2Q26 KeyCorp Basel III Pillar 3 Regulatory Capital Disclosures

Forward-looking Statements 2

Scope of Application 4

Capital Structure 6

Capital Adequacy 8

Capital Conservation Buffer 9

Risk Management 10

Credit Risk: General Disclosures 10

General Disclosure for Counterparty Credit Risk-Related Exposures 12

Credit Risk Mitigation 13

Securitization 14

Equities Not Subject to Subpart F of this Part (the Market Risk Rule) 15

Interest Rate Risk for Nontrading Activities 15

References to the Corporation's SEC Filings 17

Throughout this discussion, references to "Key," "we," "our," "us," and similar terms refer to the consolidated entity consisting of KeyCorp and its subsidiaries. "KeyCorp" refers solely to the parent holding company, and "KeyBank" refers solely to KeyCorp's subsidiary bank, KeyBank National Association. "KeyBank (consolidated)" refers to the consolidated entity consisting of KeyBank and its subsidiaries.

From time to time, we have made or will make forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. These statements do not relate strictly to historical or current facts. Forward-looking statements usually can be identified by the use of words such as "goal," "objective," "plan," "expect," "assume," "anticipate," "intend," "project," "believe," "estimate," "will," "would," "should," "could," or other words of similar meaning. Forward-looking statements provide our current expectations or forecasts of future events, circumstances, results or aspirations. Our disclosures in this report contain forward-looking statements. We may also make forward-looking statements in other documents filed with or furnished to the SEC. In addition, we may make forward-looking statements orally to analysts, investors, representatives of the media and others.

Forward-looking statements, by their nature, are subject to assumptions, risks, and uncertainties, many of which are outside of our control. Our actual results may differ materially from those set forth in our forward-looking statements. There is no assurance that any list of risks and uncertainties or risk factors is complete. In addition, no assurance can be given that any plan, initiative, projection, goal, commitment, expectation, or prospect set forth in this report can or will be achieved. Factors that could cause our actual results to differ from those described in forward-looking statements include, but are not limited to:

• the extensive regulation of the U.S. financial services industry;

• complex and evolving laws and regulations regarding privacy and cybersecurity;

• operational or risk management failures by us or critical third parties;

• breaches of security or failures of our technology systems due to technological or other factors and cybersecurity threats;

• an ineffective risk management framework;

• negative outcomes from claims, litigation, arbitration, investigations, or governmental proceedings;

• failure or circumvention of our controls and procedures;

• our exposure to a wide range of climate-related physical risks across different geographical areas;

• evolving capital and liquidity standards under applicable regulatory rules;

• disruption of the U.S. and global financial system and markets, including the impact of inflation, tariffs or other trade policies, political instability, a prolonged shutdown of the U.S. government, a potential global economic downturn or recession, and extended military conflicts;

• unanticipated changes in our liquidity position, including but not limited to, changes in our access to or the cost of funding and our ability to secure alternative funding sources;

• our ability to receive dividends from our subsidiaries, including KeyBank;

• downgrades in our credit ratings or those of KeyBank;

• a worsening of the U.S. economy due to financial, political or other shocks;

• our ability to anticipate interest rate changes and manage interest rate risk;

• deterioration of economic conditions in the geographic regions where we operate;

• the soundness of other financial institutions, including instability in the financial industry;

• our concentrated credit exposure in commercial and industrial loans;

• deterioration of commercial real estate market fundamentals;

• defaults by our loan clients or counterparties;

• adverse changes in credit quality trends;

• declining asset prices;

• deterioration of asset quality and an increase in credit losses;

• geopolitical destabilization, including ongoing military conflicts;

• labor shortages, increases in unemployment rates, and supply chain constraints;

• our ability to develop and effectively use the quantitative models we rely upon in our business planning;

• our ability to timely and effectively implement our strategic initiatives;

• damage to our reputation;

• increased competitive pressure;

• our ability to adapt our products and services to industry standards and consumer preferences;

• our ability to attract and retain talented executives and employees;

• unanticipated adverse effects of strategic partnerships or acquisitions and dispositions of assets or businesses;

• the potential impact of Scotiabank's significant equity interest in our business;

• inaccurate assumptions or estimates underlying our consolidated financial statements;

• changes in accounting policies, standards, and interpretations; and

• impairment of goodwill.

