Q4 2025 Pillar 3 Form

DISCLOSURE MAP 2

OVERVIEW 3

SCOPE OF APPLICATION 5

CAPITAL STRUCTURE 7

CAPITAL ADEQUACY 9

CAPITAL REQUIREMENTS 11

CREDIT RISK 12

COUNTERPARTY CREDIT RISK 18

CREDIT RISK MITIGATION 20

SECURITIZATION 22

EQUITY EXPOSURES 23

INTEREST RATE RISK 24

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Organization

First Citizens BancShares, Inc. (the "Parent Company" and, when including all its subsidiaries on a consolidated basis, "BancShares," "we," "us," or "our") is a financial holding company organized under the laws of Delaware that conducts operations through its banking subsidiary, First-Citizens Bank & Trust Company ("FCB"), which is headquartered in Raleigh, North Carolina. BancShares and its subsidiaries operate a network of branches and offices, predominantly located in the Southeast, Mid-Atlantic, Midwest and Western United States. BancShares provides various types of commercial and consumer banking services, including lending, leasing, and wealth management services. Deposit services include checking, savings, money market, and time deposit accounts.

Business Combinations

Pending Branch Acquisition

On October 16, 2025, FCB announced that it had entered into an agreement to consummate the acquisition of 138 branches from BMO Bank N.A. ("BMO Bank") located throughout the Midwest, Great Plains and West regions of the U.S. (the "BMO Branch Acquisition"). In connection with the BMO Branch Acquisition, FCB expects to assume approximately $5.7 billion in deposit liabilities and acquire approximately $1.1 billion in loans. We expect the transaction to close in mid-2026, subject to customary closing terms and conditions and regulatory approvals.

Completed Acquisition

On March 27, 2023, FCB acquired substantially all loans and certain other assets and assumed all customer deposits and certain other liabilities of Silicon Valley Bridge Bank, N.A. ("SVBB") from the Federal Deposit Insurance Corporation (the "FDIC") pursuant to the terms of a purchase and assumption agreement by and among FCB, the FDIC, and the FDIC, as receiver of SVBB (the "SVBB Acquisition"). SVBB was established following the closure of the former Silicon Valley Bank. BancShares maintains the Silicon Valley Bank brand as Silicon Valley Bank, a division of FCB.

For further discussion refer to Note 2-Business Combinations of Item 8. Financial Statements and Supplementary Data in our 2025 Annual Report Form 10-K as of December 31, 2025.

General Business

BancShares provides financial services for a wide range of consumer and commercial clients. BancShares offers deposit products, loans and wealth management and private banking services to consumer clients. BancShares provides lending, leasing, capital markets and other financial and advisory services, to small and middle-market companies across a variety of industries. Additionally, BancShares provides a full suite of financial products and services to private equity firms, venture capital firms, and commercial clients in innovation markets, such as technology, life sciences and healthcare industries. BancShares also provides deposit, cash management and lending to homeowner associations and property management companies and owns a fleet of railcars and locomotives that are leased to railroads and shippers.

In addition to our banking operations, we provide various investment products and services through FCB's wholly owned subsidiaries, including First Citizens Investor Services, Inc. ("FCIS"), First Citizens Asset Management, Inc. ("FCAM"), First Citizens Delaware Trust Company, and a non-bank subsidiary, First Citizens Capital Securities, LLC ("FCCS"). As a registered broker-dealer, FCIS provides a full range of investment products, including annuities, brokerage services and third-party mutual funds. As registered investment advisers, FCIS and FCAM provide investment management services and advice. FCCS is a broker-dealer that also provides underwriting and private placement services. We also have other wholly owned subsidiaries, including SVB Wealth LLC, SVB Asset Management, and First Citizens Institutional Asset Management, LLC, which are active investment advisers.

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Information regarding our business activities and operations is found in Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations, in our 2025 Annual Report on Form 10-K as of December 31, 2025..

Capital Requirements

BancShares and FCB are subject to various regulatory capital requirements administered by the federal banking agencies. Failure to meet capital requirements can initiate certain mandatory and possibly additional discretionary actions by regulators that, if undertaken, could have a direct material effect on BancShares' Consolidated Financial Statements. Certain activities, such as the ability to undertake new business initiatives, including acquisitions, the access to and cost of funding for new business initiatives, the ability to pay dividends, the ability to repurchase shares or other capital instruments, the level of deposit insurance costs, and the level and nature of regulatory oversight, largely depend on a financial institution's capital strength

