Commission published proposals aimed at 
simplifying the EU sustainability rules (the “Omnibus 
Package”).  Under the Omnibus Package, only 
companies with more than 1,000 employees and 
either a turnover above EUR 50 million or a balance 
sheet total above EUR 25 million would be obliged to 
report under CSRD.  In addition, there is a proposal 
to postpone the application of all reporting 
requirements for companies currently in scope of 
CSRD and which are required to report as of 2026 
and 2027 until 2028. 
The Omnibus Package also puts forward proposals 
that would amend the obligations under the current 
Corporate Sustainability Due Diligence Directive 
(“CSDDD”).  CSDDD entered into force in the EU 
on July 25, 2024, and applies to large EU companies 
and non-EU companies with significant EU activity.  
Under the current legislative text, CSDDD will apply 
on a phased-in basis, starting three years after 
CSDDD’s entry into force, dependent on a 
company’s number of employees and net worldwide 
or EU turnover.  In-scope companies are required to 
comply with due diligence obligations for their 
operations and for their upstream chains of activities 
and to adopt a transition plan for climate change 
mitigation.  The Omnibus Package introduces 
proposals aimed at simplifying aspects of CSDDD’s 
sustainability due diligence requirements and 
postponing the first phase of their application 
(covering the largest companies) to July 26, 2028.
If the proposals put forward by the European 
Commission under the Omnibus Package are 
implemented, this may have a direct impact on the 
obligations of the BNY entities currently in scope of 
CSRD and CSDDD.
Our UK supervisory authorities have adopted new 
disclosure requirements and supervisory expectations 
that currently apply or will apply to our subsidiaries 
and branches that are regulated by the UK Financial 
Conduct Authority (“FCA”) and the UK Prudential 
Regulation Authority (“PRA”).  For example, since 
the end of 2021 our PRA regulated branch and 
banking subsidiary have been subject to the PRA’s 
supervisory expectations for the management of 
climate-related financial risks, including as regards 
governance, risk management, scenario analysis and 
disclosure.  Further, new FCA rules on anti-
greenwashing will require that from May 31, 2024, 
any sustainability-related claims made about our 
products and services by our FCA regulated entities 
are consistent with the sustainability characteristics of 
such products or services and are fair, clear and not 
misleading.  
Published guidance from our regulators globally, 
including the Agencies and NYSDFS, has primarily 
focused on climate-related financial risk 
management, including with respect to, among other 
things, governance, policies and procedures, strategy, 
risk management, data and reporting, and scenario 
analysis.  As the global regulatory framework for 
climate and sustainability-related disclosure and risk 
management practices continues to evolve, including 
potential expansion, contraction or streamlining of 
regulations, we continue to monitor developments 
and evaluate the potential impacts on our business 
and operations.
Incentive Compensation Arrangements
Section 956 of the Dodd-Frank Act requires six 
federal regulators to jointly prescribe regulations or 
guidelines regarding incentive-based compensation 
practices at certain financial institutions, including 
BNY.  The timeframe for a joint proposal and 
implementation of a final rule, if any, is currently 
unknown. 
Regulated Entities of BNY and Ancillary Regulatory 
Requirements
BHC and Bank Entities
BNY is registered as an FHC under the BHC Act and 
subject to supervision by the Federal Reserve.  In 
Supervision and Regulation (continued)
72 BNY

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 
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. IDI subsidiaries qualifying on an 
ongoing basis as “well capitalized” and “well 
managed” under the prompt corrective action 
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. IDI subsidiaries’ continuing to maintain at least 
a “satisfactory” rating under the CRA.
The Federal Reserve’s rating system for the 
supervision of large financial institutions (“LFIs”) 
applies to, among other entities, all BHCs with total 
consolidated assets of $100 billion or more, including 
BNY.  The LFI rating system includes a 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.  See “U.S. Capital Rules – Leverage 
Ratios” and “Prompt Corrective Action Regarding 
IDI Capital Requirements” above for details on 
qualifying as “well capitalized.” 
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, continue current activities, 
or make acquisitions that are not generally 
permissible for BHCs without FHC status.  As of 
Dec. 31, 2024, BNY 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’s largest 
banking subsidiary, is a New York state-chartered 
bank, a member of the Federal Reserve and subject to 
regulation, supervision and examination by the 
Federal Reserve, the FDIC and the NYSDFS.  BNY’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.
On Aug. 8, 2023, the Federal Reserve issued a 
Supervision and Regulation Letter (SR 23-7) 
announcing the establishment of its Novel Activities 
Supervision Program (“NASP”) to complement its 
existing supervision and oversight of supervised 
banking organizations, including BNY.  The NASP 
encompasses risk-based monitoring and examination 
and focuses on, novel activities related to crypto-
assets, distributed ledger technology, and complex, 
technology-driven partnerships with non-bank 
providers of banking products and services to 
customers.  The Federal Reserve also evaluates, under 
the NASP, the concentrated provision of banking 
services to crypto-asset-related entities and fintechs. 
Securities Markets
We operate a number of broker-dealers that engage in 
securities underwriting and other broker-dealer 
activities in the U.S.  These companies are SEC-
registered broker-dealers and members of Financial 
Industry Regulatory Authority, Inc. (“FINRA”), a 
securities industry self-regulatory organization.  
BNY’s non-bank subsidiaries engaged in securities-
related activities are regulated by supervisory 
agencies in the countries in which they conduct 
business, where required.
Certain of BNY’s public finance and advisory 
activities are regulated by the Municipal Securities 
Rulemaking Board and the relevant BNY affiliates 
have registered with the SEC, as required under the 
SEC’s Municipal Advisors Rule 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’s subsidiaries are registered with the 
CFTC as commodity pool operators, introducing 
Supervision and Regulation (continued)
BNY 73

brokers and/or commodity trading advisors and, as 
such, are subject to CFTC regulation.  The Bank of 
New York Mellon is 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.
On Dec. 13, 2023, the SEC approved a final rule 
requiring covered clearing agencies that clear 
transactions in U.S. Treasuries (“CCPs”) to establish 
policies requiring their direct participants, including 
BNY, to submit for clearing all “eligible secondary 
market transactions” in U.S. Treasuries to which such 
direct participant is a counterparty, which include all 
repurchase and reverse repurchase agreements 
(“repo”) collateralized by U.S. Treasuries and certain 
cash transactions in U.S. Treasuries engaging specific 
institutions, including inter-dealer brokers, registered 
broker-dealers, government securities brokers and 
government securities dealers.  Eligible secondary 
market transactions, however, exclude (i) repo 
transactions with affiliates (under certain conditions), 
central banks, sovereign entities, international 
financial institutions, natural persons and CCPs and 
(ii) securities lending transactions involving U.S. 
Treasuries.  The compliance date for all eligible cash 
market transactions is Dec. 31, 2026 and the 
compliance date for all eligible repo market 
transactions is June 30, 2027.
SEC Rules Impacting Investment and Wealth 
Management
SEC regulations impose requirements on mutual 
funds, exchange-traded funds and other registered 
investment companies (“RICs”) under the 1940 Act.  
Among other things, these rules require mutual funds 
(other than money market funds) to provide portfolio-
wide and position-level holdings data to the SEC on a 
monthly basis.
The regulations 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.
On July 12, 2023, the SEC adopted amendments to 
rules that govern money market funds.  The 
amendments became effective Oct. 2, 2023, with 
tiered compliance dates.  The amendments include, 
among other things: (i) a mandatory liquidity fee for 
institutional prime and institutional tax-exempt 
money market funds, which will apply when a fund 
experiences daily net redemptions that exceed 5% of 
net assets (effective Oct. 2, 2023); (ii) maintenance of 
a fund board’s ability to impose liquidity fees (not to 
exceed 2% of the value of the shares redeemed) on a 
discretionary basis for non-government money 
market funds (effective April 2, 2024); (iii) 
substantially increasing the required minimum levels 
of daily and weekly liquid assets for all money 
market funds from 10% and 30%, to 25% and 50%, 
respectively (effective April 2, 2024); and (iv) 
removal of a money market fund’s ability to impose 
temporary “gates” to suspend redemptions in order to 
prevent dilution and remove the link between a 
money market fund’s liquidity level and its 
imposition of liquidity fees (effective Oct. 2, 2023).
On Sept. 20, 2023, the SEC adopted amendments 
expanding the scope of terms that the SEC considers 
materially deceptive and misleading in a fund’s name 
without a corresponding policy and related controls to 
invest at least 80% of the fund’s net asset value (plus 
certain borrowings) in the manner suggested by the 
fund’s name (“80% Policy”), including names that 
reference “growth” or “value,” or a name indicating 
that investment decisions incorporate any 
environmental, social and governance factors.  The 
amendments became effective Dec. 10, 2023 and 
fund groups will have either 24 months or 30 months 
to come into compliance, depending upon their net 
asset size.
On Oct. 26, 2022, the SEC proposed for comment 
new rules to prohibit RIAs from outsourcing certain 
services and functions without first meeting certain 
threshold requirements, including conducting due 
diligence, and thereafter requiring ongoing 
monitoring of the service providers.  The proposal 
would apply to RIAs that outsource select “covered 
functions,” which include those services or functions 
that are necessary for providing advisory services in 
compliance with federal securities laws and that, if 
not performed or performed negligently, would result 
in potential harm to clients.  The proposal would 
further require RIAs to conduct due diligence and 
monitoring for all third-party recordkeepers and 
obtain reasonable assurances that the recordkeepers 
will meet certain standards.  Finally, it would require 
RIAs to maintain books and records related to the 
new rule’s oversight obligations and to report census-
Supervision and Regulation (continued)
74 BNY

type information about the service providers covered 
under the rule.  We continue to evaluate the impact of 
the proposed rule.
On Nov. 2, 2022, the SEC proposed for public 
comment rule amendments that would require the 
adoption of “swing pricing” and a “hard close” by all 
open-end RICs other than money market funds and 
exchange-traded funds (“Open-End Funds”).  The 
requirements would alter the manner in which shares 
in Open-End Funds are traded, as shareholders would 
no longer receive the NAV per share for their 
transactions but instead could receive a price more or 
less than the NAV depending on whether a “swing 
factor” was applied to their transaction.  This swing 
factor would be the amount by which the Open-End 
Fund adjusts its per-share NAV and would represent 
a good-faith estimate of the transaction costs imposed 
on current shareholders of the Open-End Fund by the 
transacting shareholders.  To facilitate the operation 
of swing pricing, the SEC also proposed to require a 
“hard close” for Open-End Funds, which would make 
a purchase or sale order for shares of an Open-End 
Fund eligible for a given day’s price only if the Open-
End Fund or certain designated agents receive the 
order before the time when the Open-End Fund 
calculates its NAV, which is typically as of 4:00 PM 
Eastern Time.  We continue to evaluate the impact of 
the proposed rule.
SEC Rule 6c-11 (the “ETF Rule”) under the 1940 Act 
permits exchange traded funds (“ETFs”) that satisfy 
certain conditions to organize and operate without 
first obtaining an exemptive order from the SEC and 
requires an ETF to make certain disclosures, 
including historical data on an ETF’s premiums, 
discounts and bid-ask spread information, as well as 
the ETF’s daily portfolio holdings.  The ETF Rule 
also requires ETFs using custom baskets to put 
written policies and procedures in place establishing 
that the custom baskets are in the best interests of the 
ETF and its shareholders.  Pursuant to the ETF Rule, 
BNY has launched a number of ETFs.
Certain of our subsidiaries are RIAs, 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 RICs, including the BNY Mellon Family of 
Funds and BNY Mellon ETF Funds, and private 
investment companies which are not registered under 
the 1940 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.  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 Regulation Best Interest (“Reg BI”) requires 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.  The Form CRS Relationship 
Summary (“Form CRS”) requires RIAs and broker-
dealers to provide retail investors with a brief 
summary about the nature of their relationship with 
their investment professional and supplements other 
more detailed disclosures.
On Feb. 15, 2023, the SEC adopted final rule 
amendments to shorten the standard settlement cycle 
for certain broker-dealer securities transactions to 
T+1.  The compliance date for the transition to T+1 
settlement under the final rule for in-scope 
transactions was May 28, 2024. 
On Dec. 14, 2022, the SEC proposed four 
rulemakings related to market structure, including a 
proposed Regulation Best Execution, which would 
establish a best execution regulatory framework for 
broker-dealers, and proposals regarding order 
competition and disclosure of order execution 
information.  We continue to assess the potential 
impacts of the proposals.
On Feb. 15, 2023, the SEC proposed amendments to 
the custody rule under the 1940 Act, which generally 
requires RIAs deemed to have custody of client funds 
or securities to, among other requirements, maintain 
client funds or securities with a qualified custodian.  
The proposal would expand the types of investments 
covered by the custody rule to include any client 
“assets.” It would also require RIAs to enter into a 
written agreement with, and obtain reasonable 
assurances from, the qualified custodian that the 
custodian will comply with protections in the 
proposed rule, including with respect to 
indemnification of the client, responsibility for 
subcustodians and central securities depositaries, 
asset segregation, and not subjecting client assets to 
any liens.  In addition, the SEC proposed 
Supervision and Regulation (continued)
BNY 75

amendments to the investment adviser recordkeeping 
rule to require advisers to keep additional, more 
detailed records.  We continue to evaluate the 
potential impact of the proposals.
Operations and Regulations Outside the U.S.
We maintain a presence in the UK through the 
London branch of The Bank of New York Mellon, 
The Bank of New York Mellon (International) 
Limited (a credit institution incorporated and 
authorized in the UK), and a number of our 
investment firms.  We maintain a presence in the EU 
through the Frankfurt branch of The Bank of New 
York Mellon, BNY SA/NV, which is headquartered 
in Belgium and has a branch network in a number of 
other EU countries, and through certain of our 
investment firms.
BNY 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 and is authorized to carry out all banking 
and savings activities as a credit institution.  The 
European Central Bank (the “ECB”) has 
responsibility for the direct supervision of significant 
banks and banking groups in the Euro area, including 
BNY SA/NV.  The ECB’s supervision is carried out 
in conjunction with the relevant national prudential 
regulator (the National Bank of Belgium in BNY SA/
NV’s case), as part of the Single Supervisory 
Mechanism.  BNY SA/NV conducts its activities in 
Belgium as well as through its branch offices in 
Denmark, France, Germany, Ireland, Italy, 
Luxembourg, the Netherlands, Poland and Spain.  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 BNY’s U.S. regulators.
Certain of our financial services operations in the UK 
are subject to regulation and supervision by the FCA 
and the 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’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, are registered with the FCA and are 
offered for sale to retail investors in the UK.
The types of activities in which the foreign branches 
of our banking subsidiaries and our international 
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.
The primary prudential framework in the EU is 
provided by the Capital Requirements Directive (“EU 
CRD”) and Capital Requirements Regulation (“EU 
CRR”), both of which implement many elements of 
the Basel III framework.  On July 9, 2024, the texts of 
the EU Capital Requirements Regulation 3 (“CRR3”) 
and Capital Requirements Directive 6 (“CRD6”) 
came into effect and will be implemented in phases 
through to January 2027.  Through these regulations, 
the EU will implement the Basel 3.1 standards via 
amendments to EU CRD and CRR.  These changes 
will affect the operations of BNY SA/NV (including 
capital and liquidity requirements) and the Frankfurt 
branch of The Bank of New York Mellon (including a 
capital endowment requirement and additional 
governance, reporting and supervisory obligations).  
In addition, CRD6 will restrict the provision of 
prescribed core banking services by non-EU entities 
to EU clients, except where these services are 
provided through an authorized EU branch or where 
an exemption applies. 
The UK’s version of the EU Capital Requirements 
Regulation (“UK CRR”) provides the prudential 
framework for credit institutions in the UK.  Aspects 
of UK CRR are currently proposed to be amended as 
Supervision and Regulation (continued)
76 BNY

part of the PRA’s plans to implement the Basel 3.1 
standards in the UK.  The amended rules, which will 
be relevant to the operations of The Bank of New 
York Mellon (International) Limited, are set to apply 
from Jan. 1, 2027.  
In the EU, the Investment Firms Directive/Investment 
Firms Regulation (“IFD/IFR”) is the EU’s prudential 
regime for investment firms.  The UK has 
implemented its version of the IFD/IFR via the UK 
Investment Firms Prudential Regime (“UK IFPR”).  
Under both IFD/IFR and UK IFPR, the capital 
requirements for most investment firms are based on 
factors that are more tailored to the risks that 
investment firms face, rather than Basel standards for 
banks such as credit risk, market risk or operational 
risk.  BNY has several EU and UK-domiciled 
investment firms that are subject to IFD/IFR and UK 
IFPR respectively.
In addition, various proposed changes to regulations 
in both the EU and the UK may impact our business.  
In the EU, this includes the revised Markets in 
Financial Instruments Directive II and Markets in 
Financial Instruments Regulation (collectively, 
“MiFID II”), the revised Alternative Investment Fund 
Managers Directive (“AIFMD”), the Securitisation 
Regulations, the revised regulation on OTC 
derivatives, central counterparties and trade 
repositories (commonly known as “EMIR”), and the 
revised Payment Services Directive II (“PSD”).
The UK continues to implement post-Brexit changes 
to its financial services’ regulatory framework as part 
of an ongoing work program by HM Treasury, the 
FCA and the PRA.  This program is undertaken 
pursuant to a range of initiatives, including the UK 
Government’s Edinburgh Reforms (a series of 
measures to promote stability and competitive growth 
in the UK financial markets post-Brexit), the 
Financial Services and Markets Act 2023, the Smarter 
Financial Services Regulatory framework (which 
continues to progress with the replacement of 
assimilated EU law), and the UK's Wholesale 
Markets Review.
The lines of business included in our Securities 
Services, Market and Wealth Services and Investment 
and Wealth Management business segments 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.
BNY continues to assess the impact of the 
forthcoming changes outlined above on its operations.
Operational Resilience in Europe
The EU’s Digital Operational Resilience Act 
(“DORA”) became effective on Jan. 17, 2025 and 
harmonizes operational resiliency requirements 
across the EU.  DORA is broadly aligned with the 
BCBS’ Principles for Operational Resilience, with a 
focus on reducing risk of failure of information and 
communication technology and the risk related to 
financial entities’ dependencies on these items.  
DORA requires financial entities operating in the EU, 
including BNY SA/NV and the Frankfurt branch of 
The Bank of New York Mellon to establish an 
information and communications technology risk 
management framework, including monitoring and 
testing, incident response, business continuity, and 
third-party risk management.  BNY has implemented 
a program designed to meet the applicable 
requirements. 
Banks and branches operating in the UK, including 
the London branch of The Bank of New York Mellon 
and The Bank of New York Mellon (International) 
Limited, are required to finalize implementation of 
PRA and FCA requirements on operational resilience 
by March 31, 2025.  The UK’s operational resilience 
regime requires in-scope firms to identify “important 
business services” critical to operations, map 
necessary resources, processes and information to 
deliver the critical services, establish maximum 
disruption impact tolerances and related testing, 
maintain a communication strategy, and document the 
processes in policies and procedures.  BNY has 
evaluated the final rules and is working towards 
implementing applicable requirements. 
Funds Regulation in Europe
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 the Directive on Undertakings for 
Supervision and Regulation (continued)
BNY 77

Collective Investment in Transferable Securities 
(“UCITS V”).
Under the regulations for depositary safekeeping 
duties under AIFMD and UCITS V, the European 
Commission recognizes the use of omnibus account 
structures when accounting for assets in a chain of 
custody, but requires that depositaries and trustees, 
such as BNY, maintain their own books and records.
On April 15, 2024, an EU directive amending the 
AIFMD entered into force (known as “AIFMD II”).  
The revised AIFMD II regime introduces updated 
rules for depositaries, a new loan origination 
framework, and liquidity management rules for 
alternative investment funds (“AIFs”).  EU Member 
States have until April 2026 to implement the 
relevant changes under AIFMD II into their national 
laws.  BNY is assessing the impact of the changes on 
its business.
Supervision and Regulation (continued)
78 BNY

An investment in securities issued by us involves 
certain risks that you should carefully consider and 
evaluate both at the time of initial purchase and 
throughout the holding period of such securities.  The 
following discussion sets forth the most material 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.  Additionally, factors 
other than those discussed below or in our other 
reports filed with or furnished to the SEC could also 
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 
considerations 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.”
Summary
Investing in our securities and in the securities of 
banks and financial services companies more broadly 
is inherently risky.  Our business, financial condition 
and results of operations may be materially and 
adversely affected by various risk types and 
considerations, including operational risk, market 
risk, credit risk, capital and liquidity risk, strategic 
risk and additional risks, including as a result of the 
following:
Operational Risk
•
Errors or delays in our operational and 
transaction processing, or those of third parties.
•
Our risk management framework, policies and 
processes not being effective in identifying or 
mitigating risk and reducing the potential for 
losses and any inadequacy or lapse in our risk 
management framework, policies and processes 
exposing us to unexpected losses.
•
Limitations of the models we use to measure, 
monitor and manage risk.
•
A communications or technology disruption or 
failure within our infrastructure or the 
infrastructure of third parties that results in a loss 
of information, delays our ability to access 
information or impacts our ability to provide 
services to our clients.
•
A cybersecurity incident, or failure in our 
computer systems, networks and information, or 
those of third parties, resulting in the theft,  
disclosure, use or alteration of information, 
unauthorized access to or loss of information, or 
system or network failures.
•
The development and use of artificial 
intelligence.
•
Extensive government rulemaking, policies, 
regulation and supervision that impact our 
operations, and changes to and introduction of 
new rules and regulations compelling us to 
change how we manage our businesses.
•
Regulatory or enforcement actions or litigation.
•
Failure to attract, retain, develop and motivate 
employees.
•
Failure or circumvention of our controls, policies 
and procedures.
Market Risk
•
Weakness and volatility in financial markets and 
the economy generally.
•
Dependence on fee-based business and fee-based 
revenues, which could be adversely affected by 
slowing market activity, weak financial markets, 
underperformance and/or negative trends in 
savings rates or in investment preferences.
•
Levels of and changes in interest rates impacting 
our profitability and capital levels.
•
Unrealized or realized losses on securities related 
to volatile and illiquid market conditions, 
reducing our capital levels and/or earnings.
Credit Risk
•
Failure or perceived weakness of any of our 
significant clients or counterparties, and our 
assumption of credit, counterparty and 
concentration risk.
•
Inadequacy in our allowance for credit losses, 
including loan and lending-related commitment 
reserves and a deterioration in our expectations of 
future economic conditions.
Capital and Liquidity Risk
•
Failure to effectively manage our liquidity.
•
Failure to satisfy regulatory standards, including 
“well capitalized” and “well managed” status or 
Risk Factors
BNY 79

capital adequacy and liquidity rules more 
generally. 
•
The Parent’s dependence 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, payment of income taxes and 
payment of dividends to its stockholders.
•
Ability to return capital to shareholders, which 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 
capital planning, applicable provisions of 
Delaware law and our failure to pay full and 
timely dividends on our preferred stock.
•
Any material reduction in our credit ratings or the 
credit ratings of our principal bank subsidiaries, 
The Bank of New York Mellon, BNY Mellon, 
N.A. or The Bank of New York Mellon SA/NV, 
which could increase the cost of funding and 
borrowing to us and our rated subsidiaries.
•
The application of our Title I preferred resolution 
strategy or resolution under the Title II orderly 
liquidation authority.
Strategic Risk
•
New lines of business, new products and services 
or transformational or strategic project initiatives, 
and the failure to implement these initiatives.
•
Our strategic transactions. 
•
Failure to realize some or all of the expected 
benefits of our transition to a platforms operating 
model.
•
Competition in all aspects of our business.
Additional Risks
•
Adverse events, publicity, government scrutiny or 
other reputational harm. 
•
Impacts from geopolitical events, acts of 
terrorism, war, natural disasters, the physical 
effects of climate change, pandemics and other 
similar events.
•
Sustainability concerns, including a focus on 
climate change and diversity, which could 
adversely affect our business, affect client 
activity levels, subject us to additional regulatory 
requirements and damage our reputation.
•
Tax law changes or challenges to our tax 
positions with respect to historical transactions.
•
Changes in accounting standards governing the 
preparation of our financial statements and future 
events.
Operational Risk
Errors or delays in our operational and transaction 
processing, or those of third parties, may materially 
adversely affect our business, financial condition, 
results of operations and reputation.
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, therefore, 
are subject to execution and processing errors and 
failures.  In situations reliant upon manual processes, 
the risk of execution and processing errors and 
failures is heightened.  Manual processes are 
inherently more prone to human and other processing 
error, malfeasance, fraud and other misconduct than 
automated processes.  With more complex and 
voluminous transactions at ever increasing speeds, 
which present an increased risk of error or significant 
operational delay, we must continuously evolve and 
automate our processes, controls, technology, systems 
and workforce in a manner designed to achieve 
accurate and timely execution of these transactions.  
When errors or delays do occur, they may be difficult 
to detect and remediate in a timely manner.  The use 
of automation, artificial intelligence and other 
emerging technologies in connection with automated 
processes, may amplify the impact of any such error 
or delay, as the failure to timely discover and respond 
to an operational error can have dramatic 
consequences, especially in connection with 
automated processes in light of the speed and volume 
of transactions involved.  These risks are heightened 
in connection with the implementation of new 
products, systems or processes, which may present 
new risks that may not be adequately identified, or for 
which we may not have adequate controls.  
Furthermore, the risks resulting from an operational 
error may be heightened with respect to certain asset 
classes, such as some digital assets, with respect to 
which it may be impossible to retrieve wrongfully or 
erroneously transferred digital assets.
Risk Factors (continued)
80 BNY

Our business, financial, accounting and processing 
systems or other operating systems may stop 
operating properly, become insufficient or become 
disabled or damaged as a result of a number of factors 
including events that are wholly or partially beyond 
our control.  We have experienced, and in the future 
expect to continue to experience, operational errors 
and delays and disruptions to our transaction 
processing systems.  Such operational errors, 
disruptions or significant operational delays could 
have a material and negative impact on our ability to 
conduct our business or service our clients, which 
could adversely affect our results due to potentially 
higher expenses and lower revenues, lower our 
capital ratios, create liability for us or our clients or 
negatively impact our reputation.  We also recognize 
that service reliability and systems resilience are 
essential components to processing transactions and 
safeguarding financial assets, and an operational error 
impacting a large number of transactions could have 
unfavorable ripple effects in the financial markets, 
which could exacerbate the adverse effects of the 
error on us.  There can be no assurance that our 
business continuity response plans will effectively 
mitigate our operational risks, and any backup 
systems or processes may not sufficiently replace our 
primary systems.
Affiliates or third parties (including their downstream 
service providers) with which we do business or that 
facilitate our business activities, including by 
providing data, information, technology, security or 
infrastructure services, have been, and could in the 
future continue to be, sources of execution and 
processing errors, breaches or loss, failures or 
significant operational delays.  These risks may be 
amplified to the extent third parties (including their 
downstream service providers, such as those that 
provide data, cloud computing or other security or 
technology services) with which we do business have 
adopted the use of automation, artificial intelligence 
and other emerging technologies.  These risks are 
further heightened to the extent that we rely on a 
limited, or otherwise concentrated, set of third parties 
with respect to certain processes or business 
activities. 
Our operations must comply with complex and 
evolving laws and regulations, including heightened 
regulatory and supervisory expectations with respect 
to operational and information security systems.  In 
certain jurisdictions, we may be deemed to be 
statutorily or criminally liable for operational errors, 
fraud, breakdowns or delays by affiliates or third 
parties with which we do business or that facilitate 
our business activities.  Additionally, as a result of 
regulations, including the Alternative Investment 
Fund Managers Directive and the Undertakings for 
Collective Investment in Transferable Securities V, 
when we act as depositary in the European Economic 
Area, we 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.  When we are not acting as a 
European Economic Area depositary, we may accept 
similar liabilities to that of a European Economic 
Area depositary as a matter of contract in connection 
with our custody services. 
Our risk management framework, policies and 
processes may not be effective in identifying or 
mitigating risk and reducing the potential for losses 
and any inadequacy or lapse in our risk 
management framework, policies and processes 
could expose us to unexpected losses that could 
materially adversely affect our results of operations 
or financial condition.
Our risk management framework seeks to identify 
and 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, model risk and 
strategic risk.  We have also established frameworks 
designed to mitigate risk and loss to us as a result of 
the actions of affiliates or third parties with which we 
do business (including their common and downstream 
service providers) 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 may not have appropriately 
anticipated, identified or monitored.
Our regulators remain focused on ensuring that 
financial institutions build and maintain robust risk 
management policies.  Regulators’ views of the 
quality of our risk models and framework affect our 
regulators’ evaluations of us, and we are exposed to 
the risk of adverse regulatory and supervisory 
developments, including enforcement actions and 
increased costs in connection with remediation 
efforts, if our regulators view our risk models and 
framework to be insufficient or if remediation is not 
Risk Factors (continued)
BNY 81

completed in a timely manner.  Accurate and timely 
enterprise-wide risk information is necessary to 
enhance management’s decision-making in times of 
crisis.  If our risk management framework or 
governance structure 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 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, industry or the financial markets or fail to 
adequately or timely enhance our risk framework to 
address those changes.  If our risk framework is 
ineffective because it fails to keep pace with changes 
in the industry, financial markets, regulatory 
requirements, our businesses, our counterparties, 
clients or service providers or for other reasons, we 
could incur losses, suffer reputational damage, face 
significant remediation expenses or find ourselves out 
of compliance with applicable regulatory or 
contractual mandates or supervisory expectations.
Our control environment and related systems, from 
time to time, have in the past not sufficiently 
detected, and may in the future not sufficiently detect, 
each error, omission or other mistake made by us.  
These have in the past included, and may in the future 
include, calculation errors, errors in software or 
model development or implementation, data or 
informational errors or incompleteness, or errors in 
judgment.  Human errors, malfeasance, failure to 
follow applicable policies, laws, rules or procedures 
and other misconduct in connection with our risk 
management framework, policies and processes, even 
if promptly discovered and remediated, have in the 
past resulted, and could in the future result, in 
inaccurate reporting to regulatory bodies, reputational 
damage and losses and liabilities for us. 
An important aspect of our risk management 
framework is creating a risk culture that is sustainable 
and appropriate to our role as a major financial 
institution in which our employees 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 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 – Overview.”
Limitations of the models we use to measure, 
monitor and manage risk could lead to unexpected 
losses and adverse business impacts.
We rely on quantitative and qualitative models, 
analytical techniques and judgment-based estimations 
to measure, monitor and manage various risks, 
including credit, market, liquidity and operational 
risks.  These models are also used for financial and 
other regulatory reporting, capital planning and other 
critical functions.  While essential for decision-
making, models are inherently limited and subject to 
inaccuracies stemming from flawed assumptions, 
design issues or evolving market conditions. Further, 
even absent flawed or inadequate model assumptions, 
design issues and data inaccuracies, there can be no 
assurance that the models we utilize will adequately 
mitigate risk or loss to us under all circumstances.  
Our models depend on historical data, assumptions 
and correlations that may not accurately predict future 
conditions, particularly during periods of market 
stress or economic uncertainty.  For example, 
unexpected geopolitical events, rapidly evolving 
market conditions or unforeseen economic downturns 
may render model assumptions inadequate.  
Additionally, models may fail to fully capture 
interdependencies among risk factors, leading to 
incomplete or misleading outputs.
In certain instances, we rely on models to measure, 
monitor and predict risks, including as part of our 
overall asset/liability management.  However, these 
models are inherently limited because they involve 
techniques, including the use of historical data and 
trends, assumptions, estimates, judgments and 
forecasts, which may be incomplete or inaccurate.  
These models cannot anticipate every economic and 
financial outcome, particularly during severe market 
downturns, geopolitical events or other stress events 
such as those experienced during the COVID-19 
pandemic or in connection with the insolvencies of 
Silicon Valley Bank and Signature Bank in 2023. 
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 
Risk Factors (continued)
82 BNY

limitations of managing unanticipated risks.  In times 
of market stress, limited liquidity or other unforeseen 
circumstances, previously uncorrelated indicators 
may become correlated, or previously correlated 
indicators may move in different directions.  
Additionally, sudden illiquidity in markets or declines 
in prices of certain assets may make it more difficult 
to value certain financial instruments.  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.  
Weaknesses in model design, implementation or 
governance may result in flawed outputs, increasing 
risks.  Inaccuracies in input data or issues with data 
quality or effectiveness can further amplify these 
risks. To the extent that our models utilize data 
provided by third parties, deficiencies in the accuracy, 
timeliness or completeness of third-party data or the 
effectiveness in our controls and validation processes, 
could further amplify these risks.  Models utilizing 
artificial intelligence, machine learning or other 
emerging technologies present additional challenges, 
including biases in algorithms or datasets, potentially 
leading to ineffective decision-making, reporting 
errors or other unintended consequences.
Weaknesses in model risk management practices, 
including lapses in oversight, monitoring and 
application, could negatively impact business 
operations and regulatory compliance.  Failure to 
identify or address deficiencies promptly may result 
in operational losses, penalties, increased capital 
requirements or reputational harm.
Although we have implemented policies, procedures 
and controls designed to mitigate model risk, these 
measures cannot fully eliminate the inherent 
limitations of modeling practices.  If our models fail 
to measure, monitor or predict risks appropriately, we 
could face financial losses, reputational harm, 
regulatory actions and material impacts on our 
business and financial results.
A communications or technology disruption or 
failure within our infrastructure or the 
infrastructure of third parties 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 extensively rely on communications and 
information systems to conduct our business.  Our 
businesses are highly dependent on our ability to 
process large volumes of data in an accurate, 
complete and timely manner, which requires 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 have 
in the past experienced, and could in the future 
experience, production and system outages or 
failures, or other significant operational delays.  In 
addition, any technology disruption or failure could 
result in the loss of confidential or customer data, as a 
result of which we could incur losses, suffer 
reputational damage, face significant remediation 
expenses or find ourselves out of compliance with 
applicable regulatory or contractual mandates or 
supervisory expectations with respect to the 
preservation of confidential information.  Any such 
disruption, 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.  Remote 
work arrangements have increased our reliance on 
remote access systems and video conferencing 
services, and, as a result, we are exposed to similar 
risks if the technology and communications systems 
our employees or employees of third parties use while 
working remotely fail.  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.  These incidents are 
unpredictable and can arise from numerous sources, 
not all of which are in our control, including, among 
others, human error, malfeasance and other 
misconduct, as well as operational disruptions at a 
third party or third party’s downstream service 
provider.
Upgrading our computer systems, software and 
networks may be time-consuming and may subject us 
to the risk of disruptions, failures or delays due to the 
complexity and interconnectedness of our computer 
systems, software and networks.  The failure to 
properly upgrade or maintain these computer systems, 
Risk Factors (continued)
BNY 83

software and networks could result in greater 
susceptibility to cyberattacks, particularly in light of 
the greater frequency and severity of cyberattacks in 
recent years, as well as the growing prevalence of 
cyberattacks affecting third-party software and 
information service providers.  Additionally, cloud 
technologies are becoming increasingly critical to the 
operation of our systems and platforms, and, as our 
reliance on this technology continues to grow, we will 
continue to be increasingly subject to evolving risks 
relating to the use of cloud technologies.  Our new 
product initiatives, including in connection with 
digital asset services, may further expose us to new 
and evolving technology risks and may lead to 
dependencies on, and compatibility issues with, 
decentralized or third-party blockchains and their 
protocols, which we do not control.  Although we 
have programs and processes to identify such risks, 
there can be no assurance that any such disruptions, 
failures or delays will not occur or, if they do occur, 
that actions taken to mitigate their impact will be 
timely or adequate.  Although we maintain insurance 
covering certain technology infrastructure losses and 
intend to maintain such insurance coverage if it is 
available to us on commercially reasonable terms, 
there can be no assurance that liabilities or losses we 
may incur, including as a result of a cybersecurity 
incident, will be covered under such policies or that 
the amount of insurance will be adequate.  
We continue to evaluate and seek opportunities to 
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, 
including as a result of failures related to upgrades 
and maintenance, that our incident response processes 
will be effective to efficiently identify and respond to 
an adverse event, 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 – Risk Types Overview – Operational 
Risk.”
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, have in the past been, and could in the 
future also be, sources of technology risk to us, 
including from breakdowns, capacity constraints, 
attacks (including cyberattacks targeted at 
downstream service providers), failures or delays of 
their own systems or other services that impede their 
ability to provide products or services to us, which, in 
turn, could impair our ability to process transactions 
and communicate with customers and counterparties.  
This risk may be intensified to the extent that there is 
concentration in a single unique product or service 
provided by a single vendor, or to the extent we rely 
on service providers from a single geographic area or 
due to the nature of the third-party’s industry and 
operations (e.g., firms that may have less robust scale, 
financial and operational resiliency standards with 
which to defend against a cyberattack).  We may not 
be able to effectively monitor or mitigate operational 
risks impacting our vendors or relating to the use of 
common and other vendors by third-party service 
providers, which could result in potential liability to 
clients and customers, regulatory fines, penalties or 
other sanctions, increased operational costs or harm 
to our reputation. 
As our business areas evolve, whether due to the 
introduction of technology, new service offering 
requirements for our clients, interactions with third-
party service providers, or changes in regulation 
relative to these service offerings, unforeseen risks 
materially impacting our business operations could 
arise.    The technology used has become increasingly 
complex and relies 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 adequately review and consider critical business 
changes prior to and during introduction and 
deployment of key technological systems, or the 
failure to adequately align operational capabilities 
with evolving client commitments and expectations, 
subjects us to the risk of an adverse impact on our 
ability to service and retain customers and on our 
operations.  The costs we incur in enhancing our 
technology could be substantial and may not 
ultimately improve our competitiveness or 
profitability.
Risk Factors (continued)
84 BNY

As a result of financial entities, including financial 
technology companies, central agents, clearing agents 
and houses, exchanges and technology systems across 
the globe becoming more interconnected and 
complex, a technology failure or other operational 
incident that significantly degrades, deletes or 
compromises the systems or data of one or more 
financial entities or suppliers increases the risk that 
such disruptions could have a material impact on 
counterparties or other market participants, including 
us.  A disruptive event, failure or delay experienced 
by one institution could disrupt the functioning of the 
overall financial system and has in the past impaired, 
and could in the future impair, our ability to settle 
transactions, which could, in turn, increase our 
counterparty credit and other exposures. 
A cybersecurity incident, or a failure in our 
computer systems, networks and information, or 
those of third parties, could result in the theft, 
disclosure, use or alteration of information, 
unauthorized access to or loss of information, or 
system or network failures.  Any such incident or 
failure could adversely impact our ability to conduct 
our businesses, damage our reputation and cause 
losses.
We have been, and we expect to continue to be, the 
target of varying degrees of attempted cyberattacks, 
computer viruses or other malicious software, denial 
of service efforts, phishing attacks, penetration 
attempts and other information security threats 
intended to disrupt our operations, including 
unauthorized access attempts and cyberattacks 
targeted at third-party service providers and their 
downstream service providers.  Remote working 
arrangements, our employees’ usage of mobile and 
cloud technologies and our reliance on third-party 
service providers leave our networks susceptible to 
greater access points for attackers to exploit.  This 
further increases the risk of unauthorized access to 
our networks and results in greater amounts of 
information being available for access, all of which 
heightens risks relating to the frequency and severity 
of cyberattacks against us and our third-party service 
providers and their downstream service providers.  
Although we deploy a broad range of sophisticated 
defenses and continue to expend significant resources 
to bolster these protections, there can be no assurance 
that these security measures will provide absolute 
security or prevent breaches and attacks, and we 
could suffer a material adverse impact or disruption 
as a result of a cybersecurity incident.
Cybersecurity incidents may occur through or as a 
result of system errors, lack of adequate policies and 
procedures, human error, software vulnerabilities 
(which may be unknown), potential lapses in 
information security practices or other irregularities, 
and intentional or unintentional acts by individuals or 
groups (including employees, vendors, customers and 
state actors, as well as others with malicious intent) 
having authorized or unauthorized access to our 
systems, data-bearing devices or facilities as well as 
the systems, devices or facilities of our clients, 
counterparties or third-party service providers.  
Malicious actors, who may see their effectiveness 
enhanced by the use of artificial intelligence, such as 
through the use of “deep-fake” technology or 
quantum computing, may also attempt to place 
individuals within BNY or fraudulently induce 
employees, vendors, customers or other users of our 
systems through social engineering, such as phishing, 
to disclose sensitive information in order to gain 
access to our data or that of our clients, or to send 
funds or authorize the sending of funds.  A 
cybersecurity incident that results in the theft, loss, 
disclosure, use or alteration of information (which 
may include confidential or proprietary information), 
system or network failures, or unauthorized access or 
loss of access to information, may require us to 
reconstruct lost data (which may not be possible) or 
reimburse clients for data and credit monitoring 
services, or result in loss of customer business or 
damage to our computers or systems and those of our 
customers and counterparties.  Further, although the 
application of distributed ledger technology is 
growing, such technology is nascent and may be 
vulnerable to cyberattacks or have other weaknesses, 
which could result in the loss of customer assets, 
including customer funds or custodied digital assets.  
Losses of certain types of assets, such as digital 
assets, may be distinctly difficult to recover and could 
subject us to customer disputes, claims for 
reimbursement, losses, negative publicity, 
reputational damage and governmental and regulatory 
scrutiny, investigations and enforcement actions.  
Cyberattacks are expected to accelerate on a global 
basis in both frequency and magnitude as threat 
actors are becoming increasingly sophisticated in 
using novel techniques and tools, including artificial 
intelligence and other emerging technologies, that 
have the potential to circumvent controls, evade 
detection and even remove forensic evidence.  Thus, 
the risk of an occurrence of a cybersecurity incident is 
inherent to a decision to invest in our company and 
Risk Factors (continued)
BNY 85

the financial services sector as a whole.  These 
impacts could be costly and time-consuming and 
could materially adversely affect our business, 
financial condition and results of operations.
While we seek to mitigate these risks to ensure the 
integrity of our systems and information and 
continuously evolve our cybersecurity capabilities, 
there can be no assurance that our mitigation 
strategies will be effective against all forms of 
cyberattacks.  It is also possible that employees or 
services providers may not follow our policies and 
procedures and we may not anticipate or implement 
effective preventive measures against all 
cybersecurity threats, or detect all such threats, 
including because the techniques used change, 
develop and evolve frequently or are not recognized 
until after they are launched.  Third parties with 
which we do business or that facilitate our business 
activities are also subject to the foregoing risks, and 
we can not guarantee that they will maintain effective 
systems and controls to mitigate and respond to these 
threats, or that they will properly implement and 
execute the policies and processes in the manner 
described to us.  The failure of any third-party service 
provider to promptly detect, respond to or report 
cybersecurity incidents may adversely affect our 
ability to effectively report or respond to 
cybersecurity incidents in a timely manner.  
Moreover, attacks can originate from a wide variety 
of sources, including malicious actors who are 
involved with organized crime or who may be linked 
to terrorist organizations or state or quasi-state actors, 
or from cross-contamination of legitimate parties 
(including vendors and their service providers, 
clients, financial market utilities and other financial 
institutions).  Risks relating to attacks on our vendors, 
including supply chain attacks affecting our software 
and information technology service providers, have 
been rising as such attacks become increasingly 
frequent and severe and as financial entities and 
technology systems have become increasingly 
consolidated, interdependent and complex.
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, 
including through the use of third parties, to address 
exposures arising from cybersecurity risks and 
threats.  Despite our procedures intended to identify 
and mitigate the impact of cybersecurity incidents, a 
cybersecurity incident, including as a result of a 
successful cyberattack, could occur and persist for an 
extended period of time before being detected.  In 
addition, we may not be able to identify and fully 
assess the impact of a cybersecurity incident in a 
timely manner.  An investigation of a cybersecurity 
incident is inherently unpredictable and 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 reliable 
information about the incident is known.  While such 
an investigation is ongoing, we may not necessarily 
know the source and extent of the harm or how best 
to contain and remediate it, certain errors or actions 
could be repeated or compounded before they are 
discovered and remediated, and communication to the 
public, clients, regulators and other stakeholders may 
not be sufficiently timely or accurate, any or all of 
which could further increase the costs and 
consequences of a cybersecurity incident.  Moreover, 
as a public company subject to Exchange Act 
reporting requirements, we are required to publicly 
disclose certain information about a material 
cybersecurity event, including the impact or 
reasonably likely impact.  Disclosure may be required 
before the incident has been resolved or fully 
investigated.  As with the determination of materiality 
of any other type of event, the determination 
regarding the materiality of any particular 
cybersecurity incident or series of related incidents 
entails a facts-and-circumstances test that takes a 
number of quantitative and qualitative factors into 
account.  As a result, our management may determine 
that certain cybersecurity incidents are immaterial 
and not subject to disclosure under applicable 
cybersecurity regulations.  For example, depending 
on the particular facts and circumstances, our 
management may reach such a determination if, 
among other things, the incident (or a series of related 
incidents) does not substantially disrupt our ability to 
operate normally, or deliver our products and services 
to our clients and the market on a timely basis, or 
result in the loss or compromise of a significant 
amount of data or potentially significant expenses or 
liabilities.  As a result, investors should not assume 
that the absence of disclosure under the new 
Risk Factors (continued)
86 BNY

regulations means that our defenses have been 
successful in preventing and defending every 
cyberattack directed at us or our third-party service 
providers.
In addition, 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 a significant amount of resources 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.  In addition, we 
conduct business in various jurisdictions that may not 
have comparable levels of protection for intellectual 
property and proprietary information as the U.S.  The 
protection afforded in those jurisdictions may be less 
established and/or predictable.  As a result, there may 
also be heightened risks associated with the potential 
theft of data, proprietary information, technology and 
intellectual property in those jurisdictions by 
domestic or foreign actors, including private parties 
and those affiliated with or controlled by state actors.  
Any theft of data, proprietary information, technology 
or intellectual property may negatively impact our 
operations and reputation, including disrupting our 
business activities in those jurisdictions.
We are also subject to laws and regulations relating to 
the protection and privacy of the information of 
clients, employees and others, and any failure to 
comply with these laws and regulations could expose 
us to liability, increased regulatory oversight and/or 
reputational damage.
The development and use of artificial intelligence 
present risks and challenges that may adversely 
impact our business.
The use and development of artificial intelligence by 
us, our third-party vendors, clients, counterparties and 
other market participants in certain business 
processes, models, including generative artificial 
intelligence models, services or products may expose 
us to risks and potential liabilities.  These risks may 
occur as a result of enhanced governmental or 
regulatory scrutiny, litigation, ethical concerns, 
confidentiality or other security risks, intellectual 
property concerns over data rights and protection, 
heightened susceptibility to cyberattacks, increased 
frequency and severity of cyberattacks, inaccurate or 
biased algorithms or underlying datasets, misuse or 
misappropriation as well as other factors that could 
adversely affect our business, reputation and financial 
results.  In addition, poor implementation of artificial 
intelligence, by us or our third-party providers, could 
subject us to additional risks that we cannot 
adequately predict or mitigate. 
The failure to strategically embrace the potential of 
artificial intelligence may result in a competitive 
disadvantage for us.  Although we are incorporating 
artificial intelligence technologies into some of our 
products, services and processes, if we cannot offer 
new artificial intelligence-facilitated technologies as 
quickly as our competitors, if our competitors 
develop more cost-effective solutions or other 
product offerings, or if we are not able to source 
components, such as artificial intelligence chips due 
to a supply chain shortage amid rising geopolitical 
uncertainty, we could experience a material adverse 
effect on our operating results, customer relationships 
and growth opportunities.
Furthermore, the use or adoption of artificial 
intelligence into our products or services may result 
in exposure to claims by third parties of copyright 
infringement or other intellectual property 
misappropriation, which may require us to pay 
compensation or license fees to third parties.  The 
evolving legal, regulatory and compliance framework 
for artificial intelligence both in the U.S. and 
internationally may also impact our ability to protect 
our own data and intellectual property against 
infringing use and could require changes in our 
implementation of artificial intelligence technology 
and increase our compliance costs and the risk of 
non-compliance.  Additionally, we may not be able to 
control how third-party artificial intelligence that we 
choose to use are developed or maintained, or how 
data we input into such tools are used or disclosed, 
even where we have sought protections with respect 
to these matters.
We are subject to extensive government rulemaking, 
policies, regulation and supervision that impact our 
operations.  Changes to and introduction of new 
rules and regulations have compelled, and in the 
Risk Factors (continued)
BNY 87

