2025 Shared National Credit Program Report

Shared National Credit (SNC) Program Attachment Document - 2025 SNC Program Charts 1st and 3rd Quarter 2025 Reviews Board of Governors of the Federal Reserve System Federal Deposit Insurance Corporation Office of the Comptroller of the Currency Washington, D.C. January 12, 2026

• 1 - Table of Contents Changes to the Shared National Credit Annual Report Attachment................................. 2 2025 SNC Review Exhibits and Appendices.................................................................... 2 Exhibit 1: Overall Credit Facilities and Commitment Trends.............................................. 2 Exhibit 2: SNC Summary Statistics............................................................................... 2 Exhibit 3: Overall Special Mention Plus Classified Volume and Percentage Trends............ 3 Exhibit 4: SNC Leveraged Lending Exposure and Non-Pass Trends........................... 3 Exhibit 5: Agent Bank Identified Leveraged Lending by Ownership, Credit Type and Quality............................................................................................................... 4 Exhibit 6: Distribution of SNC Commitments by Lender Type....................................... 4 Exhibit 7: Distribution of SNC Special Mention and Classified Commitments by Lender Type............................................................................................................. 4 Appendix A: Definitions .................................................................................................... 6 Appendix B: Committed and Outstanding Balances......................................................... 7 Appendix C: Summary of SNC Industry Trends ............................................................... 8 Appendix D: Exposures by Entity Type .......................................................................... 11

• 2 - Changes to the Shared National Credit Annual Report Attachment To streamline the presentation of the annual SNC Press Release and SNC Program document, the agencies have modified the format of this SNC Program document. This attachment will no longer include qualitative text but concentrates on presenting the quantitative data supporting the high-level commentary in the annual SNC Press Release. In addition, Appendix C has been modified to include a more granular industry breakdown of twenty-one sub-sectors from the prior seven sector grouping. 2025 SNC Review Exhibits Exhibit 1 details the trend of credit facility numbers and volume of unfunded and outstanding commitments for the past twenty years. Exhibit 1: Overall Credit Facilities and Commitment Trends Note: The decline in the number of SNC credit facilities between 2017 and 2018 mainly reflects the minimum commitment increase from $20 million to $100 million. Exhibit 2 details the year-over-year changes in aggregate SNC commitment and outstanding amounts, total number of borrowers and facilities, and non-pass commitment and nonaccrual amounts.

• 3 - Exhibit 2: SNC Summary Statistics Exhibit 3 shows trends in the dollar volume of special mention plus classified commitments as a percentage of total commitments. Exhibit 3: Overall Special Mention Plus Classified Volume and Percentage Trends Exhibit 4 details the volume and changes in leverage lending commitments, special mention, classified, and total non-pass year-over-year for leveraged lending loans. SNC Total Commitments $6,521.9 $6,911.4 $389.5 6.0% SNC Total Outstanding $3,151.4 $3,362.4 $211.0 6.7% SNC Total Borrowers (#) 6,699 6,857 158 2.4% SNC Total Facilities (#) 11,188 11,952 764 6.8% SM and Classified Commitments $595.8 $592.9 ($2.9) -0.5% SM Commitments $161.8 $155.3 ($6.5) -4.0% Classified Commitments $434.0 $437.5 $3.5 0.8% Nonaccrual Commitments $65.1 $84.9 $19.8 30.4% Note: Figures may not add to totals due to rounding. 2025 vs. 2024 (%) 2025 vs. 2024 ($Billions) 2025 Commitments ($Billions) 2024 Commitments ($Billions)