The Federal Reserve imposes certain capital requirements on bank holding companies under the Bank Holding Company Act ("BHCA"), including a minimum leverage ratio and minimum ratios of "qualifying" capital to risk-weighted assets. The metrics utilized include the Tier 1 leverage-based Capital ("Leverage Ratio") and the risk-based capital ("Total Capital"), Tier 1 risk-based capital ("Tier 1 Capital Ratio"), and common equity Tier 1 capital ("CET1" or "Common Equity Tier 1") risk-based capital ratios (collectively, the "Regulatory Capital Ratios"). Federal banking agencies approved regulatory capital guidelines ("Basel III") aimed at strengthening previous capital requirements for banking organizations. The FDIC also has Prompt Corrective Action ("PCA") thresholds for regulatory capital ratios. The regulatory capital ratios for BancShares and FCB are calculated in accordance with the guidelines of the federal banking authorities. The "Capital Requirements" section of this document includes the Basel III requirements and well-capitalized thresholds for the Regulatory Capital Ratios.

For further information on capital requirements, refer to First Citizens BancShares, Inc.: Capital Requirements in Item 1. Business - Regulatory Considerations and Note 17 - Regulatory Capital in the Notes to the Consolidated Financial Statements in our 2025 Annual Report on Form 10-K as of December 31, 2025.

Pillar 3 Reporting

This document presents the Pillar 3 Disclosures in compliance with Basel III as described in Subpart D -Risk-weighted Assets - Standardized Approach of the Basel III Rule. These Pillar 3 Disclosures should be read in conjunction with the Form 10-K of the Company's 2025 Annual Report as of December 31, 2025.

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Principles of Consolidation

The accounting and reporting policies of BancShares are in accordance with accounting principles generally accepted in the United States of America ("GAAP") and general practices within the banking industry.

The consolidated financial statements of BancShares include the accounts of BancShares and its subsidiaries, certain partnership interests and variable interest entities ("VIEs") where BancShares is the primary beneficiary ("PB"), if applicable. All significant intercompany accounts and transactions are eliminated upon consolidation. Assets held in agency or fiduciary capacity are not included in the consolidated financial statements.

Unconsolidated VIEs

VIEs are legal entities that either do not have sufficient equity to finance their activities without the support from other parties or whose equity investors lack a controlling financial interest. BancShares has investments in certain partnerships and limited liability entities that have been evaluated and determined to be VIEs. However, consolidation of a VIE is only appropriate if a reporting entity holds a controlling financial interest in the VIE and is the primary beneficiary. As BancShares is not the primary beneficiary and does not hold a controlling interest in any VIEs, it does not have the power to direct the activities that most significantly impact the VIEs' economic performance. As such, assets and liabilities of these entities are not consolidated into the financial statements of BancShares, and only the exposure to unconsolidated VIEs are reported. The recorded investment in these entities is reported within other assets.

BancShares does have investments in qualified affordable housing projects, primarily to support our Community Reinvestment Act ("CRA") initiatives and obtain tax credits. These investments are accounted for using the Proportional Amortization Method ("PAM") and provide tax benefits in the form of tax deductions from operating losses and tax credits. Under the PAM, the initial cost of the investment is amortized in proportion to the tax credits and other tax benefits received, and the net investment performance is recognized on the Consolidated Statements of Income as a component of income tax expense.

For additional information see Note 10 - Variable Interest Entities in the Notes to the Consolidated Financial Statements our 2025 Annual Report on Form 10-K as of December 31, 2025.

Transfer of Funds or Capital Restrictions

BancShares and FCB are subject to regulatory capital requirements under Basel III for the Tier 1 leverage ratio and ratios of qualifying capital to RWA (the "Risk-Based Capital Ratios" and, together with the Tier 1 leverage ratio, the "Regulatory Capital Ratios"). The total risk-based capital, Tier 1 risk-based capital, and common equity Tier 1 risk-based capital ("CET1") ratios are the Risk-Based Capital Ratios. CET1 capital is generally common stock, additional paid in capital, and retained earnings less applicable capital deductions.

BancShares is also subject to the SCB requirements for the Risk-Based Capital Ratios, as calculated by the Federal Reserve in connection with its supervisory stress tests under the CCAR process. Specifically, the SCB is calculated by the Federal Reserve for each banking organization that participates in the CCAR process as the greater of (i) the difference between the organization's starting and minimum projected Risk-Based Capital Ratios under the severely adverse scenario in the supervisory stress test, plus the sum of the dollar amount of the firm's planned common stock dividends for each of the fourth through seventh quarters of the planning horizon as a percentage of RWA, or (ii) 2.50%, which is equal to the minimum CCB under Basel III. BancShares will participate in the 2026 supervisory stress test which will determine the SCB applicable to BancShares. Additionally, federal banking agencies have developed prompt corrective action ("PCA") thresholds (described below) for Regulatory Capital Ratios to determine whether an institution is well capitalized. Failure of a banking organization to meet regulatory capital guidelines may subject it to a variety of enforcement remedies, including constraints on capital distributions and discretionary executive compensation, restrictions on its operations and activities, termination of deposit insurance by the FDIC and, under certain conditions, the appointment of a conservator or receiver.