Any forward-looking statements made by us or on our behalf speak only as of the date they are made, and we do not undertake any obligation to update any forward-looking statement to reflect the impact of subsequent events or circumstances, except as required by applicable securities laws. Before making an investment decision, you should carefully consider all risks and uncertainties disclosed in our 2025 Form 10-K, our Form 10-Q for the quarter ended June 30, 2026, and in any subsequent reports filed with the SEC by Key, as well as our registration statements under the Securities Act of 1933, as amended, all of which are or will upon filing be accessible on the SEC's website at https://www.sec.gov and on our website at https://www.key.com/ir.

‌SCOPE OF APPLICATION

KeyCorp, organized in 1958 under the laws of the State of Ohio, is headquartered in Cleveland, Ohio. KeyCorp is a bank holding company ("BHC") under the Bank Holding Company Act of 1956 ("BHCA"), as amended, and is one of the nation's largest bank-based financial services companies, with consolidated total assets of $191.3 billion and shareholders' equity of $19.8 billion at June 30, 2026. KeyCorp is the parent holding company for KeyBank National Association, its principal subsidiary, through which most of our banking services are provided. Through KeyBank and certain other subsidiaries, we provide a wide range of retail and commercial banking, commercial leasing, investment management, consumer finance, student loan refinancing, commercial mortgage servicing and special servicing, and investment banking products and services to individual, corporate, and institutional clients through two major business segments: Consumer Bank and Commercial Bank.

The Consumer Bank serves individuals and small businesses throughout our 15-state branch footprint and through our digital brand by offering a variety of deposit and investment products, personal finance and financial wellness services, lending, student loan refinancing, mortgage and home equity, credit card, treasury services, and business advisory services. In addition, wealth management and investment services are offered to assist non-profit and high-net-worth clients with their banking, trust, portfolio management, charitable giving, and related needs.

The Commercial Bank consists of the Commercial and Institutional operating segments. The Commercial operating segment is a full-service, commercial banking platform that focuses primarily on serving the borrowing, cash management, and capital markets needs of middle market clients within Key's 15-state branch footprint. The Institutional operating segment operates nationally in providing lending, equipment financing, and banking products and services to large corporate and institutional clients. The industry coverage and product teams have established expertise in the following sectors: Consumer, Energy, Healthcare, Industrial, Public Sector, Real Estate, and Technology. It is also a significant, national, commercial real estate lender and third-party master and special servicer of commercial mortgage loans. The operating segment includes the KBCM platform which provides a broad suite of capital markets products and services including syndicated finance, debt and equity underwriting, fixed income and equity sales and trading, derivatives, foreign exchange, mergers & acquisition and other advisory, and public finance.

As an FHC, KeyCorp is subject to regulation, supervision, and examination by the Federal Reserve under the BHCA. Our national bank subsidiaries and their subsidiaries are subject to regulation, supervision, and examination by the OCC. At June 30, 2026, we operated one full-service, FDIC-insured national bank subsidiary, KeyBank, and one national bank subsidiary that is limited to fiduciary activities. The FDIC also has certain, more limited regulatory, supervisory, and examination authority over KeyBank and KeyCorp under the FDIA and the Dodd-Frank Act.

The Basel III Capital Framework, as described below, requires regulatory capital disclosures under the third pillar of Basel III ("Pillar 3"). The purpose of the Pillar 3 disclosures is to provide key information relating to a bank's regulatory capital, risk exposures, and risk management practices. This Pillar 3 report is designed to satisfy these requirements and should be read in conjunction with KeyCorp's Annual Report on Form 10-K for the year ended December 31, 2025 ("2025 Form 10-K") and KeyCorp's Quarterly Report on Form 10-Q for the quarterly period ended June 30, 2026 ("Second Quarter 2026 Form 10-Q") which has been filed with the SEC. The table appearing on page 17 of this report provides references to those pages of the 2025 Form 10-K and Second Quarter 2026 Form 10-Q that set forth information required under the Pillar 3 disclosures.