• 4 - Exhibit 5 provides a breakdown of the ownership of investment grade and non-investment grade leveraged lending credit facilities for the two main credit types, which are revolvers and term loans. In this document, the terms “investment grade” and "non-investment grade" are based on bank￾provided facility-level equivalent ratings. Exhibit 5: Agent Bank Identified Leveraged Lending by Ownership, Credit Type and Quality Exhibit 6 details the breakout of ownership of total commitments year-over-year by dollar and percent of U.S. Banks, Foreign Banking Organizations (FBOs) and Other Investors. Exhibit 6: Distribution of SNC Commitments by Lender Type Exhibit 7 provides a breakdown of total commitments and total non-pass loans held by U.S. Banks, Foreign Banking Organizations (FBOs) and Other Investors, and the percent of non-pass loans to their total commitment held and the percent held of total non-pass loans. Exhibit 4: SNC Leveraged Lending Exposure and Non-Pass Trends Leveraged Lending Commitments $2,963.5 $3,077.1 $113.6 SM Leveraged Lending Commitments $158.3 $104.4 ($53.9) Classified Leveraged Lending Commitments $342.7 $373.0 $30.3 SM and Classified Leveraged Lending Commitments $501.0 $477.4 ($23.6) Note: Figures may not add to totals due to rounding. 2025 vs. 2024 ($Billions) 2025 SNC Review ($Billions) 2024 SNC Review ($Billions) 2025 SNC 2025 SNC Bank Owned ($Billions) Other Investor ($Billions) Investment Grade - Revolver $819.9 $17.8 Investment Grade - Term Loan $141.1 $48.3 Non-Investment Grade - Revolver $633.0 $32.1 Non-Investment Grade - Term Loan $259.0 $1,093.7 Total $1,853.0 $1,191.9 Note: Figures may not add to totals due to rounding. Agent Bank-Identified Leveraged Lending U.S. Banks $2,986.9 $3,081.0 45.8% 44.6% FBOs $2,209.8 $2,344.7 33.9% 33.9% Other Investors $1,325.1 $1,485.7 20.3% 21.5% Total $6,521.9 $6,911.4 100.0% 100.0% Note: Figures may not add to totals due to rounding. Lender Type 2024 Commitments ($Billions) 2025 Commitments ($Billions) 2025 Commitments % 2024 Commitments %

• 5 - Exhibit 7: Distribution of SNC Special Mention and Classified Commitments by Lender Type Details on supervisory definitions, outstanding balances, industry trends, and exposure by entity type can be found in the appendices of this document. U.S. Banks $3,081.0 $129.7 4.2% 21.9% FBOs $2,344.7 $103.3 4.4% 17.4% Other Investors $1,485.7 $359.9 24.2% 60.7% Total $6,911.4 $592.9 8.6% 100.0% Note: Figures may not add to totals due to rounding. Lender Type 2025 Special Mention and Classified ($Billions by Owner) 2025 Special Mention and Classified (% by Owner) 2025 Special Mention and Classified (% of total Committed by Owner) 2025 Total Commitments ($Billions by Owner)

• 6 - Appendix A: Definitions Agent Bank: Agent Bank is defined as a federally supervised institution that originates or administers a SNC for the syndication or participating lenders. Classified Commitments: Classified commitments include commitments rated substandard, doubtful, and loss as defined below. Doubtful: Doubtful commitments have all the weaknesses of commitments classified substandard with the added characteristic that the weaknesses make collection or liquidation in full, on the basis of available current information, highly questionable and improbable. Loss: Commitments classified as loss are uncollectible and of so little value that their continuance as bankable commitments is not warranted. Amounts classified as loss should be promptly charged off. This classification does not mean that there is no recovery or salvage value, but rather that it is not practical or desirable to defer writing off these commitments, even though some value may be recovered in the future. Nonaccrual: Nonaccrual loans are defined for regulatory reporting purposes as loans and lease financing receivables that are required to be reported on a nonaccrual basis because (a) they are maintained on a cash basis owing to a deterioration in the financial position of the borrower, (b) payment in full of interest or principal is not expected, or (c) principal or interest has been in default for 90 days or longer, unless the obligation is both well secured and in the process of collection. Non-pass: A non-pass loan is any loan rated special mention, substandard, doubtful, or loss. Pass: A loan that is in good standing and is not rated special mention or classified. Shared National Credit (SNC): A SNC is any loan or formal commitment, and any asset such as real estate, stocks, notes, bonds, and debentures taken as debts previously contracted, extended to borrowers by a federally supervised institution, its subsidiaries, and affiliates, that aggregates to $100 million or more and is shared by three or more unaffiliated federally supervised institutions, or a portion of which is sold to two or more such institutions. Special Mention (SM): Special mention commitments have potential weaknesses that deserve management's close attention. If left uncorrected, these potential weaknesses could result in further deterioration of the repayment prospects or in the institution's credit position in the future. Special mention commitments are not adversely classified and do not expose institutions to sufficient risk to warrant adverse rating. Substandard: Substandard commitments are inadequately protected by the current sound worth and paying capacity of the obligor or of the collateral pledged, if any. Substandard commitments have well-defined weaknesses that jeopardize the liquidation of the debt and present the distinct possibility that the institution will sustain some loss if deficiencies are not corrected.