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.
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 affecting all aspects 
of our business and operations, including oversight by 
governmental agencies both inside and outside the 
U.S.  Regulations and related regulatory guidance and 
supervisory oversight impact how we analyze certain 
business opportunities, our capital and liquidity 
requirements, the revenue profile of certain of our 
core activities, the products and services we provide, 
how we manage our balance sheet, how we return 
capital to shareholders, how we monitor and manage 
risk and how we promote a sound governance and 
control environment.  Any changes to the regulatory 
frameworks and environment in which we operate, 
including changes to interpretation of existing and 
future laws, rules and regulations, 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. 
In the future, we could become subject to additional 
laws, rules and regulations, including related to the 
safekeeping of client assets, cybersecurity and data 
protection, digital assets, artificial intelligence and 
other emerging technologies, climate risk 
management and sustainability-related governance 
and reporting, including additional disclosure 
requirements with respect to sustainability-related 
goals, investment strategies, risk management and 
emissions.  In addition, certain regulatory initiatives 
within and outside of the U.S. may overlap and/or 
conflict with each other, which could subject us to 
additional compliance costs and regulatory risk.  This 
reflects the nature of developments relating to 
cybersecurity, digital assets, artificial intelligence and 
climate regulation, including the increased and ever 
shifting focus globally by regulators and other 
governmental authorities on these topics and the 
relatively uncertain, distinct and novel nature of the 
associated principles.
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.  We also face the risk of 
becoming subject to new or more stringent 
requirements in connection with the introduction of 
new regulations or modification of existing 
regulations, which could require us to hold more 
capital or liquidity, limit our ability to make 
distributions or have other adverse effects on our 
businesses or profitability.  In addition, regulatory 
responses in connection with severe market 
downturns or unforeseen stress events may lead to 
new rules and regulations, all of which may increase 
our operational costs and alter or disrupt our planned 
future strategies and actions.  We are also exposed to 
the risk of a special assessment, including under the 
FDI Act, in the event of the failure of a bank or non-
bank financial institution, which has in the past 
adversely affected, and may in the future adversely 
affect, our results of operations.
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, the 
imposition of tariffs, counter tariffs or other 
limitations on international trade and travel, and 
overall financial market performance, which can 
impact our business, results of operations and capital.  
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.  For example, the outcome of elections in 
the United States and internationally, and the 
resulting political administration transition in 
jurisdictions in which we operate, could result in 
additional uncertainties in the regulatory and 
economic landscape.  Legal or regulatory changes 
affecting access to financial markets can also 
adversely affect 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 both within jurisdictions (in relation to 
national versus non-national financial services 
providers) and across jurisdictions may be divergent 
and otherwise may not be applied in a manner that is 
consistent and harmonized.  Additionally, banking 
regulators have wide supervisory discretion in the 
Risk Factors (continued)
88 BNY

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 limit our capital 
distributions, maintain more capital or hold more 
highly liquid assets.
The U.S. capital rules subject us and our U.S. banking 
subsidiaries to 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.
The LCR and NSFR require us to maintain significant 
holdings of high-quality and generally lower-yielding 
liquid assets.  In calculating the LCR and NSFR, we 
must also determine which deposits should be 
considered stable deposits.  Stable deposits must meet 
a series of requirements and typically receive 
favorable treatment under the LCR and NSFR.  We 
use qualitative and quantitative analysis to identify 
core stable deposits.  It is possible that our LCR and 
NSFR could fall below applicable regulatory 
requirements as a consequence of the inherent 
uncertainties associated with this analysis (including 
as a result of regulatory changes or additional 
guidance from our regulators).  In addition to facing 
potential regulatory 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 have a material negative impact on our net 
interest income.
We develop and submit plans for our rapid and 
orderly resolution in the event of material financial 
distress or failure to the Federal Reserve and the 
FDIC.  If the agencies determine that our 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, we may be subject to more stringent capital 
or liquidity requirements or restrictions on our 
growth, activities or operations, or may be required to 
divest assets or operations, which could adversely 
affect our business, financial condition and results of 
operations.
Our global activities are also subject to extensive 
regulation and supervision 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, 
regulation of markets, recovery and resolution 
planning and payments and financial market 
infrastructure.
Various laws, regulations, rules and directives 
effective in the jurisdictions in which we operate have 
an impact on our provision of many products and 
services.  Implementation of, and revisions to, these 
laws, regulations, rules and directives have affected 
our operations and risk profile.  For example, the key 
regulatory frameworks impacting our operations in 
the EU and UK continue to diverge in a number of 
respects.  Further divergence in the nature and scope 
of these regulations could have an adverse impact on 
our results of operations and business prospects. 
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 Bank Secrecy Act, as 
amended by 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.  
Government sanctions and our actions in response to 
them have had, and in the future could continue to 
have, a negative impact on our revenue and business.  
For example, following Russia’s invasion of Ukraine 
in 2022, we ceased new banking business in Russia.
As a result of the implementation of data protection-
related laws and regulations, including the EU GDPR, 
the California Privacy Rights Act of 2020, the China 
Personal Information Protection Law of 2021 and the 
New York Department of Financial Services’ 
Risk Factors (continued)
BNY 89

cybersecurity regulation, we need to allocate 
additional time and resources to comply with such 
laws and regulations, and our potential liability for 
non-compliance and reporting obligations in the case 
of data breaches has significantly increased.  In 
addition, our businesses are increasingly subject to 
laws and regulations relating to privacy, surveillance, 
encryption and data localization in the jurisdictions in 
which we operate.  Compliance with these laws and 
regulations has required us to change our policies, 
procedures and technology for information security 
and segregation of data, which, among other things, 
makes us more vulnerable to operational failures, and 
to monetary penalties for breach of such laws and 
regulations.
Failure to comply with laws, regulations or policies, 
or meet supervisory expectations, applicable to us and 
our businesses could result in civil or criminal 
sanctions or enforcement proceedings by regulatory 
or governmental authorities, money penalties and 
reputational damage, which could have a material 
adverse effect on our business, financial condition 
and results of operations.  If violations of legal or 
regulatory requirements do occur, they could damage 
our reputation, increase our legal and compliance 
costs, including requiring us to devote substantial 
resources towards remediation efforts, and ultimately 
adversely impact our results of operations.  Laws, 
regulations or policies currently affecting us and our 
subsidiaries, supervisory expectations, or regulatory 
and governmental authorities’ interpretation of 
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, tax authorities and regulatory and 
other governmental agencies in the U.S. and abroad, 
as well as the Department of Justice and state 
attorneys general.  See “Legal proceedings” in Note 
22 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 have in the past been, and 
may in the future 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.  
Regulators and other governmental authorities may 
also be more likely to pursue enforcement actions, or 
seek admissions of wrongdoing or guilty pleas, in 
connection with the resolution of an inquiry or 
investigation to the extent a firm has previously been 
subject to other governmental investigations or 
enforcement actions.  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, policymakers globally continue to focus 
on protection of client assets, cybersecurity and data 
protection, the improper use of electronic 
communications as well as tax avoidance and 
evasion.
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 tax and 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 or tax 
authorities 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, remediation undertakings, cease and 
Risk Factors (continued)
90 BNY

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.  Further, we are subject to regulatory 
settlements, orders and feedback that have in the past 
contained, and in the future may continue to contain, 
requirements for us to undertake certain remedial 
measures, including enhancements to existing 
controls, systems and procedures.  Failure to 
implement these remedial measures in a timely 
manner could result in further adverse consequences, 
such as further investigations or proceedings or 
additional penalties, fines, judgments or additional 
remedial actions.
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, when clients or investors are 
experiencing losses or as public attention on issues 
such as climate change or other sustainability-related 
matters intensifies.  In some cases, additional third 
parties that would otherwise be defendants in such 
cases, or that have agreed to indemnify for such 
losses, may be bankrupt or in financial distress, or 
may not honor their obligations.  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.
Increasingly, regulators, tax authorities and courts 
have sought to hold financial institutions liable for the 
misconduct of their clients where such regulators and 
courts have determined that the financial institution 
should have detected that the client was engaged in 
wrongdoing, even though the financial institution had 
no direct knowledge of the wrongdoing.
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.  These risks may be more acute when 
operating in foreign jurisdictions or in instances 
where adversaries to such disputes are government or 
quasi-government actors otherwise motivated in 
whole or in part by non-commercial incentives.  
Although we establish accruals for our litigation and 
regulatory matters in accordance with applicable 
accounting guidance, our exposure to such litigation 
and regulatory matters can be unpredictable, and 
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 business may be adversely affected if we are 
unable to attract, retain, develop and motivate 
employees.
Our success depends, in large part, on our ability to 
attract new employees, retain, develop and motivate 
our existing employees, have a diverse and inclusive 
workplace 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, 
especially in critical strategic locations, and we may 
not be able to recruit and retain key personnel.  In 
addition, third-party suppliers and service providers 
on which we rely may face challenges in attracting 
and retaining their employees, which may have a 
negative impact on our operations and our resiliency 
capabilities.
We rely on certain employees with subject matter 
expertise to assist in the implementation of important 
initiatives and to support the development of new 
products and services, including in connection with 
our technology initiatives.  As focus on technology 
and risk management increases 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.
Risk Factors (continued)
BNY 91

Our ability to attract, retain and motivate key 
executives and other highly qualified employees may 
be negatively impacted by the level and composition 
of our compensation and benefits programs and by 
continuous changes to immigration policies and other 
restrictions applicable to incentive and other 
compensation programs, including 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 may not be publicly traded or 
regulated banking organizations and, in either case, 
may not have the same limitations on compensation 
as we do.  Furthermore, because a portion of our 
annual incentive compensation paid to some of our 
employees is deferred equity that is subject to the 
value of our common stock, declines in our 
profitability or outlook could adversely affect the 
ability to attract and retain employees.  Additionally, 
recent changes to our executive management may 
create uncertainty, divert resources, be disruptive to 
our daily operations or impact public or market 
perception, any of which could result in an adverse 
impact on our business.
The loss of employees’ skills, knowledge of the 
market and industry experience, and the cost of 
finding replacements, particularly in competitive 
labor markets, have led, and may continue to lead, to 
an increase in labor costs, which may hurt our 
business.  In addition, our current or future approach 
to in-office and remote-work arrangements may not 
meet the needs or expectations of our current or 
prospective employees, may not be perceived as 
favorable as compared to the arrangements offered by 
competitors and may not be conducive to a 
collaborative working environment, which could 
adversely affect our ability to attract, retain, develop 
and motivate employees.  If we are unable to continue 
to attract, retain, develop and motivate highly 
qualified employees, our performance, including our 
competitive position, could be adversely affected.
A failure or circumvention of our controls, policies 
and procedures could have a material adverse effect 
on our business, financial condition, results of 
operations and reputation.
Management regularly reviews and updates our 
internal controls, disclosure controls and procedures, 
and corporate 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.  Moreover, 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.  
We are also subject to additional risks that the third 
parties with which we do business fail to comply with 
our policies and procedures or fail to notify us 
promptly of any noncompliance. 
Additionally, although we have policies and 
procedures prohibiting the use of unauthorized 
personal devices and applications by our employees 
and contractors, we are subject to inquiries by 
regulators with respect to recordkeeping obligations 
and are subject to additional risks related to the use of 
personal devices and non-approved platforms, 
applications and tools by our employees or by third 
parties with which we do business for work-related 
activities, including risks related to information 
security and potential violations of record retention, 
reporting and other requirements.  Any failure to 
comply with such policies and procedures could 
adversely affect our business.
Market Risk
Weakness and volatility in financial markets and the 
economy generally may materially adversely affect 
our business, financial condition and results of 
operations.
As a financial institution, our Investment 
Management, Wealth Management, Pershing, 
Depositary Receipts and Markets, including 
Securities Lending, businesses are particularly 
sensitive to economic and market conditions, 
Risk Factors (continued)
92 BNY

including in the capital and credit markets.  Further, 
when these markets are volatile or disruptive, we 
have experienced declines in our fair valued assets, 
including in our securities portfolio and seed capital, 
as well as a fair value reduction in the portfolios that 
we manage that generate investment and wealth 
management fees.  Conditions in the financial 
markets and the economy generally, both in the U.S. 
and elsewhere around the world have materially 
affected, and may continue to affect, our results of 
operations, including investment management fees.
Foreign exchange trading that we execute for clients 
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.  
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.  
Such revenues also depend on our ability to manage 
the risk associated with the currency transactions we 
execute and program pricing.
A variety of factors impact global economies and 
financial markets, including interest rates and their 
associated yield curves, commodity pricing, market 
and political instabilities, volatile debt and equity 
market values, inflation, expectations relating to 
inflation trends and monetary policy actions taken by 
central banks, the strength of the U.S. dollar, 
geopolitical tensions, the imposition of tariffs, 
counter tariffs or other limitations on international 
trade or travel, including changes to international 
trade and investment policies by the U.S., the EU or 
other large economies (which could disrupt world 
trade, lead to trade retaliation and other supply chain 
complications), unemployment levels, labor strikes, 
declining business, investor and consumer 
confidence, recessionary fears, the impact of 
volatility in digital asset markets on the broader 
market, governmental budget deficits (including, in 
the U.S., at the federal, state and municipal levels), 
partial or full government shutdowns (including 
concerns about the stability of funding for the U.S. 
federal government) and contagion risk from possible 
default on sovereign debt.  More specifically, in 
recent years, the U.S. government has approached its 
statutory debt limit, which required specific measures 
taken by the U.S. Treasury Department to prevent the 
U.S. government’s default on its payment obligations.  
In the future, delays to raise or suspend the federal 
debt ceiling in similar circumstances could have 
severe repercussions within the U.S. and to global 
credit and financial markets and could result in a 
variety of adverse effects for our business, results of 
operations, liquidity and financial condition.
Any resulting economic pressure on market 
participants and lack of confidence in the financial 
markets may adversely affect our business, financial 
condition and results of operations.  Additionally, 
global economies and financial markets may be 
adversely affected by widespread health emergencies, 
pandemics, natural disasters, climate-related 
incidents, conflicts and acts of war (such as the 
conflicts in Ukraine and in the Middle East), 
terrorism, economic sanctions, other geopolitical 
events, for example, the economic and geopolitical 
challenges related to China, including developing 
tensions between China and Taiwan and/or between 
China and the U.S., or concerns over the possible 
escalation, continuation or duration of such events.  
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 our 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 
and Wealth Management businesses 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, particularly declines, 
could result in movements from higher to lower 
fee products and/or reductions in our assets under 
Risk Factors (continued)
BNY 93

management because of investors’ decisions to 
withdraw assets or from simple declines in the 
value of assets under management as markets 
decline. 
•
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.
•
The discontinuation of an interest rate 
benchmark, and the adoption and implementation 
of alternative reference rates, could adversely 
impact our business activities and our underlying 
operations.  We utilize reference rates in a variety 
of agreements and instruments and are 
responsible for the use of reference rates in a 
variety of capacities, as well as in our operational 
functions.  We could be subject to claims from 
customers, counterparties, investors or regulators 
alleging that we did not correctly discharge our 
responsibilities in interpreting and implementing 
contractual interest rate provisions or in selecting 
new alternative reference rates.  These types of 
claims could subject us to increased legal and 
operational expenses and could damage our 
reputation.
•
Uncertain and volatile capital markets, 
particularly declines in equity prices, 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 for our own 
account to hedge and manage our 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 derivatives-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.
•
The process we use to estimate our expected 
credit losses 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 economic environments, 
and especially in environments that differ 
significantly from the historical environments 
upon which the models we use to estimate our 
expected credit losses were developed, our ability 
to estimate our expected credit losses may be 
impaired, which could adversely affect our 
overall profitability and results of operations.
For a discussion of our management of market risk, 
see “Risk Management – Risk Types Overview – 
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 market activity, weak financial markets, 
underperformance and/or negative trends in savings 
rates or in investment preferences.
Our principal commercial 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.  For the year ended Dec. 31, 
2024, 73% of our total revenue was fee-based.  Our 
fee-based businesses include investment and wealth 
management, custody, corporate trust, depositary 
receipts, clearing, collateral management and treasury 
services, which are highly competitive businesses.
Fees for many of our products and services are based 
on the volume of transactions processed, the market 
value of assets managed and/or 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, among other things, all 
affect the level of our fee revenue.  As the volume of 
these activities decreases due to low client activity, 
weak financial markets or otherwise, our fee-based 
revenues also decrease, which negatively impacts our 
results of operations.
If our Investment and Wealth Management 
businesses experience poor investment returns due to 
weak market conditions or underperformance 
(relative to competitors or benchmarks), the market 
values of the portfolios that we manage will be lower 
(on a relative basis) and our ability to retain existing 
Risk Factors (continued)
94 BNY

assets and/or attract new client assets may be 
impacted.  Market and regulatory trends have also 
resulted in increased demand for lower fee investment 
and wealth management products and services, and 
lower performance-fee structures, both of which have 
impacted and may continue to impact our fee 
revenue.  Some of these dynamics have also 
negatively impacted fees in our Market and Wealth 
Services and Securities Services businesses and any 
of these dynamics may also occur in the future.  
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 may be adversely 
impacted by decreases in the rate at which individuals 
invest in mutual funds and other collective funds, unit 
investment trusts or exchange-traded funds, or 
contribute to defined contribution plans.  Changes in 
economic and market conditions, including as a result 
of higher market volatility, inflationary pressures, 
recessionary conditions or declines in equity values, 
could result in changes in the investment patterns of 
our clients or negatively impact the market value of 
client portfolios, each of which could have a negative 
impact on our results of operations.
When our investment management revenues decline, 
interest rates rise or other market factors affect the 
value of our investment management business, we 
may have, and in the past have had, declines in the 
fair value in our Investment Management reporting 
unit, one of the two reporting units in our Investment 
and Wealth Management segment.  If the fair value of 
the Investment Management reporting unit declines 
below its carrying value, we would be required to 
take, and in the past have taken, an impairment 
charge.
Levels of and changes in interest rates have 
impacted, and will in the future continue to impact, 
our profitability and capital levels, at times 
adversely.
We earn revenue, known as “net interest income,” 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 
borrowed money.  Additionally, we earn net interest 
income on other activities relating to interest-earning 
assets and interest-bearing liabilities, such as reverse 
repurchase agreements and repurchase agreements, 
respectively.  Our net interest margin, which is the 
result of dividing net interest income by average 
interest-earning assets, is sensitive to the shape of the 
yield curve and whether the interest rate paid or 
received is fixed or moves with changes in market 
interest rates. 
The continued prevalence of higher rates, and any 
future rate increases, including unexpectedly 
precipitous increases, could adversely impact our 
business, financial condition and results of 
operations, due to:
•
higher market volatility, recessionary conditions 
and declines in equity values, resulting in a 
decline in the valuation of assets under 
management;
•
reduced liquidity in bonds and fixed-income 
funds, resulting in lower performance 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;
•
higher redemptions from our fixed-income funds 
or separate accounts, as clients move funds into 
investments with higher rates of return;
•
lower net interest income and net interest margin 
due to lower non-interest bearing deposit levels, 
as non-interest bearing deposits leave or shift to 
interest-bearing deposits; 
•
declines in deposit levels, resulting in reduced 
internal and regulatory liquidity buffers and lower 
revenues; 
•
reductions in the value of our fixed-income 
securities held for liquidity purposes; 
•
further increases in accumulated other 
comprehensive loss in our shareholders’ equity 
and therefore our tangible common equity due to 
the impact of rising long-term rates on the 
available-for-sale securities in our investment 
portfolio, which would negatively affect our risk-
based and leverage based regulatory capital 
ratios; or
•
higher funding cost.
Conversely, a material decline in the short-term rate 
environment, and/or a flat or inverted yield curve, in 
the future could adversely impact, and has in the past 
Risk Factors (continued)
BNY 95

adversely impacted, our net interest income and 
results of operations due to:
•
compression of our net interest margin, 
depending on our balance sheet position and the 
speed and size of the interest rate decline;
•
sustained weakness of our spread-based revenues, 
resulting in continued voluntary waiving of fees 
on certain money market mutual funds and 
related distribution fees, in order to prevent the 
yields on such funds from becoming uneconomic; 
or 
•
adverse impacts on the value of our fixed-rate 
mortgage-backed securities, driven by higher 
mortgage prepayment speeds.
Our business activities involve investing in interest-
bearing assets and incurring interest-bearing liabilities 
with varying durations.  Changes in the direction and 
levels of interest rates, the relationship between short-
and long-term rates and the speed of interest rate 
changes have in the past impacted, and in the future 
are expected to continue to impact, our net interest 
margin, capital ratios and overall financial position.  
Changes in the direction and level of interest rates 
may also have adverse impacts on our clients and 
counterparties, which could adversely impact 
multiple aspects of our business, including our fee 
revenue, allowance for credit losses and deposit mix.  
Although we have policies and procedures in place to 
assess and mitigate the potential impacts of changes 
in the direction and level of interest rates, these 
policies and procedures may not be able to effectively 
mitigate these risks.  If our assumptions about any 
number of factors used in our interest rate models are 
incorrect, or if there are unforeseen changes in 
external environment that are out of our control, it 
could negatively impact our results of operation and 
financial position. 
A more detailed discussion of the interest rate and 
market risks we face is contained in “Risk 
Management – Risk Types Overview – Market Risk.” 
We have experienced, and may continue to 
experience, unrealized or realized losses on 
securities related to volatile and illiquid market 
conditions, reducing our capital levels and/or 
earnings.
We maintain an investment securities portfolio of 
various holdings, types and maturities.  At Dec. 31, 
2024, approximately 64% of these securities were 
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 
approximately 36% of our securities portfolio at Dec. 
31, 2024.  Our available-for-sale securities portfolio, 
to the extent unhedged, may result in increased 
volatility in our accumulated other comprehensive 
income or earnings relative to a loan portfolio that is 
accounted for at amortized cost.
Our investment securities portfolio represents a 
greater proportion of our consolidated total assets 
(approximately 33% at Dec. 31, 2024), in comparison 
to many other major U.S. financial institutions due to 
our custody and trust bank business model.  
Accordingly, our capital levels and results of 
operations and financial condition are materially 
exposed to the risks associated with our investment 
securities portfolio, including interest rate-related 
risks.
We reserve for current expected credit losses with 
respect to our available-for-sale and held-to-maturity 
securities.  Credit losses in excess of our allowance 
for credit losses would impact our results of 
operations.
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 held-to-maturity 
securities are not subject to fair-value accounting, 
changes in the fair value of these instruments (other 
than expected 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 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 is determined based on market prices 
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 
Risk Factors (continued)
96 BNY

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.  
The estimate of expected credit losses 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, we are limited in the actions we can take 
related to our held-to-maturity securities 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.  If our determinations 
change about our intention or ability to not sell 
available-for-sale securities that have experienced a 
reduction in fair value below their amortized cost, we 
could be required to recognize a loss in earnings for 
the entire difference between fair value and amortized 
cost.
For information regarding our investment securities 
portfolio, refer to “Results of Operations – 
Consolidated balance sheet review – Securities.”
Credit Risk
The failure or perceived weakness of any of our 
significant clients or counterparties, many of whom 
are major financial institutions or sovereign entities, 
and our assumption of credit, counterparty and 
concentration risk, could expose us to credit losses 
and adversely affect our business.
We have credit 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 credit exposure 
consists of extensions 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.  We could be 
adversely affected by the actions and commercial 
soundness of organizations to whom we have lent 
funds, as defaults or non-performance (or even 
uncertainty concerning such default or non-
performance) by one or more of these institutions, or 
the markets 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.  Additionally, 
we are exposed to settlement risks, particularly in our 
payments and foreign exchange activities.  Those 
activities may lead to extensions of credit and 
consequent losses in the event of a counterparty 
breach or an operational error, including the failure to 
provide credit.  We are exposed to risk of short-term 
credit extensions to, or overdrafts by, our clients in 
connection with the process to facilitate settlement of 
trades and related foreign exchange activities, 
particularly when contractual settlement has been 
agreed with our clients.  The occurrence of overdrafts 
at peak volatility could create significant credit 
exposure to our clients depending upon the value of 
such clients’ collateral pledged to us at the time.  This 
risk may be heightened during periods of market 
volatility, during which collateral values may 
decrease suddenly.  
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.  Higher market 
volatility, inflationary pressures, recessionary 
conditions or declines in equity values could 
negatively affect the creditworthiness of our clients, 
which, in turn, would increase our credit risk.  We are 
also generally not able to net exposures across 
affiliated clients or counterparties and may not be 
Risk Factors (continued)
BNY 97

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 entity’s affiliates is over-
collateralized.  Moreover, not all of our client or 
counterparty credit exposure is secured.
In our agency securities lending program, we act as 
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 agree to replace the client’s loaned 
securities that the borrower fails 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 borrower fails 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 assume the risk of loss 
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 22 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.  Our commercial real estate portfolio also 
exposes us to concentrated credit risk, including to 
the New York metro market.  Such concentrations 
may be material.  Our 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.
We are also subject to the risk that our contractual 
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.
Risk Factors (continued)
98 BNY

Under U.S. regulatory restrictions on credit exposure, 
which include a broadening of the measure of credit 
exposure, we are required to limit our exposures to 
specific obligors or groups, including financial 
institutions.  These regulatory credit exposure 
restrictions may adversely affect our businesses and 
may require us to modify our operating models or the 
policies and practices we use. 
Further, we maintain sub-custodian relationships in 
certain jurisdictions, including emerging and other 
underdeveloped markets.  Our use of sub-custodians 
exposes us to operational, reputational and regulatory 
risk, as we are dependent upon such sub-custodians to 
perform certain services to clients in those markets.  
The risks of maintaining custody services in such 
markets are amplified due to evolving regulatory and 
sanctions requirements, which may increase our 
financial exposures, in the event those sub-
custodians, or we, are unable to return, transfer or 
reinvest clients’ assets.  Under certain regulatory 
regimes, we may be held responsible for resulting 
losses suffered by our clients, and we may agree to 
similar or more stringent standards with clients that 
are not subject to such regulations.  Where we have 
client deposit liabilities related to non-U.S. currencies 
in jurisdictions where we maintain sub-custodian 
relationships, we generally maintain a corresponding 
amount of cash on deposit with the relevant sub-
custodian or clearing agency, which increases our 
credit exposure to that entity and can accumulate over 
time based upon distributions on, or other activities 
related to, our clients’ assets.  If the sub-custodian or 
clearing agency were to become insolvent in 
circumstances not involving expropriation of assets or 
other circumstances that may excuse performance 
under relevant client agreements, the risk of loss on 
such cash on deposit could be ours rather than the 
clients’.
We could incur losses if our allowance for credit 
losses, including loan and lending-related 
commitment reserves, is inadequate or if our 
expectations of future economic conditions 
deteriorate.
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 profitability is 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 earnings.  The allowance for loan losses and 
allowance for lending-related commitments 
represents management’s estimate of current expected 
credit losses over the lifetime of the related credit 
exposure taking into account relevant information 
about past events, current conditions and reasonable 
and supportable forecasts of future economic 
conditions that affect the collectability of our loans 
and lending commitments.  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 estimates contemplate current 
conditions and how we expect them to change over 
the life of the portfolio, 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.  See 
“Results of Operations – Critical accounting 
estimates.”
Capital and Liquidity Risk
Our business, financial condition and results of 
operations could be adversely affected if we do not 
effectively manage our liquidity.
Our 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, a failure in our asset/liability 
Risk Factors (continued)
BNY 99

management, market constraints disabling asset to 
cash conversion, inability to issue debt on terms 
acceptable to us, run-offs 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 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 continue to rise or remain at elevated 
levels, or if we or our peers become subject to 
significant negative press or significant regulatory 
action or litigation, among other reasons.  Our 
liquidity could also be adversely affected by 
customers’ withdrawal of deposits in response to 
volatility and disruptions in the financial markets or a 
stress event.  Such stress events may impact certain 
industries in which our depositors may be 
concentrated or correlated and may consequently 
disproportionally affect our liquidity.  Further, 
deposit outflows could increase if our clients and 
customers with uninsured deposits look for 
alternative placements for their funds amidst market 
and financial industry volatility.  A perceived loss of 
confidence in BNY as a depository institution may be 
additionally exacerbated by the speed and 
pervasiveness with which information, which may be 
inaccurate or incomplete, is disseminated through 
social media or other internet forums.  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 income.
The degree of client demand for short-term credit 
tends to increase during periods of market turbulence.  
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.  In addition, during periods of 
market turbulence, draws under committed revolving 
credit facilities that we provide to our institutional 
clients may increase, and have in the past increased, 
substantially.  Such client demand may negatively 
impact our leverage-based capital ratios, and in times 
of sustained market volatility, may result in 
significant leverage-based ratio declines.
In addition, our access to the debt and equity capital 
markets and credit markets is a significant source of 
liquidity.  Events or circumstances often outside of 
our control, such as market disruptions, lack of 
liquidity in the markets, government fiscal and 
monetary policies, uncertainty over the U.S. 
government debt ceiling or loss of confidence by 
securities purchasers or counterparties in us or in the 
funds markets, could limit our access to capital 
markets and credit 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 our funding 
availability and cost.  Conversely, excess liquidity 
inflows could increase interest expense, limit our 
financial flexibility and increase the size of our total 
assets in a manner that could have a negative impact 
on our capital ratios.
Under the U.S. capital rules, the size of the capital 
surcharge that applies to a U.S. G-SIB 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 require large banks to 
incorporate a separate subsidiary in countries in 
which they operate and to maintain independent 
Risk Factors (continued)
100 BNY

capital and liquidity at foreign subsidiaries.  These 
requirements could hinder our ability to efficiently 
manage our funding and liquidity in a centralized 
manner, requiring us to hold more capital and 
liquidity overall.
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 
score, 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.  Further, the regulatory or stress test 
liquidity value associated with the securities we hold 
subject to a held-to-maturity accounting designation 
could be reduced in the future through regulatory or 
supervisory action, exposing us to relatively greater 
capital ratio volatility attributable to interest rate 
movements to the extent we designate a relatively 
larger percentage of our securities portfolio as 
available-for-sale going forward in response to such 
regulatory or supervisory changes.
If we are unable to raise funds using the methods 
described above, we would likely need to finance, 
reduce 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 business, 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. 
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 common stock repurchases or our common 
stock dividend, to preserve capital.  For a further 
discussion of our liquidity, see “Results of Operations 
– Liquidity and dividends.”
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, we 
and our subsidiary banks must meet or exceed 
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 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, 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 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.
The failure by one of our U.S. 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 
Risk Factors (continued)
BNY 101

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 the NSFR, or by 
regulators in implementing other portions of the Basel 
III framework, could materially adversely affect our 
financial condition.  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 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, the adoption of 
new or heightened prudential regulatory 
requirements, or the continued implementation of the 
U.S. capital rules (such as proposed revisions to 
implement and finalize the Basel III reforms), the 
LCR, the NSFR, the resolution planning process and 
related amendments, could result in changes in our 
RWAs, capital components, liquidity inflows and 
outflows, HQLA, or other elements involved in the 
calculation of these measures, which could impact 
regulatory capital and liquidity 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 generally, our level of operational 
RWAs could significantly increase or otherwise 
remain elevated and may potentially be subject to 
significant volatility, negatively impacting our capital 
ratios.  The uncertainty caused by these factors could 
ultimately impact our ability to meet our goals, 
supervisory requirements and regulatory standards. 
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, payment of income taxes 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 Pershing and the IHC.  The 
Parent is a legal entity separate and distinct from its 
banks, the IHC 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 payment obligations, including with respect to its 
securities, and to provide funds for share repurchases, 
the payment of income taxes 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 banks 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 to 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 “Results of 
Operations – Liquidity and dividends,” as well as 
Note 19 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.
Risk Factors (continued)
102 BNY

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 make distributions to the 
Parent if certain key capital and liquidity 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.
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 
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.
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 
capital planning, applicable provisions of Delaware 
law and 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 declare dividends or 
repurchase our common stock, may be subject to the 
buffers under the Federal Reserve’s capital and 
TLAC rules.  The buffers under the capital rules are 
affected by the results of CCAR.  Through the CCAR 
process, we may be, and have in the past been, 
required to resubmit our capital plan in the event of a 
deterioration in the general financial markets or 
economy or changes in our risk profile (including a 
material change in business strategy or risk 
exposure), financial condition or corporate structure.  
The Federal Reserve is also able, outside the CCAR 
process, to restrict our ability to make capital 
distributions and subject us to other supervisory or 
enforcement actions.
A Federal Reserve determination that our capital 
planning processes were weak or otherwise fail to 
meet supervisory expectations could have a variety of 
adverse consequences, including, without limitation, 
ratings downgrades, ongoing heightened supervisory 
scrutiny, expenses associated with remediation 
activities and potentially an enforcement action. 
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, our 
return on equity and market perceptions of BNY.
Our ability to declare or pay dividends on, or 
purchase, redeem or otherwise acquire, shares of our 
common stock 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 (in the case of dividends) or most recently 
completed dividend period (in the case of 
repurchases) of our Series A preferred stock or the 
last preceding dividend period (in the case of 
dividends) or most recently completed dividend 
period (in the case of repurchases) of our Series F, 
Series G, Series H or Series I 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, the stress capital 
buffer, the 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.  Changes in the 
composition of our balance sheet, including as a 
result of changing economic conditions and market 
values, may further require us to increase or alter the 
mix of our outstanding regulatory capital, which in 
turn could impact our ability to return capital to 
shareholders.
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 
Risk Factors (continued)
BNY 103

either in the form of common stock dividends or 
stock repurchases.
Any material reduction in our credit ratings or the 
credit ratings of our principal bank subsidiaries, 
The Bank of New York Mellon, BNY Mellon, N.A. 
or The Bank of New York Mellon SA/NV, could 
increase the cost of funding and borrowing to us 
and our rated subsidiaries and have a material 
adverse effect on our business, financial condition 
and results of operations 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, BNY Mellon, N.A. and The 
Bank of New York Mellon SA/NV, are currently 
rated investment grade by the major rating agencies.  
These rating agencies regularly evaluate 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 and 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, regulatory 
developments or other circumstances outside our 
control could negatively impact a rating agency’s 
judgment of the rating or outlook it assigns to us or 
our rated subsidiaries.  As a result, we or our rated 
subsidiaries may not be able to maintain our 
respective credit ratings or outlook on our securities.  
For further discussion of our and our principal bank 
subsidiaries’ credit ratings, see “Results of Operations 
– Liquidity and dividends.” 
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 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, which could impair our 
liquidity.  A downgrade by any one rating agency, 
depending on the agency’s relative ratings of the 
entity 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 or a 
review for downgrade were to occur during broader 
market instability, our options for responding to 
events may be more limited and more expensive, 
possibly significantly.  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 23 of 
the Notes to Consolidated Financial Statements. 
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 cash and other liquid financial assets to the 
IHC on an ongoing basis, subject to certain amounts 
retained by the Parent to meet its near-term 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 
Risk Factors (continued)
104 BNY

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, may 
result in greater risk of loss to holders of the Parent’s 
unsecured senior debt securities and certain other 
securities than would be the case under a different 
resolution strategy.
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, in order to avoid 
or mitigate serious adverse effects on the U.S. 
financial system.  Specifically, if the Parent 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.
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 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.
Strategic Risk
New lines of business, new products and services or 
transformational or strategic project initiatives 
subject us to new or additional risks, and the failure 
to implement these initiatives could affect our 
results of operations.
From time to time, we have launched new lines of 
business, offered new products and services within 
existing lines of business or undertaken 
transformational or strategic projects.  There are 
substantial risks and uncertainties associated with 
these efforts, including with respect to projects that 
involve the adoption of new and evolving 
technologies such as artificial intelligence.  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 
significant resources to developing new technology 
solutions for our clients, including our initiatives 
related to real-time electronic payments and global 
collateral management, as well as Wove, our 
integrative wealth management advisory platform.  If 
these technology solutions do not operate or perform 
as expected, are not successful, or do not produce the 
anticipated efficiencies, it could adversely impact our 
reputation, business and results of operations.  
Developing and providing new products and services, 
including those relating to digital assets, increases our 
operational risk exposures.  These risks are often 
heightened for projects that rely on third-party service 
providers, or in connection with new technologies 
and asset classes, such as digital assets, that are not 
only new for BNY but also relatively new to the 
financial markets more broadly.  Compared with our 
activities involving traditional assets, digital asset-
related products or services may introduce 
incremental or unique risks, particularly those 
associated with cybersecurity exposures and third-
party dependencies, as well as reputational, 
technology, legal and regulatory risks. 
Risk Factors (continued)
BNY 105

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.  The 
introduction of new accounting or regulatory 
requirements, or changes in those requirements, can 
also limit our ability to pursue strategic initiatives or 
result in significant costs. For example, prior to the 
repeal of Staff Accounting Bulletin 121, we had 
devoted considerable resources in analyzing the 
impact of such guidance on our existing and potential 
digital asset custody offerings.
Significant effort and resources are necessary to 
manage and oversee the successful completion of 
transformational or strategic project initiatives.  If 
management makes choices about these initiatives 
that prove to be incorrect, are based on incomplete, 
inaccurate or fraudulent information, fail to 
accurately assess the competitive landscape and 
industry trends or are unable to address the 
expectations of various stakeholders, then the value 
and growth prospects of our business may be 
affected.  Further, 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 we develop and 
implement related controls, processes and procedures 
and employees learn to operate under new systems, 
controls, processes and procedures.  The failure to 
successfully execute or monitor 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, 
technologies or markets, or clients and customers 
whose businesses focus on such products, 
technologies or markets, where there is regulatory 
uncertainty or different or conflicting regulations 
depending on the regulator or the jurisdiction.  We 
may invest significant time and resources into the 
expansion of existing or creation of new compliance 
and risk management systems with respect to new 
products, technologies or markets. 
Our strategic transactions present risks and 
uncertainties and could have an adverse effect on 
our business, financial condition and results of 
operations.
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 have entered into 
strategic alliances or other collaborations with third-
party service providers to deliver products and 
services to clients, 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 (including due 
to failure to obtain regulatory approval), or if the 
strategic transaction fails to deliver anticipated 
results, it could have an adverse effect on our 
business, financial condition and results of 
operations.  Anticipated challenges in obtaining any 
required governmental approvals, or uncertainty as to 
the prospects for obtaining such approvals, could also 
prevent us from pursuing a strategic transaction we 
may otherwise view as attractive.
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 employees, culture, control functions, 
systems and technology.  These risks may be 
heightened if we are unable to, or fail to, conduct 
sufficient or appropriate due diligence in connection 
with a potential acquisition.  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, 
Risk Factors (continued)
106 BNY

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 insurance, 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.  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, vendors and other business 
partners, which could have an adverse impact on our 
business, financial condition and results of 
operations.  In addition, a portion of the purchase 
price we expect to receive in a disposition may be 
contingent or based on an earnout (e.g., dependent on 
the profitability or results of operation of the business 
over a period of time after the sale is completed).  In 
such cases, we may not realize all, or any, contingent 
or earnout payments we anticipate receiving if the 
future performance of the business does not meet our 
expectations or if other contingent payment 
conditions are not satisfied. 
Joint ventures, noncontrolling investments, strategic 
alliances and other collaborations contain potentially 
increased financial, legal, reputational, operational, 
regulatory and/or compliance risks.  We may be 
dependent on joint venture partners, firms with which 
we collaborate, controlling shareholders or 
management who may have business interests, 
strategies or goals that are inconsistent with ours.  
Such dependencies, particularly in the case of 
establishing de novo joint ventures, may delay the 
launch of a new venture and result in the loss of a 
market opportunity.  Business decisions or other 
actions or omissions of the joint venture partner, the 
firms with which we collaborate, controlling 
shareholders or management may adversely affect the 
value of our investment (or, in the case of strategic 
alliances or other collaborations, the value of our 
products or services), impact our results of 
operations, result in litigation or regulatory action 
against us and otherwise damage our reputation and 
brand.
We may not realize some or all of the expected 
benefits of our transition to a platforms operating 
model. 
We are executing on a plan to transition our 
organization to a platforms operating model.  We 
expect such transition to lead to operating 
efficiencies, process simplification, cost savings, an 
increased focus on clients and improvements to the 
client experience, infrastructure improvements to 
technology and other systems, among other benefits.  
Implementing these changes to our operating model 
involves various execution challenges, complexities 
and uncertainties, may be costly and disruptive to our 
business, may result in litigation, regulatory scrutiny, 
or other negative financial, strategic or reputational 
impacts.  Projections regarding the benefits of the 
transition are based on current business operations, 
market conditions and management expectations, 
among other factors, and are subject to change.  We 
may not be able to obtain the anticipated benefits, 
cost savings and operational improvements within the 
projected timing or at all. Additionally, we may 
experience unintended and unforeseen consequences 
as a result of such transition, including a loss of 
continuity, increased complexity, issues concerning 
employee retention, labor disputes, decreased 
employee morale, loss of institutional knowledge and 
expertise of departing employees.  Such unintended 
consequences may increase as the pace of 
implementation of our platforms operating model 
accelerates or if we are unsuccessful in executing 
organizational change management.  If we are unable 
to successfully implement our transition to a 
platforms operating model, our business, financial 
condition and results of operations could be adversely 
affected.
Risk Factors (continued)
BNY 107

We are subject to competition in all aspects of our 
business, which could negatively affect our ability to 
maintain or increase our profitability.
The businesses in which we operate are intensely 
competitive around the world.  Larger and more 
geographically diverse companies, and financial 
technology firms that invest substantial resources in 
developing and designing new 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.  We have 
also experienced, and anticipate that we will continue 
to experience, pricing and other competitive pressures 
in several of our businesses.  Pricing pressures, as a 
result of the willingness of competitors to offer 
comparable or improved products or services 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.
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, 
including with respect to our clearing, settlement, 
payments and trading activities.  In the future, 
financial technology firms may be able to provide 
traditional banking products and services by 
obtaining a bank-like charter or offer 
cryptocurrencies.
Moreover, new or disruptive technologies may 
quickly impact markets and the manner in which our 
clients interact and transact within markets.  For 
example, the emergence, adoption and evolution of 
new technologies that do not require intermediation, 
including distributed ledgers, as well as advances in 
robotic process automation, could significantly affect 
the competition for payments processing and other 
financial services.  Our failure to either anticipate, or 
participate in, the transformational change within a 
given market or adapt these technologies as 
successfully as our peers, could make us less 
competitive and result in potential negative financial 
impact.  Increased competition in any of these areas 
may require us to make additional capital investments 
in our businesses in order to remain competitive.
Furthermore, regulations could 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 U.S. competitors 
not subject to the same laws and regulations.  See 
“Supervision and Regulation.”
Additional Risks
Our businesses may be negatively affected by 
adverse events, publicity, government scrutiny or 
other reputational harm.
We are subject to reputational, legal, compliance and 
regulatory risk in the ordinary course of our business.  
Harm to our reputation can result from numerous 
sources, including adverse publicity or negative 
information, whether or not true, arising from events 
occurring at BNY, other financial institutions or in 
the financial markets, perceived failure to comply 
with legal and regulatory requirements or deliver 
appropriate standards of service and quality, or a 
failure to appropriately describe our products and 
services, how we address environmental, social and 
sustainability concerns in our business activities or in 
our relationships with clients, the purported 
inappropriate or unlawful actions of our employees or 
the use of social media by our employees, the 
consequences of using emerging technologies, such 
as generative artificial intelligence or blockchain 
technology, alleged financial reporting irregularities 
involving ourselves or other large and well-known 
companies and perceived or actual conflicts of 
interest.  For example, a cybersecurity event 
impacting us or our customers’ data could have a 
negative impact on our reputation and customer 
confidence in BNY and our 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.  Our reputation may be significantly 
damaged by adverse publicity or negative information 
regarding BNY, whether or not true, that may be 
published or broadcast by the media or posted on 
social media, non-mainstream news services or other 
internet forums.  The speed and pervasiveness with 
which information, misinformation or rumors can be 
disseminated through these channels, in particular 
social media, may magnify risks relating to negative 
Risk Factors (continued)
108 BNY

publicity or media scrutiny.  Damage to our 
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.
Additionally, governmental scrutiny from regulators, 
tax authorities, legislative bodies and law 
enforcement agencies with respect to financial 
services companies has remained at elevated levels.  
Press coverage and other public statements, including 
information posted on social media or other internet 
forums, that allege some form of wrongdoing 
(including, in some cases, press coverage and public 
statements that do not directly involve BNY) 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 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.
Impacts from geopolitical events, acts of terrorism, 
war, natural disasters, the physical effects of climate 
change, pandemics and other similar events may 
have a negative impact on our business and 
operations.
In conducting our business and maintaining and 
supporting our global operations, which includes 
clients, counterparties, vendors and other third 
parties, we are subject to risks of loss from the 
outbreak of war, escalation or continuation of 
hostilities, global conflicts, acts of terrorism, natural 
disasters, the physical effects of climate change, 
pandemics and other similar unpredictable or 
catastrophic events that could have a negative impact 
on our business and operations.  For example, in July 
2024, a software update by CrowdStrike Holdings, 
Inc. (“CrowdStrike”), a cybersecurity technology 
company, caused widespread crashes of the Windows 
systems into which it was integrated resulting in 
operational disruptions to a variety of sectors 
including aviation, financial services and healthcare.  
Although we have not experienced any material 
impacts as a result of the CrowdStrike software 
update or similar events, we could in the future 
experience similar third-party software-induced 
interruptions to our operations, which could adversely 
affect our business, results of operations and financial 
condition.  We may also be impacted by unfavorable 
political, economic, legal or other developments, in 
addition 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, counter tariffs or other 
limitations on international trade and travel, which 
could disrupt world trade and lead to trade retaliation 
and other supply chain complications, and changes in 
laws and regulations.  These risks may be heightened 
as a result of uncertainties about changing rules, 
regulations and policies following the outcome of 
recent elections and the resulting political 
administration transitions in the United States and 
internationally. 
For example, as a result of Russia’s invasion of 
Ukraine in the first quarter of 2022, we ceased 
originating new banking business in Russia and 
suspended investment management purchases of 
Russian securities.  An escalation or continuation of 
hostilities, the imposition of additional sanctions or 
other laws prohibiting or limiting operations in 
certain jurisdictions or an elevated volume and 
complexity of cyberattacks as a result of the conflict 
in Ukraine, or conflicts or tensions in other regions 
such as the Middle East, could lead to unexpected 
disruptions to our businesses and could adversely 
affect the global economy and financial markets 
generally, diminish levels of economic activity and 
increase volatility in commodity prices, credit and 
capital markets.  The extent and duration of any such 
military action, and the responses to such action by 
governments, central banks and the markets, are 
difficult to predict and may magnify the impact of 
other risks described in this section.
Our operations, business, clients, supply chain and 
other stakeholders, as well as the finance sector and 
the global economy, could be adversely affected by 
the physical manifestations of climate change.  
Climate-related physical risks include the increased 
frequency or severity of acute weather events, such as 
hurricanes, floods, heatwaves and wildfires, and 
chronic shifts in the climate, such as increases in 
average global temperatures, rising sea levels, 
persistent changes in precipitation levels, prolonged 
drought, food and water insecurity, and any resulting 
population migration.  Such changes could have 
adverse financial, operational and other impacts on 
us, both directly on our business, operations and 
Risk Factors (continued)
BNY 109

employees, and indirectly as a result of impacts to our 
clients, vendors and other third parties on which we 
rely or as a result of market volatility.  These risks, 
and the impact on our business and the business of 
our clients and counterparties, are often difficult to 
predict or quantify.  Climate change risks can also 
lead to a deterioration in our credit risk exposures, for 
example, in our wealth management mortgage and 
commercial real estate portfolios.  Further, our 
headquarters is located in New York near the Hudson 
River waterfront.  Such location and the location of 
our other properties may subject us to more frequent 
or severe weather events, which could lead to 
declines in the asset values of our properties and the 
reduced availability or increased cost of insurance.
While we have business continuity and disaster 
recovery plans in place, catastrophic events, whether 
or not caused by climate change, could damage our 
facilities, disrupt or delay for prolonged periods 
normal business operations (including 
communications, technology and physical access to 
our facilities) or result in harm to or cause travel 
limitations on our employees, with a similar impact 
on our clients, suppliers and counterparties.  
Notwithstanding our efforts to maintain business 
continuity and disaster recovery plans, to the extent a 
catastrophic event occurs and our business continuity 
and disaster recovery plans fail or are otherwise 
impaired, for example, because of an internal or 
external failure of our information technology 
infrastructure or increased rates of employee illness 
or unavailability, our business continuity status would 
be adversely impacted, our ability to service and 
interact with our clients may suffer and there would 
be a disruption to our businesses.
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 operations.  In addition, such catastrophic 
events may lead, and in some cases have led, to 
higher market volatility, reduced availability or 
increased cost of insurance for our clients, as well as 
an increase in delinquencies, bankruptcies or defaults 
that could result in our experiencing higher levels of 
nonperforming assets, net charge-offs and provisions 
for credit losses, negatively impacting our business 
and operations.  Furthermore, we invest in renewable 
energy projects, which have been and may in the 
future be adversely affected by extreme weather 
events, natural disasters and other catastrophic events.
Sustainability concerns, including a focus on 
climate change and diversity, could adversely affect 
our business, affect client activity levels, subject us 
to additional regulatory requirements and damage 
our reputation.
Global efforts to mitigate climate damage, support 
climate adaptation, slow the loss of biodiverse natural 
ecosystems and promote other sustainability causes 
and standards have led and are likely to continue to 
lead to new legislative and regulatory requirements, 
heightened expectations among regulators and 
supervisors, and changes in consumers’ and 
businesses’ behaviors and business preferences. 
Conversely, there has been increasing sentiment 
against climate and diversity initiatives in the U.S., 
which has led and is likely to continue to lead to new 
policies and legislative and regulatory requirements 
discouraging or prohibiting these initiatives.  As a 
result, we may face heightened, and potentially 
conflicting, regulatory, legal and reputational scrutiny 
in the U.S., the EU and other jurisdictions in which 
we operate, and our business and financial condition 
may be adversely impacted.
The governmental and supervisory focus on these and 
other sustainability-related issues has resulted and 
could continue to result in our becoming subject to 
new, conflicting or heightened regulatory 
requirements or supervisory guidance, such as 
requirements relating to risk management, operational 
resiliency or stress testing for various climate stress 
scenarios, or additional, potentially costly, reporting 
requirements.  In particular, financial institutions 
have come under increased scrutiny regarding the 
management and disclosure of climate risks, both 
directly and indirectly, and new regulations may 
expand required disclosure of actual and potential 
climate-related impact on suppliers, clients and other 
third parties in our value chain.  For example, in 
October 2023, the Federal Reserve, the OCC and the 
FDIC jointly issued interagency guidance for large 
financial institutions, including BNY, on principles 
for climate-related financial risk management, and 
California enacted three climate-related laws 
imposing extensive new climate-related disclosure 
obligations applicable to companies doing business in 
California, and in 2024, made updates to two of those 
laws.  In 2024, the SEC also adopted rules requiring 
Risk Factors (continued)
110 BNY