As used in this report, references to "Key" refer to the consolidated entity consisting of KeyCorp and its subsidiaries. The basis of consolidation used for regulatory reporting is consistent with that used under U.S. Generally Accepted Accounting Principles ("U.S. GAAP"). For more information about Key's significant accounting policies, refer to Note 1 ("Summary of Significant Accounting Policies") beginning on page 107 of Key's 2025 Form 10-K.

Throughout this report, certain financial measures may not be based on GAAP ("non-GAAP financial measures"). These non-GAAP financial measures may not be directly comparable to financial measures reported in Key's 2025 Form 10-K and Key's Second Quarter 2026 Form 10-Q, and may not be directly comparable to similar measures used by other companies. Key's non-GAAP financial measures are not required to be, and have not been, audited by its independent auditors. Key's 2025 Form 10-K and Key's Second Quarter 2026 Form 10-Q includes more information about non-GAAP financial measures, including reconciliations to the most directly comparable GAAP

measures. Key's historical SEC and regulatory filings are located in the Investor Relations section of its website at https://www.key.com/IR.

To address deficiencies in the international regulatory capital standards identified during the 2007-2009 global financial crisis, the Basel Committee in 2010 released comprehensive revisions to the international regulatory capital framework, commonly referred to as "Basel III." The Basel III revisions are designed to strengthen the quality and quantity of regulatory capital, in part through the introduction of a Common Equity Tier 1 capital requirement; provide more comprehensive and robust risk coverage, particularly for securitization exposures, equities, and off-balance sheet positions; and address pro-cyclicality concerns through the implementation of capital buffers. The Basel Committee also released a series of revisions to the market risk capital framework to address deficiencies identified during its initial implementation (e.g., arbitrage opportunities between the credit risk-based and market risk capital rules) and in connection with the global financial crisis.

KeyCorp and KeyBank are subject to regulatory capital requirements implemented by the U.S. banking agencies that are based largely on Basel III ("Regulatory Capital Rules"). Consistent with the international framework, the Regulatory Capital Rules further restrict the type of instruments that may be recognized in tier 1 and tier 2 capital; establish a minimum Common Equity Tier 1 capital ratio requirement of 4.5% and capital buffers to absorb losses during periods of financial stress while allowing an institution to provide credit intermediation as it would during a normal economic environment; and refine several of the methodologies used for determining risk-weighted assets. The Regulatory Capital Rules provide additional requirements for large banking organizations with over $250 billion in total consolidated assets or $10 billion in foreign exposure, but those additional requirements do not apply to KeyCorp or KeyBank. For purposes of the Regulatory Capital Rules, KeyCorp and KeyBank are treated as "standardized approach" banking organizations.

Revised prompt corrective action framework

The federal Prompt Corrective Action ("PCA") framework under the FDIA groups FDIC-insured depository institutions into one of five prompt corrective action capital categories: "well capitalized," "adequately capitalized," "undercapitalized," "significantly undercapitalized," and "critically undercapitalized." In addition to implementing the Basel III capital framework in the United States, the Regulatory Capital Rules also revised the PCA capital category threshold ratios applicable to FDIC-insured depository institutions such as KeyBank.

KeyCorp's basis of consolidation for both financial and regulatory accounting purposes conforms with U.S. GAAP and includes the accounts of KeyCorp and its subsidiaries.

For information regarding the restrictions on the transfer of funds and total capital within Key, see "Dividend restrictions" on page 16, "Bank transactions with affiliates" on page 22, and Note 22 ("Regulatory Matters") on page 170, all in Key's 2025 Form 10-K.