• 7 - Appendix B: Committed and Outstanding Balances Year Special Mention Substandard Doubtful Loss Total Classified Total SM + Classified Total Committed Total Outstanding 1989 $24.0 $18.5 $3.5 $0.9 $22.9 $46.9 $692 $245 1990 $43.1 $50.8 $5.8 $1.8 $58.4 $101.5 $769 $321 1991 $49.2 $65.5 $10.8 $3.5 $79.8 $129.0 $806 $361 1992 $50.4 $56.4 $12.8 $3.3 $72.5 $122.9 $798 $357 1993 $31.7 $50.4 $6.7 $3.5 $60.6 $92.3 $806 $332 1994 $31.4 $31.1 $2.7 $2.3 $36.1 $67.5 $893 $298 1995 $18.8 $25.0 $1.7 $1.5 $28.2 $47.0 $1,063 $343 1996 $16.8 $23.1 $2.6 $1.4 $27.1 $43.9 $1,200 $372 1997 $19.6 $19.4 $1.9 $0.9 $22.2 $41.8 $1,435 $423 1998 $22.7 $17.6 $3.5 $0.9 $22.0 $44.7 $1,759 $562 1999 $30.8 $31.0 $4.9 $1.5 $37.4 $68.2 $1,829 $628 2000 $36.0 $47.9 $10.7 $4.7 $63.3 $99.3 $1,951 $705 2001 $75.4 $87.0 $22.5 $8.0 $117.5 $192.8 $2,049 $769 2002 $79.0 $112.0 $26.1 $19.1 $157.1 $236.1 $1,871 $692 2003 $55.2 $112.1 $29.3 $10.7 $152.2 $207.4 $1,644 $600 2004 $32.8 $55.1 $12.5 $6.4 $74.0 $106.8 $1,545 $500 2005 $25.9 $44.2 $5.6 $2.7 $52.5 $78.3 $1,627 $522 2006 $33.4 $58.1 $2.5 $1.2 $61.8 $95.2 $1,874 $626 2007 $42.5 $69.6 $1.2 $0.8 $71.6 $114.1 $2,275 $835 2008 $210.4 $154.9 $5.5 $2.6 $163.1 $373.4 $2,789 $1,208 2009 $195.3 $337.1 $56.4 $53.3 $446.8 $642.1 $2,881 $1,563 2010 $142.7 $256.4 $32.6 $15.4 $304.5 $447.2 $2,519 $1,210 2011 $106.4 $190.7 $14.0 $9.9 $214.6 $321.0 $2,524 $1,118 2012 $99.3 $161.7 $29.5 $4.6 $195.8 $295.1 $2,792 $1,243 2013 $115.0 $164.5 $14.5 $8.0 $187.0 $302.0 $3,011 $1,362 2014 $149.2 $171.0 $11.8 $7.8 $191.3 $340.6 $3,389 $1,568 2015 $144.2 $203.2 $20.6 $4.6 $228.4 $372.6 $3,909 $1,867 2016 $136.4 $250.7 $25.7 $8.6 $285.1 $421.4 $4,102 $1,986 2017 $131.7 $245.1 $24.2 $16.6 $285.9 $417.6 $4,304 $2,149 2018 $112.4 $173.9 $5.1 $3.4 $182.5 $294.9 $4,435 $2,106 2019 $131.2 $186.3 $10.3 $7.5 $204.1 $335.4 $4,830 $2,359 2020 $263.9 $314.8 $30.4 $20.6 $365.9 $629.8 $5,072 $2,620 2021 $217.3 $299.1 $18.8 $15.0 $332.8 $550.2 $5,179 $2,400 2022 $122.3 $268.8 $17.8 $4.7 $291.3 $413.6 $5,897 $2,931 2023 $176.6 $364.5 $25.8 $5.3 $395.6 $572.2 $6,409 $3,145 2024 $161.8 $407.8 $20.9 $5.2 $434.0 $595.8 $6,522 $3,151 2025 $155.3 $401.0 $21.6 $14.8 $437.5 $592.9 $6,911 $3,362 Note: Figures may not add to totals due to rounding. Committed and Outstanding Balances ($Billions)