enhanced disclosures of certain climate-related risks, 
which was stayed pending litigation.  On the other 
hand, certain states in which we operate have enacted, 
or have proposed to enact, statutes that prohibit 
financial institutions from denying or canceling 
products or services to a person, or otherwise 
discriminating against a person in making available 
products or services, on the basis of social credit 
scores and certain other factors.  There is also shifting 
sentiment in the U.S. against climate, sustainability 
and diversity programs and initiatives at the federal 
level, with executive orders directing federal agencies 
to eliminate programs, grants and mandates that 
support diversity, equity, inclusion or environmental 
goals.  Any changes in regulatory requirements, 
including as a result of changes in policies from 
federal, state or non-U.S. lawmakers and regulators, 
could result in increased regulatory, compliance or 
other costs or higher capital requirements, and may 
subject us to diverging and evolving requirements in 
the various jurisdictions in which we operate, 
including potentially conflicting sustainability and 
anti-sustainability requirements and expectations 
from local, state and national governments that may 
impact our ability to conduct certain business within 
those jurisdictions.
Our Investment Management line of business offers a 
range of solutions and advice for professional and 
personal investors to better manage risk-adjusted 
returns and, where applicable, achieve their 
sustainable investment goals and invest responsibly.  
Certain lawmakers and public officials have 
suggested that sustainability-related investing 
practices may result in violations of antitrust laws and 
breaches of fiduciary duty.  In addition, we may face 
compliance risks presented by regulations that are 
intended to address “greenwashing” or 
“greenhushing,” including the UK FCA Sustainability 
Disclosure Requirements and other regulations that 
may be promulgated in the future.  We have in the 
past been, and may in the future become, subject to 
enforcement actions and investigations by the SEC 
and other regulators and government officials, 
including state Attorneys General, regarding our 
sustainability-related investing practices.  
Governmental enforcement action could also lead to 
civil litigation claims by clients, fund shareholders 
and other third parties asserting violations of law or 
breaches of fiduciary duties and contractual 
obligations.
Further, as some regulators seek to mandate 
additional disclosure of sustainability-related 
information, our ability to comply with such 
requirements and to conduct more robust risk-related 
analyses may be hampered by lack of information and 
reliable data.  Climate data, particularly greenhouse 
gas emissions for clients and direct and indirect 
counterparties, may be limited in availability, based 
on estimated or unverified figures, which may have 
been derived from information or factors released by 
third-party sources, collected and reported on a lag, 
and variable in quality and consistency.  Moreover, 
the methodologies and standards used to measure and 
report such data are still in early stages, rapidly 
evolving and subject to change.  In addition, 
modeling capabilities to analyze climate-related risks 
remain incomplete and there can be no assurance that 
accurate or effective predictive tools or capabilities 
will be developed.  These and other factors could 
cause results to differ materially from those expressed 
in the estimates and beliefs made by third parties and 
by us, which could also impact our management of 
risk in this area and could result in us amending or 
restating our sustainability targets or baselines, 
including those related to greenhouse gas emissions, 
carbon neutrality, diversion of waste from landfills, 
paper neutrality and water consumption.
In the transition to a low carbon economy, changes in 
public policy, regulatory environment, stakeholder 
preferences, market pressures and advancements in 
technology may affect our business practices or result 
in additional costs or other adverse consequences to 
our business operations.  Such changes could affect 
whether and on what terms and conditions we will 
engage in certain activities or offer certain products 
or services.  Failure to adequately consider transition 
risks in developing and executing on our business 
strategy could lead to a loss of market share, lower 
revenues, decreased asset values and higher credit 
costs, as well as regulatory scrutiny.
Views about sustainability are diverse and changing, 
and our business, reputation and ability to attract and 
retain clients and employees may be harmed if our 
actions are perceived to be ineffective, insufficient or 
otherwise inappropriate, or if we are unable to 
achieve our stated objectives and commitments.  
Moreover, our reputation may be damaged as a result 
of our association, whether actual or perceived, with, 
among others, certain industries, companies, 
individuals or products perceived to be causing or 
exacerbating climate change or contributing to other 
Risk Factors (continued)
BNY 111

sustainability issues.  We are also exposed to 
reputational risk resulting from potential allegations 
of discrimination  against companies in certain 
sectors, as well as any decisions we make to continue 
to conduct or change our activities in response to 
considerations relating to climate change or other 
sustainability issues.  At the same time, certain 
financial institutions have also been subject to 
criticism and negative publicity as a result of their 
decisions to reduce their involvement in certain 
industries or projects perceived to be causing or 
exacerbating climate change or contributing to other 
sustainability issues.  Further, political pressure may 
be placed upon governmental clients not to use 
certain providers, such as us, if the legislators or 
governmental officials in such jurisdictions believe 
our positions are not consistent with the views of 
such legislators or officials.  The continuously 
evolving societal and political perspectives on 
sustainability make the ultimate impact on us difficult 
to predict, identify and monitor and may be 
detrimental to us.
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 the course of our business, we receive inquiries 
and challenges from both U.S. and non-U.S. tax 
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.  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 
addition, upon any change in tax law, we must 
recognize the effect of the change on our deferred tax 
assets and liabilities.  An increase in the U.S. tax rate 
would likely result in an increase in our net deferred 
tax liabilities and a reduction in our net income in the 
period of enactment of the change.  In addition, 
changes in tax rates or tax law could also impact the 
method and amount of capital that we return to 
shareholders.  See Note 12 of the Notes to 
Consolidated Financial Statements for further 
information.
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 Financial Accounting 
Standards Board (“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, the FASB, 
the SEC and bank regulators may change financial 
accounting and reporting standards governing the 
preparation of our financial statements or the 
interpretation of those standards that may require us 
to apply a new or revised standard retrospectively, 
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 and use judgments and 
models 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 credit 
losses, goodwill and other intangibles and litigation 
and regulatory contingencies.  Among other effects, 
such changes in estimates could result in further 
impairments of goodwill and intangible assets and 
establishment of allowances for credit losses as well 
as litigation and regulatory contingencies.  In 
performing our annual and interim goodwill 
impairment tests, we may use an income approach to 
estimate the fair values of each reporting unit.  
Estimated cash flows used in the income approach are 
Risk Factors (continued)
112 BNY

based on management’s projections.  Estimated cash 
flows extend far into the future, and, by their nature, 
are difficult to estimate over such an extended time 
frame.  Factors that may significantly affect the cash 
flow estimates include, among others, market values 
of assets we manage, the level and mix of those 
assets, customer behaviors and attrition, operating 
margins, changes in revenue growth trends, certain 
money market fee waiver practices, cost structures 
and technology, regulatory and legislative changes, 
specific industry or market sector conditions, 
competition and changes in interest rates.  In the 
future, small changes in the assumptions, such as 
changes in the cash flow estimates, discount rate or 
long-term growth rate, or a prolonged 
macroeconomic downturn may produce a material 
non-cash goodwill impairment.  If actual or 
subsequent events occur that are materially different 
than the assumptions, judgments and estimates we 
used, our results of operation may be materially and 
negatively impacted.  
Risk Factors (continued)
BNY 113

The following accounting guidance issued by FASB 
has not yet been adopted as of Dec. 31, 2024.
ASU 2023-09, Income Taxes (Topic 740): 
Improvements to Income Tax Disclosures
In December 2023, the FASB issued ASU 2023-09, 
Income Taxes (Topic 740): Improvements to Income 
Tax Disclosures, which requires a company to 
disclose, on an annual basis, additional disaggregated 
information related to the existing disclosures for the 
effective income tax rate reconciliation and income 
taxes paid.  
This ASU is effective on a prospective basis, with a 
retrospective option, for annual periods beginning 
after Dec. 15, 2024, and interim periods within fiscal 
years beginning after Dec. 15, 2025.  BNY is 
currently evaluating this guidance and the impact on 
the income tax disclosures.
Recent Accounting Developments
114 BNY

Explanation of GAAP and Non-GAAP 
financial measures
BNY has included in this Annual Report certain Non-
GAAP financial measures on a tangible basis as a 
supplement to GAAP information, which exclude 
goodwill and intangible assets, net of deferred tax 
liabilities.  We believe that the return on tangible 
common equity – Non-GAAP is additional useful 
information for investors because it presents a 
measure of those assets that can generate income, and 
the tangible book value per common share – Non-
GAAP is additional useful information because it 
presents the level of tangible assets in relation to 
shares of common stock outstanding.  
BNY included revenue measures excluding notable 
items, including a net loss from repositioning the 
securities portfolio, the reduction in the fair value of a 
contingent consideration receivable and disposal 
gains and losses.  Expense measures, excluding 
notable items, including goodwill impairment, FDIC 
special assessment, severance expense and litigation 
reserves, are also presented.  Litigation reserves 
represent accruals for loss contingencies that are both 
probable and reasonably estimable, but exclude 
standard business-related legal fees.  Income before 
taxes, net income applicable to common shareholders 
of The Bank of New York Mellon Corporation, 
diluted earnings per share, return on common equity, 
return on tangible common equity and pre-tax 
operating margin, excluding the notable items 
mentioned above, are also provided.  These measures 
are provided to permit investors to view the financial 
measures on a basis consistent with how management 
views the businesses.  
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.  
We believe 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 has also included the adjusted pre-tax operating 
margin – Non-GAAP, which is the pre-tax operating 
margin for the Investment and Wealth Management 
business segment, net of distribution and servicing 
expense that was passed to third parties who 
distribute or service our managed funds.  We believe 
that this measure is useful when evaluating the 
performance of the Investment and Wealth 
Management business segment relative to industry 
competitors.  
Forward-looking Non-GAAP financial measures
From time to time we may present or discuss 
forward-looking Non-GAAP financial measures, such 
as targets for expenses excluding notable items.  We 
are unable to provide a reconciliation of forward-
looking Non-GAAP financial measures to the 
comparable GAAP financial measures because we are 
unable to provide, without unreasonable effort, a 
meaningful or accurate estimation of amounts that 
would be necessary for the reconciliation due to the 
inherent difficulty of quantifying future amounts or 
when they may occur.  Such unavailable information 
could be significant to future results.
Supplemental Information (unaudited)
BNY 115

Reconciliation of Non-GAAP measures, excluding notable items
2024 vs.
(dollars in millions)
2024
2023
2023
Total revenue – GAAP
$ 
18,619 
$ 
17,697 
 5% 
Less:  Reduction in the fair value of a contingent consideration receivable (a)
 
— 
 
(144) 
Disposal (loss) (a)
 
— 
 
(6) 
Adjusted total revenue – Non-GAAP
$ 
18,619 
$ 
17,847 
 4% 
Total noninterest expense – GAAP
$ 
12,701 
$ 
13,295 
 (4) %
Less:  Severance expense (b)
 
240 
 
267 
Litigation reserves (b)
 
44 
 
94 
FDIC special assessment (b)
 
(63) 
 
632 
Adjusted total noninterest expense – Non-GAAP
$ 
12,480 
$ 
12,302 
 1% 
Net income applicable to common shareholders of The Bank of New York Mellon 
Corporation – GAAP
$ 
4,336 
$ 
3,067 
 41% 
Less:  Reduction in the fair value of a contingent consideration receivable (a)
 
— 
 
(144) 
Disposal (loss) (a)
 
— 
 
(5) 
Severance expense (b)
 
(183) 
 
(205) 
Litigation reserves (b)
 
(41) 
 
(91) 
FDIC special assessment (b)
 
48 
 
(482) 
Adjusted net income applicable to common shareholders of The Bank of New York 
Mellon Corporation – Non-GAAP
$ 
4,512 
$ 
3,994 
 13% 
Diluted earnings per share – GAAP
$ 
5.80 
$ 
3.89 
 49% 
Less:  Reduction in the fair value of a contingent consideration receivable (a)
 
— 
 
(0.18) 
Disposal (loss) (a)
 
— 
 
(0.01) 
Severance expense (b)
 
(0.24) 
 
(0.26) 
Litigation reserves (b)
 
(0.05) 
 
(0.12) 
FDIC special assessment (b)
 
0.06 
 
(0.61) 
Total diluted earnings per common share impact of notable items
$ 
(0.23) 
$ 
(1.18) 
Adjusted diluted earnings per share – Non-GAAP 
$ 
6.03 
$ 
5.07 
 19% 
(a) Reflected in investment and other revenue.
(b) Severance expense is reflected in staff expense, litigation reserves in other expense, and FDIC special assessment in bank assessment 
charges, respectively.
The following table presents the reconciliation of the pre-tax operating margin.
Pre-tax operating margin reconciliation
(dollars in millions)
2024
2023
Income before taxes – GAAP
$ 5,848 
$ 4,283 
Less: Impact of notable items (a)
 
(221) 
 (1,143) 
Adjusted income before taxes, excluding notable items – Non-GAAP
$ 6,069 
$ 5,426 
Total revenue – GAAP
$ 18,619 
$ 17,697 
Less: Impact of notable items (a)
 
— 
 
(150) 
Adjusted total revenue, excluding notable items – Non-GAAP
$ 18,619 
$ 17,847 
Pre-tax operating margin – GAAP (b)
 31% 
 24% 
Adjusted pre-tax operating margin  – Non-GAAP (b)
 33% 
 30% 
(a) See table above for details of notable items and line items impacted.  
(b) Income before taxes divided by total revenue.
Supplemental Information (unaudited) (continued)
116 BNY

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
2024
2023
2022
(dollars in millions)
Net income applicable to common shareholders of The Bank of New York Mellon 
Corporation – GAAP
$ 
4,336 
$ 
3,067 
$ 
2,345 
Add:  Amortization of intangible assets
 
50 
 
57 
 
67 
Less: Tax impact of amortization of intangible assets
 
12 
 
14 
 
16 
Adjusted net income applicable to common shareholders of The Bank of New York Mellon 
Corporation, excluding amortization of intangible assets – Non-GAAP
$ 
4,374 
$ 
3,110 
$ 
2,396 
Less: Impact of notable items (a)
 
(176) 
 
(927) 
 
(1,378) 
Adjusted net income applicable to common shareholders of The Bank of New York Mellon 
Corporation, excluding amortization of intangible assets and notable items – Non-GAAP
$ 
4,550 
$ 
4,037 
$ 
3,774 
Average common shareholders’ equity
$ 36,413 
$ 35,767 
$ 36,067 
Less:  Average goodwill
 
16,316 
 
16,204 
 
17,060 
Average intangible assets
 
2,839 
 
2,880 
 
2,939 
Add:  Deferred tax liability – tax deductible goodwill
 
1,221 
 
1,205 
 
1,181 
  Deferred tax liability – intangible assets
 
665 
 
657 
 
660 
Average tangible common shareholders’ equity – Non-GAAP
$ 19,144 
$ 18,545 
$ 17,909 
Return on common shareholders’ equity – GAAP 
 11.9% 
 8.6% 
 6.5% 
Adjusted return on common shareholders’ equity – Non-GAAP 
 12.4% 
 11.2% 
 10.3% 
Return on tangible common shareholders’ equity – Non-GAAP 
 22.8% 
 16.8% 
 13.4% 
Adjusted return on tangible common shareholders’ equity – Non-GAAP 
 23.8% 
 21.8% 
 21.1% 
(a) See page 116 for details of notable items and line items impacted in 2024 and 2023.  Notable items in 2022 include goodwill impairment, 
severance expense, litigation reserves, a revenue reduction related to Russia, primarily the accelerated amortization of deferred costs 
for depositary receipts services (reflected in investment services fees), a net loss from repositioning the securities portfolio (reflected in 
investment and other revenue) and gains on disposals (reflected in investment and other revenue).
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
Dec. 31,
(dollars in millions, except per share amounts and unless otherwise noted)
2024
2023
2022
The Bank of New York Mellon Corporation shareholders’ equity at year end – GAAP
$ 
41,318 $ 
40,770 $ 
40,613 
Less:  Preferred stock
 
4,343  
4,343  
4,838 
The Bank of New York Mellon Corporation common shareholders’ equity at year end – GAAP
 
36,975  
36,427  
35,775 
Less:  Goodwill
 
16,598  
16,261  
16,150 
Intangible assets
 
2,851  
2,854  
2,901 
Add:  Deferred tax liability – tax deductible goodwill
 
1,221  
1,205  
1,181 
Deferred tax liability – intangible assets
 
665  
657  
660 
The Bank of New York Mellon Corporation tangible common shareholders’ equity at year end – 
Non-GAAP
$ 
19,412 $ 
19,174 $ 
18,565 
Year-end common shares outstanding (in thousands)
 
717,680  
759,344  
808,445 
Book value per common share – GAAP
$ 
51.52 $ 
47.97 $ 
44.25 
Tangible book value per common share – Non-GAAP
$ 
27.05 $ 
25.25 $ 
22.96 
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
2024 vs.
(dollars in millions)
2024
2023
2023
Investment management and performance fees – GAAP
$ 
3,139 $ 
3,058 
 3% 
Impact of changes in foreign currency exchange rates
 
—  
11 
Adjusted investment management and performance fees – Non-GAAP
$ 
3,139 $ 
3,069 
 2% 
Supplemental Information (unaudited) (continued)
BNY 117

The following table presents the impact of changes in foreign currency exchange rates on investment management 
and performance fees reported in the Investment and Wealth Management business segment. 
Constant currency reconciliation – Investment and Wealth Management business segment
2024 vs.
(dollars in millions)
2024
2023
2023
Investment management and performance fees – GAAP
$ 
3,144 $ 
3,062 
 3% 
Impact of changes in foreign currency exchange rates
 
—  
11 
Adjusted investment management and performance fees – Non-GAAP
$ 
3,144 $ 
3,073 
 2% 
The following table presents the reconciliation of the pre-tax operating margin for the Investment and Wealth 
Management business segment. 
Pre-tax operating margin reconciliation – Investment and Wealth 
Management business segment
2024 vs.
2023 vs.
(dollars in millions)
2024
2023
2022
2023
2022
Income before income taxes – GAAP
$ 
605 
$ 
383 
$ 
47 
 58% 
 715% 
Less:  Reduction in the fair value of a contingent consideration receivable (a)
 
— 
 
(144) 
 
— 
Disposal (loss) (a)
 
— 
 
— 
 
(11) 
Revenue reduction related to Russia (b)
 
— 
 
— 
 
(6) 
Severance expense (c)
 
(22) 
 
(19) 
 
(12) 
Litigation reserves (c)
 
2 
 
(1) 
 
— 
Goodwill impairment
 
— 
 
— 
 
(680) 
Adjusted income before income taxes – Non-GAAP
$ 
625 
$ 
547 
$ 
756 
 14% 
 (28) %
Total revenue – GAAP
$ 3,389 
$ 3,155 
$ 3,563 
Less:  Distribution and servicing expense
 
363 
 
355 
 
345 
Adjusted total revenue, net of distribution and servicing expense – Non-GAAP
$ 3,026 
$ 2,800 
$ 3,218 
Less:  Reduction in the fair value of a contingent consideration receivable (a)
 
— 
 
(144) 
 
— 
Disposal (loss) (a)
 
— 
 
— 
 
(11) 
Revenue reduction related to Russia (b)
 
— 
 
— 
 
(6) 
Adjusted total revenue, excluding notable items and net of distribution and 
servicing expense – Non-GAAP
$ 3,026 
$ 2,944 
$ 3,235 
Pre-tax operating margin – GAAP (d)
 18% 
 12% 
 1% 
Adjusted pre-tax operating margin, net of distribution and servicing expense – 
Non-GAAP (d)
 20% 
 14% 
 2% 
Adjusted pre-tax operating margin, net of distribution and servicing expense and 
excluding notable items – Non-GAAP (d)
 19% 
 23% 
(a) Reflected in investment and other revenue.
(b) Primarily reflected in investment management and performance fees.
(c) Severance expense is reflected in staff expense and litigation reserves in other expense.
(d) Income before taxes divided by total revenue.
Supplemental Information (unaudited) (continued)
118 BNY

Rate/volume analysis
Rate/volume analysis (a)
2024 over (under) 2023
2023 over (under) 2022
Due to change in
 
Due to change in
 
(in millions)
Average
balance
Average
rate
Net
change
Average
balance
Average
rate
Net
change
Interest income
Interest-earning assets:
Interest-bearing deposits with the Federal Reserve and other central banks:
Domestic offices
$ 
(3) $ 
66 $ 
63 
$ 
289 $ 1,986 
$ 2,275 
Foreign offices
 
(133)  
144  
11 
 
(31)  
1,278 
 
1,247 
Total interest-bearing deposits with the Federal Reserve and other 
central banks
 
(136)  
210  
74 
 
258  
3,264 
 
3,522 
Interest-bearing deposits with banks
 
(103)  
14  
(89) 
 
(50)  
352 
 
302 
Federal funds sold and securities purchased under resale agreements
 
1,597  
2,177  
3,774 
 
57  
5,884 
 
5,941 
Loans:
Domestic offices
 
230  
214  
444 
 
(99)  
1,884 
 
1,785 
Foreign offices
 
24  
10  
34 
 
(15)  
147 
 
132 
Total loans
 
254  
224  
478 
 
(114)  
2,031 
 
1,917 
Securities:
U.S. government obligations
 
(188)  
189  
1 
 
(123)  
537 
 
414 
U.S. government agency obligations
 
65  
298  
363 
 
(65)  
603 
 
538 
Other securities:
Domestic offices (b)
 
19  
129  
148 
 
(65)  
239 
 
174 
Foreign offices
 
187  
29  
216 
 
(18)  
559 
 
541 
Total other securities (b)
 
206  
158  
364 
 
(83)  
798 
 
715 
Total investment securities (b)
 
83  
645  
728 
 
(271)  
1,938 
 
1,667 
Trading securities (primarily domestic) (b)
 
(17)  
11  
(6) 
 
16  
156 
 
172 
Total securities (b)
 
66  
656  
722 
 
(255)  
2,094 
 
1,839 
Total interest income (b)
$ 
1,678 $ 
3,281 $ 4,959 
$ 
(104) $ 13,625 
$ 13,521 
Interest expense
Interest-bearing liabilities:
Interest-bearing deposits:
Domestic offices
$ 
710 $ 
378 $ 1,088 
$ 
117 $ 3,606 
$ 3,723 
Foreign offices
 
115  
320  
435 
 
(87)  
1,901 
 
1,814 
Total interest-bearing deposits
 
825  
698  
1,523 
 
30  
5,507 
 
5,537 
Federal funds purchased and securities sold under repurchase agreements
 
(1,315)  
4,590  
3,275 
 
824  
4,941 
 
5,765 
Trading liabilities
 
(80)  
12  
(68) 
 
(1)  
89 
 
88 
Other borrowed funds:
Domestic offices
 
(45)  
14  
(31) 
 
30  
7 
 
37 
Foreign offices
 
(1)  
3  
2 
 
—  
1 
 
1 
Total other borrowed funds
 
(46)  
17  
(29) 
 
30  
8 
 
38 
Commercial paper
 
62  
—  
62 
 
—  
— 
 
— 
Payables to customers and broker-dealers
 
(73)  
147  
74 
 
(28)  
438 
 
410 
Long-term debt
 
44  
111  
155 
 
125  
726 
 
851 
Total interest expense
$ 
(583) $ 
5,575 $ 4,992 
$ 
980 $ 11,709 
$ 12,689 
Changes in net interest income (b)
$ 
2,261 $ (2,294) $ 
(33) 
$ (1,084) $ 1,916 
$ 
832 
(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 income 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.
(b) 
Presented on an FTE basis. 
Supplemental Information (unaudited) (continued)
BNY 119

Some statements in this Annual Report are forward-
looking.  These include statements about the 
usefulness of Non-GAAP measures, the future results 
of BNY, our businesses, financial, liquidity and 
capital condition, results of operations, capital plans 
including dividends and repurchases, liquidity, risk 
and capital management and processes, human capital 
management (including related ambitions, objectives, 
aims and goals), strategic priorities and initiatives, 
acquisitions, related integration and divestiture 
activity, transition to a platforms operating model, 
efficiency savings, estimates (including those 
regarding expenses, interest rate and net interest 
income sensitivities, losses inherent in our credit 
portfolios and capital ratios), intentions (including 
those regarding our capital returns and expenses, 
including our investments in technology and pension 
expense), outlook (including those regarding our 
performance results, fee revenue, net interest income, 
expenses, impacts of currency fluctuations, capital 
ratios and effective tax rate) and expectations 
(including those regarding products, nonperforming 
assets, legal proceedings and other contingencies, 
impacts of trends on our businesses, regulatory, 
technology, market, economic or accounting 
developments and the impacts of such developments 
on our businesses). 
In this report, any other report, any press release or 
any written or oral statement that BNY 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,” “momentum,” “ambition,” 
“aspiration,” “objective,” “aim,” “future,” 
“potentially,” “outlook” and words of similar 
meaning, may signify forward-looking statements.
These forward-looking statements, and other forward-
looking statements contained in other public 
disclosures of BNY, are not guarantees of future 
results or occurrences, are inherently uncertain and 
are based upon current beliefs and expectations of 
future events, many of which are, by their nature, 
difficult to predict, outside of our control and subject 
to change.  By identifying these statements in this 
manner, we are alerting investors to the possibility 
that our actual results may differ, possibly materially, 
from the anticipated results expressed or implied in 
these forward-looking statements as a result of a 
number of important factors, including those factors 
described in “Risk Factors,” such as:
•
errors or delays in our operational and transaction 
processing, or those of third parties, may 
materially adversely affect our business, financial 
condition, results of operations and reputation;
•
our risk management framework, policies and 
processes may not be effective in identifying or 
mitigating risk and reducing the potential for 
losses and any inadequacy or lapse in our risk 
management framework, policies and processes 
could expose us to unexpected losses that could 
materially adversely affect our results of 
operations or financial condition;
•
limitations of the models we use to measure, 
monitor and manage risk could lead to 
unexpected losses and adverse business impacts; 
•
a communications or technology disruption or 
failure within our infrastructure or the 
infrastructure of third parties 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 in our 
computer systems, networks and information, or 
those of third parties, could result in the theft, 
disclosure, use or alteration of information, 
unauthorized access to or loss of information, or 
system or network failures.  Any such incident or 
failure could adversely impact our ability to 
conduct our businesses, damage our reputation 
and cause losses; 
•
the development and use of artificial intelligence 
present risks and challenges that may adversely 
impact our business; 
•
we are subject to extensive government 
rulemaking, policies, regulation and supervision 
that impact our operations.  Changes to and 
introduction of new rules and regulations have 
compelled, 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; 
•
regulatory or enforcement actions or litigation 
could materially adversely affect our results of 
operations or harm our businesses or reputation; 
Forward-looking Statements
120 BNY

•
our business may be adversely affected if we are 
unable to attract, retain, develop and motivate 
employees; 
•
a failure or circumvention of our controls, 
policies and procedures could have a material 
adverse effect on our business, financial 
condition, results of operations and reputation;
•
weakness and volatility in financial markets and 
the economy generally may materially adversely 
affect our business, financial condition and 
results of 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 market activity, weak financial markets, 
underperformance and/or negative trends in 
savings rates or in investment preferences; 
•
levels of and changes in interest rates have 
impacted, and will in the future continue to 
impact, our profitability and capital levels, at 
times adversely; 
•
we have experienced, and may continue to 
experience, unrealized or realized losses on 
securities related to volatile and illiquid market 
conditions, reducing our capital levels and/or 
earnings;
•
the failure or perceived weakness of any of our 
significant clients or counterparties, many of 
whom are major financial institutions or 
sovereign entities, and our assumption of credit, 
counterparty and concentration risk, could expose 
us to credit losses and adversely affect our 
business; 
•
we could incur losses if our allowance for credit 
losses, including loan and lending-related 
commitment reserves, is inadequate or if our 
expectations of future economic conditions 
deteriorate; 
•
our business, financial condition and results of 
operations could be adversely affected if we do 
not effectively manage our liquidity; 
•
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 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, payment of income taxes and 
payment of dividends to its stockholders; 
•
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 
capital planning, applicable provisions of 
Delaware law and our failure to pay full and 
timely dividends on our preferred stock; 
•
any material reduction in our credit ratings or the 
credit ratings of our principal bank subsidiaries, 
The Bank of New York Mellon, BNY Mellon, 
N.A. or The Bank of New York Mellon SA/NV, 
could increase the cost of funding and borrowing 
to us and our rated subsidiaries and have a 
material adverse effect on our business, financial 
condition and results of operations and on the 
value of the securities we issue;
•
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; 
•
new lines of business, new products and services 
or transformational or strategic project initiatives 
subject us to new or additional risks, and the 
failure to implement these initiatives could affect 
our results of operations; 
•
our strategic transactions present risks and 
uncertainties and could have an adverse effect on 
our business, financial condition and results of 
operations; 
•
we may not realize some or all of the expected 
benefits of our transition to a platforms operating 
model; 
•
we are subject to competition in all aspects of our 
business, which could negatively affect our 
ability to maintain or increase our profitability; 
•
our businesses may be negatively affected by 
adverse events, publicity, government scrutiny or 
other reputational harm; 
•
impacts from geopolitical events, acts of 
terrorism, war, natural disasters, the physical 
effects of climate change, pandemics and other 
Forward-looking Statements (continued)
BNY 121

similar events may have a negative impact on our 
business and operations; 
•
sustainability concerns, including a focus on
climate change and diversity, could adversely
affect our business, affect client activity levels,
subject us to additional regulatory requirements
and damage our reputation;
•
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; 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 not place undue reliance on any 
forward-looking statement and should consider all 
risk factors discussed in the 2024 Annual Report and 
any subsequent reports filed with the SEC by BNY 
pursuant to the Exchange Act.  All forward-looking 
statements speak only as of the date on which such 
statements are made, and BNY 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’s 
website or any other website referenced herein are not 
part of this report.
Forward-looking Statements (continued)
122 BNY

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.
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.  
Credit valuation adjustment (“CVA”) – The 
market value of counterparty credit risk on OTC 
derivative transactions.  
Debit valuation adjustment (“DVA”) – The market 
value of our credit risk on OTC derivative 
transactions.  
Depositary receipt – A negotiable security that 
generally represents a non-U.S. company’s publicly 
traded equity.  
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.
Expense categories:
•
Revenue-related expenses generally correlate
with changes in client balances, transaction
volume or revenue.  Examples include sub-
custodian and clearing expense, distribution and
servicing expenses, bank assessments and
incentive compensation.
•
Investments in growth, infrastructure and
efficiency initiatives are primarily included in
staff, software and equipment, and professional,
legal and other purchased services expenses.
•
Employee merit expenses include the annual
assessment of employee salaries and benefits
which enable us to attract and retain top industry
talent and early talent.
•
Efficiency savings include the benefits associated
with running the company better and can impact
all expense categories.  Examples include
workforce initiatives and vendor management.
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.
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.
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.
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. 
Reverse repurchase agreement – The purchase of 
securities with the agreement to sell them at a higher 
price at a specific future date.
Sub-custodian – A local provider (e.g., a bank) 
contracted to provide specific custodial-related 
services in a selected country or geographic area. 
Glossary
BNY 123

Management of BNY is responsible for establishing 
and maintaining adequate internal control over 
financial reporting for BNY, as such term is defined 
in Rule 13a-15(f) under the Exchange Act.
BNY’s management, including its principal executive 
officer and principal financial officer, has assessed 
the effectiveness of BNY’s internal control over 
financial reporting as of December 31, 2024.  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, 2024, BNY’s internal 
control over financial reporting is effective based 
upon those criteria.
KPMG LLP, the independent registered public 
accounting firm that audited BNY’s 2024 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’s internal control 
over financial reporting.  This report begins on page 
125.
Report of Management on Internal Control Over Financial Reporting
124 BNY

KPMG LLP 
345 Park Avenue 
New York, NY 10154-0102 
KPMG LLP, a Delaware limited liability partnership and a member firm of 
the KPMG global organization of independent member firms affiliated with 
KPMG International Limited, a private English company limited by guarantee. 
Report of Independent Registered Public Accounting Firm 
To the Shareholders 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) internal control over 
financial reporting as of December 31, 2024, 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 maintained, in all material respects, effective internal control over financial reporting as of 
December 31, 2024, 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 as of December 31, 2024 and 2023, the 
related consolidated statements of income, comprehensive income, cash flows, and changes in equity for each 
of the years in the three-year period ended December 31, 2024, and the related notes (collectively, the 
consolidated financial statements), and our report dated February 27, 2025, expressed an unqualified opinion 
on those consolidated financial statements. 
Basis for Opinion 
BNY’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’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 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; 
BNY 125

 
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. 
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, 2025 
126 BNY

Consolidated Income Statement
Investment services fees
$ 
9,419 $ 
8,843 $ 
8,529 
Investment management and performance fees
3,139 
3,058 
3,299 
Foreign exchange revenue
688 
631 
822 
Financing-related fees
216 
192 
175 
Distribution and servicing fees
158 
148 
130 
Total fee revenue
13,620 
12,872 
12,955 
Investment and other revenue (a)
687 
480 
70 
Total fee and other revenue (a)
14,307 
13,352 
13,025 
Net interest income
Interest income
25,607 
20,648 
7,118 
Interest expense
21,295 
16,303 
3,614 
Net interest income
4,312 
4,345 
3,504 
Total revenue (a)
18,619 
17,697 
16,529 
Provision for credit losses
70 
119 
39 
Noninterest expense
Staff
7,130 
7,095 
6,800 
Software and equipment
1,962 
1,817 
1,657 
Professional, legal and other purchased services
1,503 
1,527 
1,527 
Net occupancy
537 
542 
514 
Sub-custodian and clearing
498 
475 
485 
Distribution and servicing
361 
353 
343 
Business development
188 
183 
152 
Bank assessment charges
36 
788 
126 
Goodwill impairment
— 
— 
680 
Amortization of intangible assets
50 
57 
67 
Other
436 
458 
659 
Total noninterest expense
12,701 
13,295 
13,010 
Income
Income before income taxes (a)
5,848 
4,283 
3,480 
Provision for income taxes (a)
1,305 
979 
937 
Net income (a)
4,543 
3,304 
2,543 
Net (income) loss attributable to noncontrolling interests related to consolidated investment
management funds
(13)
(2)
13 
Net income applicable to shareholders of The Bank of New York Mellon Corporation (a)
4,530 
3,302 
2,556 
Preferred stock dividends
(194)
(235)
(211) 
Net income applicable to common shareholders of The Bank of New York 
Mellon Corporation (a)
$ 
4,336 $ 
3,067 $ 
2,345 
Year ended Dec. 31,
(in millions)
2024
2023
2022
Fee and other revenue
(a)
Results for the years ended Dec. 31, 2023 and Dec. 31, 2022 were restated to reflect the retrospective application of adopting new
accounting guidance in 2024 related to our investments in renewable energy projects using the proportional amortization method
(Accounting Standards Update (“ASU”) 2023-02).  See Note 2 of the Notes to Consolidated Financial Statements for additional
information.
The Bank of New York Mellon Corporation (and its subsidiaries)
BNY 127

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
Year ended Dec. 31,
(in millions)
2024
2023
2022
Net income applicable to common shareholders of The Bank of New York Mellon Corporation (a)
$ 
4,336 $ 
3,067 $ 
2,345 
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 (a)
$ 
4,336 $ 
3,067 $ 
2,345 
(a)
Results for the years ended Dec. 31, 2023 and Dec. 31, 2022 were restated to reflect the retrospective application of adopting new
accounting guidance in 2024 related to our investments in renewable energy projects using the proportional amortization method (ASU
2023-02).  See Note 2 of the Notes to Consolidated Financial Statements for additional information.
Average common shares and equivalents outstanding of The Bank of New York 
Mellon Corporation
Year ended Dec. 31,
(in thousands)
2024
2023
2022
Basic
742,588 
784,069 
811,068 
Common stock equivalents
5,513 
3,821 
3,904 
Less: Participating securities
— 
(92)
(177)
Diluted
748,101 
787,798 
814,795 
Anti-dilutive securities (a)
288 
1,334 
3,142 
(a)
Represents restricted stock, restricted stock units and participating securities outstanding but not included in the computation of diluted
average common shares because their effect would be anti-dilutive.
Earnings per share applicable to common shareholders of The Bank of New York 
Mellon Corporation (a)
Year ended Dec. 31,
(in dollars)
2024
2023
2022
Basic
$ 
5.84 $ 
3.91 $ 
2.89 
Diluted
$ 
5.80 $ 
3.89 $ 
2.88 
(a)
Results for the years ended Dec. 31, 2023 and Dec. 31, 2022 were restated to reflect the retrospective application of adopting new
accounting guidance in 2024 related to our investments in renewable energy projects using the proportional amortization method (ASU
2023-02).  See Note 2 of the Notes to Consolidated Financial Statements for additional information.
See accompanying Notes to Consolidated Financial Statements.
The Bank of New York Mellon Corporation (and its subsidiaries)
128 BNY

Consolidated Comprehensive Income Statement
Year ended Dec. 31,
(in millions)
2024
2023
2022
Net income (a)
$ 
4,543 $ 
3,304 $ 
2,543 
Other comprehensive income (loss), net of tax:
Foreign currency translation adjustments
(191)
272
(603) 
Unrealized gain (loss) on assets available-for-sale:
Unrealized gain (loss) arising during the period
365 
829
(3,245) 
Reclassification adjustment
64 
52
338 
Total unrealized gain (loss) on assets available-for-sale
429 
881 
(2,907) 
Defined benefit plans:
Net (loss) arising during the period
(9)
(75)
(306) 
Foreign exchange adjustment
—  
(1)
—
Amortization of prior service credit, net loss and initial obligation included in net periodic benefit 
cost
12 
(10)
56
Total defined benefit plans
3 
(86)
(250)
Net unrealized (loss) gain on cash flow hedges
(6)
6
(6)
Total other comprehensive income (loss), net of tax (b)
235 
1,073 
(3,766) 
Total comprehensive income (loss) (a)
4,778 
4,377 
(1,223) 
Net (income) loss attributable to noncontrolling interests
(13)
(2)
13 
Other comprehensive loss attributable to noncontrolling interests
2  
—
13 
Comprehensive income (loss) applicable to shareholders of The Bank of New York Mellon 
Corporation (a)
$ 
4,767 $ 
4,375 $ 
(1,197) 
(a)
Results for the years ended Dec. 31, 2023 and Dec. 31, 2022 were restated to reflect the retrospective application of adopting new
accounting guidance in 2024 related to our investments in renewable energy projects using the proportional amortization method (ASU
2023-02).  See Note 2 of the Notes to Consolidated Financial Statements for additional information.
(b)
Other comprehensive income (loss) attributable to The Bank of New York Mellon Corporation shareholders was $237 million for the
year ended Dec. 31, 2024, $1,073 million for the year ended Dec. 31, 2023 and $(3,753) million for the year ended Dec. 31, 2022.
See accompanying Notes to Consolidated Financial Statements.
The Bank of New York Mellon Corporation (and its subsidiaries)
BNY 129

Consolidated Balance Sheet
Dec. 31,
(dollars in millions, except per share amounts)
2024
2023
Assets
Cash and due from banks, net of allowance for credit losses of $23 and $18
$ 
4,178 $ 
4,922 
Interest-bearing deposits with the Federal Reserve and other central banks
 
89,546  
111,550 
Interest-bearing deposits with banks, net of allowance for credit losses of $1 and $2 (includes restricted of 
$1,399 and $3,420)
 
9,612  
12,139 
Federal funds sold and securities purchased under resale agreements
 
41,146  
28,900 
Securities:
Held-to-maturity, at amortized cost, net of allowance for credit losses of less than $1 and $1 (fair value of 
$44,020 and $44,711)
 
48,596  
49,578 
Available-for-sale, at fair value (amortized cost of $89,627 and $80,678, net of allowance for credit losses of 
$— and less than $1)
 
88,031  
76,817 
Total securities
 
136,627  
126,395 
Trading assets
 
13,981  
10,058 
Loans
 
71,570  
66,879 
Allowance for credit losses
 
(294)  
(303) 
Net loans
 
71,276  
66,576 
Premises and equipment
 
3,266  
3,163 
Accrued interest receivable
 
1,293  
1,150 
Goodwill
 
16,598  
16,261 
Intangible assets
 
2,851  
2,854 
Other assets, net of allowance for credit losses on accounts receivable of $2 and $3 (includes $2,151 and $1,261, 
at fair value) (a)
 
25,690  
25,909 
Total assets (a)
$ 
416,064 $ 
409,877 
Liabilities
Deposits:
Noninterest-bearing deposits (principally U.S. offices)
$ 
58,267 $ 
58,274 
Interest-bearing deposits in U.S. offices
 
139,109  
132,616 
Interest-bearing deposits in non-U.S. offices
 
92,148  
92,779 
Total deposits
 
289,524  
283,669 
Federal funds purchased and securities sold under repurchase agreements
 
14,064  
14,507 
Trading liabilities
 
4,865  
6,226 
Payables to customers and broker-dealers
 
20,073  
18,395 
Commercial paper
 
301  
— 
Other borrowed funds
 
225  
479 
Accrued taxes and other expenses (a)
 
5,270  
5,411 
Other liabilities (including allowance for credit losses on lending-related commitments of $72 and $87, also 
includes $422 and $195, at fair value) (a)
 
9,124  
9,028 
Long-term debt
 
30,854  
31,257 
Total liabilities (a)
 
374,300  
368,972 
Temporary equity
Redeemable noncontrolling interests
 
87  
85 
Permanent equity
Preferred stock – par value $0.01 per share; authorized 100,000,000 shares; issued 43,826 and 43,826 shares
 
4,343  
4,343 
Common stock – par value $0.01 per share; authorized 3,500,000,000 shares; issued 1,409,633,842 and 
1,402,429,447 shares
 
14  
14 
Additional paid-in capital
 
29,321  
28,908 
Retained earnings (a)
 
42,537  
39,549 
Accumulated other comprehensive loss, net of tax
 
(4,656)  
(4,893) 
Less: Treasury stock of 691,953,574 and 643,085,355 common shares, at cost
 
(30,241)  
(27,151) 
Total The Bank of New York Mellon Corporation shareholders’ equity (a)
 
41,318  
40,770 
Nonredeemable noncontrolling interests of consolidated investment management funds
 
359  
50 
Total permanent equity (a)
 
41,677  
40,820 
Total liabilities, temporary equity and permanent equity (a)
$ 
416,064 $ 
409,877 
(a) Prior period balances were restated to reflect the retrospective application of adopting new accounting guidance in 2024 related to our 
investments in renewable energy projects using the proportional amortization method (ASU 2023-02).  See Note 2 of the Notes to 
Consolidated Financial Statements for additional information.
See accompanying Notes to Consolidated Financial Statements.
The Bank of New York Mellon Corporation (and its subsidiaries)
130 BNY

Consolidated Statement of Cash Flows
Year ended Dec. 31,
(in millions)
2024
2023
2022
Operating activities
Net income (a)
$ 
4,543 $ 
3,304 $ 
2,543 
Net (income) loss attributable to noncontrolling interests
(13)
(2)
13 
Net income applicable to shareholders of The Bank of New York Mellon Corporation (a)
4,530 
3,302 
2,556 
Adjustments to reconcile net income to net cash provided by (used for) operating activities:
Provision for credit losses
70 
119 
39 
Pension plan contributions
(5)
(6)
(7) 
Depreciation and amortization (a)
1,803 
1,887
1,778 
Goodwill impairment
— 
— 
680 
Deferred tax (benefit) (a)
(345)
(383)
183 
Net securities losses
85 
68 
443 
Change in trading assets and liabilities
(5,639) 
436 
7,015 
Change in accruals and other, net (a)
188 
489 
2,381 
Net cash provided by operating activities
687 
5,912 
15,068 
Investing activities
Change in interest-bearing deposits with banks
(91)
1,943 
1,540 
Change in interest-bearing deposits with the Federal Reserve and other central banks
20,056 
(18,730)
7,812 
Purchases of securities held-to-maturity
(4,525) 
(341)
(2,497)
Paydowns of securities held-to-maturity
4,400 
4,675 
7,168 
Maturities of securities held-to-maturity
4,775 
1,766 
1,610 
Purchases of securities available-for-sale
(43,621) 
(23,422) 
(32,336) 
Sales of securities available-for-sale
6,812 
11,229 
14,990 
Paydowns of securities available-for-sale
7,573 
3,898 
5,215 
Maturities of securities available-for-sale
15,239 
19,748 
11,573 
Net change in loans
(4,888) 
(801)
1,423
Change in federal funds sold and securities purchased under resale agreements
(12,282) 
(4,597) 
5,294
Purchases of premises and equipment/capitalized software
(1,469) 
(1,220) 
(1,346)
Other, net
(1,458) 
42 
(572) 
Net cash (used for) provided by investing activities
(9,479) 
(5,810) 
19,874 
Financing activities
Change in deposits
9,895 
3,456 
(37,009) 
Change in federal funds purchased and securities sold under repurchase agreements
(481)
2,148 
790 
Change in payables to customers and broker-dealers
1,678 
(5,030) 
(1,488) 
Change in other borrowed funds
(242)
73 
(344) 
Change in commercial paper
301 
— 
— 
Net proceeds from the issuance of long-term debt
5,737 
6,487 
9,929 
Repayments of long-term debt
(5,963) 
(6,059) 
(4,000) 
Proceeds from the exercise of stock options
— 
— 
9 
Issuance of common stock
17 
16 
14 
Treasury stock acquired
(3,064) 
(2,604) 
(124) 
Preferred stock redemption
— 
(500)
—
Common cash dividends paid
(1,348) 
(1,262) 
(1,165)
Preferred cash dividends paid
(194)
(225)
(211) 
Amortization of preferred stock discount
—  
5
— 
Other, net
2  
(24)
(55)
Net cash provided by (used for) financing activities
6,338 
(3,519) 
(33,654) 
Effect of exchange rate changes on cash
(311)
230 
358 
Change in cash and due from banks and restricted cash
Change in cash and due from banks and restricted cash 
(2,765) 
(3,187) 
1,646 
Cash and due from banks and restricted cash at beginning of period
8,342 
11,529 
9,883 
Cash and due from banks and restricted cash at end of period
$ 
5,577 $ 
8,342 $ 
11,529 
Cash and due from banks and restricted cash
Cash and due from banks at end of period (unrestricted cash)
$ 
4,178 $ 
4,922 $ 
5,030 
Restricted cash at end of period
1,399 
3,420 
6,499 
Cash and due from banks and restricted cash at end of period
$ 
5,577 $ 
8,342 $ 
11,529 
Supplemental disclosures
Interest paid
$ 
21,374 $ 
16,021 $ 
3,307 
Income taxes paid
1,276 
882 
449 
Income taxes refunded
61 
17 
11 
(a)
Results for the years ended Dec. 31, 2023 and Dec. 31, 2022 were restated to reflect the retrospective application of adopting new accounting guidance in 
2024 related to our investments in renewable energy projects using the proportional amortization method (ASU 2023-02).  See Note 2 of the Notes to 
Consolidated Financial Statements for additional information.
See accompanying Notes to Consolidated Financial Statements.
The Bank of New York Mellon Corporation (and its subsidiaries)
BNY 131