At June 30, 2026, KeyCorp did not have any subsidiaries whose regulatory capital was less than the minimum required regulatory capital amount.

An immaterial amount of surplus capital of insurance subsidiaries was included in total shareholders' equity at June 30, 2026.

‌CAPITAL STRUCTURE

Key's qualifying regulatory capital instruments consist of common stock, noncumulative perpetual preferred stock, trust preferred securities, and subordinated debt.

Holders of KeyCorp common stock are entitled to one vote for each common share held by them on each matter properly submitted to shareholders for their vote, consent, waiver, release, or other action. For additional information on the terms and conditions of Key's common stock, see Key's "Consolidated Balance Sheets" on page 44 of Key's Second Quarter 2026 Form 10-Q.

KeyCorp noncumulative perpetual preferred stock ranks senior to KeyCorp common stock. Generally, for each series of preferred stock, so long as any share of preferred stock remains outstanding on any day during a dividend period, no dividend shall be declared or paid on any common stock and no shares of common stock shall be repurchased or redeemed, unless the full dividends for the immediately preceding dividend period on all outstanding shares of preferred stock have been declared and paid or declared and a sum sufficient for the payment of such dividends has been set aside. The holders of preferred stock do not have any voting rights other than those described in the corresponding section of KeyCorp's articles of incorporation. For additional terms and conditions of Key's outstanding preferred stock, see Note 16 ("Shareholders' Equity") on page 81 of Key's Second Quarter 2026 Form 10-Q and the following Exhibits filed with the SEC:

The Basel III Regulatory Capital Rules require us to treat Key's trust preferred securities as Tier 2 capital. For additional information regarding the terms of Key's outstanding trust preferred securities, see Note 17 ("Borrowings") beginning on page 163 of Key's 2025 Form 10-K.

For terms and conditions of Key's outstanding subordinated debt, see Note 17 ("Borrowings") beginning on page 163 of Key's 2025 Form 10-K and "Liquidity Risk Management" beginning on page 33 of Key's Second Quarter 2026 Form 10-Q.

The following table presents Key's Common Equity Tier 1, Tier 1 Capital, Tier 2 Capital, and Total Capital at

June 30, 2026. For more information on Key's regulatory capital tiers, see Schedule HC-R, "Regulatory Capital" in Key's FR Y-9C.

‌CAPITAL ADEQUACY

The Federal Reserve's capital plan rule requires each U.S.-domiciled, top-tier BHC with total consolidated assets of at least $100 billion (like KeyCorp) to develop and maintain on an annual basis a written capital plan supported by a robust internal capital adequacy process. The capital plan must include, among other things, an assessment of the expected uses and sources of capital over a nine-quarter planning horizon, a description of all planned capital actions over the planning horizon, a detailed description of the BHC's process for assessing capital adequacy, a discussion of any expected changes to the BHC's business plan that are likely to have a material impact on its capital adequacy or liquidity, and the BHC's capital policy. The capital plan must be submitted to the Federal Reserve for supervisory review in connection with the BHC's CCAR (described below). The supervisory review includes an assessment of many factors, including KeyCorp's ability to maintain capital above each minimum regulatory capital ratio on a pro forma basis under expected and stressful conditions throughout the planning horizon.

The Federal Reserve's CCAR is an intensive assessment of the capital adequacy of large U.S. BHCs and of the practices these BHCs use to assess their capital needs. The Federal Reserve expects BHCs subject to CCAR to have and maintain regulatory capital in an amount that is sufficient to withstand a severely adverse operating environment and, at the same time, be able to continue operations, maintain ready access to funding, meet obligations to creditors and counterparties, and provide credit intermediation.

The Federal Reserve conducts a supervisory stress test on BHCs with at least $100 billion in total consolidated assets (including KeyCorp), pursuant to which the Federal Reserve projects revenues, expenses, losses, and resulting post-stress capital levels and regulatory capital ratios under conditions that affect the U.S. economy under supervisory baseline and severely adverse scenarios that are determined by the Federal Reserve. The Federal Reserve conducts a supervisory stress test of the largest BHCs on an annual basis. Under one of the Tailoring Rules, Category IV BHCs (such as KeyCorp) are subject to a supervisory stress test conducted by the Federal Reserve every other year rather than every year.