• 8 - Appendix C: Summary of SNC Industry Trends Industry 2021 2022 2023 2024 2025 Consumer Services Commitment ($Billions) $23.1 $29.3 $36.3 $35.3 $39.1 Special Mention ($Billions) $1.7 $2.1 $0.8 $1.4 $1.1 Classified ($Billions) $1.0 $2.6 $9.1 $8.9 $9.2 % Special Mention 7.4% 7.2% 2.2% 4.0% 2.8% % Classified 4.3% 8.9% 25.1% 25.2% 23.5% Technology, Telecom, and Media Commitment ($Billions) $817.2 $956.1 $1,044.8 $1,026.1 $1,113.8 Special Mention ($Billions) $47.1 $40.3 $48.8 $34.2 $31.8 Classified ($Billions) $73.5 $77.6 $152.9 $168.3 $175.8 % Special Mention 5.8% 4.2% 4.7% 3.3% 2.9% % Classified 9.0% 8.1% 14.6% 16.4% 15.8% Commercial Servcies Commitment ($Billions) $232.1 $254.2 $283.5 $297.3 $339.8 Special Mention ($Billions) $7.2 $3.6 $18.4 $7.7 $1.8 Classified ($Billions) $24.3 $21.7 $21.5 $43.9 $48.3 % Special Mention 3.1% 1.4% 6.5% 2.6% 0.5% % Classified 10.5% 8.5% 7.6% 14.8% 14.2% Materials & Commodities Excluding Oil & Gas Commitment ($Billions) $344.3 $395.3 $423.0 $426.0 $439.8 Special Mention ($Billions) $11.3 $9.4 $15.4 $24.2 $24.3 Classified ($Billions) $18.8 $12.7 $19.3 $28.5 $38.8 % Special Mention 3.3% 2.4% 3.6% 5.7% 5.5% % Classified 5.5% 3.2% 4.6% 6.7% 8.8% Entertainment & Recreation Commitment ($Billions) $133.7 $160.3 $163.2 $164.1 $183.2 Special Mention ($Billions) $13.8 $7.7 $5.5 $3.3 $8.6 Classified ($Billions) $31.5 $27.2 $24.2 $20.2 $14.7 % Special Mention 10.3% 4.8% 3.4% 2.0% 4.7% % Classified 23.6% 17.0% 14.8% 12.3% 8.0% Apparel & Textiles Manufacturing Commitment ($Billions) $31.5 $43.5 $45.0 $44.7 $41.8 Special Mention ($Billions) $1.1 $0.2 $3.0 $3.7 $2.7 Classified ($Billions) $2.5 $0.0 $2.5 $1.4 $2.4 % Special Mention 3.5% 0.5% 6.7% 8.3% 6.5% % Classified 7.9% 0.0% 5.6% 3.1% 5.7% Healthcare & Pharmaceuticals Commitment ($Billions) $319.4 $349.7 $367.3 $349.2 $350.6 Special Mention ($Billions) $11.6 $3.2 $16.1 $9.9 $2.5 Classified ($Billions) $20.4 $25.6 $36.9 $40.3 $34.5 % Special Mention 3.6% 0.9% 4.4% 2.8% 0.7% % Classified 6.4% 7.3% 10.0% 11.5% 9.8% Food & Beverage Manufacturing & Wholesale Commitment ($Billions) $155.5 $199.3 $226.8 $230.0 $241.9 Special Mention ($Billions) $0.4 $1.6 $12.6 $7.7 $7.5 Classified ($Billions) $2.8 $4.3 $4.9 $18.4 $13.3 % Special Mention 0.3% 0.8% 5.6% 3.3% 3.1% % Classified 1.8% 2.2% 2.2% 8.0% 5.5%