Consolidated Statement of Changes in Equity
The Bank of New York Mellon Corporation shareholders
Nonredeemable
noncontrolling
interests of
consolidated
investment
management
funds
Total
permanent
equity
Redeemable
non-
controlling
interests/
temporary
equity
(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
Balance at Dec. 31, 2023 (a)
$ 4,343 $ 
14 $ 
28,908 $ 39,549 $ 
(4,893) $ (27,151) $ 
50 $ 40,820 (b)
$ 
85 
Shares issued to shareholders of 
noncontrolling interests
— 
— 
— 
— 
— 
— 
— 
— 
42 
Redemption of subsidiary shares 
from noncontrolling interests
— 
— 
— 
— 
— 
— 
— 
— 
(48) 
Other net changes in 
noncontrolling interests
— 
— 
(9)
— 
— 
— 
296 
287 
10 
Net income
— 
— 
—  
4,530 
— 
— 
13 
4,543 
— 
Other comprehensive income 
(loss)
— 
— 
— 
— 
237 
— 
— 
237 
(2) 
Dividends:
Common stock at $1.78 per 
share (c)
— 
— 
— 
(1,348) 
— 
— 
— 
(1,348) 
— 
Preferred stock
— 
— 
— 
(194)
— 
— 
— 
(194)
—
Repurchase of common stock
— 
— 
— 
— 
— 
(3,064) 
— 
(3,064) 
—
Common stock issued under 
employee benefit plans
— 
— 
22 
— 
— 
— 
— 
22 
—
Stock-based compensation
— 
— 
423 
— 
— 
— 
— 
423 
—
Excise tax on share repurchases
— 
— 
— 
— 
— 
(26)
— 
(26)
—
Other
— 
— 
(23)
— 
— 
—  
— 
(23)
—
Balance at Dec. 31, 2024
$ 4,343 $ 
14 $ 
29,321 $ 42,537 $ 
(4,656) $ (30,241) $ 
359 $ 41,677 (b)
$ 
87 
(a)
Retained earnings was restated to reflect the retrospective application of adopting new accounting guidance in 2024 related to our investments in 
renewable energy projects using the proportional amortization method (ASU 2023-02).  See Note 2 of the Notes to Consolidated Financial Statements for 
additional information.
(b)
Includes total The Bank of New York Mellon Corporation common shareholders’ equity of $36,427 million at Dec. 31, 2023 and $36,975 million at Dec.
31, 2024.
(c)
Includes dividend-equivalents on share-based awards.
The Bank of New York Mellon Corporation (and its subsidiaries)
132 BNY

Consolidated Statement of Changes in Equity (continued) 
The Bank of New York Mellon Corporation shareholders
Nonredeemable
noncontrolling
interests of
consolidated
investment
management
funds
Total
permanent
equity
Redeemable
non-
controlling
interests/
temporary
equity
(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
Balance at Dec. 31, 2022 (a)
$ 4,838 $ 
14 $ 
28,508 $ 37,743 $ 
(5,966) $ (24,524) $ 
7 $ 40,620 (b)
$ 
109 
Shares issued to shareholders of 
noncontrolling interests
— 
— 
— 
— 
— 
— 
— 
— 
38 
Redemption of subsidiary shares 
from noncontrolling interests
— 
— 
— 
— 
— 
— 
— 
— 
(54) 
Other net changes in 
noncontrolling interests
— 
— 
16 
— 
— 
— 
41 
57 
(12) 
Net income (a)
— 
— 
— 
3,302 
— 
— 
2 
3,304 
— 
Other comprehensive income
— 
— 
— 
— 
1,073 
— 
— 
1,073 
— 
Dividends:
Common stock at $1.58 per 
share (c)
— 
— 
— 
(1,262) 
— 
— 
— 
(1,262) 
— 
Preferred stock
— 
— 
— 
(225)
— 
— 
— 
(225)
—
Repurchase of common stock
— 
— 
— 
— 
— 
(2,604) 
— 
(2,604) 
—
Common stock issued under 
employee benefit plans
— 
— 
20 
— 
— 
— 
— 
20 
—
Preferred stock redemption
(500)
—
— 
— 
— 
— 
— 
(500)
—
Stock-based compensation
—  
—
364 
— 
— 
— 
— 
364 
— 
Amortization of preferred stock 
discount
5 
— 
— 
(5)
— 
— 
— 
— 
— 
Excise tax on share repurchases
— 
— 
— 
—  
— 
(23)
— 
(23)
—
Excise tax on preferred stock 
redemption
— 
— 
— 
(5)
— 
— 
— 
(5)
—
Other
— 
— 
— 
1  
— 
— 
— 
1 
 
4
Balance at Dec. 31, 2023 (a)
$ 4,343 $ 
14 $ 
28,908 $ 39,549 $ 
(4,893) $ (27,151) $ 
50 $ 40,820 (b)
$ 
85 
(a)
Retained earnings and net income were restated to reflect the retrospective application of adopting new accounting guidance in 2024 related to our 
investments in renewable energy projects using the proportional amortization method (ASU 2023-02).  See Note 2 of the Notes to Consolidated Financial 
Statements for additional information.
(b)
Includes total The Bank of New York Mellon Corporation common shareholders’ equity of $35,775 million at Dec. 31, 2022 and $36,427 million at Dec.
31, 2023.
(c)
Includes dividend-equivalents on share-based awards.
The Bank of New York Mellon Corporation (and its subsidiaries)
BNY 133

Consolidated Statement of Changes in Equity (continued) 
The Bank of New York Mellon Corporation shareholders
Nonredeemable
noncontrolling
interests of
consolidated
investment
management
funds
Total
permanent
equity
Redeemable
non-
controlling
interests/
temporary
equity
(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
Balance at Dec. 31, 2021 (a)
$ 4,838 $ 
14 $ 
28,128 $ 36,563 $ 
(2,213) $ (24,400) $ 
196 $ 43,126 (b)
$ 
161 
Shares issued to shareholders of 
noncontrolling interests
 
—  
—  
—  
—  
—  
—  
—  
—   
 
31 
Redemption of subsidiary shares 
from noncontrolling interests
 
—  
—  
—  
—  
—  
—  
—  
—   
 
(31) 
Other net changes in 
noncontrolling interests
 
—  
—  
44  
—  
—  
—  
(176)  
(132) 
 
(37) 
Net income (loss) (a)
 
—  
—  
—  
2,556  
—  
—  
(13)  
2,543   
 
— 
Other comprehensive (loss)
 
—  
—  
—  
—  
(3,753)  
—  
—  
(3,753) 
 
(13) 
Dividends:
Common stock at $1.42 per 
share (c)
 
—  
—  
—  
(1,165)  
—  
—  
—  
(1,165) 
 
— 
Preferred stock
 
—  
—  
—  
(211)  
—  
—  
—  
(211) 
 
— 
Repurchase of common stock
 
—  
—  
—  
—  
—  
(124)  
—  
(124) 
 
— 
Common stock issued under 
employee benefit plans
 
—  
—  
20  
—  
—  
—  
—  
20 
 
— 
Stock awards and options 
exercised
 
—  
—  
316  
—  
—  
—  
—  
316 
 
— 
Other
 
—  
—  
—  
—  
—  
—  
—  
— 
 
(2) 
Balance at Dec. 31, 2022 (a)
$ 4,838 $ 
14 $ 
28,508 $ 37,743 $ 
(5,966) $ (24,524) $ 
7 $ 40,620 (b)
$ 
109 
(a)
Retained earnings and net income were restated to reflect the retrospective application of adopting new accounting guidance in 2024 related to our 
investments in renewable energy projects using the proportional amortization method (ASU 2023-02).  See Note 2 of the Notes to Consolidated Financial 
Statements for additional information.
(b)
Includes total The Bank of New York Mellon Corporation common shareholders’ equity of $38,092 million at Dec. 31, 2021 and $35,775 million at Dec. 
31, 2022.
(c) 
Includes dividend-equivalents on share-based awards.
See accompanying Notes to Consolidated Financial Statements.
The Bank of New York Mellon Corporation (and its subsidiaries)
134 BNY

Note 1–Summary of significant accounting 
and reporting policies
In this Annual Report, references to “our,” “we,” 
“us,” “BNY,” 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.
Nature of operations
BNY is a global leader in providing a broad range of 
financial products and services in domestic and 
international markets.  Through our three principal 
business segments, Securities Services, Market and 
Wealth Services and Investment and Wealth 
Management, we serve institutions, corporations and 
high-net-worth individuals.  See Note 24 for the 
primary products and services of our lines of business 
and other information.
Basis of presentation
The accounting and financial reporting policies of 
BNY, a global financial services company, conform 
to U.S. generally accepted accounting principles 
(“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.  
Use of estimates
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.  Our most significant estimates 
pertain to our allowance for credit losses, goodwill 
and other intangibles and litigation and regulatory 
contingencies.  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. 
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.  Translation gains 
and losses on investments in foreign entities with 
functional currencies that are not the U.S. dollar are 
recorded as foreign currency translation adjustments 
in other comprehensive income (“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.  For transactions that are denominated in a 
currency other than the functional currency, the 
effects of exchange rate changes are included in 
foreign exchange revenue in the income statement.  
Acquisitions and divestitures 
The income statement and balance sheet include 
results of acquired businesses accounted for under the 
acquisition method of accounting pursuant to 
Accounting Standards Codification (“ASC”) 805, 
Business Combinations, and equity investments from 
the dates of acquisition.  Contingent purchase 
consideration is 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 to other noninterest expense.  
Gains or losses on divested business are reflected in 
investment and other revenue.  For businesses that are 
determined to be held-for-sale and the fair value less 
costs to sell is less than its carrying value, a loss is 
recognized for that difference.  Contingent 
consideration received is measured at fair value and 
recorded at the date of sale.  Any subsequent changes 
in the fair value of a contingent consideration 
receivable are recorded to investment and other 
revenue.  
Consolidation
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 
Notes to Consolidated Financial Statements
BNY 135

the entity, no further analysis is required and the 
entity is not consolidated. 
If we hold a variable interest in the entity, further 
analysis is performed to determine if the entity is a 
variable interest entity (“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 and the other investors.  This could 
occur when BNY disposes of any portion of its 
variable interests in the VIE, when we acquire 
additional variable interests in the VIE, when 
additional variable interests are issued to other 
investors or when other investors liquidate their 
variable interest 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 typically 
occurs if we have a 50% or more voting interest in the 
entity.
See Note 14 for additional disclosures related to our 
variable interests.
Equity method investments
Equity investments of less than a majority but at least 
20% ownership or where we are deemed to have 
significant influence are accounted for by the equity 
method and included in other assets.  Earnings on 
these investments are reflected as investment services 
fees, investment management and performance fees 
or investment and other revenue, 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 to its fair value.  
Effective in 2024, but applied retrospectively, the 
Company’s investments in renewable energy projects 
through limited liability companies are accounted for 
using the proportional amortization method, when 
certain established criteria are met.  Previously, these 
investments were accounted for as equity method 
investments utilizing the hypothetical liquidation at 
book value approach.  See “Tax credit investments” 
below for information on the proportional 
amortization method.  See Note 2 for additional 
information on the impact of adopting the new 
accounting guidance for the amount of our renewable 
energy investments.  
Below are our most significant equity method 
investments.
Equity method investments at Dec. 31, 2024
(dollars in millions)
Percentage 
ownership
Book
value
CIBC Mellon Trust Company (“CIBC 
Mellon”)
 50% $ 
583 
Siguler Guff
 20% $ 
228 
Restricted cash and securities
Cash and securities may be segregated under federal 
and other regulatory requirements and primarily 
consists of excess client funds held by our broker-
dealer entities.  Restricted cash is included in interest-
Notes to Consolidated Financial Statements (continued)
136 BNY

bearing deposits with banks on the 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 generally 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 on the balance sheet.
Securities – Debt
Debt securities are classified as available-for-sale, 
held-to-maturity or trading securities when they are 
purchased.  Debt securities are classified as available-
for-sale when we intend to hold them for an indefinite 
period of time or when they 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.  Debt securities 
are classified as held-to-maturity when we intend and 
have the ability to hold them until maturity.  Debt 
securities are classified as trading when we intend to 
resell them.  
Available-for-sale securities are measured at fair 
value.  The difference between fair value and 
amortized cost representing unrealized gains or losses 
is recorded net of tax as an addition to, or deduction 
from, OCI, unless an expected credit loss is 
recognized.  Realized gains and losses on sales of 
available-for-sale securities are reported in 
investment and other revenue on the income 
statement.  The cost of debt securities sold is 
determined on a specific identification method.  Held-
to-maturity securities are measured at amortized cost, 
net of expected credit loss, if any.  
From time to time our intention to hold available-for-
sale securities has changed such that we intend, and 
have the ability, to hold the securities to maturity.  
Transfers of securities from available-for-sale to held-
to-maturity are accounted for at fair value and create 
a new cost basis.  The unrealized gains or losses at 
date of transfer continue to be recorded in 
accumulated OCI and are subsequently amortized 
into net interest income over the contractual lives of 
the securities. 
The Company’s policy for recognition of expected 
credit losses for securities available-for-sale and 
securities held-to-maturity is contained within 
“Allowance for credit losses – Securities – Debt” and 
“Allowance for credit losses – Other” below.
Trading securities are measured at fair value and 
included in trading assets on the balance sheet.  
Trading revenue, which is reflected in investment and 
other revenue, includes both realized and unrealized 
gains and losses.  The liability incurred on short-sale 
transactions, representing the obligation to deliver 
securities, is included in trading liabilities at fair 
value.
Income on securities purchased is adjusted for 
amortization of premium and accretion of discount on 
a level yield basis, generally over their contractual 
life.  
Debt securities that are beneficial interests in 
securitized financial assets and are not high credit 
quality are discounted at the current yield used to 
accrete the beneficial interest.  A credit loss is 
recognized when there is an adverse change in 
expected cash flows.
If we intend to sell a debt security or it is more likely 
than not that we will be required to sell a debt 
security prior to recovery of its cost basis, the security 
is written down to fair value and the credit and non-
credit components of the unrealized loss are 
recognized in earnings and subsequently accreted to 
interest income on an effective yield basis over the 
life of the security.  Subsequent increases in the fair 
value of the security after the write-down are 
included in OCI.
Notes to Consolidated Financial Statements (continued)
BNY 137

Securities – Equity
Investments in equity securities that do not result in 
consolidation and are not accounted for under the 
equity method are measured at fair value with 
changes in the fair value recognized through earnings, 
unless one of two available exceptions applies.  The 
first exception, a scope exception, allows Federal 
Reserve Bank stock, Federal Home Loan Bank 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 in other assets on the 
balance sheet at cost adjusted for impairment, if any, 
plus or minus observable price changes in orderly 
transactions for an identical or similar investment of 
the same issuer with any such changes reflected in 
investment and other revenue.  Equity securities with 
readily determinable fair values are classified in 
trading assets with changes in fair value reflected in 
other trading revenue, which is included in 
investment and other revenue in the consolidated 
income statement.
Loans
Loans are reported at amortized cost, 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.
Loan modifications
A loan may be modified if the debtor is experiencing 
financial difficulties and the modification results in 
more than an insignificant delay in payment.  A 
determination of whether a debtor is experiencing 
financial difficulty is based on payment status, and 
for commercial borrowers, the determination also 
considers debtor risk ratings.  The determination of 
whether the modification results in more than an 
insignificant delay in payment is based on analysis of 
the payment amount subject to delay, the time span of 
the modified terms, as well as a review of 
modification activity in the previous 12-month 
period.  
Credit losses related to modified loans are generally 
accounted for under an individual evaluation 
methodology (see “Allowance for credit losses” 
below).  
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 or second lien residential mortgage loan 
reaches 90 days delinquent, it is subject to an 
individual evaluation of credit loss and placed on 
nonaccrual status. 
When a loan is placed on nonaccrual status, 
previously accrued and uncollected interest is 
reversed against current period interest income.  
Interest receipts on nonaccrual loans are recognized 
as interest income 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 interest become 
current and remain current for a specified period.
“Allowance for credit losses” below provides 
additional information regarding the individual 
evaluation of credit losses for nonperforming loans. 
Allowance for credit losses
The accounting policy for determining 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 judgmental and inherently 
uncertain. 
The allowance for credit losses represents 
management’s estimate of expected credit losses over 
the expected contractual life of the financial 
instruments as of the balance sheet date.  The 
allowance methodology is designed to provide 
procedural discipline in assessing the appropriateness 
of the allowance. 
A quantitative methodology and qualitative 
framework is used to estimate the allowance for 
credit losses.  The qualitative framework is described 
in further detail within “Allowance for credit losses – 
Other” below.  The quantitative component of our 
Notes to Consolidated Financial Statements (continued)
138 BNY

estimate uses models and methodologies that 
categorize financial assets based on product type, 
collateral type, and other credit trends and risk 
characteristics, including relevant information about 
past events, current conditions and reasonable and 
supportable forecasts of future economic conditions 
that affect the collectability of the recorded amounts.  
The allowance may be determined using various 
methods, including discounted cash flow methods, 
loss-rate methods, probability of default methods or 
other methods that we determine to be appropriate.  
We estimate our expected credit losses using the 
probability of default method for the majority of our 
financial assets.  We measure expected credit losses 
of financial assets on a collective (pool) basis when 
similar risk characteristics exist.  For a financial asset 
that does not share risk characteristics with other 
assets, expected credit losses are measured based on 
an individual evaluation method.
In our estimate, with the exception of our small home 
equity line of credit portfolio, available-for-sale debt 
securities, and individually evaluated financial assets, 
we utilize a multi-scenario macroeconomic forecast 
which includes a weighting of three scenarios: a 
baseline and upside and downside scenarios and 
allows us to develop our estimate using a wide span 
of economic variables.  Our baseline scenario reflects 
a view on likely performance of each global region 
and the other two scenarios are designed relative to 
the baseline scenario.  This approach incorporates a 
reasonable and supportable forecast period spanning 
the life of the asset, and this period includes both an 
initial estimated economic outlook component as well 
as a reversion component for each economic input 
variable.  The length of each of the two components 
depends on the underlying financial instrument, 
scenario and underlying economic input variable.  In 
general, the initial economic outlook period for each 
economic input variable under each scenario ranges 
between several months and two years.  The speed at 
which the scenario-specific forecasts revert to long-
term historical mean is based on observed historical 
patterns of mean reversion at the economic variable 
input level that are reflected in our model parameter 
estimates.  Certain macroeconomic variables such as 
unemployment or home prices take longer to revert 
after a contraction, though specific recovery times are 
scenario-specific.  Reversion will usually take longer 
the further away the scenario-specific forecast is from 
the historical mean.  On a quarterly basis, within a 
developed governance structure, we update these 
scenarios for current economic conditions and may 
adjust the scenario weighting based on our economic 
outlook.
Allowance for credit losses – Loans and lending-
related commitments
The allowance for credit losses on loans is presented 
as a valuation allowance to loans, and the allowance 
for credit losses on lending-related commitments is 
recorded in other liabilities.  The components of the 
allowance for credit losses on loans and lending-
related commitments consist of the following three 
elements: 
•
a pooled allowance component for higher risk-
rated and pass-rated commercial and institutional 
credits and loans secured by commercial real 
estate; 
•
a pooled allowance component for residential 
mortgage loans; and
•
an asset-specific allowance component involving 
individually evaluated credits of $1 million or 
greater which no longer share risk characteristics 
with other loans. 
The first element, a pooled allowance component for 
higher risk-rated and pass-rated commercial and 
institutional credits and loans secured by commercial 
real estate, is based on our expected credit loss model 
using the probability of default method, which has 
been adjusted for the forecast of economic conditions.  
Individual credit analyses are performed on such 
loans before being assigned a credit rating.  
Segmentation is established based on risk 
characteristics of the loans and how risk is monitored.  
In estimating the terms of the exposures and resulting 
effect on the measurement of expected credit loss, we 
consider the impact of potential prepayments as well 
as the effect of borrower extension options.  Borrower 
ratings are reviewed at least annually and are mapped 
to third-party databases, including rating agency and 
default and recovery databases, to support ongoing 
consistency and validity.  Higher risk-rated loans and 
lending-related commitments are reviewed quarterly.  
For the higher-risk rated and pass-rated commercial 
and institutional credits, the loss expected 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 for unfunded lending exposures, an 
estimate of the use of the facility at default (usage 
given default).  The borrower’s probability of default 
Notes to Consolidated Financial Statements (continued)
BNY 139

is derived from the associated credit rating.  The 
probability of default and the loss given default are 
applied to the estimated facility amount at default to 
determine the quantitative component of the 
allowance.  For each of the different parameters, 
specific credit models are developed for each segment 
of our portfolio, including commercial loans and 
lease financing, financial institutions and other.  We 
use both internal and external data in the development 
of these parameters.  
For loans secured by commercial real estate, a 
separate modeled approach is used that considers 
collateral specific data and loan maturity, as well as 
commercial real estate market factors by geographical 
region and property type under different 
macroeconomic scenarios.  A statistical method is 
used to simulate the property value and income of 
each property, and to estimate the probability of 
default, loss given default and expected credit loss for 
each loan.  The model outputs are established by 
using a baseline, upside and downside 
macroeconomic scenario to generate projected 
property values and incomes.
The second element, a pooled allowance component 
for residential mortgage loans, is determined by first 
segregating our mortgage pools into two categories: 
(i) our wealth management mortgages and other
residential mortgages purchased primarily in 2023
and (ii) our legacy mortgage portfolio disclosed as
other residential mortgages.  We then apply models to
each portfolio to predict prepayments, default rates
and loss severity.  We consider historical loss
experience and use a loan-level, multi-period default
model which further segments each portfolio by
product type, including first lien fixed rate mortgages,
first lien adjustable rate mortgages, second lien
mortgages and interest-only mortgages.  We calculate
the mortgage loss up to loan contractual maturity and
embed a reasonable and supportable forecast and
macroeconomic variable inputs which are described
above.  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 limited internal data.  Our legacy
mortgage portfolio and home equity line of credit
portfolios represent small sub-segments of our
mortgage loans.
The third element, individually evaluated credits, is 
based on individual analysis of loans of $1 million 
and greater which no longer share risk characteristics 
with other loans.  Factors we consider in measuring 
the extent of expected credit loss include the payment 
status, collateral value, the borrower’s financial 
condition, guarantor support, the probability of 
collecting scheduled principal and interest payments 
when due, modifications of payment structure or term 
for troubled borrowers, and recoveries if they can be 
reasonably estimated.  We measure the expected 
credit loss as the difference between the amortized 
cost basis of the loan and the present value of the 
expected future cash flows from the borrower which 
is generally discounted at the loan’s effective interest 
rate, or the fair value of the collateral, if the loan is 
collateral dependent.  We generally individually 
evaluate nonperforming loans as well as loans that 
have been modified given the risk characteristics of 
such loans. 
Allowance for credit losses – Securities – Debt
When estimating expected credit losses, we segment 
our available-for-sale and held-to-maturity debt 
securities portfolios by major asset class.  This is 
influenced by whether the security is structured or 
non-structured (i.e., direct obligation), as well as the 
issuer type. 
For available-for-sale debt securities with an 
unrealized loss at the balance sheet date, if we 
determine that a credit loss exists, the amount is 
recognized as an allowance for credit losses in 
securities – available-for-sale, with a corresponding 
adjustment to the provision for credit losses.  We 
evaluate credit losses at the individual security level 
and do not recognize credit losses if the fair value 
exceeds amortized cost, and if we determine that a 
credit loss exists, we limit the recognition of the loss 
to the difference between fair value and amortized 
cost.  In our determination of whether an expected 
credit loss exists for a non-structured security, we 
routinely conduct periodic reviews and examine 
various quantitative and qualitative factors that are 
unique to each portfolio, including the severity of the 
unrealized loss position, agency rating, credit 
enhancement, cash flow deterioration and other 
factors.  For a structured security, a credit loss model 
is utilized and the components of the credit loss 
calculation for each major portfolio or asset class 
include a probability of default and loss given default 
(severity).  These values depend on forecasted 
behavior of variables in the macroeconomic 
environment that are incorporated into our baseline 
forecast scenario described in “Allowance for credit 
Notes to Consolidated Financial Statements (continued)
140 BNY

losses” above.  Generally, cash flows are discounted 
at the effective interest rate implicit in the debt 
security.  Changes to the present value of cash flows 
due to the passage of time are recognized within the 
allowance for credit losses.
We estimate expected credit losses for held-to-
maturity debt securities using a similar multi-scenario 
macroeconomic forecast methodology as described in 
“Allowance for credit losses” above.  The allowance 
for credit losses on held-to-maturity debt securities is 
recorded in securities – held-to-maturity.  The 
components of the modeled credit loss calculation for 
each major portfolio or asset class include a 
probability of default and loss given default and their 
values depend on the forecast behavior of variables in 
the macroeconomic environment.  For structured debt 
securities, we estimated expected credit losses at the 
individual security level and use a cash flow model to 
project principal losses.  Generally, cash flows are 
discounted at the effective interest rate implicit in the 
debt security.  The difference is reflected in the 
allowance for credit losses, and changes to the present 
value of cash flows due to the passage of time are 
recognized within the allowance for credit losses.
We currently do not require an estimate of expected 
credit losses to be measured and recorded for U.S. 
Treasury securities, agency debt securities, and other 
debt securities that meet certain conditions that are 
based on a combination of factors such as guarantees, 
credit ratings and other credit quality factors.  These 
assets are monitored within our established 
governance structure on a recurring basis to 
determine if any changes are warranted.
Allowance for credit losses – Other financial 
instruments
We also estimate expected credit losses associated 
with margin loans, reverse repurchase agreements, 
security lending indemnifications, and deposits with 
third-party financial institutions using a similar risk 
rating-based modeling approach as described in the 
first allowance element within “Allowance for credit 
losses – Loans and lending-related commitments” 
above.  The allowance for credit losses on reverse 
repurchase agreements is recorded in federal funds 
sold and securities purchased under resale 
agreements; the allowance for credit losses on 
securities lending indemnifications is recorded in 
other liabilities and the allowance for credit losses on 
deposits with third-party financial institutions is 
recorded in cash and due from banks or interest-
bearing deposits with banks.  Our reverse repurchase 
agreements are short term and subject to continuous 
over-collateralization by our counterparties and 
timely collateral replenishment, when necessary.  As 
a result, we estimate the expected credit loss related 
to the uncollateralized portion of the asset at the 
balance sheet date, if any, and when there is a 
reasonable expectation that the counterparty will not 
replenish the collateral in compliance with the terms 
of the repurchase agreement.  This method is also 
applied to margin lending arrangements and securities 
lending indemnifications.
Allowance for credit losses – Other
We do not apply our credit loss measurement 
methodologies to accrued interest receivable balances 
related to our loan, debt securities and deposits with 
third-party financial institution assets given our 
nonaccrual policy that requires charge-off of interest 
receivable when deemed uncollectible.  Accrued 
interest receivable related to these instruments, along 
with other interest-bearing instruments, is included on 
the consolidated balance sheet.  Accrued interest 
receivable related to each major loan class is 
disclosed in our credit quality disclosure in Note 5.  
Our policy for credit losses related to purchased 
financial assets requires an evaluation to be 
performed prior to the effective purchase date to 
determine if more than an insignificant decline in 
credit quality has occurred during the period between 
the origination and purchase date, or, in the case of 
debt securities, the period between the issuance and 
purchase date.  If we purchase a financial asset with 
more than insignificant deterioration in credit quality, 
the measurement of expected credit loss is performed 
using the methodologies described above, and the 
credit loss is recorded as an allowance for credit 
losses on the purchase date.  Subsequent to purchase, 
changes (favorable and unfavorable) in expected cash 
flows are recognized immediately in net income by 
adjusting the allowance.  We evaluate various factors 
in the determination of whether a more than an 
insignificant decline in credit quality has occurred 
and these factors vary depending upon the type of 
asset purchased.  Such factors include changes in risk 
rating and/or agency rating, collateral deterioration, 
payment status, purchase price, credit spreads and 
other factors.  We did not purchase any such assets in 
2024 or 2023 and did not own such assets as of Dec. 
31, 2024 or Dec. 31, 2023. 
Notes to Consolidated Financial Statements (continued)
BNY 141

We apply a separate credit loss methodology to 
accounts receivables to estimate the expected credit 
losses associated with these short-term receivables 
which historically have not resulted in significant 
credit losses.  The allowance for credit losses on 
accounts receivables is reflected in other assets. 
The qualitative component of our estimate for the 
allowance for credit losses is intended to capture 
expected losses that may not have been fully captured 
in the quantitative component.  Through an 
established governance structure, management 
determines the qualitative allowance each period 
based on an evaluation of various internal and 
environmental factors that include: scenario 
weighting and sensitivity risk, credit concentration 
risk, economic conditions and other considerations.  
We may also make adjustments for idiosyncratic 
risks.  Once determined in the aggregate, our 
qualitative allowance is then allocated to each of our 
financial instrument portfolios except for debt 
securities and those instruments carried in other assets 
based on the respective instruments’ quantitative 
allowance balances.  The allocation of this additional 
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.
The credit quality of our financial assets is assessed 
on an ongoing basis.  Write-offs of financial assets, 
which may be full or partial, are deducted from the 
allowance for credit losses and are recorded in the 
period in which the financial asset(s) are deemed 
uncollectible.
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 two 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. 
Leasing
We determine if an arrangement is a lease at 
inception.  Right-of-use (“ROU”) assets represent our 
right to use an underlying asset for the lease term and 
lease liabilities represent our obligation to make lease 
payments.  The ROU assets and lease liabilities are 
recognized based on the present value of the future 
minimum lease payments over the lease term at 
commencement date or at lease modification date for 
certain lease modifications.  For all leases, we use a 
discount rate that represents a collateralized 
borrowing rate based on similar terms and 
information available at lease commencement date or 
at the modification date for certain lease 
modifications in determining the present value of 
lease payments.  In addition to the lease payments, 
the determination of an ROU asset may also include 
certain adjustments related to lease incentives and 
initial direct costs incurred.  Options to extend or 
terminate a lease are included in the determination of 
the ROU asset and lease liability only when it is 
reasonably certain that we will exercise that option.  
Lease expense for operating leases is recognized on a 
straight-line basis over the lease term, while the lease 
expense for finance leases is recognized using the 
effective interest method.  ROU assets are reviewed 
for impairment when events or circumstances indicate 
that the carrying amount may not be recoverable.  For 
operating leases, if deemed impaired, the ROU asset 
is written down and the remaining balance is 
subsequently amortized on a straight-line basis which 
results in lease expense recognition that is similar to 
finance leases.
For all leases, we have elected to account for the 
contractual lease and non-lease components as a 
single lease component and include them in the 
calculation of the lease liability.  The non-lease 
variable components, such as maintenance expense 
and other variable costs, including non-index or rate 
escalations, have been excluded from the calculation 
and disclosed separately.  Additionally, for certain 
equipment leases, we apply a portfolio approach to 
account for the operating lease ROU assets and 
liabilities. 
For subleasing activities, the rental income is reported 
as part of net occupancy expense, as this activity is 
not a significant business activity and is part of the 
Company’s customary business practice.
Notes to Consolidated Financial Statements (continued)
142 BNY

For direct finance leases, unearned revenue 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.  We have leveraged lease 
transactions that were entered into prior to Dec. 31, 
2018.  These leases are grandfathered under ASC 
842, Leases, which became effective Jan. 1, 2019, 
and will continue to be accounted for under the prior 
guidance unless the leases are subsequently modified.  
Revenue on leveraged 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 revenue.  Impairment of leveraged lease 
residual values that is deemed other-than-temporary 
is reflected in net interest income.  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.
Software
We capitalize 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 on the balance sheet.  We record amortization 
of capitalized software in software and equipment 
expense on the income statement.
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, if any, 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.  
Tax credit investments
Investments in renewable energy projects and 
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 the provision for income 
taxes.  Additionally, the value of the commitments to 
fund renewable energy projects and 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 unless we are 
required to consolidate the investee due to having a 
controlling financial interest.  Unrealized gains and 
losses on seed capital investments are recorded in 
investment and other revenue.  
Noncontrolling interests
Noncontrolling interests represent the portion of 
consolidated entities that are owned by parties other 
than BNY.  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 and represent the redemption value resulting 
from equity-classified share-based payment 
arrangements that are currently redeemable or are 
expected to become redeemable.  We recognize 
changes in the redemption value of the redeemable 
Notes to Consolidated Financial Statements (continued)
BNY 143

noncontrolling interests as they occur and adjust the 
carrying value to be equal to the redemption value.
Fee revenue
Investment services fee revenue and investment 
management and performance fee revenue are based 
on terms specified in a contract with a customer and 
are shown net of fee waivers and exclude 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 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 income
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 income 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 interest 
expense, respectively.
Pension
The measurement date for BNY’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.
Notes to Consolidated Financial Statements (continued)
144 BNY

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 and the largest foreign 
pension plan in the UK are frozen.  Future 
unrecognized actuarial gains and losses for these 
frozen 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.
The market-related value utilized to determine the 
expected return on plan assets is based on the fair 
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.
Stock-based compensation
Compensation expense relating to share-based 
payments is generally recognized in staff expense on 
the income statement, on a straight-line basis, over 
the applicable vesting period.
Certain 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.
A portion of performance share unit awards are 
granted with performance conditions and for which 
the ultimate payout is subject to the discretion of the 
Human Resources and Compensation Committee.  
These awards are classified as equity and marked-to-
market to earnings over the vesting period due to this 
discretion.  A portion of performance share unit 
awards contain market conditions.  The grant date fair 
value of this portion of the awards is recognized on a 
straight-line-basis to staff expense unless the requisite 
service period is not rendered.
Severance
BNY provides separation benefits to eligible U.S.-
based 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 expense 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
Derivatives are recorded on the balance sheet at fair 
value and include futures, forwards, interest rate 
swaps, foreign currency swaps, options and similar 
products.  Derivatives in an unrealized gain position 
Notes to Consolidated Financial Statements (continued)
BNY 145

are recognized as assets while derivatives in an 
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 revenue or investment and other 
revenue, as applicable.
We enter into various derivative financial instruments 
for non-trading purposes primarily as part of our 
asset/liability management process.  These non-
trading derivatives are designated as one of three 
types of hedge activities: fair value, cash flow or net 
investment hedges.  
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, including 
hedging instruments and hedged items, as well as our 
risk management objectives and strategy for 
undertaking each hedging transaction.  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 hedging relationship.  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 
revenue or other trading revenue, as applicable.  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, foreign exchange revenue and staff expense.  
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.  We evaluate the effectiveness of 
foreign currency derivatives designated as hedges of 
net investments utilizing the forward rate method.
Earnings per common share
Basic earnings per common share is calculated by 
dividing net income allocated to common 
shareholders of BNY by the weighted average 
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 treasury stock method by dividing net 
income allocated to common shareholders of BNY by 
the weighted average number of common shares 
outstanding for the period plus the shares representing 
the dilutive effect of equity-based awards.
Prior to 2024, we had stock-based awards that were 
considered participating securities.  As a result, 
earnings per common share was 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 
Notes to Consolidated Financial Statements (continued)
146 BNY

dividends or dividend equivalents are considered 
participating securities under the two-class method. 
Under the two-class method, we increased 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 was calculated by dividing net income 
allocated to common shareholders of BNY by the 
adjusted average number of common shares 
outstanding.
Statement of cash flows
We have defined cash as cash and due from banks.  
Distributions received from equity method investees 
are classified as cash inflows from operating activities 
on the statement of cash flows.  Excess returns on 
investments of equity method investments are 
classified as cash flows from investing activities on 
the statement of cash flows. 
Note 2–Accounting changes and new 
accounting guidance
The following accounting guidance was adopted in 
2024. 
ASU 2023-02, Investments—Equity Method and Joint 
Ventures (Topic 323): Accounting for Investments in 
Tax Credit Structures Using the Proportional 
Amortization Method
In March 2023, the Financial Accounting Standards 
Board (“FASB”) issued ASU 2023-02, Investments—
Equity Method and Joint Ventures (Topic 323): 
Accounting for Investments in Tax Credit Structures 
Using the Proportional Amortization Method, which 
permits reporting entities to elect to account for their 
tax equity investments, regardless of the tax credit 
program from which the income tax credits are 
received, using the proportional amortization method 
if certain conditions are met.  Under the proportional 
amortization method, an entity amortizes the initial 
cost of the investment in proportion to the income tax 
credits and other income tax benefits received, and 
recognizes the net amortization and income tax 
credits and other income tax benefits in the income 
statement as a component of the provision for income 
taxes. 
We adopted this guidance on Jan. 1, 2024.  The 
impact of adopting this new guidance for our 
renewable energy investments that met the eligibility 
criteria was an increase in investment and other 
revenue and an increase in the provision for income 
taxes on the consolidated income statement. 
Renewable energy investments are recorded in other 
assets on the balance sheet.  In 2024, we restated the 
prior period financial statements to reflect the impact 
of the retrospective application of the new accounting 
guidance.  The required disclosures are included in 
Note 8. 
The table below presents the impact of the new accounting guidance on our previously reported income statement 
amounts.
Consolidated Income Statement
Previously reported
Adjustment
Restated
(in millions)
2023
2022
2023
2022
2023
2022
Investment and other revenue
$ 
285 $ 
(82)
$
195 $ 
152 
$ 
480 $ 
70 
Total fee and other revenue
13,157 
12,873 
195 
152 
13,352 
13,025 
Total revenue
17,502 
16,377 
195 
152 
17,697 
16,529 
Income before income taxes
4,088 
3,328 
195 
152 
4,283 
3,480 
Provision for income taxes
800 
768 
179 
169 
979 
937 
Net income
3,288 
2,560 
16 
(17)
3,304
2,543 
Net income applicable to shareholders of The Bank of New 
York Mellon Corporation
3,286 
2,573 
16 
(17)
3,302
2,556 
Net income applicable to common shareholders of 
The Bank of New York Mellon Corporation
3,051 
2,362 
16 
(17)
3,067
2,345 
Notes to Consolidated Financial Statements (continued)
BNY 147

The table below presents the impact of the new accounting guidance on our previously reported earnings per share 
applicable to common shareholders.
Earnings per share applicable to common shareholders of The Bank of New York 
Mellon Corporation
Previously reported
Restated
(in dollars)
2023
2022
2023
2022
Basic
$ 
3.89 $ 
2.91 
$ 
3.91 $ 
2.89 
Diluted
3.87 
2.90 
3.89 
2.88 
The table below presents the impact of the new accounting guidance on our previously reported balance sheet 
amounts.
Consolidated Balance Sheet
Dec. 31, 2023
(in millions)
Previously 
Reported
Adjustment
Restated
Other assets
$ 
25,985 
$ 
(76)
$
25,909 
Total assets
409,953 
(76)
409,877
Accrued taxes and other expenses
5,567 
(156)
5,411
Other liabilities
8,844 
184 
9,028 
Total liabilities
368,944 
28 
368,972 
Retained earnings
39,653 
(104)
39,549
Total The Bank of New York Mellon Corporation shareholders’ equity
40,874 
(104)
40,770
Total permanent equity
40,924 
(104)
40,820
Total liabilities, temporary equity and permanent equity
409,953 
(76)
409,877
ASU 2023-07, Segment Reporting (Topic 280): 
Improvements to Reportable Segment Disclosures
In November 2023, the FASB issued ASU 2023-07, 
Segment Reporting (Topic 280): Improvements to 
Reportable Segment Disclosures, which requires a 
public entity to disclose, on an annual and interim 
basis, significant segment expenses that are regularly 
provided to the chief operating decision maker 
(“CODM”) and included within each reported 
measure of segment profit or loss (collectively 
referred to as the “significant expense principle”).  In 
addition, disclosure will be required of the title and 
position of CODM, and how the CODM uses the 
reported measure of segment profit or loss in 
assessing segment performance and deciding how to 
allocate resources.
We adopted this guidance as of Dec. 31, 2024.  The 
impact of adopting this ASU did not have a material 
effect on BNY’s business segment disclosures.  The 
required disclosures are included in Note 24.  
Staff Accounting Bulletin No. 122
In January 2025, the SEC staff released Staff 
Accounting Bulletin No. 122 (“SAB 122”), which 
rescinds the interpretative guidance included in SAB 
121 which had expressed the staff’s views regarding 
the accounting for entities that have obligations to 
safeguard “crypto-assets” held for their platform 
users.  SAB 121 provided that these entities should 
present a liability and corresponding asset in respect 
of the crypto-assets safeguarded for their platform 
users.  We have elected to early adopt SAB 122 on a 
retrospective basis as of and for the year-ended Dec. 
31, 2024.  Adopting SAB 122 had no impact to our 
balance sheet.  We will continue to determine 
whether to recognize a liability related to the risk of 
loss related to our obligation to safeguard client assets 
based on incurring a loss contingency that is both 
probable and reasonably estimable. 
Note 3–Acquisitions and dispositions
We sometimes structure our acquisitions and 
divestitures with both an initial payment or receipt 
and later contingent payments or receipts tied to post-
closing revenue or income growth.  
At Dec. 31, 2024, we are potentially obligated to pay 
additional consideration which is recorded at fair 
value totaling approximately $5 million and, using 
reasonable assumptions and estimates, could range 
from $0 million to $5 million over the next year.  
During 2024, we made contingent payments that 
Notes to Consolidated Financial Statements (continued)
148 BNY

totaled $14 million.  We recorded a decrease of $3 
million to contingent earnout payables reflected in 
other expense in 2024.  
At Dec. 31, 2024, we could potentially receive 
additional consideration which is recorded at fair 
value totaling approximately $15 million and, using 
reasonable assumptions and estimates, could range 
from $5 million to $25 million over the next three 
years.  During 2024, contingent receipts totaled $18 
million.
Transactions in 2024
On Nov. 1, 2024, we acquired all of the outstanding 
ownership interests in Archer Holdco, LLC, a leading 
technology-enabled service provider of managed 
account solutions to the asset and wealth management 
industry, for cash.  Non-tax deductible goodwill, 
software and a customer contract intangible asset 
were recorded related to this acquisition, and are 
included in the Securities Services business segment.  
Transactions in 2022
On Nov. 1, 2022, BNY completed the sale of BNY 
Alcentra Group Holdings, Inc. (together with its 
subsidiaries, “Alcentra”) for $350 million cash 
consideration at close and contingent consideration 
dependent on the achievement of certain performance 
thresholds.  We recorded an $11 million pre-tax loss 
and a $40 million after-tax loss on this transaction.  
At Oct. 31, 2022, Alcentra had $32 billion in assets 
under management (“AUM”) concentrated in senior 
secured loans, high yield bonds, private credit, 
structured credit, special situations and multi-strategy 
credit strategies.  In addition, goodwill related to 
Alcentra of $434 million was removed from the 
consolidated balance sheet as a result of this sale. 
On Aug. 1, 2022, BNY completed the sale of 
HedgeMark Advisors, LLC (“HedgeMark”), and 
recorded a $37 million pre-tax gain.  As part of the 
sale, BNY received an equity interest in the acquiring 
firm.  In addition, goodwill related to HedgeMark of 
$13 million was removed from the consolidated 
balance sheet as result of this sale.
Note 4–Securities
The following tables present the amortized cost, the 
gross unrealized gains and losses and the fair value of 
securities at Dec. 31, 2024 and Dec. 31, 2023.
Securities at Dec. 31, 2024
Gross
unrealized
Fair
value
Amortized 
cost
(in millions)
Gains
Losses
Available-for-sale (a):
Non-U.S. government (b)
$ 25,042 $ 
61 $ 356 $ 24,747 
Agency residential 
mortgage-backed 
securities (“RMBS”)
 
20,459  
16  
575  
19,900 
U.S. Treasury
 
16,575  
9  
181  
16,403 
Agency commercial 
mortgage-backed 
securities (“MBS”)
 
7,467  
5  
247  
7,225 
Foreign covered bonds
 
7,129  
33  
94  
7,068 
Collateralized loan 
obligations (“CLOs”)
 
5,809  
10  
—  
5,819 
Non-agency commercial 
MBS
 
2,641  
2  
156  
2,487 
U.S. government agencies  
2,304  
4  
19  
2,289 
Non-agency RMBS
 
1,639  
2  
163  
1,478 
Other asset-backed 
securities (“ABS”)
 
654  
1  
40  
615 
Total available-for-sale 
securities excluding 
portfolio level basis 
adjustments (c)
 
89,719  
143  1,831  
88,031 
Portfolio level basis 
adjustments (d)
 
(92)  
—  
(92)  
— 
Total available-for-sale 
securities
$ 89,627 $ 143 $ 1,739 $ 88,031 
Held-to-maturity:
Agency RMBS
$ 25,824 $ 
4 $ 3,545 $ 22,283 
U.S. Treasury
 
8,833  
—  
443  
8,390 
Non-U.S. government (b)
 
4,479  
8  
36  
4,451 
U.S. government agencies  
3,669  
—  
322  
3,347 
Agency commercial MBS  
3,395  
—  
243  
3,152 
CLOs
 
1,816  
2  
—  
1,818 
Foreign covered bonds
 
555  
1  
1  
555 
Non-agency RMBS
 
14  
—  
—  
14 
Other debt securities
 
11  
—  
1  
10 
Total held-to-maturity 
securities (e)
$ 48,596 $ 
15 $ 4,591 $ 44,020 
Total securities
$ 138,223 $ 158 $ 6,330 $ 132,051 
(a) Beginning Dec. 31, 2024, we are reporting basis adjustments 
related to the hedges of available-for-sale securities as an 
adjustment to the amortized cost, which results in the unrealized 
gains and losses being reflected net of hedges.  See Note 23 for 
additional information on our hedging activities and related 
impacts.
(b) Includes supranational securities.
(c) The amortized cost of available-for-sale and held-to-maturity 
securities is net of the allowance for credit losses.  There was no 
allowance for credit losses on available-for-sale securities at 
Dec. 31, 2024.  The allowance for credit losses on held-to-
maturity securities was less than $1 million at Dec. 31, 2024 
and related to other debt securities.
(d) Represents fair value hedge basis adjustments related to active 
portfolio layer method hedges of available-for-sale securities, 
which are not allocated to individual securities in the portfolio. 
See Note 23 for additional information on our hedging 
activities.
(e) Held-to-maturity securities transferred from available-for-sale 
are initially recorded at fair value as of the date of transfer.  
The amortized cost of held-to-maturity securities includes the 
net unamortized portion of unrealized gains and losses related 
to securities transferred, which are offset in OCI.  See Note 16 
for additional information.
Notes to Consolidated Financial Statements (continued)
BNY 149

Securities at Dec. 31, 2023
Gross
unrealized
Amortized 
cost
Fair
value
(in millions)
Gains
Losses
Available-for-sale:
Non-U.S. government (a)
$ 18,998 $ 
68 $ 
684 $ 18,382 
U.S. Treasury
 
18,193  
63  1,652  
16,604 
Agency RMBS
 
13,457  
119  
465  
13,111 
Agency commercial MBS  
8,191  
69  
531  
7,729 
Foreign covered bonds
 
6,489  
25  
180  
6,334 
CLOs
 
6,142  
5  
10  
6,137 
Non-agency commercial 
MBS
 
3,245  
1  
311  
2,935 
U.S. government agencies  
3,053  
42  
194  
2,901 
Non-agency RMBS
 
1,883  
32  
175  
1,740 
Other ABS
 
1,026  
1  
84  
943 
Other debt securities
 
1  
—  
—  
1 
Total available-for-sale 
securities (b)
$ 80,678 $ 425 $ 4,286 $ 76,817 
Held-to-maturity:
Agency RMBS
$ 29,740 $ 
1 $ 3,493 $ 26,248 
U.S. Treasury
 
9,123  
—  
612  
8,511 
U.S. government agencies  
4,146  
—  
401  
3,745 
Agency commercial MBS  
3,411  
1  
296  
3,116 
Non-U.S. government (a)
 
2,137  
3  
67  
2,073 
CLOs
 
983  
—  
1  
982 
Non-agency RMBS
 
26  
1  
1  
26 
Other debt securities
 
12  
—  
2  
10 
Total held-to-maturity 
securities (c)
$ 49,578 $ 
6 $ 4,873 $ 44,711 
Total securities
$ 130,256 $ 431 $ 9,159 $ 121,528 
(a) Includes supranational securities.
(b) The amortized cost of available-for-sale securities is net of the 
allowance for credit loss of less than $1 million.  The allowance 
for credit loss primarily relates to non-agency RMBS.
(c) Held-to-maturity securities transferred from available-for-sale 
are initially recorded at fair value as of the date of transfer.  
The amortized cost of held-to-maturity securities includes the 
net unamortized portion of unrealized gains and losses related 
to securities transferred, which are offset in OCI.  See Note 16 
for additional information.
The following table presents the realized gains and 
losses, on a gross basis.
Net securities gains (losses)
(in millions)
2024
2023
2022
Realized gross gains
$ 
44 $ 
20 $ 
92 
Realized gross losses
 
(129)  
(88)  
(535) 
Total net securities (losses)
$ 
(85) $ 
(68) $ (443) 
The following table presents pre-tax net securities 
gains (losses) by type.
Net securities gains (losses)
(in millions)
2024
2023
2022
U.S. Treasury
$ 
(24) $ 
(76) $ 
12 
Non-agency RMBS
 