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The Parent Company and FCB are subject to limitations on dividends and other payments. A principal source of the Parent Company's liquidity is dividends from FCB. Failure to meet any enhanced prudential standards discussed above, or other mandatory or discretionary action by regulators, could impact the Parent Company's or FCB's ability to declare dividends or make other payments or capital distributions, including equity repurchases. Federal and state banking agencies also have the authority to prohibit BancShares from engaging in an unsafe or unsound practice in conducting its business, which may limit or preclude capital distributions, depending on financial condition. In addition, the Parent Company's ability to make capital distributions, including paying dividends and repurchasing shares, is subject to the Federal Reserve's restrictions on capital distributions under CCAR (as described above) as well as under the Basel III capital rules. Furthermore, under the Federal Deposit Insurance Act (the "FDI Act"), IDIs, such as FCB, are prohibited from making capital distributions, including the payment of dividends, if, after making such distributions, the institution would become undercapitalized. Additionally, banking organizations that are not considered well capitalized under the Basel III capital rules could be subject to restrictions on dividends, equity repurchases and compensation based on the amount of the shortfall. State law also prescribes certain limitations on payment of dividends.

Dividend Restrictions

The Board of Directors of FCB may approve distributions, including dividends, as it deems appropriate, subject to the requirements of the FDIC and the General Statutes of North Carolina, provided that the distributions do not reduce the regulatory capital ratios below the applicable requirements. FCB could have paid additional dividends to the Parent Company in the amount of $6.57 billion while continuing to meet the requirements for well capitalized banks at December 31, 2025. Dividends declared by FCB and paid to the Parent Company amounted to $1.68 billion for the year ended December 31, 2025. Payment of dividends is made at the discretion of FCB's Board of Directors and may be contingent upon satisfactory earnings as well as projected capital needs.

See Note 17 - Regulatory Capital, and Item 1 - Business under Regulatory Considerations; Limitations on Dividends and Other Payments in the Consolidated Financial Statements in our 2025 Annual Report on Form 10-K as of December 31, 2025, for additional information.

Regulated Subsidiaries' Capital

The Company's regulated subsidiaries include the regulated banking subsidiary, the Edge and Agreement Corporation, a regulated insurance entity, two broker-dealer subsidiaries, and two registered investment advisors. All these entities met their respective minimum total capital requirements as of December 31, 2025.

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Capital Instruments

The Company's qualifying common equity tier 1 capital instruments consists of common stock and surplus common stock; the Parent Company also has Class A Common Stock and Class B Common Stock. The qualifying additional Tier 1 capital instruments are non-cumulative perpetual preferred (NCPP) stock of $1.38 billion, and its qualifying Tier 2 capital instrument is subordinated notes of $1.77 billion, net of capital phase out of $258 million.

Debt Transactions

Partial Prepayments of the Purchase Money Note

In connection with the SVBB Acquisition (as defined and described in Note 2-Business Combinations), FCB issued a five-year, 3.50% fixed rate Purchase Money Note (as defined in Note 2-Business Combinations), which had a carrying value of $33.39 billion and $35.82 billion at December 31, 2025 and 2024, respectively. During December 2025, FCB prepaid $2.49 billion of the Purchase Money Note (the "Partial Prepayment of the Purchase Money Note"), which resulted in a $9 million loss on extinguishment of debt. We will continue to monitor the interest rate environment and FCB's collateral position for the Purchase Money Note and assess further prepayments as discussed below in the Funding, Liquidity and Capital Overview. In both January 2026 and February 2026, we made additional prepayments of approximately $500 million.

Debt Redemption

On June 15, 2025, the Parent Company executed a callable feature and redeemed all $350 million aggregate principal amount of its 3.375% Fixed-to-Floating Rate Subordinated Notes due in 2030 (when combined with the Purchase Money Note Partial Prepayment, the "2025 Debt Redemptions").

Debt Issuances

The Parent Company issued and sold the following during 2025 (together the "2025 Debt Issuances") in public offerings:

• On September 5, 2025, $600 million aggregate principal amount of its 5.600% Fixed Rate Reset Subordinated Notes due in 2035, and

• On March 12, 2025, $500 million aggregate principal amount of its 5.231% Fixed-to-Floating Rate Senior Notes due in 2031 and $750 million aggregate principal amount of its 6.254% Fixed -to-Fixed Rate Subordinated Notes due in 2040.