• 9 - Industry 2021 2022 2023 2024 2025 Equipment, Machinery, Parts Manufacturing Excluding Auto Commitment ($Billions) $323.4 $342.0 $364.0 $362.5 $395.6 Special Mention ($Billions) $31.6 $19.1 $16.9 $15.1 $17.5 Classified ($Billions) $16.4 $17.2 $17.5 $12.0 $15.8 % Special Mention 9.8% 5.6% 4.6% 4.2% 4.4% % Classified 5.1% 5.0% 4.8% 3.3% 4.0% Real Estate & Construction Commitment ($Billions) $390.4 $426.0 $564.7 $560.1 $566.1 Special Mention ($Billions) $30.7 $5.9 $10.3 $17.5 $13.5 Classified ($Billions) $23.9 $17.6 $21.7 $28.2 $32.5 % Special Mention 7.9% 1.4% 1.8% 3.1% 2.4% % Classified 6.1% 4.1% 3.8% 5.0% 5.7% Trasportation Services Commitment ($Billions) $114.8 $119.4 $132.4 $133.9 $144.0 Special Mention ($Billions) $1.8 $2.0 $1.4 $5.3 $6.2 Classified ($Billions) $34.7 $42.4 $27.9 $3.7 $5.1 % Special Mention 1.6% 1.7% 1.1% 4.0% 4.3% % Classified 30.2% 35.5% 21.1% 2.8% 3.5% Agribusiness Commitment ($Billions) $37.8 $43.3 $43.3 $45.5 $40.2 Special Mention ($Billions) $0.0 $1.4 $0.4 $1.0 $0.5 Classified ($Billions) $1.0 $0.4 $0.3 $1.4 $2.2 % Special Mention 0.0% 3.2% 0.9% 2.2% 1.2% % Classified 2.6% 0.9% 0.7% 3.1% 5.5% Diversified Miscellaneous Commitment ($Billions) $136.5 $114.7 $122.6 $140.5 $53.5 Special Mention ($Billions) $1.2 $0.6 $0.3 $0.0 $2.0 Classified ($Billions) $5.0 $1.3 $2.0 $1.4 $1.4 % Special Mention 0.9% 0.5% 0.2% 0.0% 3.7% % Classified 3.7% 1.1% 1.6% 1.0% 2.6% Retail Commitment ($Billions) $238.1 $292.9 $346.8 $334.0 $349.3 Special Mention ($Billions) $8.7 $1.2 $5.0 $5.2 $4.9 Classified ($Billions) $15.0 $12.4 $20.7 $24.7 $17.2 % Special Mention 3.7% 0.4% 1.4% 1.6% 1.4% % Classified 6.3% 4.2% 6.0% 7.4% 4.9% Auto-Related Commitment ($Billions) $156.3 $196.0 $213.3 $220.4 $252.3 Special Mention ($Billions) $4.3 $1.8 $2.4 $0.1 $4.5 Classified ($Billions) $5.5 $4.7 $8.9 $10.4 $8.4 % Special Mention 2.8% 0.9% 1.1% 0.0% 1.8% % Classified 3.5% 2.4% 4.2% 4.7% 3.3% Utilities Commitment ($Billions) $298.2 $324.6 $378.6 $412.3 $475.5 Special Mention ($Billions) $3.3 $3.6 $3.0 $6.3 $12.1 Classified ($Billions) $15.8 $7.3 $9.3 $8.6 $10.2 % Special Mention 1.1% 1.1% 0.8% 1.5% 2.5% % Classified 5.3% 2.2% 2.5% 2.1% 2.1% Appendix C: Summary of SNC Industry Trends (Cont.)