24  
2  
49 
Non-U.S. government
 
(46)  
2  
3 
Other ABS
 
(13)  
—  
1 
Other
 
(26)  
4  
(508) (a)
Total net securities (losses)
$ 
(85) $ 
(68) $ (443) 
(a) Includes net securities losses from repositioning the 
securities portfolio which was comprised of $337 million 
related to state and political subdivisions and $177 million 
related to corporate bonds.
In 2024, U.S. Treasury securities and CLOs with an 
aggregate amortized cost of $4.0 billion and fair value 
of $3.7 billion were transferred from available-for-
sale securities to held-to-maturity securities.  This 
transfer reduced the impact of changes in interest 
rates on accumulated OCI.
Allowance for credit losses – Securities
The allowance for credit losses related to securities 
was less than $1 million at Dec. 31, 2024 and related 
to other debt securities.  The allowance for credit 
losses related to securities was $1 million at Dec. 31, 
2023, and related to non-agency RMBS and other 
debt securities.  
Credit quality indicators – Securities
At Dec. 31, 2024, the gross unrealized losses on the 
securities portfolio were primarily attributable to an 
increase in interest rates from the 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.  
As the transfers created a new cost basis for the 
securities, if these securities have experienced 
unrealized losses since the date of transfer, the 
corresponding unrealized losses would be reflected in 
the held-to-maturity securities portfolio in the 
following tables.  
Notes to Consolidated Financial Statements (continued)
150 BNY

The following tables show the aggregate fair value of available-for-sale 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 without an allowance for credit losses.
Available-for-sale securities in an unrealized loss 
position without an allowance for credit losses at 
Dec. 31, 2024
Less than 12 months
12 months or more
Total
Fair
value
Unrealized
losses
Fair
value
Unrealized
losses
Fair
value
Unrealized
losses
(in millions)
Agency RMBS
$ 
10,469 $ 
249 
$ 
7,003 $ 
326 
$ 
17,472 $ 
575 
Non-U.S. government (a)
 
7,283  
59 
 
7,305  
297 
 
14,588  
356 
U.S. Treasury
 
4,154  
15 
 
8,334  
166 
 
12,488  
181 
Agency commercial MBS
 
554  
5 
 
5,841  
242 
 
6,395  
247 
Foreign covered bonds
 
892  
2 
 
2,287  
92 
 
3,179  
94 
Non-agency commercial MBS
 
58  
— 
 
2,127  
156 
 
2,185  
156 
U.S. government agencies
 
576  
9 
 
905  
10 
 
1,481  
19 
Non-agency RMBS
 
139  
2 
 
995  
161 
 
1,134  
163 
Other ABS
 
3  
— 
 
536  
40 
 
539  
40 
Total securities available-for-sale
$ 
24,128 $ 
341 
$ 
35,333 $ 
1,490 
$ 
59,461 $ 
1,831 
(a) Includes supranational securities.
Available-for-sale securities in an unrealized loss 
position without an allowance for credit losses at 
Dec. 31, 2023
Less than 12 months
12 months or more
Total
Fair
value
Unrealized
losses
Fair
value
Unrealized
losses
Fair
value
Unrealized
losses
(in millions)
U.S. Treasury
$ 
694 $ 
48 
$ 
14,862 $ 
1,604 
$ 
15,556 $ 
1,652 
Non-U.S. government (a)
 
2,756  
24 
 
11,767  
660 
 
14,523  
684 
Agency RMBS
 
2,753  
27 
 
6,793  
438 
 
9,546  
465 
Agency commercial MBS
 
328  
5 
 
7,060  
526 
 
7,388  
531 
CLOs
 
784  
— 
 
3,158  
10 
 
3,942  
10 
Foreign covered bonds
 
268  
1 
 
3,603  
179 
 
3,871  
180 
Non-agency commercial MBS
 
187  
2 
 
2,607  
309 
 
2,794  
311 
U.S. government agencies
 
573  
4 
 
1,779  
190 
 
2,352  
194 
Non-agency RMBS
 
30  
1 
 
1,300  
174 
 
1,330  
175 
Other ABS
 
—  
— 
 
832  
84 
 
832  
84 
Total securities available-for-sale
$ 
8,373 $ 
112 
$ 
53,761 $ 
4,174 
$ 
62,134 $ 
4,286 
(a) Includes supranational securities.
Notes to Consolidated Financial Statements (continued)
BNY 151

The following tables show the credit quality of the held-to-maturity securities.  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 could indicate increased credit risk for us and could be accompanied by 
an increase in the allowance for credit losses and/or a reduction in the fair value of our securities portfolio.
Held-to-maturity securities portfolio at Dec. 31, 2024
Ratings (a)
Net 
unrealized 
gain (loss)
BB+
and
lower
(dollars in millions)
Amortized 
cost
AAA/
AA-
A+/
A-
BBB+/
BBB-
Not
rated
Agency RMBS
$ 
25,824 
$ 
(3,541) 
 100% 
 —% 
 —% 
 —% 
 —% 
U.S. Treasury
 
8,833 
 
(443) 
 100 
 — 
 — 
 — 
 — 
Non-U.S. government (b)(c)
 
4,479 
 
(28) 
 100 
 — 
 — 
 — 
 — 
U.S. government agencies
 
3,669 
 
(322) 
 100 
 — 
 — 
 — 
 — 
Agency commercial MBS
 
3,395 
 
(243) 
 100 
 — 
 — 
 — 
 — 
CLOs
 
1,816 
 
2 
 100 
 — 
 — 
 — 
 — 
Foreign covered bonds 
 
555 
 
— 
 100 
 — 
 — 
 — 
 — 
Non-agency RMBS
 
14 
 
— 
 23 
 77 
 — 
 — 
 — 
Other debt securities
 
11 
 
(1) 
 — 
 — 
 — 
 — 
 100 
Total held-to-maturity securities
$ 
48,596 
$ 
(4,576) 
 100% 
 —% 
 —% 
 —% 
 —% 
(a) Represents ratings by Standard & Poor’s (“S&P”) or the equivalent.
(b) Includes supranational securities.  
(c) Primarily consists of exposure to UK, Germany, the Netherlands, Austria and France.
Held-to-maturity securities portfolio at Dec. 31, 2023
Ratings (a)
Net 
unrealized 
gain (loss)
BB+
and
lower
(dollars in millions)
Amortized 
cost
AAA/
AA-
A+/
A-
BBB+/
BBB-
Not
rated
Agency RMBS
$ 
29,740 
$ 
(3,492) 
 100% 
 —% 
 —% 
 —% 
 —% 
U.S. Treasury
 
9,123 
 
(612) 
 100 
 — 
 — 
 — 
 — 
U.S. government agencies
 
4,146 
 
(401) 
 100 
 — 
 — 
 — 
 — 
Agency commercial MBS
 
3,411 
 
(295) 
 100 
 — 
 — 
 — 
 — 
Non-U.S. government (b)(c)
 
2,137 
 
(64) 
 100 
 — 
 — 
 — 
 — 
CLOs
 
983 
 
(1) 
 100 
 — 
 — 
 — 
 — 
Non-agency RMBS
 
26 
 
— 
 25 
 54 
 2 
 17 
 2 
Other debt securities
 
12 
 
(2) 
 — 
 — 
 — 
 — 
 100 
Total held-to-maturity securities
$ 
49,578 
$ 
(4,867) 
 100% 
 —% 
 —% 
 —% 
 —% 
(a) Represents ratings by S&P or the equivalent.
(b) Includes supranational securities.
(c) Primarily consists of exposure to Germany, France, UK and the Netherlands.
Notes to Consolidated Financial Statements (continued)
152 BNY

Maturity distribution
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, 2024
Within 1 year
1-5 years
5-10 years
After 10 years
Total
(dollars in millions)
Amount
Yield (a)
Amount
Yield (a)
Amount
Yield (a)
Amount
Yield (a)
Amount
Yield (a)
Available-for-sale:
U.S. Treasury
$ 
563 
 1.80% 
$ 12,759 
 2.42% 
$ 1,210 
 3.03% 
$ 1,871 
 2.92% 
$ 16,403 
 2.52% 
Non-U.S. government (b)
 
4,503 
 2.54 
 17,318 
 3.21 
 
2,894 
 2.65 
 
32 
 3.42 
 24,747 
 3.02 
Foreign covered bonds
 
805 
 3.47 
 
5,943 
 3.26 
 
320 
 2.79 
 
— 
 — 
 
7,068 
 3.27 
U.S. government agencies
 
278 
 3.85 
 
1,287 
 3.51 
 
724 
 2.57 
 
— 
 — 
 
2,289 
 3.22 
Mortgage-backed securities:
Agency RMBS
 19,900 
 4.78 
Non-agency RMBS
 
1,478 
 3.51 
Agency commercial MBS
 
7,225 
 3.05 
Non-agency commercial MBS
 
2,487 
 2.95 
CLOs
 
5,819 
 6.04 
Other ABS
 
615 
 2.33 
Total securities available-for-sale
$ 6,149 
 2.65% 
$ 37,307 
 2.95% 
$ 5,148 
 2.74% 
$ 1,903 
 2.92% 
$ 88,031 
 3.54% 
Held-to-maturity:
U.S. Treasury
$ 1,081 
 0.86% 
$ 6,653 
 1.22% 
$ 1,099 
 0.96% 
$ 
— 
 —% 
$ 8,833 
 1.14% 
U.S. government agencies
 
1,008 
 1.46 
 
1,971 
 1.52 
 
477 
 1.51 
 
213 
 1.99 
 
3,669 
 1.53 
Non-U.S. government (b)
 
709 
 1.23 
 
3,530 
 2.58 
 
240 
 2.24 
 
— 
 — 
 
4,479 
 2.35 
Foreign covered bonds
 
— 
 — 
 
555 
 2.54 
 
— 
 — 
 
— 
 — 
 
555 
 2.54 
Other debt securities
 
— 
 — 
 
— 
 — 
 
11 
 4.75 
 
— 
 — 
 
11 
 4.75 
Mortgage-backed securities:
Agency RMBS
 25,824 
 2.34 
Non-agency RMBS
 
14 
 5.52 
Agency commercial MBS
 
3,395 
 2.61 
CLOs
 
1,816 
 6.06 
Total securities held-to-maturity
$ 2,798 
 1.17% 
$ 12,709 
 1.70% 
$ 1,827 
 1.30% 
$ 
213 
 1.99% 
$ 48,596 
 2.22% 
Total securities
$ 8,947 
 2.19% 
$ 50,016 
 2.64% 
$ 6,975 
 2.38% 
$ 2,116 
 2.85% 
$ 136,627 
 3.08% 
(a) 
Yields are based upon the amortized cost of securities and consider the contractual coupon, amortization of premiums and accretion of discounts, 
excluding the effect of related hedging derivatives.
(b) 
Includes supranational securities.
Pledged assets
At Dec. 31, 2024, BNY had pledged assets of $138 
billion, including $88 billion pledged as collateral for 
potential borrowing at the Federal Reserve Discount 
Window and $10 billion pledged as collateral for 
borrowing at the Federal Home Loan Bank.  The 
components of the assets pledged at Dec. 31, 2024 
included $117 billion of securities, $15 billion of 
loans, $5 billion of trading assets and $1 billion of 
interest-bearing deposits with banks.
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 regularly moves assets in 
and out of its pledged assets account at the Federal 
Reserve.
At Dec. 31, 2023, BNY had pledged assets of $134 
billion, including $93 billion pledged as collateral for 
potential borrowing at the Federal Reserve Discount 
Window and $9 billion pledged as collateral for 
borrowing at the Federal Home Loan Bank.  The 
components of the assets pledged at Dec. 31, 2023 
included $116 billion of securities, $13 billion of 
loans, $4 billion of trading assets and $1 billion of 
interest-bearing deposits with banks. 
At Dec. 31, 2024 and Dec. 31, 2023, pledged assets 
included $23 billion and $24 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 
Notes to Consolidated Financial Statements (continued)
BNY 153

others.  At Dec. 31, 2024 and Dec. 31, 2023, the 
market value of the securities received that can be 
sold or repledged was $300 billion and $212 billion, 
respectively.  We routinely sell or repledge these 
securities through delivery to third parties.  As of 
Dec. 31, 2024 and Dec. 31, 2023, the market value of 
securities collateral sold or repledged was $264 
billion and $180 billion, respectively.
Restricted cash and securities
Cash and securities may be segregated under federal 
and other regulations or requirements.  At Dec. 31, 
2024 and Dec. 31, 2023, cash segregated under 
federal and other regulations or requirements was $1 
billion and $3 billion, respectively.  Restricted cash is 
primarily included in interest-bearing deposits with 
banks on the consolidated balance sheet.  Securities 
segregated under federal and other regulations or 
requirements were $5 billion at Dec. 31, 2024 and $3 
billion at Dec. 31, 2023.  Restricted securities were 
sourced from securities purchased under resale 
agreements and securities borrowings and are 
included in federal funds sold and securities 
purchased under resale agreements on the 
consolidated balance sheet. 
Note 5–Loans and asset quality
Loans
The table below provides the details of our loan 
portfolio.
Loans
Dec. 31,
(in millions)
2024
2023
Commercial
$ 
1,420 $ 
2,112 
Commercial real estate
6,782 
6,760 
Financial institutions
13,167 
10,521 
Lease financings
603 
599 
Wealth management loans
8,698 
9,109 
Wealth management mortgages
8,950 
9,131 
Other residential mortgages
1,068 
1,166 
Capital call financing
5,163 
3,700 
Other
3,063 
2,717 
Overdrafts
3,519 
3,053 
Margin loans
19,137 
18,011 
Total loans (a)
$ 
71,570 $ 
66,879 
(a)
Net of unearned income of $230 million at Dec. 31, 2024
and $268 million at Dec. 31, 2023, primarily related to lease
financings.
We disclose information related to our loans and asset 
quality by the class of financing receivable in the 
following tables.
Allowance for credit losses
Activity in the allowance for credit losses on loans 
and lending-related commitments is presented below. 
This does not include activity in the allowance for 
credit losses related to other financial instruments, 
including cash and due from banks, interest-bearing 
deposits with banks, federal funds sold and securities 
purchased under resale agreements, held-to-maturity 
securities, available-for-sale securities and accounts 
receivable.
Notes to Consolidated Financial Statements (continued)
154 BNY

Allowance for credit losses activity for the year ended Dec. 31, 2024 (a)
Wealth 
management 
loans
Wealth 
management 
mortgages
Other
residential
mortgages
Capital 
call 
financing
Total
(in millions)
Commercial
Commercial
real estate
Financial
institutions
Lease
financings
Beginning balance
$ 
27 $ 
325 $ 
19 $ 
1 $ 
1 $ 
9 $ 
4 $ 
4 $ 
390 
Charge-offs
— 
(82)
—
— 
— 
(1)
(1)
— 
(84) 
Recoveries
— 
— 
— 
— 
— 
— 
1 
— 
1 
Net (charge-offs) 
— 
(82)
—
— 
— 
(1)
—
— 
(83) 
Provision (b)
(7)
72 
—
(1)
— 
(2)
(2)
(1)
59 
Ending balance
$ 
20 $ 
315 $ 
19 $ 
— $ 
1 $ 
6 $ 
2 $ 
3 $ 
366 
Allowance for:
Loan losses
$ 
7 $ 
265 $ 
11 $ 
— $ 
1 $ 
6 $ 
2 $ 
2 $ 
294 
Lending-related commitments
13 
50 
8 
— 
— 
— 
— 
1 
72 
Individually evaluated for impairment:
Loan balance (c)
$ 
— $ 
237 $ 
— $ 
— $ 
— $ 
9 $ 
1 $ 
— $ 
247 
Allowance for loan losses
— 
49 
— 
— 
— 
— 
— 
— 
49 
(a)
There was no activity in the other loan portfolio.
(b)
Does not include provision for credit losses related to other financial instruments of $11 million for the year ended Dec. 31, 2024.
(c)
Includes collateral dependent loans of $247 million with $258 million of collateral value.
Allowance for credit losses activity for the year ended Dec. 31, 2023
Wealth 
management 
loans
Wealth 
management 
mortgages
Other
residential
mortgages
Capital 
call 
financing
Other
Total
(in millions)
Commercial
Commercial
real estate
Financial
institutions
Lease
financings
Beginning balance
$ 
18 $ 
184 $ 
24 $ 
1 $ 
1 $ 
12 $ 
8 $ 
6 $ 
— $ 
254 
Charge-offs
— 
— 
— 
— 
— 
— 
(3)
—
— 
(3) 
Recoveries
1 
— 
— 
— 
— 
— 
2  
—
5 
8 
Net recoveries (charge-
offs)
1 
— 
— 
— 
— 
— 
(1)
—
5 
5 
Provision (a)
8 
141 
(5)
— 
— 
(3)
(3)
(2)
(5)
131 
Ending balance
$ 
27 $ 
325 $ 
19 $ 
1 $ 
1 $ 
9 $ 
4 $ 
4 $ 
— $ 
390 
Allowance for:
Loan losses
$ 
12 $ 
266 $ 
9 $ 
1 $ 
1 $ 
8 $ 
4 $ 
2 $ 
— $ 
303 
Lending-related 
commitments
15 
59 
10 
— 
— 
1 
— 
2 
— 
87 
Individually evaluated for 
impairment:
Loan balance (b)
$ 
— $ 
290 $ 
— $ 
— $ 
— $ 
12 $ 
1 $ 
— $ 
— $ 
303 
Allowance for loan losses
— 
76 
— 
— 
— 
— 
— 
— 
— 
76 
(a)
Does not include provision for credit losses benefit related to other financial instruments of $12 million for the year ended Dec. 31, 2023.
(b)
Includes collateral dependent loans of $303 million with $348 million of collateral at fair value.
Allowance for credit losses activity for the year ended Dec. 31, 2022 (a)
Wealth 
management 
loans
Wealth 
management 
mortgages
Other
residential
mortgages
Capital 
call 
financing
Total
(in millions)
Commercial
Commercial
real estate
Financial
institutions
Lease
financings
Beginning balance 
$ 
12 $ 
199 $ 
13 $ 
1 $ 
1 $ 
6 $ 
7 $ 
2 $ 
241 
Charge-offs
— 
— 
— 
— 
— 
— 
— 
— 
— 
Recoveries
— 
— 
— 
— 
— 
— 
4 
— 
4 
Net recoveries
— 
— 
— 
— 
— 
— 
4 
— 
4 
Provision (b)
6 
(15)
11
— 
— 
6 
(3)
4 
9 
Ending balance
$ 
18 $ 
184 $ 
24 $ 
1 $ 
1 $ 
12 $ 
8 $ 
6 $ 
254 
Allowance for:
Loan losses
$ 
4 $ 
137 $ 
10 $ 
1 $ 
1 $ 
11 $ 
8 $ 
4 $ 
176 
Lending-related commitments 
14 
47 
14 
— 
— 
1 
— 
2 
78 
Individually evaluated for impairment:
Loan balance (c)
$ 
— $ 
62 $ 
— $ 
— $ 
— $ 
16 $ 
1 $ 
— $ 
79 
Allowance for loan losses
— 
— 
— 
— 
— 
— 
— 
— 
— 
(a)
There was no activity in the other loan portfolio.
(b)
Does not include provision for credit losses related to other financial instruments of $30 million for the year ended Dec. 31, 2022.
(c)
Includes collateral dependent loans of $79 million with $126 million of collateral at fair value.
Notes to Consolidated Financial Statements (continued)
BNY 155

Nonperforming assets
The table below presents our nonperforming assets.
Nonperforming assets
Dec. 31, 2024
Dec. 31, 2023
Recorded investment
Recorded investment
With an
allowance
Without an 
allowance
With an
allowance
Without an 
allowance
(in millions)
Total
Total
Nonperforming loans:
Commercial real estate
$ 
104 $ 
39 $ 
143 
$ 
189 $ 
— $ 
189 
Other residential mortgages
 
18  
1  
19 
 
23  
1  
24 
Wealth management mortgages
 
6  
9  
15 
 
7  
12  
19 
Total nonperforming loans
 
128  
49  
177 
 
219  
13  
232 
Other assets owned
 
—  
2  
2 
 
—  
5  
5 
Total nonperforming assets
$ 
128 $ 
51 $ 
179 
$ 
219 $ 
18 $ 
237 
Past due loans
The table below presents our past due loans.
Past due loans and still accruing interest
Dec. 31, 2024
Dec. 31, 2023
 
Days past due
Total
past due
Days past due
Total
past due
(in millions)
30-59
60-89
≥90
30-59
60-89
≥90
Wealth management loans
$ 
47 $ 
— $ 
— $ 
47 
$ 
52 
$ 
— $ 
— $ 
52 
Wealth management mortgages
 
34  
2  
—  
36 
 
26 
 
3  
—  
29 
Commercial real estate
 
15  
—  
—  
15 
 
9 
 
3  
—  
12 
Other residential mortgages
 
7  
1  
—  
8 
 
7 
 
1  
—  
8 
Financial institutions
 
—  
—  
—  
— 
 
339 (a)  
—  
—  
339 
Total past due loans
$ 
103 $ 
3 $ 
— $ 
106 
$ 
433 
$ 
7 $ 
— $ 
440 
(a) The past due financial institutions loans have been collected since Dec. 31, 2023.
Loan modifications
Modified loans are evaluated to determine whether a 
modification or restructuring with a borrower 
experiencing financial difficulty results in principal 
forgiveness, an interest rate reduction, an other-than-
insignificant payment delay, or a term extension.  The 
modification could result in a new loan or a 
continuation of the existing loan.  
In 2024, we modified five commercial real estate 
loans, with an aggregate recorded investment of 
$212 million and unfunded lending commitments of 
$20 million, by extending the maturity dates, and, in 
certain instances, changing the interest rate or 
providing other payment modifications.  Commercial 
real estate loans of $118 million were repaid prior to 
Dec. 31, 2024, and unfunded lending commitments of 
$16 million were canceled prior to Dec. 31, 2024.
Also in 2024, we also modified four other residential 
mortgage loans, with an aggregate recorded 
investment of $1 million, by providing payment 
modifications.
At Dec. 31, 2024, other residential mortgage loans 
that were modified in the previous 12 months and that 
are now past due by more than 90 days totaled $1 
million.
In 2023, we modified two commercial real estate 
loans, with an aggregate recorded investment of 
$71 million and an unfunded lending commitment of 
$15 million, by extending the maturity dates.  One of 
these loans matured in 2023 after the modification.
Also in 2023, we modified six other residential 
mortgage loans, with an aggregate recorded 
investment of $2 million, by providing payment 
modifications, extending maturity dates, reducing the 
interest rate, or a combination of these modifications.
Notes to Consolidated Financial Statements (continued)
156 BNY

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 tables below provide information about the credit profile of the loan portfolio by the period of origination.
Credit profile of the loan portfolio
Dec. 31, 2024
Revolving loans
Originated, at amortized cost
Amortized 
cost
Converted to 
term loans – 
Amortized 
cost
Accrued
interest
receivable
(in millions)
2024
2023
2022
2021
2020
Prior to 
2020
Total (a)
Commercial:
Investment grade
$ 
41 $ 
69 $ 
20 $ 
55 $ 
— $ 
116 $ 
1,010 $ 
— $ 
1,311 
Non-investment grade
 
14  
29  
—  
17  
—  
—  
49  
—  
109 
Total commercial
 
55  
98  
20  
72  
—  
116  
1,059  
—  
1,420 $ 
2 
Commercial real estate (b):
Investment grade
 
396  
567  
762  
392  
460  
1,384  
126  
—  
4,087 
Non-investment grade
 
335  
315  
751  
351  
214  
617  
94  
18  
2,695 
Total commercial real estate
 
731  
882  
1,513  
743  
674  
2,001  
220  
18  
6,782  
28 
Financial institutions:
Investment grade
 
491  
370  
20  
26  
42  
—  
10,363  
—  
11,312 
Non-investment grade
 
131  
—  
10  
—  
—  
—  
1,714  
—  
1,855 
Total financial institutions
 
622  
370  
30  
26  
42  
—  
12,077  
—  
13,167  
157 
Wealth management loans:
Investment grade
 
3  
29  
33  
110  
33  
109  
8,261  
100  
8,678 
Non-investment grade
 
—  
—  
—  
—  
—  
—  
20  
—  
20 
Total wealth management loans
 
3  
29  
33  
110  
33  
109  
8,281  
100  
8,698  
50 
Wealth management mortgages (b)
 
495  
798  
1,585  
1,812  
818  
3,423  
19  
—  
8,950  
23 
Lease financings
 
—  
—  
—  
10  
31  
562  
—  
—  
603  
— 
Other residential mortgages (b)
 
15  
148  
529  
184  
5  
187  
—  
—  
1,068  
4 
Capital call financing
 
91  
—  
—  
—  
—  
—  
5,072  
—  
5,163  
28 
Other loans
 
—  
—  
—  
—  
—  
—  
3,063  
—  
3,063  
6 
Margin loans
 
7,732  
—  
—  
—  
—  
—  
11,405  
—  
19,137  
38 
Total loans
$ 
9,744 $ 2,325 $ 3,710 $ 2,957 $ 1,603 $ 
6,398 $ 
41,196 $ 
118 $ 68,051 $ 
336 
(a) 
Excludes overdrafts of $3,519 million.  Overdrafts occur on a daily basis primarily in the custody and securities clearance business and are generally 
repaid within two business days.
(b) 
The gross write-offs related to commercial real estate loans were $82 million, other residential mortgage loans were $1 million and wealth management 
mortgage loans were less than $1 million in 2024.
Notes to Consolidated Financial Statements (continued)
BNY 157

Credit profile of the loan portfolio
Dec. 31, 2023
Revolving loans
Originated, at amortized cost
Amortized 
cost
Converted to 
term loans – 
Amortized 
cost
Accrued
interest
receivable
(in millions)
2023
2022
2021
2020
2019
Prior to 
2019
Total (a)
Commercial:
Investment grade
$ 
193 $ 
114 $ 
70 $ 
— $ 
— $ 
45 $ 
1,483 $ 
— $ 
1,905 
Non-investment grade
 
52  
18  
—  
—  
—  
—  
137  
—  
207 
Total commercial
 
245  
132  
70  
—  
—  
45  
1,620  
—  
2,112 $ 
3 
Commercial real estate:
Investment grade
 
1,518  
864  
585  
152  
271  
875  
136  
22  
4,423 
Non-investment grade
 
1,172  
685  
154  
43  
47  
152  
84  
—  
2,337 
Total commercial real estate
 
2,690  
1,549  
739  
195  
318  
1,027  
220  
22  
6,760  
30 
Financial institutions:
Investment grade
 
616  
74  
57  
—  
—  
10  
6,948  
—  
7,705 
Non-investment grade
 
134  
10  
—  
—  
—  
—  
2,672  
—  
2,816 
Total financial institutions
 
750  
84  
57  
—  
—  
10  
9,620  
—  
10,521  
120 
Wealth management loans:
Investment grade
 
39  
30  
110  
26  
7  
167  
8,542  
101  
9,022 
Non-investment grade
 
—  
2  
—  
—  
—  
—  
85  
—  
87 
Total wealth management 
loans
 
39  
32  
110  
26  
7  
167  
8,627  
101  
9,109  
57 
Wealth management mortgages
 
850  
1,689  
1,909  
863  
736  
3,066  
18  
—  
9,131  
22 
Lease financings
 
230  
—  
—  
40  
7  
322  
—  
—  
599  
— 
Other residential mortgages (b)
 
184  
561  
200  
5  
—  
216  
—  
—  
1,166  
5 
Capital call financing
 
10  
—  
—  
—  
—  
—  
3,690  
—  
3,700  
15 
Other loans
 
—  
—  
—  
—  
—  
—  
2,717  
—  
2,717  
7 
Margin loans
 
7,283  
—  
—  
—  
—  
—  
10,728  
—  
18,011  
41 
Total loans
$ 12,281 $ 
4,047 $ 
3,085 $ 
1,129 $ 
1,068 $ 
4,853 $ 
37,240 $ 
123 $ 63,826 $ 
300 
(a) 
Excludes overdrafts of $3,053 million.  Overdrafts occur on a daily basis primarily in the custody and securities clearance business and are generally 
repaid within two business days.
(b) 
The gross write-offs related to other residential mortgage loans were $3 million in 2023.
Commercial loans
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.
Commercial real estate
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. 
Financial institutions
Financial institution exposures are high-quality, with 
96% of the exposures meeting the investment grade 
equivalent criteria of our internal credit rating 
classification at Dec. 31, 2024.  In addition, 67% of 
the financial institutions exposure is secured.  For 
example, securities industry clients and asset 
managers often borrow against marketable securities 
held in custody.  The exposure to financial 
institutions is generally short-term, with 84% expiring 
within one year. 
Wealth management loans 
Wealth management 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 loan portfolio, 
therefore, would equate to investment grade external 
Notes to Consolidated Financial Statements (continued)
158 BNY

ratings.  Wealth management loans are provided to 
select customers based on the pledge of other types of 
assets.  For the loans collateralized by other assets, 
the credit quality of the obligor is carefully analyzed, 
but we do not consider this portion of wealth 
management loan portfolio to be investment grade.
Wealth management mortgages
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 61% at 
origination.  Delinquency rate is a key indicator of 
credit quality in the wealth management portfolio.  At 
Dec. 31, 2024, less than 1% of the mortgages were 
past due.
At Dec. 31, 2024, the wealth management mortgage 
portfolio consisted of the following geographic 
concentrations:  California – 21%; New York – 14%; 
Florida – 11%; Massachusetts – 8%; and other – 
46%.
Lease financings
At Dec. 31, 2024, all of leasing exposure was 
investment grade, or investment grade equivalent and  
consisted of exposures backed by well-diversified 
assets.  The largest components of our lease residual 
value exposure related to real estate and large-ticket 
transportation equipment.  Assets are both foreign 
and domestic-based, with primary concentrations in 
Germany and the U.S.  
Other residential mortgages
The other residential mortgage portfolio primarily 
consists of 1-4 family residential mortgage loans and 
totaled $1.1 billion at Dec. 31, 2024 and $1.2 billion 
at Dec. 31, 2023.  These loans are not typically 
correlated to external ratings.  
Capital call financing
Capital call financing includes loans to private equity 
funds that are secured by the fund investors’ capital 
commitments and the funds’ right to call capital.
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 $19.1 billion of secured margin loans at Dec. 
31, 2024, compared with $18.0 billion at Dec. 31, 
2023.  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.
Overdrafts
Overdrafts primarily relate to custody and securities 
clearance clients and totaled $3.5 billion at Dec. 31, 
2024 and $3.1 billion at Dec. 31, 2023.  Overdrafts 
occur on a daily basis and are generally repaid within 
two business days.
Reverse repurchase agreements
Reverse repurchase agreements at Dec. 31, 2024 and 
Dec. 31, 2023 were fully secured with high-quality 
collateral.  As a result, there was no allowance for 
credit losses related to these assets at Dec. 31, 2024 
and Dec. 31, 2023.  
Notes to Consolidated Financial Statements (continued)
BNY 159

Note 6–Leasing
We have operating leases for corporate offices, data 
centers and certain equipment.  Our leases have 
remaining lease terms up to 14 years, some of which 
include options to extend or terminate the lease.  In 
some of our corporate office locations, we may enter 
into sublease arrangements for portions or all of the 
space and/or lease term. 
The table below presents the consolidated balance 
sheet information related to operating leases.
Operating leases
Dec. 31,
(dollars in millions)
2024
2023
ROU assets (a)
$ 1,076 
$ 1,125 
Lease liability (b)
$ 1,321 
$ 1,356 
Weighted average:
Remaining lease term
9.0 years
9.4 years
Discount rate (annualized)
 3.50% 
 3.11% 
(a) Included in premises and equipment on the consolidated 
balance sheet.
(b) Operating lease liabilities are included in other liabilities on 
the consolidated balance sheet.
The table below presents the components of lease 
expense.
Lease expense
Year ended Dec. 31,
(in millions)
2024
2023
2022
Operating lease expense
$ 
229 $ 
215 $ 
224 
Variable lease expense
 
44  
43  
36 
Sublease income
 
(31)  
(34)  
(33) 
Finance lease expense:
Amortization of ROU assets
 
—  
—  
6 
Total lease expense
$ 
242 $ 
224 $ 
233 
The table below presents cash flow information 
related to leases.
Cash flow information
Year ended Dec. 31,
(in millions)
2024
2023
2022
Cash paid for amounts 
included in measurement of 
liabilities:
Operating cash flows from 
operating leases
$ 
217 $ 
224 $ 
224 
Financing cash flows from 
finance leases
$ 
— $ 
— $ 
23 
See Note 26 for information on non-cash operating 
lease transactions.
The table below presents the maturities of our 
operating lease liabilities.
Maturities of operating lease liabilities
(in millions)
For the year ended Dec. 31,
2025
$ 
204 
2026
 
199 
2027
 
177 
2028
 
150 
2029
 
139 
2030 and thereafter
 
669 
Total lease payments
 
1,538 
Less: Imputed interest
 
217 
Total
$ 
1,321 
Notes to Consolidated Financial Statements (continued)
160 BNY

Note 7–Goodwill and intangible assets
Goodwill
The table below provides a breakdown of goodwill by business segment.
Goodwill by business segment
(in millions)
Securities 
Services
Market and 
Wealth
Services
Investment
and Wealth
Management
Consolidated
Balance at Dec. 31, 2023
Goodwill
$ 
7,004 $ 
1,429 $ 
8,508 $ 
16,941 
Accumulated impairment losses
— 
— 
(680)
(680)
Net goodwill
$ 
7,004 $ 
1,429 $ 
7,828 $ 
16,261 
Business realignment (a)
(51)
48
3 
— 
Acquisition
426  
—
— 
426 
Foreign currency translation
(48)
(2)
(39)
(89)
Balance at Dec. 31, 2024
Goodwill
$ 
7,331 $ 
1,475 $ 
8,472 $ 
17,278 
Accumulated impairment losses
— 
— 
(680)
(680)
Net goodwill
$ 
7,331 $ 
1,475 $ 
7,792 $ 
16,598 
(a)
In 2024, we made certain realignments of similar products and services within our lines of business.  See Note 24 for additional
information.
Goodwill by business segment
(in millions)
Securities 
Services
Market and 
Wealth
Services
Investment
and Wealth
Management
Consolidated
Balance at Dec. 31, 2022
Goodwill
$ 
6,973 $ 
1,424 $ 
8,433 $ 
16,830 
Accumulated impairment losses
— 
— 
(680)
(680)
Net goodwill
$ 
6,973 $ 
1,424 $ 
7,753 $ 
16,150 
Foreign currency translation
31 
5 
75 
111 
Balance at Dec. 31, 2023
Goodwill
$ 
7,004 $ 
1,429 $ 
8,508 $ 
16,941 
Accumulated impairment losses
— 
— 
(680)
(680)
Net goodwill
$ 
7,004 $ 
1,429 $ 
7,828 $ 
16,261 
Goodwill impairment testing
The goodwill impairment test is performed at least 
annually at the reporting unit level.  BNY’s business 
segments include seven reporting units for which 
goodwill impairment testing is performed.  An 
interim goodwill impairment test is performed when 
events or circumstances occur that may indicate that 
it is more likely than not that the fair value of any 
reporting unit may be less than its carrying value.
In each quarter of 2024, we completed an interim 
goodwill impairment test of the Investment 
Management reporting unit, which had $6.0 billion of 
allocated goodwill as of Dec. 31, 2024.  In all cases, 
we determined the fair value of the Investment 
Management reporting unit exceeded its carrying 
value and no goodwill impairment was recorded.
For the Dec. 31, 2024 test, the fair value of the 
Investment Management reporting unit exceeded its 
carrying value by approximately 11%.  We 
determined the fair value of the Investment 
Management reporting unit using an income approach 
based on management’s projections as of Dec. 31, 
2024.  The discount rate applied to these cash flows 
was 10.5%.
The cash flow estimates for the Investment 
Management reporting unit are impacted by 
projections of the level and mix of assets under 
management, market values, operating margins and 
long-term growth rates.
In the second quarter of 2024, we performed our 
annual goodwill impairment test on the remaining six 
reporting units using an income approach to estimate 
the fair values of each reporting unit.  Estimated cash 
Notes to Consolidated Financial Statements (continued)
BNY 161

flows used in the income approach were based on 
management’s projections as of April 1, 2024.  The 
discount rate applied to these cash flows was 10%.  
As a result of the annual goodwill impairment test, no 
goodwill impairment was recognized.  The fair values 
of the Company’s remaining six reporting units were 
substantially in excess of the respective reporting 
units’ carrying value.
Determining the fair value of a reporting unit is 
subject to uncertainty as it is reliant on estimates of 
cash flows that extend far into the future, and, by 
their nature, are difficult to estimate over such an 
extended time frame.  In the future, changes in the 
assumptions or the discount rate could produce a 
material non-cash goodwill impairment. 
In the third quarter 2022, based on results of an 
interim goodwill impairment test we recorded an 
impairment charge of $680 million.  This goodwill 
impairment represents a non-cash charge and did not 
affect BNY’s liquidity position, tangible common 
equity or regulatory capital ratios.  
Intangible assets
The table below provides a breakdown of intangible assets by business segment.
Intangible assets – net carrying amount by 
business segment
(in millions)
Securities 
Services
Market and 
Wealth
Services
Investment
and Wealth
Management
Other
Consolidated
Balance at Dec. 31, 2022
$ 
193 $ 
384 $ 
1,475 $ 
849 $ 
2,901 
Amortization
 
(31)  
(6)  
(20)  
—  
(57) 
Foreign currency translation 
 
2  
—  
8  
—  
10 
Balance at Dec. 31, 2023
$ 
164 $ 
378 $ 
1,463 $ 
849 $ 
2,854 
Acquisition
 
53  
—  
—  
—  
53 
Amortization
 
(28)  
(4)  
(18)  
—  
(50) 
Foreign currency translation
 
(3)  
—  
(3)  
—  
(6) 
Balance at Dec. 31, 2024
$ 
186 $ 
374 $ 
1,442 $ 
849 $ 
2,851 
The table below provides a breakdown of intangible assets by type.
Intangible assets
Dec. 31, 2024
Dec. 31, 2023
(dollars in millions)
Gross
carrying
amount
Accumulated
amortization
Net
carrying
amount
Remaining
weighted-
average
amortization
period
Gross
carrying
amount
Accumulated
amortization
Net
carrying
amount
Subject to amortization (a):
Customer contracts—Securities Services
$ 
779 $ 
(593) $ 
186 
12 years
$ 
731 $ 
(567) $ 
164 
Customer contracts—Market and Wealth 
Services
 
269  
(266)  
3 
2 years
 
280  
(273)  
7 
Customer relationships—Investment and 
Wealth Management
 
553  
(495)  
58 
7 years
 
553  
(479)  
74 
Other
 
42  
(14)  
28 
12 years
 
41  
(12)  
29 
Total subject to amortization
$ 
1,643 $ 
(1,368) $ 
275 
11 years
$ 1,605 $ 
(1,331) $ 
274 
Not subject to amortization (b):
Tradenames
$ 
1,291 
N/A $ 
1,291 
N/A
$ 1,292 
N/A $ 1,292 
Customer relationships
 
1,285 
N/A  
1,285 
N/A
 
1,288 
N/A  
1,288 
Total not subject to amortization
$ 
2,576 
N/A $ 
2,576 
N/A
$ 2,580 
N/A $ 2,580 
Total intangible assets
$ 
4,219 $ 
(1,368) $ 
2,851 
N/A
$ 4,185 $ 
(1,331) $ 2,854 
(a) Excludes fully amortized intangible assets.
(b)
Intangible assets not subject to amortization have an indefinite life.
N/A – Not applicable.
Notes to Consolidated Financial Statements (continued)
162 BNY

Estimated annual amortization expense for current 
intangibles for the next five years is as follows:
For the year ended
Dec. 31,
Estimated amortization expense
(in millions)
2025
$ 
45 
2026
 
36 
2027
 
30 
2028
 
27 
2029
 
23 
Intangible asset impairment testing
Intangible assets not subject to amortization are tested 
for impairment annually or more often if events or 
circumstances indicate they may be impaired.
Note 8–Other assets
The following table provides the components of other 
assets presented on the consolidated balance sheet.
Other assets
Dec. 31,
(in millions)
2024
2023
Corporate/bank-owned life insurance
$ 
5,552 $ 
5,480 
Accounts receivable (a)
 
4,931  
6,567 
Tax credit investments
 
2,821  
2,186 
Software
 
2,676  
2,430 
Prepaid pension assets
 
2,035  
1,818 
Fails to deliver
 
1,292  
1,514 
Assets of consolidated investment 
management funds
 
891  
526 
Equity method investments
 
852  
873 
Fair value of hedging derivatives
 
781  
236 
Prepaid expense
 
736  
737 
Other equity investments (b)
 
679  
741 
Federal Reserve Bank stock
 
478  
480 
Cash collateral receivable on derivative 
transactions
 
292  
621 
Income taxes receivable
 
255  
270 
Seed capital (c)
 
196  
232 
Other (d)
 
1,223  
1,198 
Total other assets
$ 
25,690 $ 25,909 
(a) Includes receivables for securities sold or matured that have 
not yet settled.
(b) Includes strategic equity, private equity and other 
investments.
(c) Includes investments in BNY funds that hedge deferred 
incentive awards.
(d) At Dec. 31, 2024 and Dec. 31, 2023, other assets include 
$57 million and $7 million, respectively, of Federal Home 
Loan Bank stock, at cost.
Non-readily marketable equity securities
Non-readily marketable equity securities do not have 
readily determinable fair values.  These investments 
are valued using a measurement alternative where the 
investments are carried at cost, less any impairment, 
and plus or minus changes resulting from observable 
price changes in orderly transactions for an identical 
or similar investment of the same issuer.  The 
observable price changes are recorded in investment 
and other revenue on the consolidated income 
statement.  Our non-readily marketable equity 
securities totaled $413 million at Dec. 31, 2024 and 
$479 million at Dec. 31, 2023, and are included in 
other equity investments in the table above.  
The following table presents the adjustments on the 
non-readily marketable equity securities.
Adjustments on non-readily marketable equity 
securities
Life-to-
date
(in millions)
2024
2023
2022
Upward adjustments
$ 
1 $ 
52 $ 125 $ 336 
Downward adjustments
 
(2)  
(41)  
(8)  
(55) 
Net adjustments
$ 
(1) $ 
11 $ 117 $ 281 
Tax credit investments
Tax credit investments include affordable housing 
projects and renewable energy investments.  We 
invest in affordable housing projects primarily to 
satisfy the Company’s requirements under the 
Community Reinvestment Act.  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.  
On Jan. 1, 2024, we adopted ASU 2023-02, 
Investments—Equity Method and Joint Ventures 
(Topic 323): Accounting for Investments in Tax 
Credit Structures Using the Proportional 
Amortization Method for our renewable energy 
projects that met the eligibility criteria.  See Note 2 
for additional information.
Our tax credit investments totaled $2.8 billion at Dec. 
31, 2024 and $2.2 billion at Dec. 31, 2023.  
Commitments to fund future investments totaled $951 
million at Dec. 31, 2024 and $780 million at Dec. 31, 
2023 and are recorded in other liabilities on the 
consolidated balance sheet.  A summary of the 
commitments to fund future investments is as 
follows: 2025 – $455 million; 2026 – $113 million; 
2027 – $103 million; 2028 – $79 million; 2029 – $31 
million; and 2030 and thereafter – $170 million.
Notes to Consolidated Financial Statements (continued)
BNY 163

Tax credits and other tax benefits recognized were 
$418 million in 2024, $373 million in 2023 and $325 
million in 2022. 
Amortization expense included in the provision for 
income taxes was $343 million in 2024, $293 million 
in 2023 and $255 million in 2022. 
Investments valued using net asset value (“NAV”) per 
share
In our Investment and Wealth Management business 
segment, we make seed capital investments in certain 
funds we manage.  We also hold private equity 
investments, primarily small business investment 
companies (“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 
certain of these investments was estimated using the 
NAV per share for our ownership interest in the 
funds.  
The table below presents information on our investments valued using NAV.
Investments valued using NAV
Dec. 31, 2024
Dec. 31, 2023
(in millions)
Fair value
Unfunded 
commitments
Fair value
Unfunded
commitments
Seed capital (a)
$ 
7 
$ 
— 
$ 
3 
$ 
— 
Private equity investments (b)
137 
59 
143 
42 
Other
8 
— 
7 
— 
Total
$ 
152 
$ 
59 
$ 
153 
$ 
42 
(a)
Seed capital investments at Dec. 31, 2024 are generally redeemable on request.  Distributions are received as the underlying
investments in the funds, which have redemption notice periods of up to seven days, are liquidated.
(b)
Private equity investments primarily 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.
Note 9–Deposits
Time deposits in denominations of $250,000 or more 
totaled $2.1 billion at Dec. 31, 2024 and $1.5 billion 
at Dec. 31, 2023.  
At Dec. 31, 2024, the scheduled maturities of total 
time deposits are $4.1 billion in 2025, $557 million in 
2026, $330 million in 2027, $361 million in 2028 and 
$251 million in 2029.  No time deposits are scheduled 
to mature after 2029.
Note 10–Contract revenue
Fee and other revenue in the Securities Services, 
Market and Wealth Services and Investment and 
Wealth Management business segments is primarily 
variable, based on levels of assets under custody and/
or administration (“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. 
Investment services fees also include transaction-
based fees, 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 investment 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.
Substantially all services within the Securities 
Services and Market and Wealth Services business 
segments 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. 
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 
Notes to Consolidated Financial Statements (continued)
164 BNY

typically subject to fee schedules contained in an 
investment management agreement or fund
documents 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 24 for additional information on our 
principal business segments, Securities Services, 
Market and Wealth Services and Investment and 
Wealth Management, and the primary services 
provided. 
Disaggregation of contract revenue 
Contract revenue is included in fee and other revenue on the consolidated income statement.  The following tables 
present fee and other revenue related to contracts with customers, disaggregated by type of fee revenue, for each 
business segment.  Business segment data has been determined on an internal management basis of accounting, 
rather than GAAP which is used for consolidated financial reporting.
Disaggregation of contract revenue by business segment
Year ended Dec. 31,
2024
2023 (a)
(in millions)
Securities 
Services
Market and 
Wealth 
Services
Investment 
and Wealth 
Management
Other
Total
Securities 
Services
Market and 
Wealth 
Services
Investment 
and Wealth 
Management
Other
Total
Fee and other revenue – contract 
revenue:
Investment services fees
$ 
5,204 $ 
4,103 $ 
105 $ 
(68) $ 9,344 
$ 
4,959 $ 
3,805 $
99 $ 
(63) $ 8,800 
Investment management and 
performance fees
— 
7 
3,149 
(13)
3,143
— 
8 
3,067 
(12)
3,063 
Financing-related fees
51 
24 
1 
— 
76 
37 
14 
1 
— 
52 
Distribution and servicing fees
4 
(123)
275 
2 
158 
6 
(98)
241 
— 
149 
Investment and other revenue
248 
251 
(379)
4 
124 
236 
207 
(323)
1 
121 
Total fee and other revenue 
– contract revenue
5,507 
4,262 
3,151 
(75)
12,845
5,238 
3,936 
3,085 
(74)
12,185 
Fee and other revenue – not in 
scope of ASC 606 (b)(c)(d)
941 
273 
62 
173 
1,449
791 
224 
(98)
248 
1,165 
Total fee and other revenue
$ 
6,448 $ 
4,535 $ 
3,213 $ 
98 $ 14,294 
$ 
6,029 $ 
4,160 $ 
2,987 $ 
174 $ 13,350 
(a)
Results for the year ended Dec. 31, 2023 were revised to reflect certain realignments of similar products and services within our lines of business in 2024. 
See Note 24 for additional information.
(b)
Primarily includes investment services fees, foreign exchange revenue, financing-related fees and investment and other revenue, all of which are 
accounted for using other accounting guidance. 
(c)
The Investment and Wealth Management business segment is net of income attributable to noncontrolling interests related to consolidated investment 
management funds of $13 million in 2024 and $2 million in 2023.
(d)
Fee and other revenue – not in scope of ASC 606 for the year ended Dec. 31, 2023 for the Other segment was restated to reflect the retrospective 
application of adopting new accounting guidance in 2024 related to our investments in renewable energy projects using the proportional amortization 
method (ASU 2023-02).  See Note 2 for additional information.
Notes to Consolidated Financial Statements (continued)
BNY 165