Share Repurchase Programs

On July 25, 2025, BancShares announced that the Board authorized a new share repurchase program (the "2025 SRP"), which allows BancShares to repurchase shares of its Class A common stock in an aggregate amount up to $4.0 billion through December 31, 2026. Repurchases under the 2025 SRP commenced in September 2025 upon the completion of the $3.5 billion share repurchase program announced in July 2024 (the "2024 SRP"). During 2025, BancShares repurchased approximately $3.03 billion of its Class A common stock in aggregate under the 2024 SRP and the 2025 SRP. The total capacity remaining under the 2025 SRP was $2.81 billion as of December 31, 2025.

During the fourth quarter of 2025, we repurchased 479,470 shares of our Class A common stock for approximately $900 million and paid a dividend of $2.10 per share on our Class A and Class B common stock. Shares repurchased during the fourth quarter of 2025 represented 4.13% of Class A common stock and 3.80% of total Class A and Class B common stock outstanding at September 30, 2025. From inception of the 2024 SRP and 2025 SRP through December 31, 2025, we have repurchased 2,393,103 shares of our Class A common stock for approximately $4.69 billion, representing 17.69% of Class A common stock and 16.47% of total Class A and Class B common stock outstanding as of June 30, 2024.

For additional information on the Capital Instruments, Share Repurchase program, and Debt Transactions, please refer to Note 12 - Borrowings, Note 15 - Stockholders' Equity, Item 5. Market for Registrants Common Equity, and Share Repurchase Programs, Debt Transactions in Item 7 - MD&A Executive Overview under Recent Events - in our 2025 Annual Report on Form 10-K as of December 31, 2025.

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Regulatory Capital Tiers

The components of capital including Common Equity Tier 1, Tier 1 and Total Capital are as follows:

Regulatory Capital Tiers (dollars in millions)

December 31, 2025

Common stock $ 12

Retained earnings 20,768

Total common stockholders' equity 20,864

Adjusted total equity 20,780

Less: Intangible assets, net of associated DTLs

Total CET1 Capital 20,285

Total Additional Tier 1 Capital 1,375

Qualifying Tier 2 Capital instruments 1,514

(1) AACL includes credit loss allowances related to loans, except for allowances for purchased credit deteriorated ("PCD") assets. AACL also includes the allowance for off-balance sheet credit exposures (i.e., unfunded lending commitments and Deferred Purchase Agreements) recorded in other liabilities.

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Capital Management

BancShares maintains a comprehensive capital adequacy process. BancShares establishes internal capital risk limits and warning thresholds, which utilize Risk-Based and Leverage-Based Capital calculations, internal and external early warning indicators, its capital planning process, and stress testing to evaluate BancShares' capital adequacy for multiple types of risk in both normal and stressed environments. The capital management framework requires contingency plans be defined and that may be employed at management's discretion.

We are committed to effectively managing our capital to protect our depositors, creditors, and stockholders. We continually monitor the capital levels and ratios for BancShares and FCB to ensure they exceed the minimum requirements imposed by regulatory authorities and to ensure they are appropriate, given growth projections, risk profile and potential changes in the regulatory or external environment. Failure to meet certain capital requirements may result in actions by regulatory agencies that could have a material impact on our consolidated financial statements.

In accordance with GAAP, the unrealized gains and losses on certain assets and liabilities, net of deferred taxes, are included in accumulated other comprehensive loss within stockholders' equity. These amounts are excluded from the calculation of our regulatory capital ratios under current regulatory guidelines.

Termination of the Shared-Loss Agreement with the FDIC

The risk-based capital ratios of FCB and BancShares for periods in which the Shared Loss Agreement was effective, were calculated using favorable risk-weighted assets ("RWA") assumptions permissible for Covered Assets (as defined in Note 2-Business Combinations in our 2025 Form 10-K). FCB and the FDIC entered into the Shared-Loss Termination Agreement on April 7, 2025 (the "Shared-Loss Termination Date") as further discussed in the "Recent Events" section in our 2025 Annual Report on Form 10-K at December 31, 2025.

Further, FCB and BancShares are not permitted after the Shared-Loss Termination Date to apply the favorable RWA assumptions to assets that were previously Covered Assets under the Shared-Loss Agreement. The regulatory capital tiers table above includes risk-based capital ratios as of December 31, 2025 excluding the impact of the Shared Loss Agreement as a result of entering into the Shared-Loss Termination Agreement. Refer to the "Non-GAAP Financial Measurements" section of the Annual Report on Form 10-K for further discussion. The total RWA increased $8.4 billion because of the SLA termination during the second quarter of 2025.

For additional information regarding capital management, refer to the Item 1. Business - Regulatory Considerations: Capital Planning & Stress Testing, and Capital Requirements and Note 12 - Stockholders' Equity, and Capital under Item 2. Management Discussion and Analysis in the Notes to the Consolidated Financial Statements in our 2025 Annual Report on Form 10-K as of December 31, 2025.

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