• 10 - Industry 2021 2022 2023 2024 2025 Financials Excluding Banks Commitment ($Billions) $940.2 $1,139.9 $1,119.3 $1,214.8 $1,321.1 Special Mention ($Billions) $24.7 $12.7 $5.4 $15.6 $13.1 Classified ($Billions) $17.1 $8.2 $8.3 $7.9 $3.2 % Special Mention 2.6% 1.1% 0.5% 1.3% 1.0% % Classified 1.8% 0.7% 0.7% 0.7% 0.2% Oil & Gas & Pipeline Commitment ($Billions) $339.6 $327.5 $336.4 $318.2 $307.8 Special Mention ($Billions) $15.6 $5.5 $10.5 $3.3 $1.0 Classified ($Billions) $21.8 $7.4 $5.5 $3.7 $2.2 % Special Mention 4.6% 1.7% 3.1% 1.0% 0.3% % Classified 6.4% 2.3% 1.6% 1.2% 0.7% Insurance & Fiducuaries Commitment ($Billions) $121.6 $167.8 $180.6 $191.2 $240.6 Special Mention ($Billions) $1.2 $0.2 $0.4 $0.1 $0.0 Classified ($Billions) $0.6 $0.7 $2.2 $1.8 $2.3 % Special Mention 1.0% 0.1% 0.2% 0.1% 0.0% % Classified 0.5% 0.4% 1.2% 0.9% 1.0% Banks Commitment ($Billions) $5.6 $4.2 $5.3 $5.1 $5.0 Special Mention ($Billions) $0.0 $0.2 $0.0 Classified ($Billions) $0.0 % Special Mention 0.0% 4.8% 0.0% 0.0% 0.0% % Classified 0.0% 0.0% 0.0% 0.0% 0.0% Government & Education Commitment ($Billions) $19.1 $11.2 $11.6 $10.7 $10.4 Special Mention ($Billions) $0.0 Classified ($Billions) $1.3 $0.0 % Special Mention 0.0% 0.0% 0.0% 0.0% 0.0% % Classified 6.8% 0.0% 0.0% 0.0% 0.0% All Industries (Total) Commitment ($Billions) $5,178.5 $5,897.2 $6,408.8 $6,521.9 $6,911.4 Special Mention ($Billions) $217.3 $122.3 $176.6 $161.8 $155.3 Classified ($Billions) $332.8 $291.3 $395.6 $434.0 $437.5 % Special Mention 4.2% 2.1% 2.8% 2.5% 2.2% % Classified 6.4% 4.9% 6.2% 6.7% 6.3% Note: Figures may not add to totals due to rounding. Appendix C: Summary of SNC Industry Trends (Cont.)

• 11 - 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 U.S. Banks 44.9 45.3 44.3 44.4 44.5 44.8 44.7 46.1 45.8 44.6 FBOs 33.6 33.9 33.4 33.5 33.3 32.6 32.3 32.8 33.9 33.9 Other Investors 21.6 20.8 22.2 22.1 22.2 22.6 22.9 21.1 20.3 21.5 2016 2016 2018 2019 2020 2021 2022 2023 2024 2025 U.S. Banks $63.9 $66.7 $35.5 $41.2 $74.3 $71.9 $55.2 $74.7 $95.7 $89.6 FBOs $54.0 $53.2 $29.7 $31.9 $58.2 $55.3 $42.1 $61.3 $64.9 $59.1 Other Investors $167.2 $165.9 $117.3 $131.0 $233.3 $205.6 $194.1 $259.6 $273.4 $288.9 Totals $285.1 $285.9 $182.5 $204.1 $365.9 $332.8 $291.3 $395.6 $434.0 $437.6 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 U.S. Banks 3.5 3.4 1.8 1.9 3.3 3.1 2.1 2.5 3.2 2.9 FBOs 3.9 3.7 2.0 2.0 3.5 3.3 2.2 2.9 2.9 2.5 Other Investors 18.9 18.6 11.9 12.3 20.7 17.6 14.4 19.2 20.6 19.4 Totals 6.9 6.6 4.1 4.2 7.2 6.4 4.9 6.2 6.7 6.3 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 U.S. Banks $15.0 $15.6 $8.8 $8.8 $15.6 $9.5 $5.7 $7.2 $12.5 $15.1 FBOs $15.9 $12.1 $7.9 $6.7 $10.8 $7.2 $5.6 $7.9 $11.5 $13.8 Other Investors $41.8 $30.3 $19.1 $23.9 $41.0 $35.6 $37.0 $35.3 $41.1 $56.0 Totals $72.6 $58.0 $35.8 $39.3 $67.4 $52.3 $48.2 $50.4 $65.1 $84.9 Note: Figures may not add to totals due to rounding. Appendix D: Exposure by Entity Type Ownership Share as % of Total Commitments Total Classified Commitments ($Billions) Classified as % of Total Commitments Total Nonaccrual Commitments ($Billions)