Disaggregation of contract revenue by business segment
Year ended Dec. 31, 2022 (a)
(in millions)
Securities 
Services
Market and 
Wealth 
Services
Investment 
and Wealth 
Management
Other
Total
Fee and other revenue – contract revenue:
Investment services fees
$ 
4,824 $ 
3,630 $ 
99 $ 
(65) $ 
8,488
Investment management and performance fees
— 
10 
3,303 
(14)
3,299
Financing-related fees
30 
23 
1 
1 
55 
Distribution and servicing fees
4 
(66)
192 
— 
130 
Investment and other revenue
215 
143 
(245)
1 
114 
Total fee and other revenue – contract revenue
5,073 
3,740 
3,350 
(77)
12,086
Fee and other revenue – not in scope of ASC 606 (b)(c)(d)
901 
149 
(15)
(83)
952
Total fee and other revenue
$ 
5,974 $ 
3,889 $ 
3,335 $ (160) $ 13,038 
(a)
Results for the year ended Dec. 31, 2022 were revised to reflect certain realignments of similar products and services within our lines of business in 2024. 
See Note 24 for additional information.
(b)
Primarily includes investment services fees, foreign exchange revenue, financing-related fees and investment and other revenue, all of which are 
accounted for using other accounting guidance. 
(c)
The Investment and Wealth Management business segment is net of (loss) attributable to noncontrolling interests related to consolidated investment 
management funds of $(13) million in 2022.
(d)
Fee and other revenue – not in scope of ASC 606 for the year ended Dec. 31, 2022 for the Other segment was restated to reflect the retrospective 
application of adopting new accounting guidance in 2024 related to our investments in renewable energy projects using the proportional amortization 
method (ASU 2023-02).  See Note 2 for additional information.
Contract balances 
Our clients are billed based on fee schedules that are 
agreed upon in each customer contract.  Receivables 
from customers were $2.5 billion at Dec. 31, 2024 
and $2.6 billion at Dec. 31, 2023. 
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 $34 million at Dec. 31, 2024 and $27 million at 
Dec. 31, 2023.  Accrued revenues recorded as 
contract assets are usually billed on an annual basis.  
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 $171 million at Dec. 31, 2024 and $172 
million at Dec. 31, 2023.  Contract liabilities are 
included in other liabilities on the consolidated 
balance sheet.  Revenue recognized in 2024 relating 
to contract liabilities as of Dec. 31, 2023 was $116 
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 $44 million at Dec. 31, 2024 
and $46 million at Dec. 31, 2023.  Capitalized sales 
incentives are amortized based on the transfer of 
goods or services to which the assets relate.  The 
amortization of capitalized sales incentives, which is 
primarily included in staff expense on the 
consolidated income statement, totaled $14 million in 
2024, $16 million in 2023 and $19 million in 2022.
Costs to fulfill a contract are capitalized when they 
relate directly to an existing contract or a 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 
the inception of a contract which enables the 
fulfillment of the performance obligation, and totaled 
$98 million at Dec. 31, 2024 and $90 million at Dec. 
31, 2023.  These capitalized costs are amortized on a 
straight-line basis over the expected contract period.  
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 
Notes to Consolidated Financial Statements (continued)
166 BNY

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 11–Net interest income
The following table provides the components of net 
interest income presented on the consolidated income 
statement.
Net interest income
Year ended Dec. 31,
(in millions)
2024
2023
2022
Interest income
Deposits with the Federal Reserve 
and other central banks
$ 4,615 $ 4,541 $ 1,019 
Deposits with banks
 
434  
523  
221 
Federal funds sold and securities 
purchased under resale 
agreements
 10,915 
7,141 
1,200 
Loans
4,394 
3,916 
1,999 
Securities:
Taxable
4,941 
4,213 
2,502 
Exempt from federal income 
taxes
1 
1 
35 
Total securities
4,942 
4,214 
2,537 
Trading securities
307 
313 
142 
Total interest income
 25,607  20,648 
7,118 
Interest expense
Deposits in domestic offices
5,791 
4,703 
980 
Deposits in foreign offices
2,856 
2,421 
607 
Federal funds purchased and 
securities sold under repurchase 
agreements
9,974 
6,699 
934 
Trading liabilities
88 
156 
68 
Other borrowed funds
18 
47 
9 
Commercial paper
62 
— 
— 
Customer payables
640 
566 
156 
Long-term debt
1,866 
1,711 
860 
Total interest expense
 21,295  16,303 
3,614 
Net interest income
4,312 
4,345 
3,504 
Provision for credit losses
70 
119 
39 
Net interest income after 
provision for credit losses
$ 4,242 $ 4,226 $ 3,465 
Note 12–Income taxes
The components of the income tax provision are as 
follows:
Provision for income taxes
Year ended Dec. 31,
(in millions)
2024 2023 (a) 2022 (a)
Current tax expense:
Federal
$ 
902 $ 
727 $ 
331 
Foreign
595 
443 
404 
State and local
153 
192 
19 
Total current tax expense 
1,650 
1,362 
754 
Deferred tax expense (benefit):
Federal
(277)
(344)
130 
Foreign
(30)
31
(5) 
State and local
(38)
(70)
58 
Total deferred tax expense 
(benefit)
(345)
(383)
183 
Provision for income taxes $ 1,305 $ 
979 $ 
937 
(a)
The provision for income taxes for the years ended Dec. 31,
2023 and Dec. 31, 2022 was restated to reflect the
retrospective application of adopting new accounting
guidance in 2024 related to our investments in renewable
energy projects using the proportional amortization method
(ASU 2023-02).  See Note 2 for additional information.
In accordance with ASU 2023-02, Investments— 
Equity Method and Joint Ventures (Topic 323): 
Accounting for Investments in Tax Credit Structures 
Using the Proportional Amortization Method, we 
elected to account for investments in renewable 
energy projects that met the eligibility requirement 
using the proportional amortization method on a 
retrospective basis.  
For additional information, see Note 2 and Note 8.
The components of income before taxes are as 
follows:
Income before taxes
Year ended Dec. 31,
(in millions)
2024
2023
2022
Domestic (a)
$ 3,462 $ 2,196 $ 1,849 
Foreign
2,386 
2,087 
1,631 
Income before taxes (a)
$ 5,848 $ 4,283 $ 3,480 
(a)
Domestic income before taxes for the years ended Dec. 31,
2023 and Dec. 31, 2022 was restated to reflect the
retrospective application of adopting new accounting
guidance in 2024 related to our investments in renewable
energy projects using the proportional amortization method
(ASU 2023-02).  See Note 2 for additional information.
Notes to Consolidated Financial Statements (continued)
BNY 167

The components of our net deferred tax liability are 
as follows:
Net deferred tax liability
Dec. 31,
(in millions)
2024
2023
Depreciation and amortization
$ 1,700 $ 1,811 
Pension obligation
 
421  
388 
Other liabilities
 
189  
149 
Equity investments
 
55  
56 
Securities valuation
 
(39)  
(29) 
Leasing
 
(41)  
(41) 
Other assets
 
(62)  
(55) 
Credit losses on loans
 
(98)  
(106) 
Reserves not deducted for tax
 
(236)  
(314) 
Employee benefits
 
(269)  
(252) 
U.S. foreign tax credits
 
(101)  
(96) 
Valuation allowance
 
135  
130 
Net deferred tax liability (a)
$ 1,654 $ 1,641 
(a) The deferred tax liability for the year ended Dec. 31, 2023 
was restated to reflect the retrospective application of 
adopting new accounting guidance in 2024 related to our 
investments in renewable energy projects using the 
proportional amortization method (ASU 2023-02).  See Note 
2 for additional information.
As of Dec. 31, 2024, BNY had $101 million of U.S. 
foreign tax credit carryforwards which will begin to 
expire in 2029.  In addition, we have an unrealized 
capital loss of $34 million.  We believe it is more 
likely than not that the benefit from these items will 
not be realized.  Accordingly, we have recorded a 
valuation allowance of $135 million.  We believe it is 
more likely than not that we will fully realize our 
remaining deferred tax assets.  This conclusion is 
based on historical financial results and profit 
forecasts.
As of Dec. 31, 2024, we had approximately $1.4 
billion 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, 2024 would be 
up to $170 million. 
The statutory federal income tax rate is reconciled to 
our effective income tax rate below:
Effective tax rate
Year ended Dec. 31,
2024 2023 (a) 2022 (a)
Federal rate
 21.0% 
 21.0% 
 21.0% 
State and local income taxes, net 
of federal income tax benefit
 1.6 
 2.2 
 1.9 
Foreign operations
 1.3 
 1.1 
 2.1 
Tax credits
 (1.3) 
 (2.3) 
 (2.1) 
Tax-exempt income
 (0.6) 
 (0.7) 
 (1.0) 
Federal Deposit Insurance 
Corporation (“FDIC”) 
assessment
 0.3 
 0.4 
 0.4 
Stock compensation
 (0.2) 
 (0.1) 
 (0.6) 
Goodwill impairment
 — 
 — 
 3.7 
Divestiture of stock in subsidiary
 — 
 0.7 
 0.9 
Other – net
 0.2 
 0.6 
 0.6 
Effective tax rate
 22.3% 
 22.9% 
 26.9% 
(a) The effective tax rate for the years ended Dec. 31, 2023 and 
Dec. 31, 2022 was restated to reflect the retrospective 
application of adopting new accounting guidance in 2024 
related to our investments in renewable energy projects 
using the proportional amortization method (ASU 2023-02).  
See Note 2 for additional information.
Unrecognized tax positions
(in millions)
2024
2023
2022
Beginning balance at Jan. 1, – 
gross
$ 
109 $ 
106 $ 
138 
Prior period tax positions:
Increases
 
2  
—  
— 
Decreases
 
(2)  
(5)  
(11) 
Current period tax positions
 
8  
8  
8 
Settlements
 
—  
—  
(16) 
Statute expiration
 
(8)  
—  
(13) 
Ending balance at Dec. 31, – 
gross
$ 
109 $ 
109 $ 
106 
Our total tax reserves as of Dec. 31, 2024 were $109 
million compared with $109 million at Dec. 31, 2023.  
If these tax reserves were unnecessary, $109 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, 
2024 is accrued interest, where applicable, of $41 
million.  The additional tax expense related to interest 
for the year ended Dec. 31, 2024 was $2 million, 
compared with $6 million for the year ended Dec. 31, 
2023.
It is reasonably possible the total reserve for uncertain 
tax positions could decrease within the next 12 
months by approximately $25 million as a result of 
Notes to Consolidated Financial Statements (continued)
168 BNY

adjustments related to tax years that are still subject to 
examination.
Our federal income tax returns are open to 
examination from 2017 through 2019 and 2021 and 
forward.  Our New York State income tax returns are 
open to examination after 2015 and our New York 
City income tax returns are open to examination after 
2014.  Our UK income tax returns are open to 
examination after 2020.
Note 13–Long-term debt
The table below presents information on our long-term debt.
Long-term debt
Dec. 31, 2024
Dec. 31, 2023
(dollars in millions)
Rate
Maturity
Amount
Rate
Amount
Senior debt:
Fixed rate
0.75 - 6.47% 
2025 - 2035 $ 
28,006 
0.50 - 6.47% $ 
28,886 
Floating rate
4.94 - 5.32%
2025 - 2038  
1,226 
5.39 - 6.00%  
1,226 
Subordinated debt (a)
3.00 - 5.61%
2028 - 2039  
1,622 
3.00 - 3.30%  
1,145 
Total
 
 
$ 
30,854 
 
$ 
31,257 
(a)
Fixed rate.
Total long-term debt maturing during the next five 
years is as follows: 2025 – $3.3 billion; 2026 – $5.0 
billion; 2027 – $3.1 billion; 2028 – $6.1 billion; and 
2029 – $3.2 billion.
Note 14–Variable interest entities
We have variable interests in VIEs, which include 
investments in retail, institutional and alternative 
investment funds. 
We earn management fees from these funds, as well 
as performance fees in certain funds, and may also 
provide start-up capital for new funds.  The funds are 
primarily financed by our customers’ investments in 
the funds’ equity or debt.
Additionally, we invest in qualified affordable 
housing and renewable energy projects, which are 
designed to generate a return primarily through the 
realization of tax credits.  The projects, which are 
structured as limited partnerships and limited liability 
companies, are also VIEs, but are not consolidated.  
The following table presents the incremental assets 
and liabilities included on the consolidated balance 
sheet as of Dec. 31, 2024 and Dec. 31, 2023.  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 we invested in the VIE.  
Consolidated investment management funds
Dec. 31,
(in millions)
2024
2023
Trading assets
$ 
846 $ 
510 
Other assets
 
45  
16 
Total assets (a)
$ 
891 $ 
526 
Other liabilities
$ 
5 $ 
1 
Total liabilities (b)
$ 
5 $ 
1 
Nonredeemable noncontrolling 
interests  (c)
$ 
359 $ 
50 
(a) Includes VMEs with assets of $43 million at Dec. 31, 2024 
and $91 million at Dec. 31, 2023.
(b) Includes VMEs with liabilities of less than $1 million at Dec. 
31, 2024 and $1 million at Dec. 31, 2023.
(c) Includes VMEs with nonredeemable noncontrolling interests 
of $7 million at Dec. 31, 2024 and $12 million at Dec. 31, 
2023.
We have 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. 
Non-consolidated VIEs
As of Dec. 31, 2024 and Dec. 31, 2023, assets and 
liabilities related to the VIEs where we are not the 
primary beneficiary were included in other assets and 
other liabilities on the consolidated balance sheet and 
primarily related to accounting for our investments in 
qualified affordable housing and renewable energy 
projects.  
Notes to Consolidated Financial Statements (continued)
BNY 169

The maximum loss exposure indicated in the 
following table relates solely to our investments in, 
and unfunded commitments to, the VIEs.
Non-consolidated VIEs
Dec. 31, 
2024
Dec. 31, 
2023
(in millions)
Other assets
$ 
2,905 $ 
2,261 
Other liabilities
951 
780 
Maximum loss exposure
3,856 
3,041 
Note 15–Shareholders’ equity
Common stock
BNY has 3.5 billion authorized shares of common 
stock with a par value of $0.01 per share.  At Dec. 31, 
2024, 717,680,268 shares of common stock were 
outstanding.  
In July 2024, our Board of Directors approved a 12% 
increase in the quarterly cash dividend on common 
stock, from $0.42 to $0.47 per share.  We began 
paying the increased quarterly cash dividend in the 
third quarter of 2024. 
Common stock repurchase program
In January 2023, we announced a share repurchase 
program approved by our Board of Directors 
providing for the repurchase of up to $5.0 billion of 
common shares beginning Jan. 1, 2023.  This share 
repurchase plan replaced all previously authorized 
share repurchase plans.
In April 2024, we announced a new authorization
providing for the repurchase of $6.0 billion of
common shares in addition to any remaining capacity
under the existing January 2023 authorization. 
In 2024, we repurchased 48.9 million common shares 
at an average price of $62.70 per common share for a 
total of $3.1 billion.  
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.  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 limitations and considerations.
Preferred stock
The Parent has 100 million authorized shares of preferred stock with a par value of $0.01 per share.  The following 
table summarizes the Parent’s preferred stock issued and outstanding at Dec. 31, 2024 and Dec. 31, 2023.
Preferred stock summary (a)
Total shares issued and 
outstanding
Carrying value (b)
(in millions)
Dec. 31, 
2024
Dec. 31, 
2023
Dec. 31, 
2024
Dec. 31, 
2023
Per annum dividend rate (c)
Series A
Greater of (i) SOFR plus 0.565% and (ii) 4.000%
5,001 
5,001 
$ 
500 $ 
500 
Series F
4.625% to but excluding Sept. 20, 2026, then SOFR plus 3.131%
10,000 
10,000 
990 
990 
Series G
4.700% to but excluding Sept. 20, 2025, then a floating rate equal to 
the five-year treasury rate plus 4.358%
10,000 
10,000 
990 
990 
Series H
3.700% to but excluding March 20, 2026, then a floating rate equal to 
the five-year treasury rate plus 3.352%
5,825 
5,825 
576 
576 
Series I
3.750% to but excluding Dec. 20, 2026, then a floating rate equal to 
the five-year treasury rate plus 2.630%
13,000 
13,000 
1,287 
1,287 
Total
43,826 
43,826 
$ 
4,343 $ 
4,343 
(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 F, Series G, Series H and Series I preferred stock is recorded net of issuance costs.
(c)
References to SOFR are to a floating rate equal to the three-month CME Term SOFR (plus a spread adjustment of 0.26161% per
annum).
Notes to Consolidated Financial Statements (continued)
170 BNY

Holders of the Series A preferred stock are entitled to 
receive dividends, if declared by the Parent’s Board 
of Directors, on each March 20, June 20, 
September 20 and December 20.  Holders of the 
Series F preferred stock are entitled to receive 
dividends, if declared by the Parent’s Board of 
Directors, on each March 20 and September 20, to 
and including Sept. 20, 2026; and on each March 20, 
June 20, September 20 and December 20, from and 
including Dec. 20, 2026.  Holders of the Series G 
preferred stock are entitled to receive dividends, if 
declared by the Parent’s Board of Directors, on each 
March 20 and September 20.  Holders of the Series H 
preferred stock are entitled to receive dividends, if 
declared by the Parent’s Board of Directors, on each 
March 20, June 20, September 20 and December 20, 
commencing on March 20, 2021.  Holders of the 
Series I preferred stock are entitled to receive 
dividends, if declared by the Parent’s Board of 
Directors, on each March 20, June 20, September 20 
and December 20, commencing on March 20, 2022.  
BNY’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 the Parent 
will be prohibited, subject to certain exceptions, in 
the event that we do not declare and pay in full 
preferred dividends for the then-current dividend 
period (in the case of dividends) or most recently 
completed dividend period (in the case of 
repurchases) of the Series A preferred stock or the 
last preceding dividend period (in the case of 
dividends) or most recently completed dividend 
period (in the case of repurchases) of the Series F, 
Series G, Series H and Series I preferred stock.
All of the outstanding shares of the Series A preferred 
stock are owned by Mellon Capital IV, a 100% 
owned financing subsidiary of the Parent, which will 
pass through any dividend on the Series A preferred 
stock to the holders of its Normal Preferred Capital 
Securities.  The Parent’s obligations under the trust 
and other agreements relating to Mellon Capital IV 
have the effect of providing a full and unconditional 
guarantee, on a subordinated basis, of payments due 
on the Normal Preferred Capital Securities.  No other 
subsidiary of the Parent guarantees the securities of 
Mellon Capital IV.  All of the outstanding shares of 
the Series F, Series G, Series H and Series I preferred 
stock are held by the depositary of the depositary 
shares, which will pass through the applicable portion 
of any dividend on the Series F, Series G, Series H 
and Series I preferred stock to the holders of record of 
their respective depositary shares.  
In December 2023, the Parent redeemed all 
outstanding shares of its Series D preferred stock, 
$100,000 liquidation preference per share.  Deferred 
fees of approximately $10 million were realized as 
preferred stock dividends upon redemption. 
The table below presents the Parent’s preferred dividends.
Preferred dividends
(dollars in millions, except 
per share amounts)
Depositary 
shares 
per share
2024
2023
2022
Per share
Total 
dividend
Per share
Total 
dividend
Per share
Total
dividend
Series A
 
100 (a)
$ 6,143.97 $ 
30 
$ 5,866.23 $ 
29 
$ 4,088.49 $ 
20 
Series D
 
100 
N/A
N/A
 
6,339.20  
42 (b)
 
4,500.00  
23 
Series F
 
100 
 
4,625.00  
46 
 
4,625.00  
46 
 
4,625.00  
46 
Series G
 
100 
 
4,700.00  
47 
 
4,700.00  
47 
 
4,700.00  
47 
Series H
 
100 
 
3,700.00  
22 
 
3,700.00  
22 
 
3,700.00  
22 
Series I
 
100 
 
3,750.00  
49 
 
3,750.00  
49 
 
4,083.33  
53 
Total
$ 
194 
$ 
235 
$ 
211 
(a) Represents Normal Preferred Capital Securities.
(b) Includes deferred fees of approximately $10 million related to the redemption of the Series D preferred stock.
N/A – Not applicable.
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 preferred stock, in whole or in 
part, at our option.  We may also, at our option, 
redeem the shares of the Series F preferred stock on 
any dividend payment date, in whole or in part, on or 
Notes to Consolidated Financial Statements (continued)
BNY 171

after the dividend payment date in September 2026, 
the Series G preferred stock on any dividend payment 
date, in whole or in part, on or after the dividend 
payment date in September 2025, the Series H 
preferred stock on any dividend payment date, in 
whole or in part, on or after the dividend payment 
date in March 2026 and the Series I preferred stock 
on any dividend payment date, in whole or in part, on 
or after the dividend payment date in December 2026.  
The Series F, Series G, Series H or Series I preferred 
stock can be redeemed, in whole but not in part, at 
any time within 90 days following a regulatory 
capital treatment event.  Redemption of the preferred 
stock is subject to the prior approval of the Federal 
Reserve.  
Temporary equity
Temporary equity was $87 million at Dec. 31, 2024 
and $85 million at Dec. 31, 2023.  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 bank 
holding companies (“BHCs”) and banks, including 
BNY 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 must, 
among other things, qualify as “well capitalized.”  As 
of Dec. 31, 2024 and Dec. 31, 2023, BNY and our 
U.S. bank subsidiaries were “well capitalized.”  
The regulatory capital ratios of our consolidated and 
largest bank subsidiary, The Bank of New York 
Mellon, are shown below.
Consolidated and largest bank 
subsidiary regulatory capital ratios (a)
Dec. 31,
2024
2023
Consolidated regulatory capital ratios:
Common Equity Tier 1 (“CET1”) ratio
 11.2% 
 11.5% 
Tier 1 capital ratio
 13.7 
 14.2 
Total capital ratio
 14.8 
 14.9 
Tier 1 leverage ratio
 5.7 
 6.0 
Supplementary leverage ratio (“SLR”) (b)
 6.5 
 7.3 
The Bank of New York Mellon 
regulatory capital ratios:
CET1 ratio
 16.1% 
 16.2% 
Tier 1 capital ratio
 16.1 
 16.2 
Total capital ratio
 16.3 
 16.3 
Tier 1 leverage ratio
 6.3 
 6.6 
SLR (b)
 7.6 
 8.5 
(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.  The Tier 1 leverage ratio is based 
on Tier 1 capital and quarterly average total assets.  For 
BNY 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) The SLR is based on Tier 1 capital and total leverage 
exposure, which includes certain off-balance sheet 
exposures.  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, or a bank such as The Bank 
of New York Mellon or BNY Mellon, N.A., fails to 
satisfy minimum capital requirements or qualify as 
“adequately capitalized,” regulatory sanctions and 
limitations will be imposed.  
Notes to Consolidated Financial Statements (continued)
172 BNY

The following table presents our capital components 
and risk-weighted assets determined under the 
Standardized and Advanced Approaches, the average 
assets used for leverage capital purposes and leverage 
exposure used for SLR purposes.
Capital components and risk-
weighted assets
Dec. 31,
(in millions)
2024
2023
CET1:
Common shareholders’ equity
$ 36,975 $ 36,427 
Adjustments for:
Goodwill and intangible assets (a)
(17,563) 
(17,253) 
Net pension fund assets
(333)
(297)
Embedded goodwill
(254)
(275)
Deferred tax assets
(62)
(62)
Other
(4)
(6)
Total CET1
18,759 
18,534 
Other Tier 1 capital:
Preferred stock
4,343 
4,343 
Other
(63)
(14)
Total Tier 1 capital
$ 23,039 $ 22,863 
Tier 2 capital:
Subordinated debt
$ 
1,398 $ 
1,148 
Allowance for credit losses
392 
414 
Other
(11)
(11)
Total Tier 2 capital – Standardized 
Approach
1,779 
1,551 
Excess of expected credit losses
109 
85 
Less: Allowance for credit losses
392 
414 
Total Tier 2 capital – Advanced 
Approaches
$ 
1,496 $ 
1,222 
Total capital:
Standardized Approach
$ 24,818 $ 24,414 
Advanced Approaches
$ 24,535 $ 24,085 
Risk-weighted assets:
Standardized Approach
$ 167,786 $ 156,178 
Advanced Approaches:
Credit Risk
$ 90,076 $ 87,223 
Market Risk
4,808 
3,380 
Operational Risk
65,588 
70,925 
Total Advanced Approaches
$ 160,472 $ 161,528 
Average assets for Tier 1 leverage 
ratio
$ 402,069 $ 383,705 
Total leverage exposure for SLR
$ 353,523 $ 313,555 
(a)
Reduced by deferred tax liabilities associated with
intangible assets and tax deductible goodwill.
The following table presents the amount of capital by 
which BNY and our largest bank subsidiary, The 
Bank of New York Mellon, exceeded the capital 
thresholds determined under U.S. capital rules.
Capital above thresholds at Dec. 31, 2024
(in millions)
Consolidated (a)
The Bank of 
New York 
Mellon
CET1
$ 
4,497 
$ 
11,890 (a)
Tier 1 capital
6,260 
9,926 (a)
Total capital
4,684 
7,521 (a)
Tier 1 leverage ratio
6,956 
4,378 (b)
SLR 
5,363 
4,330 (b)
(a)
Based on minimum required standards, with applicable
buffers.
(b)
Based on well capitalized standards.
Notes to Consolidated Financial Statements (continued)
BNY 173

Note 16–Other comprehensive income (loss)
Components of other comprehensive 
income (loss)
Year ended Dec. 31,
2024
2023
2022
(in millions)
Pre-tax
amount
Tax
(expense)
benefit
After-tax
amount
Pre-tax
amount
Tax
(expense)
benefit
After-tax
amount
Pre-tax
amount
Tax
(expense)
benefit
After-tax
amount
Foreign currency translation:
Foreign currency translation adjustments arising 
during the period (a)
$ 
(29) $ 
(162) $ 
(191) $ 
204 $
68 $ 
272 
$ 
(455) $ 
(148) $ 
(603)
Total foreign currency translation
(29)
(162)
(191)
204
68 
272 
(455)
(148)
(603) 
Unrealized gain (loss) on assets available-for-sale:
Unrealized gain (loss) arising during the period
489 
(124)
365
1,100
(271)
829
(4,292) 
1,047 
(3,245) 
Reclassification adjustment (b)
85 
(21)
64
68 
(16)
52
443 
(105)
338 
Net unrealized gain (loss) on assets available-
for-sale
574 
(145)
429
1,168 
(287)
881
(3,849) 
942 
(2,907) 
Defined benefit plans:
Net (loss) arising during the period
(15)
6
(9)
(107)
32 
(75)
(400)
94 
(306) 
Foreign exchange adjustment
—  
—
— 
 
(1)
—
(1)
—
— 
— 
Amortization of prior service credit, net loss and 
initial obligation included in net periodic benefit 
cost (b)
14 
(2)
12
(18)
8
(10)
68
(12)
56 
Total defined benefit plans
(1)
4
3 
(126)
40
(86)
(332)
82 
(250) 
Unrealized gain (loss) on cash flow hedges:
Unrealized hedge (loss) gain arising during the 
period
(1)
—
(1)
7
(2)
5
(16)
4 
(12) 
Reclassification of net (gain) loss to net income:
Foreign exchange (“FX”) contracts – investment 
and other revenue
(2)
1
(1)
2
(1)
1
(1)
— 
(1) 
FX contracts – staff expense
(5)
1
(4)
—
—  
—
9 
(2)
7 
Total reclassifications to net income
(7)
2
(5)
2
(1)
1
8 
(2)
6 
Net unrealized (loss) gain on cash flow hedges
(8)
2
(6)
9
(3)
6
(8)
2 
(6) 
Total other comprehensive income (loss)
$ 
536 $ 
(301) $ 
235 
$ 1,255 $ 
(182) $ 1,073 
$ (4,644) $
878 $ (3,766) 
(a)
Includes the impact of hedges of net investments in foreign subsidiaries.  See Note 23 for additional information.
(b)
The reclassification adjustment related to the unrealized gain (loss) on assets available-for-sale is recorded as net securities gains (losses) in investment 
and other revenue 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 other expense on the consolidated income statement.
Changes in accumulated other comprehensive income (loss) attributable to The Bank of New York Mellon Corporation shareholders
Unrealized gain 
(loss) on assets 
available-for-
sale (a)
Unrealized 
gain (loss) on 
cash flow 
hedges
Total accumulated
other comprehensive
(loss) income, 
net of tax
(in millions)
Foreign 
currency 
translation
Pensions
Other post-
retirement 
benefits
2021 ending balance
$ 
(1,524) 
$ 
(1,016) 
$ 
(31)
$
357 
$ 
1 
$ 
(2,213) 
Change in 2022
(590)
(240)
(10)
(2,907)
(6)
(3,753)
2022 ending balance
(2,114) 
(1,256) 
(41)
(2,550)
(5)
(5,966)
Change in 2023
272 
(87)
1 
881 
6 
 
1,073
2023 ending balance
(1,842) 
(1,343) 
(40)
(1,669)
1 
(4,893) 
Change in 2024
(189)
(1)
4 
 
429 
(6)
237
2024 ending balance
$ 
(2,031) 
$ 
(1,344) 
$ 
(36)
$ 
(1,240)
$ 
(5)
$
(4,656) 
(a)
Held-to-maturity securities transferred from available-for-sale securities are initially recorded at fair value as of the date of transfer.  Included in 
accumulated OCI (loss) are net unamortized pre-tax gains (losses) of $(193) million at Dec. 31, 2024, $104 million at Dec. 31, 2023 and $168 million at 
Dec. 31, 2022, associated with available-for-sale securities that were transferred to held-to-maturity securities, before consideration of hedges.  Also 
included in accumulated OCI (loss) are net pre-tax gains (losses) of $188 million at Dec. 31, 2024, $(49) million at Dec. 31, 2023 and $(67) million at 
Dec. 31, 2022, associated with hedged item basis adjustments associated with available-for-sale securities that were transferred to held-to-maturity 
securities.  On an after-tax basis, accumulated OCI (loss) includes $(4) million at Dec. 31, 2024, $42 million at Dec. 31, 2023 and $78 million at Dec. 31,
2022, associated with available-for-sale securities that were transferred to held-to-maturity securities inclusive of hedges.
Notes to Consolidated Financial Statements (continued)
174 BNY

Note 17–Stock-based compensation
Our Long-Term Incentive Plans provide for the 
issuance of restricted stock, restricted stock units 
(“RSUs”) and other stock-based awards, including 
options, to employees and directors of BNY.  At Dec. 
31, 2024, under the Long-Term Incentive Plan 
approved in April 2023, we may issue 37,099,283 
new stock-based awards, all of which may be issued 
as restricted stock or RSUs.  Stock-based 
compensation expense related to retirement eligibility 
vesting totaled $77 million in 2024, $81 million in 
2023 and $72 million in 2022.
RSUs and Performance share units
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.  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 cash dividends are paid at the time 
of vesting.
The fair value of 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 RSUs was 
$386 million in 2024, $332 million in 2023 and $293 
million in 2022.  The total income tax benefit 
recognized in the consolidated income statement 
related to compensation costs was $92 million in 
2024, $79 million in 2023 and $69 million in 2022.
BNY’s Executive Committee members were granted 
a target award of 851,939 performance share units 
(“PSUs”) in 2024, 577,549 in 2023 and 513,101 in 
2022.  The Executive Committee PSUs will vest 
based on two separate and distinct measurements, a 
performance condition and a market condition split 
70% based on return on tangible common 
shareholders’ equity (“ROTCE”) and 30% on Total 
Shareholder Return (“TSR”).  The ROTCE portion 
was measured based on the fair market value on the 
date of the grant, while the TSR portion was valued 
using a Monte Carlo simulation method.  Each 
condition only impacts its applicable portion 
(70%/30%) of the total PSU award.  The performance 
and market conditions are measured after three years 
to determine the final percentage of the total PSUs to 
vest.  The final total amount of vested PSUs will be 
the sum of the two separate and distinct performance 
and market-based portions of the PSU awards, but 
will be capped at 150% of the total PSUs awarded.  
The ultimate payout is subject to the discretion of the 
Human Resources and Compensation Committee.  
These awards are classified as equity and the ROTCE 
portion is marked-to-market to earnings as a result of 
this discretion.  The TSR portion of the award 
contains a market condition, and as a result the grant 
date fair value is recognized over the service period 
unless the requisite service is not rendered.
The following table summarizes our non-vested PSU 
and RSU activity for 2024. 
Non-vested PSU and RSU activity
Number of
shares (a)
Weighted-
average fair 
value at 
grant date
Non-vested PSUs and RSUs at 
  Dec. 31, 2023
 16,456,716 $ 
51.20 
Granted
 8,813,757  
57.01 
Vested
 (6,833,859)  
49.82 
Forfeited
 
(976,336)  
54.42 
Non-vested PSUs and RSUs at 
Dec. 31, 2024
 17,460,278 $ 
54.49 
(a) Includes dividend shares earned on the Executive Committee 
PSUs and Board of Director’s stock awards.
As of Dec. 31, 2024, $434 million of total 
unrecognized compensation costs related to non-
vested PSUs and RSUs is expected to be recognized 
over a weighted-average period of 2.3 years.
The total fair value of RSUs and PSUs that vested 
was $347 million in 2024, $305 million in 2023 and 
$264 million in 2022.  The actual excess tax benefit 
realized for the tax deductions from shares vested 
totaled $7 million in 2024, $3 million in 2023 and 
$16 million in 2022.  The tax impacts were 
recognized in the provision for income taxes.
Subsidiary Long-Term Incentive Plans
BNY 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 
Notes to Consolidated Financial Statements (continued)
BNY 175

shares are generally 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 at a price 
based generally on the fair value of the subsidiary at 
the time of repurchase.  In certain instances, BNY has 
an election to call the shares. 
Stock options
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.  No 
stock options were granted in 2024, 2023 or 2022, 
and no stock options were outstanding at Dec. 31, 
2024, Dec. 31, 2023 or Dec. 31, 2022.  
The total intrinsic value of options exercised was $15 
million in 2022.  Cash received from option exercises 
totaled $9 million in 2022.  The actual excess tax 
benefit realized for the tax deductions from options 
exercised totaled $3 million in 2022 and was 
recognized in the provision for income taxes.
Note 18–Employee benefit plans
BNY has defined benefit and/or defined contribution 
retirement plans and other post-retirement plans 
providing healthcare benefits.
The defined benefit pension plans cover 
approximately 6,400 U.S. employees and 
approximately 18,400 non-U.S. employees.
BNY 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 non-qualified 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 
participants effective Dec. 31, 2010.
Effective Dec. 31, 2018, the benefit accruals were 
frozen under our largest foreign plan, which covers 
certain UK employees.  This change resulted 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 began earning benefits on 
a defined contribution basis on Jan. 1, 2019.
Notes to Consolidated Financial Statements (continued)
176 BNY

Pension and post-retirement healthcare plans
The following tables report the combined data for our domestic and foreign defined benefit pension and post-
retirement healthcare plans.
Pension Benefits
Healthcare Benefits
Domestic
Foreign
Domestic
Foreign
(dollars in millions)
2024
2023
2024
2023
2024
2023
2024
2023
Weighted-average assumptions used to determine benefit 
obligations
Discount rate
 5.72% 
 5.25% 
 5.15% 
 4.44% 
 5.72% 
 5.25% 
 5.60% 
 4.65% 
Rate of compensation increase
N/A
N/A
 3.83 
 3.71 
 3.00 
 3.00 
N/A
N/A
Cash balance interest crediting rate
 4.00 
 4.00 
N/A
N/A
N/A
N/A
N/A
N/A
Change in benefit obligation (a)
Benefit obligation at beginning of period
$ (3,602) 
$ (3,527) 
$ (889) 
$ (768) 
$ (92) 
$ 
(95) 
$ 
(2) 
$ 
(2) 
Service cost
 
— 
 
— 
 
(11) 
 
(10) 
 
— 
 
(1) 
 
— 
 
— 
Interest cost
 
(182) 
 
(190) 
 
(39) 
 
(36) 
 
(5) 
 
(5) 
 
— 
 
— 
Actuarial gain (loss)
 
178 
 
(122) 
 
111 
 
(67) 
 
1 
 
(2) 
 
— 
 
(1) 
Curtailments
 
— 
 
— 
 
— 
 
1 
 
— 
 
— 
 
— 
 
— 
Benefits paid
 
235 
 
237 
 
31 
 
26 
 
4 
 
11 
 
— 
 
— 
Foreign exchange adjustment
N/A
N/A
 
28 
 
(35) 
N/A
N/A
 
— 
 
1 
Benefit obligation at end of period
 (3,371) 
 (3,602) 
 
(769) 
 
(889) 
 
(92) 
 
(92) 
 
(2) 
 
(2) 
Change in fair value of plan assets
Fair value at beginning of period
 5,089 
 4,806 
 1,052 
 
975 
 
135 
 
116 
 
— 
 
— 
Actual return on plan assets
 
179 
 
501 
 
(29) 
 
43 
 
16 
 
19 
 
— 
 
— 
Employer contributions
 
13 
 
19 
 
9 
 
11 
 
4 
 
11 
 
— 
 
— 
Benefit payments
 
(235) 
 
(237) 
 
(31) 
 
(26) 
 
(4) 
 
(11) 
 
— 
 
— 
Foreign exchange adjustment
N/A
N/A
 
(30) 
 
49 
N/A
N/A
 
— 
 
— 
Fair value at end of period
 5,046 
 5,089 
 
971 
 1,052 
 
151 
 
135 
 
— 
 
— 
Funded status at end of period
$ 1,675 
$ 1,487 
$ 
202 
$ 163 
$ 
59 
$ 
43 
$ 
(2) 
$ 
(2) 
Amounts recognized in accumulated other comprehensive 
loss (income) consist of:
Net loss (gain)
$ 1,637 
$ 1,637 
$ 
245 
$ 243 
$ 
32 
$ 
38 
$ 
(1) 
$ 
(1) 
Prior service (credit)
 
— 
 
— 
 
(1) 
 
(1) 
 
— 
 
(6) 
 
— 
 
— 
Total loss (gain) (before tax effects)
$ 1,637 
$ 1,637 
$ 
244 
$ 242 
$ 
32 
$ 
32 
$ 
(1) 
$ 
(1) 
(a)
The benefit obligation for pension benefits is the projected benefit obligation, and for healthcare benefits, it is the accumulated benefit obligation.
N/A – Not applicable.
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 5.72% as of 
Dec. 31, 2024.
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 on the benefit obligation for the 
domestic and foreign pension plans in 2024 are 
primarily attributable to increases in discount rates.  
Actuarial losses on the benefit obligation for the 
domestic pension plans in 2023 are primarily 
attributable to decreases in discount rates.  Actuarial 
losses on the benefit obligation for the foreign 
pension plans in 2023 are primarily attributable to 
decreases in discount rates and increases in assumed 
inflation rates.
Notes to Consolidated Financial Statements (continued)
BNY 177

Net periodic benefit (credit) 
cost 
Pension Benefits
Healthcare Benefits
Domestic
Foreign
Domestic
Foreign
(dollars in millions)
2024
2023
2022
2024
2023
2022
2024
2023
2022
2024
2023
2022
Weighted-average 
assumptions as of Jan. 1:
Market-related value of plan 
assets
$ 5,773 
$ 5,757 
$ 5,924 
$ 1,377 
$ 1,358 
$ 1,627 
$ 143 
$ 135 
$ 133 
N/A
N/A
N/A
Discount rate
 5.25% 
 5.61% 
 3.03% 
 4.44% 
 4.62% 
 2.11% 
 5.25% 
 5.61%  3.03% 
 4.65%  4.75%  2.15% 
Expected rate of return on plan 
assets
 6.75 
 6.75 
 5.375 
 5.64 
 6.38 
 2.40 
 6.75 
 6.75 
 5.375 
N/A
N/A
N/A
Rate of compensation increase
N/A
N/A
N/A
 3.74 
 3.72 
 3.43 
 3.00 
 3.00 
 3.00 
N/A
N/A
N/A
Cash balance interest crediting 
rate
 4.00 
 4.00 
 4.00 
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Components of net periodic 
benefit (credit) cost:
Service cost
$ 
— 
$ 
— 
$ 
— 
$ 
11 
$ 
10 
$ 
11 
$ — 
$ 
1 
$ 1 
$ — 
$ — 
$ — 
Interest cost
 
182 
 
190 
 
140 
 
39 
 
36 
 
28 
 
5 
 
5 
 
4 
 — 
 — 
 — 
Expected return on assets
 (381) 
 
(380) 
 
(312) 
 
(80) 
 
(89) 
 
(35) 
 (10) 
 
(9) 
 (7) 
 — 
 — 
 — 
Amortization of:
Prior service (credit) 
 
— 
 
— 
 
— 
 
— 
 
— 
 
— 
 
(6) 
 
(7) 
 (7) 
 — 
 — 
 — 
Net actuarial loss (gain)
 
25 
 
8 
 
69 
 
(4) 
 
(14) 
 
3 
 
(1) 
 
(5) 
 
3 
 — 
 — 
 — 
Settlement loss (gain)
 
— 
 
1 
 
— 
 
— 
 
(1) 
 
— 
 
— 
 
— 
 — 
 — 
 — 
 — 
Curtailment (gain)
 
— 
 
— 
 
— 
 
— 
 
(1) 
 
— 
 
— 
 
— 
 — 
 — 
 — 
 — 
Net periodic benefit (credit) 
cost 
$ (174) 
$ (181) 
$ (103) 
$ (34) 
$ 
(59) 
$ 
7 
$ (12) 
$ (15) 
$ (6) 
$ — 
$ — 
$ — 
N/A – Not applicable.
Changes in other comprehensive (income) loss in 2024
Pension Benefits
Healthcare Benefits
(in millions)
Domestic
Foreign
Domestic
Foreign
Net loss (gain) arising during period
$ 
24 $ 
(2) $ 
(7) $ 
— 
Recognition of prior years’ net (loss) gain
 
(25)  
4 
 
1  
— 
Recognition of prior years’ service credit
 
—  
— 
 
6  
— 
Foreign exchange adjustment
N/A
N/A
N/A
N/A
Total recognized in other comprehensive (income) loss (before tax effects)
$ 
(1) $ 
2 
$ 
— $ 
— 
N/A – Not applicable.
Domestic
Foreign
(in millions)
2024
2023
2024
2023
Pension benefits:
Prepaid benefit cost
$ 
1,777 $ 
1,599 
$ 
258 $ 
219 
Accrued benefit cost
 
(102)  
(112)  
(56)  
(56) 
Total pension benefits
$ 
1,675 $ 
1,487 
$ 
202 $ 
163 
Healthcare benefits:
Accrued benefit cost
$ 
59 $ 
43 
$ 
(2) $ 
(2) 
Total healthcare benefits
$ 
59 $ 
43 
$ 
(2) $ 
(2) 
The accumulated benefit obligation for all defined benefit plans was $4.2 billion at Dec. 31, 2024 and $4.5 billion at 
Dec. 31, 2023.
Plans with obligations in excess of plan 
assets
Pension Benefits
Healthcare Benefits
Domestic
Foreign
Domestic
Foreign
(in millions)
2024
2023
2024
2023
2024
2023
2024
2023
Projected benefit obligation
$ 
102 $ 
112 
$ 
68 $ 
172 
N/A
N/A
N/A
N/A
Fair value of plan assets
 
—  
— 
 
11  
116 
N/A
N/A
N/A
N/A
Accumulated benefit obligation
 
102  
112 
 
47  
55 
$ 
65 $ 
62 
$ 
2 $ 
2 
Fair value of plan assets
 
—  
— 
 
11  
17 
 
—  
— 
 
—  
— 
N/A – Not applicable.
Notes to Consolidated Financial Statements (continued)
178 BNY

Assumed healthcare cost trend 
The assumed healthcare cost trend rate used in 
determining domestic benefit expense for 2025 is 
8.90%, decreasing to 4.50% in 2035 for pre-Medicare 
costs and 9.80% decreasing to 4.50% in 2035 for 
Medicare costs.  The initial trend rate assumption 
represents an estimate of short-term cost increases 
based on recent health care marketplace experience, 
and taking into consideration the cost characteristics 
of plans available to retirees.  Annual increases in 
national health expenditures have exceeded the 
general growth in GDP for many years.  However, 
there are practical limitations to how long these 
trends can continue.  It is unrealistic to assume that 
health care expenditures will be allowed to consume 
the majority of the economy.  Therefore, over the 
long term we expect that health care costs will be 
constrained by the public’s ability and willingness to 
pay the higher cost of health care coverage.  This 
assumption implies that the ultimate trend rate should 
be related to the expected long-term growth in the 
economy.  Therefore, we assume the ultimate rate to 
be comprised of real growth in per capita GDP, long- 
term growth attributable to technology innovations, 
and the assumed long-term inflation rate.  The initial 
trend is assumed to decrease to this ultimate rate over 
time.
The following benefit payments for the 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)
Domestic
Foreign
Pension benefits:
Year
2025
$ 
282 
$ 
29 
2026
268 
33 
2027
267 
36 
2028
265 
40 
2029
264 
14 
2030-2034
1,269 
70 
Total pension benefits
$ 
2,615 
$ 
222 
Healthcare benefits:
Year
2025
$ 
9 
$ 
— 
2026
9 
— 
2027
9 
— 
2028
9 
— 
2029
9 
— 
2030-2034
41 
1 
Total healthcare benefits
$ 
86 
$ 
1 
Plan contributions
We expect to make cash contributions to fund our 
defined benefit pension plans in 2025 of $11 million 
for the domestic plans and $6 million for the foreign 
plans.
We expect to make cash contributions to fund our 
post-retirement healthcare plans in 2025 of $9 million 
for the domestic plans and less than $1 million for the 
foreign plans.
Investment strategy and asset allocation
We are 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’s 
Benefits Administration Committee, a named 
fiduciary.  Subject to the following, at all relevant 
times, BNY’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.  
Our plans are primarily invested in fixed income and 
equity securities.  In general, for the domestic plan’s 
portfolio, fixed income securities can range from 35% 
to 100% of plan assets, equity securities and 
alternative investments can range from 0% to 65% of 
plan assets and cash equivalents can be held in 
amounts ranging from 0% to 10% of plan assets.  
Actual asset allocation within the approved ranges 
varies from time to time based on economic 
conditions (both current and forecast), the timing of 
transitional reallocations and the advice of 
professional advisors.
Notes to Consolidated Financial Statements (continued)
BNY 179

Our pension assets were invested as follows:
Asset allocations
Domestic
Foreign
2024
2023
2024
2023
Fixed income
 59% 
 62% 
 75% 
 74% 
Equities
 36 
 34 
 14 
 13 
Alternative investments
 4 
 3 
 9 
 11 
Cash
 1 
 1 
 2 
 2 
Total pension assets
 100% 
 100% 
 100% 
 100% 
We held no The Bank of New York Mellon 
Corporation stock in our pension plans at Dec. 31, 
2024 and Dec. 31, 2023.  Assets of the U.S. 
postretirement healthcare plan are invested in an 
insurance contract.
Fair value measurement of plan assets
We have established a three-level hierarchy for fair 
value measurements of our pension plan assets based 
upon the transparency of inputs to the valuation of an 
asset as of the measurement date.  
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.
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 foreign exchange rates.
Common and preferred stock and exchange-traded 
funds
These investments include equities and are valued at 
the closing price reported in the active market in 
which the individual securities are traded, if available. 
Common and preferred stock and exchange-traded 
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, non-U.S. 
government securities, sovereign government 
obligations, state and political subdivisions, U.S. 
corporate bonds and foreign corporate debt funds.  
U.S. Treasury and certain non-U.S. government 
securities that are actively traded in highly liquid 
over-the-counter (“OTC”) markets 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, non-U.S. government securities, sovereign 
government obligations, state and political 
subdivisions, 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, non-U.S. 
government securities, sovereign government 
obligations, state and political subdivisions, U.S. 
corporate bonds and foreign corporate debt funds are 
primarily included in Level 2 of the valuation 
hierarchy.
Other assets measured at NAV per share, as a 
practical expedient
Other assets measured at NAV, as a practical 
expedient, include funds of funds, venture capital and 
partnership interests 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 reflect the 
value of the underlying investments held by the fund, 
less its liabilities.  The fair value of the underlying 
investments is typically the amount that the fund 
might reasonably expect to receive upon selling those 
hard to value or illiquid investments 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 
Notes to Consolidated Financial Statements (continued)
180 BNY

underlying funds as provided by the fund managers.  
These funds are typically valued on a quarterly basis.  
The following tables present the fair value of each 
major category of plan assets as of Dec. 31, 2024 and 
Dec. 31, 2023, 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, 2024
(in millions)
Level 1
Level 2
Level 3
Total fair 
value
Common and preferred stock:
U.S. equity
$ 
936 $ 
— $ 
— $ 
936 
Non-U.S. equity
 
392  
—  
—  
392 
Collective trust funds:
U.S. equity
 
—  
141  
—  
141 
Commingled
 
—  
535  
—  
535 
Fixed income:
U.S. corporate bonds
 
—  2,456  
—  
2,456 
U.S. Treasury securities
 
184  
—  
—  
184 
State and political 
subdivisions
 
—  
65  
—  
65 
Non-U.S. government
 
1  
20  
—  
21 
U.S. government agencies
 
—  
33  
—  
33 
Other
 
—  
40  
—  
40 
Exchange-traded funds
 
7  
—  
—  
7 
Total domestic plan assets in 
the fair value hierarchy
$ 1,520 $ 3,290 $ 
— $ 4,810 
Other assets measured at NAV:
Funds of funds
 
232 
Venture capital and 
partnership interests
 
4 
Total domestic plan assets, at 
fair value
$ 5,046 
Plan assets measured at fair value on a recurring basis—
foreign plans at Dec. 31, 2024
(in millions)
Level 1
Level 2
Level 3
Total fair 
value
Corporate debt funds
$ 
— $ 
588 $ 
— $ 
588 
Equity funds
 
—  
144  
—  
144 
Sovereign/government 
obligation funds
 
—  
139  
—  
139 
Cash and currency
 
17  
—  
—  
17 
Total foreign plan assets in 
the fair value hierarchy
$ 
17 $ 
871 $ 
— $ 
888 
Other assets measured at NAV
 
83 
Total foreign plan assets, at 
fair value
$ 
971 
Plan assets measured at fair value on a recurring basis—
domestic plans at Dec. 31, 2023
(in millions)
Level 1
Level 2
Level 3
Total fair 
value
Common and preferred stock:
U.S. equity
$ 
920 $ 
— $ 
— $ 
920 
Non-U.S. equity
 
373  
—  
—  
373 
Collective trust funds:
U.S. equity
 
—  
116  
—  
116 
Commingled
 
—  
530  
—  
530 
Fixed income:
U.S. corporate bonds
 
—  2,539  
—  
2,539 
U.S. Treasury securities
 
233  
—  
—  
233 
State and political  
subdivisions
 
—  
110  
—  
110 
Non-U.S. government
 
3  
27  
—  
30 
U.S. government agencies
 
—  
26  
—  
26 
Other
 
—  
35  
—  
35 
Exchange-traded funds
 
8  
—  
—  
8 
Total domestic plan assets in 
the fair value hierarchy
$ 1,537 $ 3,383 $ 
— $ 4,920 
Other assets measured at NAV:
Funds of funds
 
164 
Venture capital and 
partnership interests
 
5 
Total domestic plan assets, at 
fair value
$ 5,089 
Plan assets measured at fair value on a recurring basis—
foreign plans at Dec. 31, 2023
(in millions)
Level 1
Level 2
Level 3
Total fair 
value
Corporate debt funds
$ 
— $ 
659 $ 
— $ 
659 
Equity funds
 
—  
137  
—  
137 
Sovereign/government 
obligation funds
 
—  
123  
—  
123 
Cash and currency
 
19  
—  
—  
19 
Total foreign plan assets in 
the fair value hierarchy
$ 
19 $ 
919 $ 
— $ 
938 
Other assets measured at NAV
 
114 
Total foreign plan assets, at 
fair value
$ 1,052 
Other assets measured at NAV per share, as a 
practical expedient
Certain pension and post-retirement plan assets are 
invested in funds of funds, venture capital and 
partnership interests and other contracts valued using 
NAV, as a practical expedient.  The funds of funds 
investments are redeemable at NAV under 
agreements with the funds of funds managers.
Notes to Consolidated Financial Statements (continued)
BNY 181

Assets valued using NAV at Dec. 31, 2024
(dollars in millions)
Fair
value
Unfunded
commitments
Redemption
frequency
Redemption 
notice 
period
Funds of funds (a)
$ 232 $ 
— 
Monthly
30-45 days
Venture capital and 
partnership 
interests (b)
 
67  
— 
N/A
N/A
Other contracts (c)
 
20  
— 
N/A
N/A
Total
$ 319 $ 
—  
 
Assets valued using NAV at Dec. 31, 2023
(dollars in millions)
Fair
value
Unfunded
commitments
Redemption
frequency
Redemption 
notice 
period
Funds of funds (a)
$ 164 $ 
— 
Monthly
30-45 days
Venture capital and 
partnership 
interests (b)
 
83  
— 
N/A
N/A
Other contracts (c)
 
36  
— 
N/A
N/A
Total
$ 283 $ 
—  
 
(a)
Funds of funds includes 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)
Other contracts include assets invested in pooled accounts at 
insurance companies that are privately valued by the asset manager.
N/A – Not applicable. 
Defined contribution plans
We sponsor 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 for 2024, 2023 and 2022, the 
Company matched 100% of participant contributions 
up to 7% of an employee’s eligible base pay with a 
monetary limit of $16,000 per participant.  In 
addition, an annual non-elective contribution of $750 
was made in 2024, 2023 and 2022 to each participant 
with eligible base pay of less than $100,000 a year 
and who are credited with at least one year of service.
At Dec. 31, 2024 and Dec. 31, 2023, The Bank of 
New York Mellon Corporation 401(k) Savings Plan 
owned 7.8 million and 8.7 million shares of our 
common stock, respectively.  The fair value of total 
assets was $10.0 billion at Dec. 31, 2024 and $8.8 
billion at Dec. 31, 2023.  We recorded expenses of 
$264 million in 2024, $282 million in 2023 and $276 
million in 2022, primarily for contributions to our 
defined contribution plans. 
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, 2024 and Dec. 31, 2023, the ESOP 
owned 3.1 million and 3.5 million shares of our 
common stock, respectively.  The fair value of total 
ESOP assets was $244 million at Dec. 31, 2024 and 
$185 million at Dec. 31, 2023.  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 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 that are managed by BNY or its affiliates 
to be offered to participants as investment options 
under the plans, excluding self-directed accounts.
Note 19–Company financial information 
(Parent Corporation) 
In connection with our single point of entry resolution 
strategy, we have established an intermediate holding 
company (“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 on an 
ongoing basis, 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 
unsecured subordinated funding notes to the Parent as 
well as 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 
Notes to Consolidated Financial Statements (continued)
182 BNY

have access to the funds necessary to pay dividends, 
repurchase common stock, service its debt and satisfy 
its other obligations.  If our projected financial 
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 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 and buffers imposed 
on banks.  As of Dec. 31, 2024, our bank subsidiaries 
exceeded these requirements.
Subsequent to Dec. 31, 2024, our U.S. bank 
subsidiaries could declare dividends to the Parent of 
approximately $82 million, without the need for a 
regulatory waiver.  In addition, at Dec. 31, 2024, non-
bank subsidiaries of the Parent had liquid assets of 
approximately $3.8 billion.
The bank subsidiaries declared dividends of $4.3 
billion in 2024, $3.5 billion in 2023 and $1.0 billion 
in 2022.  The Federal Reserve and the Office of the 
Comptroller of the Currency 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 
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.  
In January 2023, we announced a share repurchase 
program approved by our Board of Directors 
providing for the repurchase of up to $5.0 billion of 
common shares beginning Jan. 1, 2023.  This new 
share repurchase plan replaced all previously 
authorized share repurchase plans.
In April 2024, we announced a new authorization 
providing for the repurchase of $6.0 billion of 
common shares in addition to any remaining capacity 
under the existing January 2023 authorization. 
The Federal Reserve Act limits, and requires 
collateral for, extensions of credit by our insured 
subsidiary banks to the Parent 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 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 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. 
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 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 
Notes to Consolidated Financial Statements (continued)
BNY 183

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 Parent’s condensed financial statements are as 
follows:
Condensed Income Statement—The Bank of New 
York Mellon Corporation (Parent Corporation) 
Year ended Dec. 31,
(in millions)
2024
2023
2022
Dividends from bank subsidiaries
$ 4,256 $ 3,472 $ 1,006 
Dividends from non-bank subsidiaries
 
1,616  
1,070  
880 
Interest income from bank subsidiaries
 
53  
71  
25 
Interest income from non-bank 
subsidiaries
 
70  
64  
37 
(Loss) on securities held for sale
 
(2)  
(1)  
— 
Other revenue
 
51  
83  
57 
Total revenue
 
6,044  
4,759  
2,005 
Interest expense (including $20, $23 and 
$10, to subsidiaries, respectively)
 
1,838  
1,716  
853 
Other expense
 
200  
291  
433 
Total expense
 
2,038  
2,007  
1,286 
Income before income taxes and equity 
in undistributed net income of 
subsidiaries
 
4,006  
2,752  
719 
(Benefit) for income taxes
 
(438)  
(258)  
(190) 
Equity in undistributed net income:
Bank subsidiaries (a)
 
(131)  
(295)  
1,685 
non-bank subsidiaries (a)
 
217  
587  
(38) 
Net income (a)
 
4,530  
3,302  
2,556 
Preferred stock dividends and 
redemption charge
 
(194)  
(235)  
(211) 
Net income applicable to common 
shareholders of The Bank of New York 
Mellon Corporation (a)
$ 4,336 $ 3,067 $ 2,345 
(a) 
Results for the years ended Dec. 31, 2023 and Dec. 31, 2022 were 
restated to reflect the retrospective application of adopting new 
accounting guidance in 2024 related to our investments in 
renewable energy projects using the proportional amortization 
method (ASU 2023-02).  See Note 2 for additional information.
Condensed Balance Sheet—The Bank of New 
York Mellon Corporation (Parent Corporation)
Dec. 31,
(in millions)
2024
2023
Assets:
Cash and due from banks
$ 
117 $ 
229 
Investment in and advances to subsidiaries and 
associated companies:
Banks (a)
 
34,315  
34,087 
Other (a)
 
39,712  
38,831 
Subtotal
 
74,027  
72,918 
Corporate-owned life insurance
 
809  
796 
Other assets
 
436  
363 
Total assets
$ 75,389 $ 74,306 
Liabilities:
Deferred compensation
$ 
369 $ 
367 
Affiliate borrowings
 
1,850  
1,294 
Other liabilities
 
2,025  
1,889 
Long-term debt
 
29,827  
29,986 
Total liabilities
 
34,071  
33,536 
Shareholders’ equity (a)
 
41,318  
40,770 
Total liabilities and shareholders’ equity
$ 75,389 $ 74,306 
(a) 
Prior period balances were restated to reflect the retrospective 
application of adopting new accounting guidance in 2024 related to 
our investments in renewable energy projects using the proportional 
amortization method (ASU 2023-02).  See Note 2 for additional 
information.
Notes to Consolidated Financial Statements (continued)
184 BNY

Condensed Statement of Cash Flows—The Bank 
of New York Mellon Corporation (Parent 
Corporation)
Year ended Dec. 31,
(in millions)
2024
2023
2022
Operating activities:
Net income (a)
$ 4,530 $ 3,302 $ 2,556 
Adjustments to reconcile net income to net 
cash provided by (used for) operating 
activities:
Equity in undistributed net (income) of 
subsidiaries (a)
(86)
(292)  (1,647)
Change in accrued interest receivable
(30)
24 
(8) 
Change in accrued interest payable
54 
24 
78 
Change in taxes payable (b)
(3)
395 
(3) 
Other, net
(67)
86 
221 
Net cash provided by operating 
activities
4,398 
3,539 
1,197 
Investing activities:
Acquisitions of, investments in, and 
advances to subsidiaries (c)
(497)
592  (1,962)
Other, net
(4)
— 
— 
Net cash (used for) provided by 
investing activities
(501)
592  (1,962)
Financing activities:
Proceeds from issuance of long-term debt
5,237 
5,988 
9,179 
Repayments of long-term debt
(5,213) (6,055) (4,000) 
Change in advances from subsidiaries
556 
364 
(2,917) 
Issuance of common stock
17 
16 
23 
Treasury stock acquired
(3,064) (2,604) 
(124)
Redemption of preferred stock
— 
(500)
— 
Cash dividends paid
(1,542)  (1,487) (1,376) 
Net cash (used for) provided by 
financing activities
(4,009)  (4,278) 
785 
Change in cash and due from banks
(112)
(147)
20 
Cash and due from banks at beginning of 
year
229 
376 
356 
Cash and due from banks at end of year
$ 
117 $ 
229 $ 
376 
Supplemental disclosures
Interest paid
$ 1,783 $ 1,693 $ 
774 
Income taxes refunded
—  
2  
— 
(a)
Results for the years ended Dec. 31, 2023 and Dec. 31, 2022 were 
restated to reflect the retrospective application of adopting new 
accounting guidance in 2024 related to our investments in 
renewable energy projects using the proportional amortization 
method (ASU 2023-02).  See Note 2 of the Notes to Consolidated 
Financial Statements for additional information.
(b)
Includes payments received from subsidiaries for taxes of $1,075
million in 2024, $986 million in 2023 and $70 million in 2022.
(c)
Includes $1,456 million of cash outflows, net of $959 million of cash 
inflows in 2024, $1,963 million of cash outflows, net of $2,555 
million of cash inflows in 2023 and $2,778 million of cash outflows, 
net of $816 million of cash inflows in 2022. 
Note 20–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’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 models 
which are calibrated to observable 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’s own credit 
spreads, as implied by the credit default swap market. 
Notes to Consolidated Financial Statements (continued)
BNY 185

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.
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.  
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 non-U.S. government 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 RMBS, MBS, certain 
non-U.S. government debt, foreign covered bonds 
and CLOs.
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 
Notes to Consolidated Financial Statements (continued)
186 BNY

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.
At Dec. 31, 2024, approximately 99% of our 
securities were valued by pricing sources with 
reasonable levels of price transparency.  The 
remaining securities were generally valued using 
observable inputs.  Additional disclosures of 
securities are provided in Note 4.
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.  As of Dec. 31, 2024, we have no 
instruments included in Level 3 of the valuation 
hierarchy.  
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 options and interest rate futures and 
options.  Since few other classes of derivative 
contracts are listed on an exchange, most of our 
derivative positions are valued using 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 
structured products, where correlation risk is 
unobservable.  As of Dec. 31, 2024, we have no 
Level 3 derivatives.  Additional disclosures of 
derivative instruments are provided in Note 23.
Seed capital
In our Investment and Wealth Management business 
segment, we make seed capital investments in certain 
funds we manage.  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. 
Other assets measured at NAV
We hold private equity investments, primarily 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, 2024 and Dec. 31, 
2023, 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. 
Notes to Consolidated Financial Statements (continued)
BNY 187

Assets and liabilities measured at fair value on a recurring basis at Dec. 31, 2024
Total carrying
value
(dollars in millions)
Level 1
Level 2
Level 3
Netting (a)
Assets:
Available-for-sale securities:
Non-U.S. government (b)
$ 4,780 
$ 19,967 
$ 
— 
$ 
— $ 
24,747 
Agency RMBS
 
— 
 19,900 
 
— 
 
—  
19,900 
U.S. Treasury
 16,403 
 
— 
 
— 
 
—  
16,403 
Agency commercial MBS
 
— 
 
7,225 
 
— 
 
—  
7,225 
Foreign covered bonds
 
— 
 
7,068 
 
— 
 
—  
7,068 
CLOs
 
— 
 
5,819 
 
— 
 
—  
5,819 
Non-agency commercial MBS
 
— 
 
2,487 
 
— 
 
—  
2,487 
U.S. government agencies
 
— 
 
2,289 
 
— 
 
—  
2,289 
Non-agency RMBS
 
— 
 
1,478 
 
— 
 
—  
1,478 
Other ABS
 
— 
 
615 
 
— 
 
—  
615 
Total available-for-sale securities
 21,183 
 66,848 
 
— 
 
—  
88,031 
Trading assets:
Debt instruments
 
2,268 
 
3,007 
 
— 
 
—  
5,275 
Equity instruments
 
5,781 
 
— 
 
— 
 
—  
5,781 
Derivative assets not designated as hedging:
Interest rate
 
2 
 
833 
 
— 
 
(835)  
— 
Foreign exchange
 
— 
 10,559 
 
— 
 
(7,698)  
2,861 
Equity and other contracts
 
6 
 
137 
 
— 
 
(79)  
64 
Total derivative assets not designated as hedging
 
8 
 11,529 
 
— 
 
(8,612)  
2,925 
Total trading assets
 
8,057 
 14,536 
 
— 
 
(8,612)  
13,981 
Other assets:
Derivative assets designated as hedging:
Interest rate
 
— 
 
326 
 
— 
 
—  
326 
Foreign exchange
 
— 
 
455 
 
— 
 
—  
455 
Total derivative assets designated as hedging
 
— 
 
781 
 
— 
 
—  
781 
Other assets (c)
 
532 
 
686 
 
— 
 
—  
1,218 
Total other assets
 
532 
 
1,467 
 
— 
 
—  
1,999 
Assets measured at NAV (c)
 
152 
Total assets
$ 29,772 
$ 82,851 
$ 
— 
$ 
(8,612) $ 
104,163 
Percentage of total assets prior to netting
 26% 
 74% 
 —% 
Liabilities:
Trading liabilities:
Debt instruments
$ 1,931 
$ 
18 
$ 
— 
$ 
— $ 
1,949 
Equity instruments
 
52 
 
— 
 
— 
 
—  
52 
Derivative liabilities not designated as hedging:
Interest rate
 
9 
 
1,201 
 
— 
 
(475)  
735 
Foreign exchange
 
— 
 10,636 
 
— 
 
(8,533)  
2,103 
Equity and other contracts
 
— 
 
51 
 
— 
 
(25)  
26 
Total derivative liabilities not designated as hedging
 
9 
 11,888 
 
— 
 
(9,033)  
2,864 
Total trading liabilities
 
1,992 
 11,906 
 
— 
 
(9,033)  
4,865 
Other liabilities:
Derivative liabilities designated as hedging:
Foreign exchange
 
— 
 
12 
 
— 
 
—  
12 
Total derivative liabilities designated as hedging
 
— 
 
12 
 
— 
 
—  
12 
Other liabilities
 
400 
 
10 
 
— 
 
—  
410 
Total other liabilities
 
400 
 
22 
 
— 
 
—  
422 
Total liabilities
$ 2,392 
$ 11,928 
$ 
— 
$ 
(9,033) $ 
5,287 
Percentage of total liabilities prior to netting
 17% 
 83% 
 —% 
(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 supranational securities.
(c)
Includes seed capital, private equity investments and other assets. 
Notes to Consolidated Financial Statements (continued)
188 BNY

Assets:
Available-for-sale securities:
Non-U.S. government (b)
$ 2,439 
$ 15,943 
$ 
— 
$ 
— $ 
18,382 
U.S. Treasury
 16,604 
 
— 
 
— 
 
—  
16,604 
Agency RMBS
 
— 
 13,111 
 
— 
 
—  
13,111 
Agency commercial MBS
 
— 
 
7,729 
 
— 
 
—  
7,729 
Foreign covered bonds
 
— 
 
6,334 
 
— 
 
—  
6,334 
CLOs
 
— 
 
6,137 
 
— 
 
—  
6,137 
Non-agency commercial MBS
 
— 
 
2,935 
 
— 
 
—  
2,935 
U.S. government agencies
 
— 
 
2,901 
 
— 
 
—  
2,901 
Non-agency RMBS
 
— 
 
1,740 
 
— 
 
—  
1,740 
Other ABS
 
— 
 
943 
 
— 
 
—  
943 
Other debt securities
 
— 
 
1 
 
— 
 
—  
1 
Total available-for-sale securities
 19,043 
 57,774 
 
— 
 
—  
76,817 
Trading assets:
Debt instruments
 
1,246 
 
2,255 
 
— 
 
—  
3,501 
Equity instruments
 
4,518 
 
— 
 
— 
 
—  
4,518 
Derivative assets not designated as hedging:
Interest rate
 
7 
 
1,053 
 
— 
 
(751)  
309 
Foreign exchange
 
— 
 
9,227 
 
— 
 
(7,498)  
1,729 
Equity and other contracts
 
— 
 
8 
 
— 
 
(7)  
1 
Total derivative assets not designated as hedging
 
7 
 10,288 
 
— 
 
(8,256)  
2,039 
Total trading assets
 
5,771 
 12,543 
 
— 
 
(8,256)  
10,058 
Other assets:
Derivative assets designated as hedging:
Interest rate
 
— 
 
214 
 
— 
 
—  
214 
Foreign exchange
 
— 
 
22 
 
— 
 
—  
22 
Total derivative assets designated as hedging
 
— 
 
236 
 
— 
 
—  
236 
Other assets (c)
 
486 
 
386 
 
— 
 
—  
872 
Total other assets
 
486 
 
622 
 
— 
 
—  
1,108 
Assets measured at NAV (c)
 
153 
Total assets
$ 25,300 
$ 70,939 
$ 
— 
$ 
(8,256) $ 
88,136 
Percentage of total assets prior to netting
 26% 
 74% 
 —% 
Assets and liabilities measured at fair value on a recurring basis at Dec. 31, 2023
Total carrying
value
(dollars in millions)
Level 1
Level 2
Level 3
Netting (a)
Liabilities:
Trading liabilities:
Debt instruments
$ 2,508 
$ 
12 
$ 
— 
$ 
— $ 
2,520 
Equity instruments
 
23 
 
— 
 
— 
 
—  
23 
Derivative liabilities not designated as hedging:
Interest rate
 
8 
 
1,339 
 
— 
 
(635)  
712 
Foreign exchange
 
— 
 
9,282 
 
— 
 
(6,341)  
2,941 
Equity and other contracts
 
9 
 
135 
 
— 
 
(114)  
30 
Total derivative liabilities not designated as hedging
 
17 
 10,756 
 
— 
 
(7,090)  
3,683 
Total trading liabilities
 
2,548 
 10,768 
 
— 
 
(7,090)  
6,226 
Other liabilities:
Derivative liabilities designated as hedging:
Foreign exchange
 
— 
 
173 
 
— 
 
—  
173 
Total derivative liabilities designated as hedging
 
— 
 
173 
 
— 
 
—  
173 
Other liabilities
 
— 
 
22 
 
— 
 
—  
22 
Total other liabilities
 
— 
 
195 
 
— 
 
—  
195 
Total liabilities
$ 2,548 
$ 10,963 
$ 
— 
$ 
(7,090) $ 
6,421 
Percentage of total liabilities prior to netting
 19% 
 81% 
 —% 
(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 supranational securities.
(c)
Includes seed capital, private equity investments and other assets.
Notes to Consolidated Financial Statements (continued)
BNY 189

Details of certain available-for-
sale securities measured at fair 
value on a recurring basis
Dec. 31, 2024
Dec. 31, 2023
Total
carrying
value (b)
Ratings (a)
Total
carrying
value (b)
Ratings (a)
AAA/
AA-
A+/
A-
BBB+/
BBB-
BB+ and
lower
Not 
rated
AAA/
AA-
A+/
A-
BBB+/
BBB-
BB+ and
lower
Not 
rated
(dollars in millions)
Non-agency RMBS, originated in:
2008-2024
$ 1,453 
 98% 
 2% 
 —% 
 —% 
 —% 
$ 1,487 
 100% 
 —% 
 —% 
 —% 
 —% 
2007 and earlier
25 
 — 
 100 
 — 
 — 
 — 
253 
 5 
 13 
 1 
 40 
 41 
Total non-agency RMBS
$ 1,478 
 98% 
 2% 
 —% 
 —% 
 —% 
$ 1,740 
 86% 
 2% 
 —% 
 6% 
 6% 
Non-agency commercial MBS 
originated in:
2009-2023
$ 2,487 
 100% 
 —% 
 —% 
 —% 
 —% 
$ 2,935 
 100% 
 —% 
 —% 
 —% 
 —% 
Foreign covered bonds:
Canada
$ 2,113 
 100% 
 —% 
 —% 
 —% 
 —% 
$ 2,473 
 100% 
 —% 
 —% 
 —% 
 —% 
UK
911 
 100 
 — 
 — 
 — 
 — 
1,035 
 100 
 — 
 — 
 — 
 — 
Germany
598 
 100 
 — 
 — 
 — 
 — 
664 
 100 
 — 
 — 
 — 
 — 
Australia
574 
 100 
 — 
 — 
 — 
 — 
689 
 100 
 — 
 — 
 — 
 — 
Other
2,872 
 100 
 — 
 — 
 — 
 — 
1,473 
 100 
 — 
 — 
 — 
 — 
Total foreign covered bonds
$ 7,068 
 100% 
 —% 
 —% 
 —% 
 —% 
$ 6,334 
 100% 
 —% 
 —% 
 —% 
 —% 
Non-U.S. government:
UK
$ 3,383 
 100% 
 —% 
 —% 
 —% 
 —% 
$ 1,316 
 100% 
 —% 
 —% 
 —% 
 —% 
Germany
2,308 
 100 
 — 
 — 
 — 
 — 
2,658 
 100 
 — 
 — 
 — 
 — 
France
1,732 
 100 
 — 
 — 
 — 
 — 
1,562 
 100 
 — 
 — 
 — 
 — 
Canada
1,463 
 100 
 — 
 — 
 — 
 — 
1,336 
 95 
 5 
 — 
 — 
 — 
Belgium
728 
 100 
 — 
 — 
 — 
 — 
511 
 100 
 — 
 — 
 — 
 — 
Netherlands
705 
 100 
 — 
 — 
 — 
 — 
334 
 100 
 — 
 — 
 — 
 — 
Spain
617 
 — 
 2 
 98 
 — 
 — 
293 
 — 
 17 
 83 
 — 
 — 
Finland
527 
 100 
 — 
 — 
 — 
 — 
282 
 100 
 — 
 — 
 — 
 — 
Japan 
377 
 — 
 100 
 — 
 — 
 — 
410 
 — 
 100 
 — 
 — 
 — 
Other (c)
1,924 
 74 
 15 
 4 
 7 
 — 
2,024 
 80 
 2 
 11 
 7 
 — 
Supranational
10,983 
 100 
 — 
 — 
 — 
 — 
7,656 
 100 
 — 
 — 
 — 
 — 
Total non-U.S. government
$ 24,747 
 94% 
 3% 
 3% 
 —% 
 —% 
$ 18,382 
 94% 
 3% 
 2% 
 1% 
 —% 
(a)
Represents ratings by S&P or the equivalent.
(b)
At Dec. 31, 2024 and Dec. 31, 2023, non-U.S. government securities were included in Level 1 and Level 2 in the valuation hierarchy.  All other assets in 
the table are Level 2 assets in the valuation hierarchy.
(c)
Includes non-investment grade non-U.S. government securities related to Brazil of $135 million at Dec. 31, 2024 and $140 million at Dec. 31, 2023.
Assets and liabilities measured at fair value on a nonrecurring basis
Under certain circumstances, we make adjustments to the fair value of our assets, liabilities and unfunded lending-
related commitments, although they are not measured at fair value on an ongoing basis.  The following table 
presents the carrying value as of Dec. 31, 2024 and Dec. 31, 2023 of financial instruments for which nonrecurring 
adjustments to fair value have been recorded during 2024 and/or 2023 and all non-readily marketable equity 
securities carried at cost with upward or downward adjustments by balance sheet caption and level in the fair value 
hierarchy.
Assets measured at fair value on a 
nonrecurring basis
Dec. 31, 2024
Dec. 31, 2023
Total carrying
value
Total carrying
value
(in millions)
Level 1
Level 2
Level 3
Level 1
Level 2
Level 3
Loans (a)
$ 
— $ 
25 $ 
— $ 
25 
$ 
— $ 
28 $ 
— $ 
28 
Other assets (b)
— 
414 
— 
414 
— 
481 
— 
481 
Total assets at fair value on a nonrecurring 
basis
$ 
— $ 
439 $ 
— $ 
439 
$ 
— $ 
509 $ 
— $ 
509 
(a)
The fair value of these loans decreased $1 million in 2024 and $3 million in 2023, based on the fair value of the underlying collateral, as
required by guidance in ASC 326, Financial Instruments – Credit Losses, with an offset to the allowance for credit losses.
(b)
Includes non-readily marketable equity securities carried at cost with upward or downward adjustments and other assets received in satisfaction
of debt.
Notes to Consolidated Financial Statements (continued)
190 BNY

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, 2024 and Dec. 31, 2023, by caption on the consolidated 
balance sheet and by the valuation hierarchy. 
Summary of financial instruments
Dec. 31, 2024
(in millions)
Level 1
Level 2
Level 3
Total
estimated
fair value
Carrying
amount
Assets:
Interest-bearing deposits with the Federal Reserve and other central banks 
$ 
— $ 89,546 $ 
— $ 89,546 $ 89,546 
Interest-bearing deposits with banks
 
—  
9,617  
—  
9,617  
9,612 
Federal funds sold and securities purchased under resale agreements
 
—  
41,146  
—  
41,146  
41,146 
Securities held-to-maturity
 
10,016  
34,004  
—  
44,020  
48,596 
Loans (a)
 
—  
69,738  
—  
69,738  
70,673 
Other financial assets
 
4,178  
2,271  
—  
6,449  
6,449 
Total
$ 14,194 $ 246,322 $ 
— $ 260,516 $ 266,022 
Liabilities:
Noninterest-bearing deposits
$ 
— $ 58,267 $ 
— $ 58,267 $ 58,267 
Interest-bearing deposits
 
—  226,799  
—  226,799  231,257 
Federal funds purchased and securities sold under repurchase agreements
 
—  
14,064  
—  
14,064  
14,064 
Payables to customers and broker-dealers
 
—  
20,073  
—  
20,073  
20,073 
Commercial paper
 
—  
301  
—  
301  
301 
Borrowings
 
—  
941  
—  
941  
941 
Long-term debt
 
—  
30,351  
—  
30,351  
30,854 
Total
$ 
— $ 350,796 $ 
— $ 350,796 $ 355,757 
(a) Does not include the leasing portfolio.
Summary of financial instruments
Dec. 31, 2023
(in millions)
Level 1
Level 2
Level 3
Total 
estimated
fair value
Carrying
amount
Assets:
Interest-bearing deposits with the Federal Reserve and other central banks 
$ 
— $ 111,550 $ 
— $ 111,550 $ 111,550 
Interest-bearing deposits with banks
 
—  
12,134  
—  
12,134  
12,139 
Federal funds sold and securities purchased under resale agreements
 
—  
28,900  
—  
28,900  
28,900 
Securities held-to-maturity
 
9,545  
35,166  
—  
44,711  
49,578 
Loans (a)
 
—  
65,026  
—  
65,026  
65,977 
Other financial assets
 
4,922  
2,149  
—  
7,071  
7,071 
Total
$ 14,467 $ 254,925 $ 
— $ 269,392 $ 275,215 
Liabilities:
Noninterest-bearing deposits
$ 
— $ 58,274 $ 
— $ 58,274 $ 58,274 
Interest-bearing deposits
 
—  221,463  
—  221,463  225,395 
Federal funds purchased and securities sold under repurchase agreements
 
—  
14,507  
—  
14,507  
14,507 
Payables to customers and broker-dealers
 
—  
18,395  
—  
18,395  
18,395 
Borrowings
 
—  
1,274  
—  
1,274  
1,274 
Long-term debt
 
—  
30,596  
—  
30,596  
31,257 
Total
$ 
— $ 344,509 $ 
— $ 344,509 $ 349,102 
(a) Does not include the leasing portfolio.
Notes to Consolidated Financial Statements (continued)
BNY 191

Note 21–Fair value option
We elected fair value as an alternative measurement 
for selected financial assets and liabilities that are not 
otherwise required to be measured at fair value, 
including the assets and liabilities of consolidated 
investment management funds and subordinated notes 
associated with certain equity investments.  
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
Dec. 31,
(in millions)
2024
2023
Assets of consolidated investment 
management funds:
Trading assets
$ 
846 $ 
510 
Other assets
45 
16 
Total assets of consolidated 
investment management funds
$ 
891 $ 
526 
Liabilities of consolidated investment 
management funds:
Other liabilities
$ 
5 $ 
1 
Total liabilities of consolidated 
investment management funds
$ 
5 $ 
1 
The assets and liabilities of the consolidated 
investment management funds are included in other 
assets and other liabilities, respectively, on the 
consolidated balance sheet.  We value the assets and 
liabilities of 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 holds in the economic performance of the 
consolidated investment management funds.  
Changes in the fair value of the assets and liabilities 
are recorded as income (loss) from consolidated 
investment management funds, which is included in 
investment and other revenue in the consolidated 
income statement.
We elected the fair value option on subordinated 
notes associated with certain equity investments.  The 
fair value of these subordinated notes was $26 million 
at Dec. 31, 2024 and $4 million at Dec. 31, 2023, and 
are included in other assets on the consolidated 
balance sheet.  The subordinated notes were valued 
using observable market inputs and included in Level 
2 of the valuation hierarchy. 
Note 22–Commitments and contingent 
liabilities
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.
Off-balance sheet credit risks
Dec. 31, 
2024
Dec. 31, 
2023
(in millions)
Lending commitments
$ 52,581 $ 46,518 
Standby letters of credit (“SBLC”) (a)
1,641 
1,816 
Commercial letters of credit
24 
41 
Securities lending indemnifications (b)(c)  544,601  492,739 
(a)
Net of participations totaling $192 million at Dec. 31, 2024
and $163 million at Dec. 31, 2023.
(b)
Excludes the indemnification for securities for which BNY
acts as an agent on behalf of CIBC Mellon clients, which
totaled $60 billion at Dec. 31, 2024 and $59 billion at Dec.
31, 2023.
(c)
Includes cash collateral, invested in indemnified repurchase
agreements, held by us as securities lending agent of $59
billion at Dec. 31, 2024 and $45 billion at Dec. 31, 2023.
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 
Notes to Consolidated Financial Statements (continued)
192 BNY

does not necessarily represent future cash 
requirements.  A summary of lending commitment 
maturities is as follows: $32.7 billion in less than one 
year, $19.4 billion in one to five years and $440 
million over five years.
SBLCs principally support obligations of corporate 
clients and were collateralized with cash and 
securities of $173 million at Dec. 31, 2024 and $158 
million at Dec. 31, 2023.  At Dec. 31, 2024, $1.3 
billion of the SBLCs will expire within one year and 
$298 million in one to five years.  No SBLCs expire 
in over 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. 
Payment/performance risk of SBLCs is monitored 
using both historical performance and internal ratings 
criteria.  BNY’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
Dec. 31, 
2024
Dec. 31, 
2023
Investment grade
 67% 
 74% 
Non-investment grade
 33% 
 26% 
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 $24 million at Dec. 31, 2024 and $41 
million at Dec. 31, 2023.
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 
and the structure of the transaction, including 
collateral, if any.  The allowance for lending-related 
commitments was $72 million at Dec. 31, 2024 and 
$87 million at Dec. 31, 2023.
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 $574 billion at Dec. 31, 
2024 and $518 billion at Dec. 31, 2023.
CIBC Mellon, a joint venture between BNY and the 
Canadian Imperial Bank of Commerce (“CIBC”), 
engages in securities lending activities.  CIBC 
Mellon, BNY and CIBC jointly and severally 
indemnify securities lenders against specific types of 
borrower default.  At Dec. 31, 2024 and Dec. 31, 
2023, $60 billion and $59 billion, respectively, of 
borrowings at CIBC Mellon, for which BNY acts as 
agent on behalf of CIBC Mellon clients, were secured 
by collateral of $64 billion and $62 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. 
Unsettled repurchase and reverse repurchase 
agreements
In the normal course of business, we enter into 
repurchase agreements and reverse repurchase 
agreements that settle at a future date.  In repurchase 
agreements, BNY receives cash from and provides 
securities as collateral to a counterparty at settlement.  
In reverse repurchase agreements, BNY advances 
Notes to Consolidated Financial Statements (continued)
BNY 193

cash to and receives securities as collateral from the 
counterparty at settlement.  These transactions are 
recorded on the consolidated balance sheet on the 
settlement date.  At Dec. 31, 2024, we had no 
unsettled repurchase agreements and $96.1 billion of 
unsettled reverse repurchase agreements.  At Dec. 31, 
2023, we had no unsettled repurchase agreements and 
$77.9 billion of unsettled reverse repurchase 
agreements.
Industry concentrations
We have significant industry concentrations related to 
credit exposure at Dec. 31, 2024.  The tables below 
present our credit exposure in the financial 
institutions and commercial portfolios.  
Financial institutions
portfolio exposure
(in billions)
Dec. 31, 2024
Loans
Unfunded
commitments
Total 
exposure
Securities industry
$ 
2.3 $ 
20.3 $ 
22.6 
Banks
8.9 
1.4 
10.3 
Asset managers
1.8 
8.4 
10.2 
Insurance
— 
4.2 
4.2 
Government
— 
0.4 
0.4 
Other
0.2 
0.5 
0.7 
Total
$ 
13.2 $ 
35.2 $ 
48.4 
Commercial portfolio
exposure
(in billions)
Dec. 31, 2024
Loans
Unfunded
commitments
Total 
exposure
Energy and utilities
$ 
0.2 $ 
4.1 $ 
4.3 
Services and other
0.7 
3.5 
4.2 
Manufacturing
0.5 
3.5 
4.0 
Media and telecom
— 
0.8 
0.8 
Total
$ 
1.4 $ 
11.9 $ 
13.3 
Major concentrations in securities lending are 
primarily to broker-dealers and are generally 
collateralized with cash and/or securities.
Sponsored member repo program
BNY is a sponsoring member in the Fixed Income 
Clearing Corporation (“FICC”) sponsored member 
program, where we submit eligible repurchase and 
reverse repurchase transactions in U.S. Treasury and 
agency securities (“Sponsored Member 
Transactions”) between BNY and our sponsored 
member clients for novation and clearing through 
FICC pursuant to the FICC Government Securities 
Division rulebook (the “FICC Rules”).  We also 
guarantee to FICC the prompt and full payment and 
performance of our sponsored member clients’ 
respective obligations under the FICC Rules in 
connection with such clients’ Sponsored Member 
Transactions.  We minimize our credit exposure 
under this guaranty by obtaining a security interest in 
our sponsored member clients’ collateral and rights 
under Sponsored Member Transactions.  See 
“Offsetting assets and liabilities” in Note 23 for 
additional information on our repurchase and reverse 
repurchase agreements.
Indemnification arrangements
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, 2024 and 
Dec. 31, 2023, 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, 
Notes to Consolidated Financial Statements (continued)
194 BNY

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, 2024 and Dec. 31, 2023, we did not record any 
material liabilities under these arrangements.
Legal proceedings
In the ordinary course of business, The Bank of New 
York Mellon Corporation 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, 
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, we establish 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.  
We regularly monitor 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, we do 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.  We believe 
that our accruals for legal proceedings are appropriate 
and, in the aggregate, are not material to the 
consolidated financial position of BNY, although 
future accruals could have a material effect on the 
results of operations in a given period.  In addition, if 
we have the potential to recover a portion of an 
estimated loss from a third party, we record a 
receivable up to the amount of the accrual that is 
probable of recovery.
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 
is currently unable to estimate a range of reasonably 
possible loss.  For those matters described here where 
BNY is able to estimate a reasonably possible loss, 
the aggregate range of such reasonably possible loss 
is up to $690 million in excess of the accrued liability 
(if any) related to those matters.  For matters where a 
reasonably possible loss is denominated in a foreign 
currency, our estimate is adjusted quarterly based on 
prevailing exchange rates.  We do not consider 
potential recoveries when estimating reasonably 
possible losses.
The following describes certain judicial, regulatory 
and arbitration proceedings involving BNY:
Mortgage-Securitization Trusts Proceedings
BNY 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.  Two 
actions commenced in December 2015 and February 
2017 are pending in New York federal court.  In New 
York state court, five actions are pending: two related 
cases commenced in September 2021 and October 
2022; and three related cases commenced in October 
2021, December 2021 and February 2022.
Notes to Consolidated Financial Statements (continued)
BNY 195

Matters Related to R. Allen Stanford
In late December 2005, Pershing LLC 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, also 
controlled by Stanford, issued certificates of deposit 
(“CDs”).  Some investors allegedly wired funds from 
their SGC accounts to purchase CDs.  In 2009, the 
Securities and Exchange Commission 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 
two putative class action proceedings against 
Pershing LLC: one in November 2009 in Texas 
federal court, and one in May 2016 in New Jersey 
federal court.  On Nov. 5, 2021, the court dismissed 
the class action filed in New Jersey.  Both matters 
have concluded.  Three lawsuits remain against 
Pershing LLC in Louisiana and New Jersey federal 
courts, which were filed in January 2010, October 
2015 and May 2016.  The purchasers allege that 
Pershing LLC, as SGC’s clearing firm, assisted 
Stanford in a fraudulent scheme and assert 
contractual, statutory and common law claims.  In 
March 2019, a group of investors filed a putative 
class action against The Bank of New York Mellon in 
New Jersey federal court, making the same 
allegations as in the prior actions brought against 
Pershing LLC.  On Nov. 12, 2021, the court 
dismissed the class action against The Bank of New 
York Mellon; on Dec. 15, 2022, an appeals court 
reversed the dismissal and returned the case to the 
trial court for further proceedings.  On June 28, 2024, 
an unincorporated association that claims to represent 
the interests of Stanford investors filed a lawsuit in 
New Jersey federal court against The Bank of New 
York Mellon, making the same allegations as prior 
cases.  All of the cases that have been brought in 
federal court have been consolidated in Texas federal 
court for discovery purposes.  Various alleged 
Stanford CD purchasers asserted similar claims in 
Financial Industry Regulatory Authority, Inc. 
(“FINRA”) arbitration proceedings. 
Brazilian Postalis Litigation
BNY 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 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 
Correios (“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 appealed.  On Aug. 4, 
2021, the appellate court overturned the dismissal and 
sent the lawsuit to a state lower court.  On March 2, 
2023, DTVM appealed the August 4 decision to 
Brazil’s Superior Court of Justice.  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 May 20, 2021, the court in one of 
those lawsuits entered a judgment of approximately 
$3 million against DTVM and Ativos.  DTVM 
appealed and, on June 7, 2022, the appellate court 
partially granted and partially denied the appeal, 
reducing the judgment to approximately $2 million.  
On July 13, 2023, DTVM and Ativos filed a further 
appeal to Brazil’s Superior Court of Justice, which 
was denied on Sept. 20, 2024.  DTVM and Ativos 
further appealed, but their appeal was denied on Dec. 
3, 2024.  On Aug. 24, 2022, the court dismissed one 
of the other lawsuits.  Postalis appealed that decision, 
but Postalis’s appeal was denied on Oct. 24, 2023.  
Postalis further appealed; that further appeal was 
denied on Oct. 22, 2024.  On Feb. 4, 2016, Postalis 
filed a lawsuit in Brasilia against DTVM, Ativos and 
BNY Alocação de Patrimônio Ltda. (“Alocação de 
Patrimônio”), 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 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 as 
controller of Postalis’s own investment portfolio.  On 
April 18, 2018, the court dismissed the lawsuit 
without prejudice.  On Aug. 4, 2021, the appellate 
Notes to Consolidated Financial Statements (continued)
196 BNY

court overturned the dismissal and returned the 
lawsuit to the lower court.  DTVM appealed, but that 
appeal was denied on Aug. 21, 2023.  In addition, the 
Tribunal de Contas da União (“TCU”), an 
administrative tribunal, has initiated proceedings with 
the purpose of determining liability for losses to four 
investment funds administered by DTVM in which 
Postalis was an investor.  On Sept. 9, 2020, TCU 
rendered a decision in one of the proceedings, finding 
DTVM and two former Postalis directors jointly and 
severally liable for approximately $50 million.  TCU 
also imposed on DTVM a fine of approximately $2 
million.  DTVM’s administrative appeal of the 
decision was denied.  On Feb. 25, 2022, DTVM filed 
a lawsuit in Brazil federal court in Brasilia seeking 
annulment of TCU’s decision and an injunction 
preventing TCU from enforcing the judgment.  On 
Aug. 24, 2022, the Brazilian Federal Attorneys filed 
an action in Rio de Janeiro court seeking to enforce 
the fine portion of the judgment.  On Nov. 8, 2022, 
the Brasilia federal court in the annulment action 
granted DTVM’s request for an injunction, 
suspending the Sept. 9, 2020, TCU decision until the 
annulment action is decided.  On Oct. 4, 2019, 
Postalis and another pension fund filed a request for 
arbitration in São Paulo against DTVM and Ativos 
alleging liability for losses to an investment fund for 
which DTVM was administrator and Ativos was 
manager.  On March 26, 2021, DTVM and Ativos 
filed a lawsuit in São Paulo challenging the 
Arbitration Court’s jurisdiction over the case.  On 
Feb. 24, 2023, the São Paulo court annulled the 
Arbitration Court’s decision that it had jurisdiction, 
and Postalis and the other pension fund appealed.  On 
April 8, 2024, the appellate court reversed the São 
Paulo court’s decision and found that the Arbitration 
Court did have jurisdiction.  DTVM and Ativos 
appealed; that appeal was denied on April 8, 2024.  
DTVM and Ativos have further appealed.  The 
arbitration continues during the further appeal.  On 
Oct. 25, 2019, Postalis filed a lawsuit in Rio de 
Janeiro against DTVM and Alocação de Patrimônio, 
alleging liability for losses in another fund for which 
DTVM was administrator and Alocação de 
Patrimônio and Ativos were managers.  On May 9, 
2022, the court found DTVM and Alocação de 
Patrimônio jointly and severally liable for 
approximately $20 million.  On Aug. 12, 2022, 
DTVM and Alocação de Patrimônio appealed the 
decision.  On April 30, 2024, the appeals court 
reversed the finding against DTVM and Alocação de 
Patrimônio.  Postalis appealed that reversal and, on 
Oct. 3, 2024, its appeal was denied.  Postalis has filed 
a further appeal.  On June 19, 2020, a lawsuit was 
filed in federal court in Rio de Janeiro against 
DTVM, Postalis, and various other defendants 
alleging liability against DTVM for certain Postalis 
losses in an investment fund of which DTVM was 
administrator.  On Feb. 10, 2021, Postalis and another 
pension fund served DTVM in a lawsuit filed in Rio 
de Janeiro, alleging liability for losses in another 
investment fund for which DTVM was administrator 
and the other defendant was manager.
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.  On March 21, 2024, the São Paulo 
court issued a decision finding DTVM, Deutsche 
Bank and Silverado Gestão e Investimentos jointly 
liable for losses to the Fund in an amount to be 
determined during a later calculation phase.  On Sept. 
12, 2024, DTVM filed an appeal.
German Tax Matters
German authorities are investigating past “cum/ex” 
trading, which involved the purchase of equity 
securities on or shortly before the dividend date, but 
settled after that date, potentially resulting in an 
unwarranted refund of withholding tax.  German 
authorities have taken the view that past cum/ex 
trading may have resulted in tax avoidance or 
evasion.  European subsidiaries of BNY have been 
informed by German authorities about investigations 
into potential cum/ex trading by certain third-party 
investment funds, where one of the subsidiaries had 
acquired entities that served as depositary and/or fund 
manager for those third-party investment funds.  We 
have received information requests from the 
authorities relating to pre-acquisition activity and are 
cooperating fully with those requests.  In August 
2019, the District Court of Bonn ordered that one of 
these subsidiaries be joined as a secondary party in 
connection with the prosecution of unrelated 
individual defendants.  Trial commenced in 
September 2019.  In March 2020, the court stated that 
Notes to Consolidated Financial Statements (continued)
BNY 197

it would refrain from taking action against the 
subsidiary in order to expedite the conclusion of the 
trial.  The court convicted the unrelated individual 
defendants, and determined that the cum/ex trading 
activities of the relevant third-party investment funds 
were unlawful.  In November and December 2020 
and February 2023, we received secondary liability 
notices from the German tax authorities totaling 
approximately $150 million (at then-prevailing 
exchange rates) related to pre-acquisition activity in 
various funds for which the entities we acquired were 
depositary and/or fund manager.  We have appealed 
the notices.  In connection with the acquisition of the 
subject entities, we obtained an indemnity for 
liabilities from the sellers that we intend to pursue as 
necessary.
Off-Channel Business-Related Communications
The Company has been responding to requests for 
information from the SEC and the Commodity 
Futures Trading Commission concerning compliance 
with recordkeeping obligations relating to business 
communications transmitted on unapproved 
electronic communication platforms.  SEC and CFTC 
have been conducting similar inquiries into 
recordkeeping practices at other financial institutions.  
On Aug. 14, 2024, the SEC issued an order under 
which the Company agreed to pay a $40 million 
penalty and to certain undertakings to resolve the 
SEC matter.  The fine has been paid, and the 
Company is complying with the other settlement 
terms.  The Company continues to cooperate with the 
CFTC’s inquiry.
Pershing LLC Rule 15c3-3 Matter
The Company has been responding to investigative 
requests for information and records from the SEC 
concerning Pershing LLC’s compliance with its 
obligations under SEC Rule 15c3-3, among other 
regulatory rules and statutes.  The Company 
continues to cooperate with the inquiry.
Note 23–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-
maker for our customers and facilitating customer 
trades in compliance with the Volcker Rule.
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 2024.
Hedging derivatives
We utilize interest rate swap agreements, including 
forward starting swaps, 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, loans and long-term debt to 
floating interest rates.  We also utilize interest rate 
swaps and forward exchange contracts as cash flow 
hedges to manage our exposure to interest rate and 
foreign exchange rate changes.  In designating 
interest rate swaps as hedges, we utilize both partial-
term and full-term hedge strategies. 
The available-for-sale securities hedged consist of 
U.S. Treasury, agency and non-agency commercial 
MBS, agency and non-agency RMBS, non-U.S. 
government and foreign covered bonds.  At Dec. 31, 
2024, $36.9 billion par value of available-for-sale 
securities were hedged with interest rate swaps 
designated as fair value hedges that had notional 
values of $36.9 billion.
At Dec. 31, 2024, $1.4 billion of interest rate swaps 
was designated as portfolio layer method fair value 
hedges of loans against a closed portfolio of fixed rate 
loans of $3.2 billion, essentially converting $1.4 
billion of such fixed rate loans to a floating rate.
The fixed rate long-term debt instruments hedged 
generally have original maturities of five to 30 years.  
In fair value hedging relationships, fixed rate debt is 
hedged with “receive fixed rate, pay variable rate” 
swaps.  At Dec. 31, 2024, $28.5 billion par value of 
debt was hedged with interest rate swaps designated 
as fair value hedges that had notional values of $28.5 
billion. 
Notes to Consolidated Financial Statements (continued)
198 BNY

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 
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 currencies such as the Indian rupee, Polish zloty, 
Hong Kong dollar, Singapore dollar, British pound 
and euro used in revenue and expense transactions for 
entities that have the U.S. dollar as their functional 
currency.  As of Dec. 31, 2024, the hedged forecasted 
foreign currency transactions and designated forward 
foreign exchange contract hedges were $765 million 
(notional), with a pre-tax loss of $4 million recorded 
in accumulated OCI.  Over the next 12 months, a loss 
of $6 million will be reclassified into earnings.
From time-to-time, we have utilized 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.  At Dec. 31, 2024, there were 
no remaining foreign exchange contracts.
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.  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, 2024, 
forward foreign exchange contracts with notional 
amounts totaling $11.3 billion were designated as net 
investment hedges.
From time-to-time, we also designate non-derivative 
financial instruments as hedges of our net investments 
in foreign subsidiaries.  At Dec. 31, 2024, there were 
no non-derivative financial instruments hedging our 
net investments in foreign subsidiaries.
The following table presents the pre-tax gains (losses) related to our fair value and cash flow hedging activities 
recognized in the consolidated income statement.
Income statement impact of fair value and cash flow hedges
(in millions)
Location of gains (losses)
2024
2023
2022
Interest rate fair value hedges of available-for-sale securities
Derivative
Interest income
$ 
311 $ 
(631) $ 
3,530
Hedged item
Interest income
(311)
629
(3,517) 
Interest rate fair value hedges of long-term debt
Derivative
Interest expense
(218)
366
(1,441) 
Hedged item
Interest expense
218 
(365)
1,438
Foreign exchange fair value hedges of available-for-sale securities
Derivative (a)
Foreign exchange revenue
— 
— 
(2) 
Hedged item
Foreign exchange revenue
— 
— 
4 
Interest rate fair value hedges of loans
Derivative 
Interest income
7 
— 
— 
Hedged item
Interest income
(7)
—
— 
Cash flow hedges of forecasted FX exposures
Gain (loss) reclassified from OCI into income
Staff expense
5 
—
(9) 
Gain (loss) reclassified from OCI into income
Investment and other revenue
2 
(2)
1
Gain (loss) recognized in the consolidated income statement due to 
fair value and cash flow hedging relationships
$ 
7 $ 
(3) $
4 
(a)
There was no amortization associated with the excluded component in 2024 or 2023.  Includes gains of $1 million in 2022 associated
with the amortization of the excluded component.
Notes to Consolidated Financial Statements (continued)
BNY 199

The following table presents the impact of hedging derivatives used in net investment hedging relationships.
Impact of derivative instruments used in net investment hedging relationships
(in millions)
Derivatives in net investment 
hedging relationships
Gain or (loss) recognized in 
accumulated OCI on derivatives
Year ended Dec. 31,
Location of gain or (loss) 
reclassified from 
accumulated OCI into 
income 
Gain or (loss) reclassified from 
accumulated OCI into income
Year ended Dec. 31,
2024
2023
2022
2024
2023
2022
FX contracts
$ 
684 $ 
(285) $ 
631 
Net interest income
$ 
— $ 
— $ 
— 
The following table presents information on the hedged items in fair value hedging relationships.
Hedged items in fair value hedging relationships
Carrying amount of hedged 
asset or liability
Hedge accounting basis 
adjustment increase (decrease) (a)
(in millions)
Dec. 31, 2024
Dec. 31, 2023
Dec. 31, 2024
Dec. 31, 2023
Available-for-sale securities (b)
$ 
40,751 $ 
29,941 
$ 
(1,650) $ 
(1,767) 
Loans (c)
$ 
3,162 $ 
— 
$ 
(7) $ 
— 
Long-term debt
$ 
27,458 $ 
21,854 
$ 
(1,042) $ 
(846) 
(a) Includes $474 million and $434 million of basis adjustment decreases on discontinued hedges associated with available-for-sale 
securities at Dec. 31, 2024 and Dec. 31, 2023, respectively, and $5 million and $26 million of basis adjustment decreases on 
discontinued hedges associated with long-term debt at Dec. 31, 2024 and Dec. 31, 2023, respectively.
(b) At Dec. 31, 2024 and Dec. 31, 2023, the amortized cost of the available-for-sale securities included in closed portfolios subject to 
portfolio layer method hedging was $12.1 billion and $2.0 billion, respectively, of which the notional amount hedged was $6.2 billion 
and $1.0 billion, respectively.  The cumulative basis adjustments for active hedging relationships associated with such hedges as of Dec. 
31, 2024 and Dec. 31, 2023 were a decrease of $92 million and an increase of $24 million, respectively. 
(c) At Dec. 31, 2024, loans included in closed portfolios subject to portfolio layer method hedging were $3.2 billion, of which $1.4 billion 
was designated as hedged.  The cumulative basis adjustment for active hedging relationships associated with such hedges as of Dec. 31, 
2024 was a decrease of $7 million. 
The following table summarizes the notional amount and carrying values of our total derivatives portfolio.
Impact of derivative instruments on the balance sheet
Notional value
Asset derivatives
fair value
Liability derivatives
fair value
Dec. 31, 
2024
Dec. 31, 
2023
Dec. 31, 
2024
Dec. 31, 
2023
Dec. 31, 
2024
Dec. 31, 
2023
(in millions)
Derivatives designated as hedging instruments: (a)(b)
Interest rate contracts
$ 
66,805 $ 52,808 
$ 
326 $ 
214 
$ 
— $ 
— 
Foreign exchange contracts
 
12,048  
11,099 
 
455  
22 
 
12  
173 
Total derivatives designated as hedging instruments
 
 
$ 
781 $ 
236 
$ 
12 $ 
173 
Derivatives not designated as hedging instruments: (b)(c)
Interest rate contracts
$ 169,523 $ 155,535 
$ 
835 $ 
1,060 
$ 
1,210 $ 
1,347 
Foreign exchange contracts
 
919,690  944,241 
 
10,559  
9,227 
 
10,636  
9,282 
Equity contracts
 
5,321  
3,886 
 
143  
8 
 
34  
138 
Credit contracts
 
324  
220 
 
—  
— 
 
17  
6 
Total derivatives not designated as hedging instruments
$ 
11,537 $ 10,295 
$ 
11,897 $ 10,773 
Total derivatives fair value (d)
$ 
12,318 $ 10,531 
$ 
11,909 $ 10,946 
Effect of master netting agreements (e)
 
(8,612)  
(8,256)  
(9,033)  
(7,090) 
Fair value after effect of master netting agreements
$ 
3,706 $ 
2,275 
$ 
2,876 $ 
3,856 
(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) For derivative transactions settled at clearing organizations, cash collateral exchanged is deemed a settlement of the derivative each 
day.  The settlement reduces the gross fair value of derivative assets and liabilities and results in a corresponding decrease in the 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 $1,953 million and $2,374 million, respectively, at 
Dec. 31, 2024, and $2,353 million and $1,187 million, respectively, at Dec. 31, 2023.
Notes to Consolidated Financial Statements (continued)
200 BNY

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 revenue and 
investment and other revenue on the consolidated 
income statement.
The following table presents our foreign exchange 
revenue and other trading revenue.
Foreign exchange revenue and 
other trading revenue
Year ended Dec. 31,
(in millions)
2024
2023
2022
Foreign exchange revenue
$ 688 $ 631 $ 822 
Other trading revenue 
 
314  
231  
149 
Foreign exchange revenue includes income from 
purchasing and selling foreign currencies, currency 
forwards, futures and options, as well as foreign 
currency remeasurement.  Other trading revenue 
reflects results from trading in cash instruments, 
including fixed income and equity securities, and 
trading and economic hedging activity with 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 were gains of $18 million in 2024 and 
$22 million in 2023 and a loss of $43 million in 2022. 
We manage trading risk through a system of position 
limits, a value-at-risk (“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 into 
other risk management materials.
Counterparty credit risk and collateral
We assess the 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 20.
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 
Notes to Consolidated Financial Statements (continued)
BNY 201

collateral or the right to terminate the contracts in a 
net liability position.  
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.
Dec. 31, 
2024
Dec. 31, 
2023
(in millions)
Aggregate fair value of OTC derivatives 
in net liability positions (a)
$ 
2,163 $ 
1,003 
Collateral posted
$ 
1,940 $ 
1,001 
(a)
Before consideration of cash collateral.
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 were downgraded.
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.  
Potential close-out exposures (fair value) (a)
Dec. 31, 
2024
Dec. 31, 
2023
(in millions)
If The Bank of New York Mellon’s 
rating changed to: (b)
A3/A-
$ 
40 $ 
115 
Baa2/BBB
$ 
646 $ 
792 
Ba1/BB+
$ 
2,710 $ 
1,920 
(a)
The amounts represent potential total close-out values if The
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 ratings by Moody’s/S&P.
If The Bank of New York Mellon’s debt rating had 
fallen below investment grade on Dec. 31, 2024 and 
Dec. 31, 2023, existing collateral arrangements would 
have required us to post additional collateral of $351 
million and $235 million, respectively.
Offsetting assets and liabilities
The following tables present derivative and financial instruments and their related offsets.  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, 2024
Net assets 
recognized 
in the 
balance 
sheet
Gross amounts not offset 
in the balance sheet
Gross assets 
recognized
Gross 
amounts 
offset in the 
balance 
sheet 
(in millions)
(a)
Financial 
instruments
Cash 
collateral 
received
Net 
amount
Derivatives subject to netting arrangements:
Interest rate contracts
$ 
1,032 $ 
835 
$ 
197 $ 
46 $ 
— $ 
151 
Foreign exchange contracts
10,210 
7,698 
2,512 
132 
— 
2,380 
Equity and other contracts
131 
79 
52 
— 
— 
52 
Total derivatives subject to netting arrangements
11,373 
8,612 
2,761 
178 
— 
2,583 
Total derivatives not subject to netting arrangements
945 
— 
945 
— 
— 
945 
Total derivatives
12,318 
8,612 
3,706 
178 
— 
3,528 
Reverse repurchase agreements
252,941 
228,386 (b)
24,555 
24,523 
1 
31 
Securities borrowing
18,144 
1,553 
16,591 
15,777 
— 
814 
Total
$ 
283,403 $ 
238,551 
$ 
44,852 $ 
40,478 $ 
1 $ 
4,373 
(a)
Includes the effect of netting agreements and net cash collateral received.  The offset related to the OTC derivatives was allocated to the
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.
Notes to Consolidated Financial Statements (continued)
202 BNY

Offsetting of derivative assets and financial assets at Dec. 31, 2023
Net assets 
recognized 
in the 
balance 
sheet
Gross amounts not offset 
in the balance sheet
Gross assets 
recognized
Gross 
amounts 
offset in the 
balance 
sheet 
(in millions)
(a)
Financial 
instruments
Cash 
collateral 
received
Net 
amount
Derivatives subject to netting arrangements:
Interest rate contracts
$ 
979 $ 
751 
$ 
228 $ 
60 $ 
— $ 
168 
Foreign exchange contracts
 
8,552  
7,498 
 
1,054  
320  
—  
734 
Equity and other contracts
 
7  
7 
 
—  
—  
—  
— 
Total derivatives subject to netting arrangements
 
9,538  
8,256 
 
1,282  
380  
—  
902 
Total derivatives not subject to netting arrangements
 
993  
— 
 
993  
—  
—  
993 
Total derivatives
 
10,531  
8,256 
 
2,275  
380  
—  
1,895 
Reverse repurchase agreements
 
169,092  
150,667 (b)  
18,425  
18,422  
—  
3 
Securities borrowing
 
10,475  
— 
 
10,475  
10,011  
—  
464 
Total
$ 
190,098 $ 
158,923 
$ 
31,175 $ 
28,813 $ 
— $ 
2,362 
(a)
Includes the effect of netting agreements and net cash collateral received.  The offset related to the OTC derivatives was allocated to the 
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, 2024
Net 
liabilities 
recognized 
in the 
balance 
sheet
Gross amounts not offset 
in the balance sheet
Gross 
liabilities 
recognized
Gross 
amounts 
offset in the 
balance 
sheet 
(in millions)
(a)
Financial 
instruments
Cash 
collateral 
pledged
Net 
amount
Derivatives subject to netting arrangements:
Interest rate contracts
$ 
875 $ 
475 
$ 
400 $ 
42 $ 
— $ 
358 
Foreign exchange contracts
 
9,938  
8,533 
 
1,405  
208  
—  
1,197 
Equity and other contracts
 
34  
25 
 
9  
—  
—  
9 
Total derivatives subject to netting arrangements
 
10,847  
9,033 
 
1,814  
250  
—  
1,564 
Total derivatives not subject to netting arrangements
 
1,062  
— 
 
1,062  
—  
—  
1,062 
Total derivatives
 
11,909  
9,033 
 
2,876  
250  
—  
2,626 
Repurchase agreements
 
239,957  
228,386 (b)  
11,571  
11,556  
2  
13 
Securities lending
 
4,046  
1,553 
 
2,493  
2,277  
—  
216 
Total
$ 
255,912 $ 
238,972 
$ 
16,940 $ 
14,083 $ 
2 $ 
2,855 
(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.
Offsetting of derivative liabilities and financial liabilities at Dec. 31, 2023
Net 
liabilities 
recognized 
in the 
balance 
sheet
Gross amounts not offset 
in the balance sheet
Gross 
liabilities 
recognized
Gross 
amounts 
offset in the 
balance 
sheet 
(in millions)
(a)
Financial 
instruments
Cash 
collateral 
pledged
Net 
amount
Derivatives subject to netting arrangements:
Interest rate contracts
$ 
1,118 $ 
635 
$ 
483 $ 
78 $ 
— $ 
405 
Foreign exchange contracts
 
8,454  
6,341 
 
2,113  
93  
—  
2,020 
Equity and other contracts
 
128  
114 
 
14  
—  
—  
14 
Total derivatives subject to netting arrangements
 
9,700  
7,090 
 
2,610  
171  
—  
2,439 
Total derivatives not subject to netting arrangements
 
1,246  
— 
 
1,246  
—  
—  
1,246 
Total derivatives
 
10,946  
7,090 
 
3,856  
171  
—  
3,685 
Repurchase agreements
 
162,661  
150,667 (b)  
11,994  
11,966  
28  
— 
Securities lending
 
2,513  
— 
 
2,513  
2,404  
—  
109 
Total
$ 
176,120 $ 
157,757 
$ 
18,363 $ 
14,541 $ 
28 $ 
3,794 
(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.
Notes to Consolidated Financial Statements (continued)
BNY 203

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
Dec. 31, 2024
Dec. 31, 2023
Remaining contractual maturity
Total
Remaining contractual maturity
Total
(in millions)
Overnight 
and 
continuous
Up to 
30 days
30-90
days
Over 90 
days
Overnight 
and 
continuous
Up to 
30 days
30-90
days
Over 90 
days
Repurchase agreements:
U.S. Treasury
$ 187,227 $ 
196 $ 
739 $ 
742 $ 188,904 
$ 128,304 $ 
15 $ 1,409 $ 
510 $ 130,238 
Agency RMBS
44,774 
71 
288 
295 
45,428 
25,815 
— 
896 
120 
26,831 
Corporate bonds
84 
81 
1,341 
741 
2,247 
103 
72 
1,315 
590 
2,080 
Sovereign debt/sovereign 
guaranteed
123 
655 
17 
— 
795 
1,049 
— 
— 
— 
1,049 
State and political subdivisions
37 
14 
414 
302 
767 
37 
38 
449 
257 
781 
Other debt securities
19 
278 
287 
12 
596 
4 
180 
73 
24 
281 
U.S. government agencies
131 
— 
64 
115 
310 
44 
— 
61 
32 
137 
Equity securities
— 
4 
592 
314 
910 
— 
10 
1,172 
82 
1,264 
Total 
$ 232,395 $ 1,299 $ 3,742 $ 2,521 $ 239,957 
$ 155,356 $ 
315 $ 5,375 $ 1,615 $ 162,661 
Securities lending:
Agency RMBS
$ 
98 $ 
— $ 
— $ 
— $ 
98 
$ 
111 $ 
— $ 
— $ 
— $ 
111 
Other debt securities
253 
— 
— 
— 
253 
25 
— 
— 
— 
25 
Equity securities
3,695 
— 
— 
— 
3,695 
2,377 
— 
— 
— 
2,377 
Total 
$ 
4,046 $ 
— $ 
— $ 
— $ 4,046 
$ 
2,513 $ 
— $ 
— $ 
— $ 2,513 
Total secured borrowings
$ 236,441 $ 1,299 $ 3,742 $ 2,521 $ 244,003 
$ 157,869 $ 
315 $ 5,375 $ 1,615 $ 165,174 
BNY’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 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.
Note 24–Business segments
We have an internal information system that produces 
performance data along product and service lines for 
our three principal business segments and the Other 
segment. 
The primary products and services and types of 
revenue in each line of business and a description of 
the Other segment are presented below.  
Notes to Consolidated Financial Statements (continued)
204 BNY

Securities Services business segment
Line of business
Primary products and services
Primary types of revenue
Asset Servicing
Custody, Trust & Depositary, accounting, 
ETF services, middle-office solutions, 
transfer agency, services for private 
equity and real estate funds, foreign 
exchange, securities lending, liquidity/
lending services and data analytics
– Investment services fees
(includes securities lending
revenue)
– Net interest income
– Foreign exchange revenue
– Financing-related fees
Issuer Services
Corporate Trust (trustee, paying agency, 
fiduciary, escrow and other financial 
services) and Depositary Receipts (issuer 
services and support for brokers and 
investors)
– Investment services fees
– Net interest income
– Foreign exchange revenue
Market and Wealth Services business segment
Line of business
Primary products and services
Primary types of revenue
Pershing
Clearing and custody, investment, wealth 
and retirement solutions, technology and 
enterprise data management, trading 
services and prime brokerage
– Investment services fees
– Net interest income
Treasury Services
Integrated cash management solutions 
including payments, foreign exchange, 
liquidity management, receivables 
processing, payables management and 
trade finance
– Investment services fees
– Net interest income
– Foreign exchange revenue
Clearance and Collateral Management
Clearance (including U.S. government 
and global clearing services) and Global 
Collateral Management (including tri-
party services)
– Investment services fees
– Net interest income
Investment and Wealth Management business segment
Line of business
Primary products and services
Primary types of revenue
Investment Management
Diversified investment management 
strategies and distribution of investment 
products
– Investment management fees
– Performance fees
– Distribution and servicing fees
Wealth Management
Investment management, custody, wealth 
and estate planning, private banking 
services, investment services and 
information management
– Investment management fees
– Net interest income
Other segment
Description
Primary types of revenue
Includes leasing portfolio, corporate 
treasury activities including our  
securities portfolio, derivatives and other 
trading activity, corporate and bank-
owned life insurance, tax credit 
investments and other corporate 
investments and certain business exits
– Foreign exchange revenue
– Investment and other revenue
– Other trading revenue
– Net gain (loss) on securities
– Net interest income (expense)
Notes to Consolidated Financial Statements (continued)
BNY 205

Business accounting principles
Our business segment data has been determined on an 
internal management basis of accounting, rather than 
GAAP, which is used for consolidated financial 
reporting.  These measurement principles are 
designed so that reported results of the businesses 
will track their economic performance.
Our business segments are consistent with the 
structure used by the President and Chief Executive 
Officer, our Chief Operating Decision Maker 
(“CODM”), to make key operating decisions and 
assess performance.  Our CODM evaluates the 
business segments’ operating performance primarily 
based on fee and other revenue, total revenue, income 
before income taxes, and pre-tax operating margin.  
The significant expense information regularly 
provided to and reviewed by the CODM is total 
noninterest expense.  The CODM considers this 
information when evaluating the performance of each 
business segment and making decisions about 
allocating capital and other resources to each business 
segment.  
Business segment results are subject to 
reclassification when organizational changes are 
made, or for refinements in revenue and expense 
allocation methodologies.  Refinements are typically 
reflected on a prospective basis.  In 2024, we made 
certain realignments of similar products and services 
within our lines of business.  The largest change was 
the movement of Institutional Solutions from 
Pershing to Clearance and Collateral Management, 
both in the Market and Wealth Services business 
segment.  We made other smaller changes that moved 
activity from Asset Servicing in the Securities 
Services business segment to Treasury Services in the 
Market and Wealth Services business segment, and 
from Wealth Management in the Investment and 
Wealth Management business segment and Pershing 
in the Market and Wealth Services business segment 
to Investment Management in the Investment and 
Wealth Management business segment.  The Other 
segment was not impacted by the changes.  Business 
segment results for the fiscal years 2023 and 2022 
have been revised to reflect these changes.
The accounting policies of the businesses are the 
same as those described in Note 1.
The results of our business segments are presented 
and analyzed on an internal management reporting 
basis.
•
Revenue amounts reflect fee and other revenue
generated by each business and include revenue
for services provided between the segments that
are also provided to third parties.  Fee and other
revenue transferred between businesses under
revenue transfer agreements is included within
other fees in each segment.
•
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
the Securities Services segment.
•
Net interest income 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
segment.
•
Incentives expense related to restricted stock and
RSUs is allocated to the segments.
•
Support and other indirect expenses, including
services provided between segments that are not
provided to third parties or not subject to a
revenue transfer agreement, are allocated to
businesses based on internally developed
methodologies and reflected in noninterest
expense.
•
Recurring FDIC expense is allocated to the
businesses based on average deposits generated
within each business.
•
Severance expense is recorded in the segments
based on the business or function the impacted
employees reside, with severance expense related
to corporate staff, technology and operations
reflected in the Other segment.
•
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
Notes to Consolidated Financial Statements (continued)
206 BNY

valuation of the securities portfolio are generally 
included in the Other segment.  
•
Client deposits serve as the primary funding
source for our securities portfolio.  We typically
allocate all interest income to the businesses
generating the deposits.
•
Balance sheet assets and liabilities and their
related income or expense are specifically
assigned to each business.  Segments with a net
liability position have been allocated assets.
•
Goodwill and intangible assets are reflected
within individual businesses.
The following consolidating schedules present the contribution of our segments to our overall profitability.
For the year ended Dec. 31, 2024
Securities 
Services
Market and 
Wealth 
Services
Investment 
and Wealth 
Management
Other
Consolidated
(dollars in millions)
Total fee and other revenue
$ 
6,448 
$ 
4,535 
$ 
3,213 
(a) $
98 
$ 
14,294 
(a)
Net interest income (expense)
2,468 
1,729 
176 
(61)
4,312
Total revenue 
8,916 
6,264 
3,389 
(a)
37 
18,606 
(a)
Provision for credit losses
38 
19 
4 
9 
70 
Noninterest expense
6,314 
3,353 
2,780 
254 
12,701 
Income (loss) before income taxes
$ 
2,564 
$ 
2,892 
$ 
605 
(a) $
(226)
$ 
5,835 
(a)
Pre-tax operating margin (b)
 29% 
 46% 
 18% 
N/M
 31% 
Average assets
$ 196,740 
$ 124,448 
$ 
26,385 
$ 
65,761 
$ 413,334 
(a)
Total fee and other revenue, total revenue and income before taxes are net of income attributable to noncontrolling interests related to
consolidated investment management funds of $13 million.
(b)
Income before income taxes divided by total revenue.
N/M – Not meaningful.
For the year ended Dec. 31, 2023
Securities 
Services
Market and 
Wealth 
Services
Investment 
and Wealth 
Management
Other (a)
Consolidated (a)
(dollars in millions)
Total fee and other revenue
$ 
6,029 
$ 
4,160 
$ 
2,987 
(b) $
174 
$ 
13,350 
(b)
Net interest income (expense)
2,569 
1,710 
168 
(102)
4,345
Total revenue
8,598 
5,870 
3,155 
(b)
72 
17,695 
(b)
Provision for credit losses
99 
41 
(4)
(17)
119 
Noninterest expense
6,358 
3,205 
2,776 
956
13,295 
Income (loss) before income taxes
$ 
2,141 
$ 
2,624 
$ 
383 
(b) $
(867)
$ 
4,281 
(b)
Pre-tax operating margin (c)
 25% 
 45% 
 12% 
N/M
 24% 
Average assets
$ 197,434 
$ 131,383 
$ 
26,714 
$ 
51,211 
$ 406,742 
(a)
The prior period was restated to reflect the retrospective application of adopting new accounting guidance in 2024 related to our
investments in renewable energy projects using the proportional amortization method (ASU 2023-02).  See Note 2 for additional
information.
(b)
Total fee and other revenue, total revenue and income before taxes are net of income attributable to noncontrolling interests related to
consolidated investment management funds of $2 million.
(c)
Income before income taxes divided by total revenue.
N/M – Not meaningful.
Notes to Consolidated Financial Statements (continued)
BNY 207

For the year ended Dec. 31, 2022
Securities 
Services
Market and 
Wealth 
Services
Investment 
and Wealth 
Management
Other (a)
Consolidated (a)
(dollars in millions)
Total fee and other revenue
$ 
5,974 
$ 
3,889 
$ 
3,335 
(b) $
(160)
$ 
13,038 
(b)
Net interest income (expense)
2,028 
1,410 
228 
(162)
3,504
Total revenue (loss)
8,002 
5,299 
3,563 
(b)
(322)
16,542 
(b)
Provision for credit losses
8 
7 
1 
23 
39 
Noninterest expense
6,281 
2,936 
3,515 
278 
13,010 
Income (loss) before income taxes
$ 
1,713 
$ 
2,356 
$ 
47 
(b) $
(623)
$ 
3,493 
(b)
Pre-tax operating margin (c)
 21% 
 44% 
 1% 
N/M
 21% 
Average assets
$ 212,575 
$ 138,249 
$ 
32,057 
$ 
43,806 
$ 426,687 
(a)
The prior period was restated to reflect the retrospective application of adopting new accounting guidance in 2024 related to our
investments in renewable energy projects using the proportional amortization method (ASU 2023-02).  See Note 2 for additional
information.
(b)
Total fee and other revenue, total revenue and income before taxes are net of (loss) attributable to noncontrolling interests related to
consolidated investment management funds of $(13) million.
(c)
Income before taxes divided by total revenue.
N/M – Not meaningful.
Note 25–International operations
International activity includes investment services fee 
revenue and investment management and 
performance 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 U.S. 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
income, 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.
Notes to Consolidated Financial Statements (continued)
208 BNY

Total assets, total revenue, income before income taxes and net income of our international operations are shown in 
the table below.
International operations
International
Total
International
Total
Domestic
(in millions)
Europe, the 
Middle East 
and Africa
Asia-Pacific 
region
Other
Total
2024
Total assets at period end (a)
$ 
73,111 (b) $ 
8,665 $ 1,732 $ 
83,508 
$ 
332,556 
$ 
416,064 
Total revenue
4,272 (b)
1,272 
1,006 
6,550 
12,069 
18,619 
Income before income taxes
1,664 
710 
645 
3,019 
2,829 
5,848 
Net income
1,270 
542 
492 
2,304 
2,239 
4,543 
2023
Total assets at period end (a)
$ 
76,297 (b) $ 
9,617 $ 1,687 $ 
87,601 
$ 
322,276 (c)
$ 
409,877 (c)
Total revenue
4,112 (b)
1,281 
893 
6,286 
11,411 (c)
17,697 (c)
Income before income taxes
1,367 
707 
569 
2,643 
1,640 (c)
4,283 (c)
Net income
1,057 
547 
440 
2,044 
1,260 (c)
3,304 (c)
2022
Total assets at period end (a)
$ 
78,074 (b) $ 
11,623 $ 1,622 $ 
91,319 
$ 
314,241 (c)
$ 
405,560 (c)
Total revenue
3,954 (b)
1,127 
805 
5,886 
10,643 (c)
16,529 (c)
Income before income taxes
1,164 
572 
481 
2,217 
1,263 (c)
3,480 (c)
Net income 
880 
432 
364 
1,676 
867 (c)
2,543 (c)
(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 U.S.
(b)
Includes assets of approximately $30.3 billion, $29.1 billion and $31.7 billion and revenue of approximately $2.7 billion, $2.4 billion
and $2.2 billion in 2024, 2023 and 2022, respectively, of international operations domiciled in the UK, which is 7%, 7% and 8% of total
assets and 14%, 14% and 13% of total revenue, respectively.
(c)
Results for the years ended Dec. 31, 2023 and Dec. 31, 2022 were restated to reflect the retrospective application of adopting new
accounting guidance in 2024 related to our investments in renewable energy projects using the proportional amortization method (ASU
2023-02).  See Note 2 for additional information.
Note 26–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
Year ended Dec. 31,
(in millions)
2024
2023
2022
Transfers from loans to other assets for other real estate owned
$ 
2 
$ 
2 
$ 
1 
Change in assets of consolidated investment management funds
365 
317 
253 
Change in liabilities of consolidated investment management funds
4 
— 
2 
Change in nonredeemable noncontrolling interests of consolidated investment management funds
309 
43 
189 
Securities purchased not settled
170 
174 
22 
Securities matured not settled
— 
1,840 
385 
Available-for-sale securities transferred to held-to-maturity
3,691 
— 
6,067 
Premises and equipment/operating lease obligations
203 
251 
307 
Contingent consideration and residual interests from divestiture
— 
— 
222 
Excise tax on share repurchases
26 
28 
— 
Notes to Consolidated Financial Statements (continued)
BNY 209

KPMG LLP 
345 Park Avenue 
New York, NY 10154-0102 
KPMG LLP, a Delaware limited liability partnership and a member firm of 
the KPMG global organization of independent member firms affiliated with 
KPMG International Limited, a private English company limited by guarantee. 
Report of Independent Registered Public Accounting Firm 
To the Shareholders 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) as of December 31, 2024 and 2023, the related consolidated statements of 
income, comprehensive income, cash flows, and changes in equity for each of the years in the three-year 
period ended December 31, 2024, 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 as of December 31, 2024 and 2023, and the results of its operations and its cash flows for each of the 
years in the three-year period ended December 31, 2024, 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’s internal control over financial reporting as of December 31, 2024, 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, 2025 expressed an 
unqualified opinion on the effectiveness of BNY’s internal control over financial reporting. 
Basis for Opinion 
These consolidated financial statements are the responsibility of BNY’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 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. 
Critical Audit Matters 
The critical audit matters communicated below are matters arising from the current period audit of the 
consolidated financial statements that were communicated or required to be communicated to the audit 
committee and that: (1) relate to accounts or disclosures that are material to the consolidated financial 
statements and (2) involved our especially challenging, subjective, or complex judgments. The communication 
of critical audit matters does not alter in any way our opinion on the consolidated financial statements, taken as 
a whole, and we are not, by communicating the critical audit matters below, providing separate opinions on the 
critical audit matters or on the accounts or disclosures to which they relate. 
210 BNY

 
Quantitative component of BNY’s pooled allowance for credit losses for loans and lending-related 
commitments related to higher risk-rated and pass-rated commercial and institutional credits and loans 
secured by commercial real estate 
As discussed in Notes 1 and 5 to the consolidated financial statements, BNY’s allowance for credit losses 
for loans and lending-related commitments (ACL), is presented as a valuation allowance to loans and is 
recorded in other liabilities for lending-related commitments. At December 31, 2024, BNY had an allowance 
for loan losses of $294 million and an allowance for lending-related commitments of $72 million. BNY 
utilizes a quantitative methodology and qualitative framework for determining the ACL for loans and 
lending-related commitments that share similar risk characteristics (pooled allowance). In estimating the 
quantitative component, BNY uses models and methodologies that categorize financial assets based on 
product type, collateral type, and other credit trends and risk characteristics, including relevant information 
about past events, current conditions and reasonable and supportable forecasts of future economic 
conditions that affect the collectability of the recorded amounts. The quantitative component of the ACL for 
loans and lending-related commitments consists of the following three elements: (1) a pooled allowance for 
higher risk-rated and pass-rated commercial and institutional credits and loans secured by commercial real 
estate; (2) a pooled allowance for residential mortgage loans; and (3) an asset-specific allowance involving 
individually evaluated credits of $1 million or greater.  In estimating the quantitative component of the 
pooled allowance for higher risk-rated and pass-rated commercial and institutional credits and loans 
secured by commercial real estate, BNY uses a methodology that applies the probability of default (PD) 
and loss given default (LGD) to the estimated facility amount at default. In order to capture the unique risks 
of the portfolios within the PD and LGD models, and the model used to estimate the facility amount at 
default, BNY segments the portfolio into major components based on risk characteristics of the loans and 
how risk is monitored. For each commercial and institutional credit, the expected loss considers the credit’s 
risk rating.  For each loan secured by commercial real estate, the expected loss considers collateral 
specific data and loan maturity, as well as commercial real estate market factors by geographical region 
and property type. The methodology incorporates a multi-scenario macroeconomic forecast of economic 
input variables over a reasonable and supportable forecast period spanning the life of the asset. The 
reasonable and supportable forecast period includes both an initial estimated economic outlook component 
as well as a reversion component for each economic input variable. A portion of the ACL is comprised of 
qualitative adjustments, based on various internal and external factors, intended to capture expected 
losses not reflected in the quantitative models but are likely to impact the measurement of estimated credit 
losses. 
We identified the assessment of the quantitative component of the pooled allowance for higher risk-rated 
and pass-rated commercial and institutional credits and loans secured by commercial real estate as a 
critical audit matter. A high degree of audit effort, including specialized skills and knowledge, and subjective 
and complex auditor judgment was involved in the assessment of the pooled allowance for higher risk-rated 
and pass-rated commercial and institutional credits and loans secured by commercial real estate due to 
significant measurement uncertainty. Specifically, the assessment encompassed the evaluation of the 
methodology, including the methods and models used to estimate the PD and LGD, the macroeconomic 
forecast scenarios and weighting of each scenario used in the reasonable and supportable forecast, and 
credit risk ratings for commercial and institutional credits. The assessment also included an evaluation of 
the conceptual soundness and performance of the PD and LGD models as well as the macroeconomic 
forecast assumptions. In addition, auditor judgment was required to evaluate the sufficiency of audit 
evidence obtained. 
BNY 211

 
The following are the primary procedures we performed to address this critical audit matter. We evaluated 
the design and tested the operating effectiveness of certain internal controls related to BNY’s measurement 
of the quantitative component of the pooled allowance for higher risk-rated and pass-rated commercial and 
institutional credits and loans secured by commercial real estate, including controls related to the: 
●
development and approval of the ACL methodology
●
development of certain PD and LGD models
●
continued use and appropriateness of certain PD and LGD models and macroeconomic forecasts
●
performance monitoring of the PD and LGD models and macroeconomic forecast methodology
●
determination and measurement of the significant factors and assumptions used in the PD and LGD
models and macroeconomic forecasts
●
determination of the multi-scenario macroeconomic forecasts and their respective weights
●
assessment of credit risk ratings
●
computation, analysis, and approval of the ACL results, trends, and ratios.
We evaluated BNY’s process to develop the quantitative component of the pooled allowance for higher 
risk-rated and pass-rated commercial and institutional credits and loans secured by commercial real estate 
by testing certain sources of data, factors, and assumptions that BNY used, and considered the relevance 
and reliability of such data, factors, and assumptions. In addition, we involved credit risk professionals with 
specialized skills and knowledge, who assisted in: 
●
evaluating the quantitative component of BNY’s pooled allowance for higher risk-rated and pass-rated
commercial and institutional credits and loans secured by commercial real estate for compliance with
U.S. generally accepted accounting principles
●
evaluating judgments made by BNY relative to the development and performance monitoring of the PD
and LGD models and macroeconomic forecasts by comparing them to relevant company-specific
metrics and trends and the applicable industry and regulatory practices
●
assessing the conceptual soundness and performance testing of the PD and LGD models and
macroeconomic forecast methodology by inspecting the model documentation to determine whether
they are suitable for their intended use
●
testing the reasonable and supportable forecast period to evaluate the length of the period by
comparing to specific portfolio risk characteristics and trends
●
testing individual loan risk ratings for a selection of higher risk-rated and pass-rated commercial and
institutional credits by evaluating the financial performance of the borrower, sources of repayment, and
any relevant guarantees or underlying collateral.
We also assessed the sufficiency of the audit evidence obtained related to the quantitative component of 
the pooled allowance for higher risk-rated and pass-rated commercial and institutional credits and loans 
secured by commercial real estate by evaluating the: 
●
Cumulative results of the audit procedures
212 BNY

 
●
Qualitative aspects of BNY’s accounting practices
●
Potential bias in the accounting estimate.
Identification and measurement of accruals for litigation and regulatory contingencies 
As discussed in Note 22 to the consolidated financial statements, BNY establishes accruals for litigation 
and regulatory matters when those matters present loss contingencies that are both probable and 
reasonably estimable. BNY has disclosed that for those matters described where BNY is able to estimate 
reasonably possible losses, the aggregate range of such reasonably possible losses at December 31, 
2024, is up to $690 million in excess of the accrued liability (if any) related to those matters. 
We identified the assessment of the identification and measurement of BNY’s accruals for litigation and 
regulatory contingencies as a critical audit matter. Due to the measurement uncertainty, subjective and 
complex auditor judgment was required to evaluate the sufficiency of audit evidence obtained. Specifically, 
this assessment included the evaluation of the subjective estimates used to determine the range of 
possible exposure and the probability of the predicted outcome based on the particular facts and 
circumstances at issue in each of the matters. 
The following are the primary procedures we performed to address this critical audit matter. We evaluated 
the design and tested the operating effectiveness of certain internal controls related to BNY’s process to 
identify, evaluate and measure accruals for litigation and regulatory contingencies and the reasonably 
possible losses. We performed inquiries of BNY to gain an understanding of any asserted or unasserted 
litigation, claims and assessments, and significant changes in individual accruals for litigation and 
regulatory contingencies. We performed inquiries of BNY’s regulators and examined regulatory reports to 
gain an understanding of developments of regulatory activity and related matters that may result in the 
assessment of regulatory fines or penalties. We obtained and read letters received directly from BNY’s 
internal legal counsel and a selection of external legal counsel that identified and described BNY’s potential 
exposure to certain legal or regulatory proceedings. For cases that have settled, we performed back-testing 
analyses of BNY’s litigation and regulatory contingency accruals recorded compared to amounts paid. We 
assessed the accrual for litigation and regulatory contingencies and evaluated the cumulative results of the 
procedures performed to assess the sufficiency of audit evidence obtained. We also evaluated the 
information included within the disclosures. 
Valuation of goodwill for the Investment Management reporting unit 
As discussed in Notes 1 and 7 to the consolidated financial statements, the goodwill balance as of 
December 31, 2024, was $16.6 billion, of which $6.0 billion is allocated to the Investment Management 
reporting unit. BNY performs goodwill impairment testing on an annual basis and an interim test is 
performed when events or circumstances occur that may indicate that it is more likely than not that the fair 
value of any reporting unit may be less than its carrying value. This involves estimating the fair value of the 
reporting units using an income approach which discounts estimated future cash flows that incorporate 
various assumptions including a long-term growth rate. 
We identified the assessment of the valuation of goodwill for the Investment Management reporting unit as 
a critical audit matter. A high degree of audit effort, including specialized skills and knowledge, and 
subjective and complex auditor judgment was involved in the evaluation of goodwill and determination of 
fair value for the Investment Management reporting unit due to significant measurement uncertainty relating 
to specific assumptions used in the valuation. Specifically, these assumptions included the discount rate 
and the long-term growth rate. 
BNY 213

 
The following are the primary procedures we performed to address this critical audit matter. We evaluated 
the design and tested the operating effectiveness of certain internal controls related to BNY’s determination 
of the discount rate and long-term growth rate assumptions for the Investment Management reporting unit. 
We evaluated the reasonableness of BNY’s long-term growth rate for the Investment Management 
reporting unit, by comparing BNY’s growth rates within historical revenue forecasts to actual results to 
assess BNY’s ability to accurately forecast. In addition, we involved valuation professionals with specialized 
skills and knowledge, who assisted in: 
●
Assessing the reasonableness of the valuation approach including the discount rate and long-term
growth rate assumptions used by BNY to calculate the fair value of the Investment Management
reporting unit for compliance with U.S. generally accepted accounting principles
●
Evaluating the discount rate by developing an independent range for the discount rate used in the
valuation and comparing the inputs to the discount rate to publicly available data and assessing the
resulting discount rate
●
Testing the long-term growth rate by developing an independent assumption of the long-term growth
rate and comparing the long-term growth rate to publicly available data
We have served as BNY’s auditor since 2007. 
New York, New York 
February 27, 2025 
214 BNY

Effective February 27, 2025
Directors
Linda Z. Cook
Jeffrey A. Goldstein
Elizabeth E. Robinson
Chief Executive Officer and Board member, 
Senior Advisor and member of the Investment 
Retired Global Treasurer, The Goldman Sachs 
Harbour Energy plc, a global independent oil and
Committee, Canapi Ventures, a venture capital
Group, Inc., a global financial services company
gas company
fund; and Advisor Emeritus, Hellman & 
Friedman LLC, a private equity firm
Rakefet Russak-Aminoach
Joseph J. Echevarria
Managing Partner, Team8, a venture group
Chair, The Bank of New York Mellon 
K. Guru Gowrappan
Corporation
Former President, Viasat, Inc., a global satellite
Robin Vince
Retired Chief Executive Officer, Deloitte LLP,
communications company
President and Chief Executive Officer,
a global provider of professional services
The Bank of New York Mellon Corporation
Ralph Izzo
M. Amy Gilliland
Retired Chairman, President and Chief Executive 
Alfred W. (Al) Zollar
President, General Dynamics Information 
Officer, Public Service Enterprise Group 
Retired Executive Partner, Siris Capital
Technology, a global technology and professional 
Incorporated, a diversified energy holding 
Group, LLC, a private equity firm
services company that is a business unit of 
company
General Dynamics Corporation
Sandra E. (Sandie) O’Connor
Retired Chief Regulatory Affairs Officer, 
JPMorgan Chase, a financial holding company
Executive Committee and Other Executive Officers
Jennifer Barker
Senthil Kumar *
Brian Ruane
Global Head of Treasury Services and
Chief Risk Officer
Global Head of Clearance and Collateral 
Depositary Receipts
Management, Credit Services and Corporate Trust
Kurtis R. Kurimsky *
James T. Crowley
Corporate Controller
Leigh-Ann Russell
Global Head of BNY Pershing
Chief Information Officer and Global Head of 
J. Kevin McCarthy *
Engineering
Rajashree Datta
General Counsel
Deputy Chief Risk Officer
Akash Shah
Dermot McDonogh *
Chief Growth Officer and Global Head of 
Shannon Hobbs *
Chief Financial Officer
Growth Ventures
Chief People Officer
Jose Minaya *
Robin Vince *
Hani Kablawi 
Global Head of BNY Investments and Wealth
President and Chief Executive Officer
Head of International
Alejandro Perez
Adam Vos
Catherine M. Keating *
Chief Administrative Officer 
Global Head of Markets
Global Head of BNY Wealth
Joseph Pizzuto
Cathinka Wahlstrom
Jayee Koffey *
Chief Auditor
Chief Commercial Officer
Global Head of Enterprise Execution and Chief 
Corporate Affairs Officer
Emily Portney
Carolyn Weinberg
Global Head of Asset Servicing
Chief Solutions Innovation Officer
*
Designated as an Executive Officer.
Directors, Executive Committee and Other Executive Officers
BNY 215

Cumulative Total Shareholder Return (5 Years)
The Bank of New York Mellon Corporation
S&P 500 Financials Index
S&P 500 Index
2019
2020
2021
2022
2023
2024
$0
$50
$100
$150
$200
$250
Cumulative shareholder returns
Dec. 31,
(in dollars)
2019
2020
2021
2022
2023
2024
The Bank of New York Mellon Corporation
$ 
100.0 
$ 
87.1 
$ 
122.4 
$ 
98.9 
$ 
117.2 
$ 
178.0 
S&P 500 Financials Index (a)
100.0 
98.3 
132.8 
118.8 
133.2 
173.9 
S&P 500 Index (a)
100.0 
118.4 
152.4 
124.8 
157.6 
197.0 
(a)
Returns are weighted by market capitalization at the beginning of the measurement period.
This graph shows The Bank of New York Mellon Corporation’s cumulative total shareholder returns over the five-
year period from Dec. 31, 2019 to Dec. 31, 2024.  We 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 and the S&P 500 Index.  The comparison assumes a $100 investment on Dec. 31, 2019 in The 
Bank of New York Mellon Corporation common stock, in the S&P 500 Financials Index and in the S&P 500 Index 
and assumes that all dividends were reinvested.
Performance Graph
216 BNY

CORPORATE HEADQUARTERS 
240 Greenwich Street, New York, NY 10286 
+ 1 212 495 1784 
www.bny.com 
ANNUAL MEETING 
On behalf of our Board of Directors, we cordially invite you to our 
2025 Annual Meeting of Stockholders on Tuesday, April 15, 2025, 
at 9:00 a.m., Eastern Time, which you can attend virtually at 
www.virtualshareholdermeeting.com/BK2025.
EXCHANGE LISTING 
BNY’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 
(symbol BK/P), fully and unconditionally guaranteed by BNY, 
is also listed on the New York Stock Exchange. 
STOCK PRICES 
Prices for BNY’s common stock can be viewed at 
www.bny.com/corporate/global/en/investor-relations/overview.html. 
CORPORATE GOVERNANCE 
Corporate governance information is available at www.bny.com/
corporate/global/en/investor-relations/corporate-governance.html. 
SUSTAINABILITY 
Information about BNY’s approach to sustainability is available at 
www.bny.com/corporate/global/en/about-us/sustainability-report-
strategy.html. 
INVESTOR RELATIONS 
Visit www.bny.com/corporate/global/en/investor-relations/
overview.html.
COMMON STOCK DIVIDEND PAYMENTS 
Subject to approval of the Board of Directors, dividends are 
paid on BNY’s common stock quarterly in February, May, August 
and November. 
FORM 10-K AND SHAREHOLDER PUBLICATIONS 
For a free copy of BNY’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@bny.com, or by mail to Investor Relations at 
The Bank of New York Mellon Corporation, 240 Greenwich Street, 
New York, NY 10286. The 2024 Annual Report, as well as 
Forms 10-K, 10-Q and 8-K and quarterly earnings and other 
news releases can be viewed and printed at www.bny.com/corporate/
global/en/investor-relations/overview.html.
TRANSFER AGENT AND REGISTRAR  
Computershare
P.O. Box 43006
Providence, RI 02940-3006
www.computershare.com/investor
SHAREHOLDER SERVICES
Computershare 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 Computershare, visit
www.computershare.com/investor or call +1 800 205 7699.
DIRECT STOCK PURCHASE AND DIVIDEND REINVESTMENT PLAN
The Direct Stock Purchase and Dividend Reinvestment Plan (the “Plan”)
provides a way to purchase shares of common stock directly from 
BNY at the current market value. New shareholders may purchase their 
first shares of BNY’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 at www.computershare.com/investor, or obtained 
in printed form by calling +1 800 205 7699.
ELECTRONIC DEPOSIT OF DIVIDENDS
Registered shareholders may have quarterly dividends paid on 
BNY’s common stock deposited electronically to their checking or 
savings accounts. To have dividends deposited electronically, go 
to www.computershare.com/investor to set up your account(s) for 
direct deposit. If you prefer, you may also send a request by mail to 
Computershare, P.O. Box 43006, Providence, RI 02940-3006. 
For more information, call +1 800 205 7699.
SHAREHOLDER ACCOUNT ACCESS

BY INTERNET
www.computershare.com/investor
Shareholders can register to receive shareholder information 
electronically. To enroll, visit www.computershare.com/investor.
BY PHONE
Toll-free in the U.S. +1 800 205 7699
Outside the U.S. +1 617 360 6990
BY MAIL
Computershare
P.O. Box 43006
Providence, RI 02940-3006
The contents of the listed Internet sites are not incorporated 
in this Annual Report.
CORPORATE INFORMATION
BNY is a global financial services company that helps make money work for the world — managing it, moving it and keeping it safe. 
For more than 240 years BNY has partnered alongside clients, putting its expertise and platforms to work to help them achieve their 
ambitions. Today BNY helps over 90% of Fortune 100 companies and nearly all the top 100 banks globally to access the money they need. 
BNY supports governments in funding local projects and works with over 90% of the top 100 pension plans to safeguard investments 
for millions of individuals, and so much more. As of December 31, 2024, BNY oversees $52.1 trillion in assets under custody and/or 
administration and $2.0 trillion in assets under management.
BNY is the corporate brand of The Bank of New York Mellon Corporation (NYSE: BK). Headquartered in New York City, 
BNY employs over 50,000 people globally and has been named among Fortune’s World’s Most Admired Companies and 
Fast Company’s Best Workplaces for Innovators. Additional information is available on www.bny.com. Follow on LinkedIn 
or visit the BNY Newsroom for the latest company news.

THE BANK OF NEW YORK MELLON CORPORATION
240 GREENWICH STREET
NEW YORK, NY 10286
UNITED STATES
+1 212 495 1784
BNY.COM