On August 29, 2025, the Federal Reserve published the updated stress capital buffer requirements for large BHCs, including BHCs like KeyCorp that did not participate in the supervisory stress test in 2025. KeyCorp's updated stress capital buffer is 3.2% (based on the results of KeyCorp's 2024 supervisory stress test and adjusted for KeyCorp's planned common stock dividends as set forth in KeyCorp's 2025 capital plan). This stress capital buffer became effective on October 1, 2025. On February 4, 2026, the Federal Reserve announced that it would maintain the current stress capital buffer requirements until 2027 for the BHCs that are subject to its supervisory stress tests (rather than updating the requirements in 2026) so that the Federal Reserve will be able to consider public feedback on its stress test models before setting the new requirements.

The following table presents Key's risk-weighted assets, Common Equity Tier 1 capital ratio, Tier 1 risk-based capital ratio, Total risk-based capital ratio, and Tier 1 leverage ratio at June 30, 2026. For more information on Key's risk-weighted assets, see Schedule HC-R, "Regulatory Capital" in Key's FR Y-9C. For more information on Key's market risk-weighted assets, including Key's market risk management practices, see the "Market Risk Management" section beginning on page 30 of Key's Second Quarter 2026 Form 10-Q.

dollars in millions 2026

Exposures to government-sponsored enterprises 4,210

Corporate exposures 72,162

Residential mortgage exposures 13,562

High volatility commercial real estate 212

Other assets 11,788

Securitization loans 1,421

Equity exposures 3,623

Market risk-weighted assets 500

Total risk-weighted assets $ 152,068

Total off-balance sheet and market risk exposures

All other off balance sheet liabilities

Letters of credit

Unused commitments with an original maturity of more than one year

Total on-balance sheet exposures

Common Equity Tier 1 11.2

Total risk-based capital 14.8

1. This table does not present the quantitative disclosures required under the capital rules for any exposure category with respect to which Key has no related activity.

The table below lists KeyBank's Common Equity Tier 1 capital ratio, Tier 1 risk-based capital ratio, and Total risk-based capital ratio at June 30, 2026.

Common Equity Tier 1 12.3 %

Tier 1 risk-based capital 12.3

‌CAPITAL CONSERVATION BUFFER

The following table discloses Key's capital conservation buffer, eligible retained income, and limitations on distributions and discretionary bonus payments under the capital conservation buffer framework at June 30, 2026.

1. Federal Reserve-regulated institution's capital conservation buffer is equal to the lowest of the following ratios, calculated as of the last day of the previous calendar quarter based on the Federal Reserve-regulated institution's most recent Call Report, for a state member bank, or FR Y-9C, for a bank holding company or savings and loan holding company, as applicable:

   1. The Federal Reserve-regulated institution's common equity tier 1 capital ratio minus the Federal Reserve-regulated institution's minimum common equity tier 1 capital ratio requirement under §217.10;

   2. The Federal Reserve-regulated institution's tier 1 capital ratio minus the Federal Reserve-regulated institution's minimum tier 1 capital ratio requirement under §217.10; and

   3. The Federal Reserve-regulated institution's total capital ratio minus the Federal Reserve-regulated institution's minimum total capital ratio requirement under §217.10

   4. The Capital Conservation Buffer is greater than KeyCorp's Stress Capital Buffer of 3.20% Key's capital conservation buffer at June 30, 2026, was based upon the Common Equity Tier 1 ratio.

2. The eligible retained income of a Federal Reserve-regulated institution is the greater of

   1. The Federal Reserve-regulated institution's net income for the four calendar quarters preceding the current calendar quarter, net of any distributions and associated tax effects not already reflected in net income, and

   2. Average of Federal Reserve-regulated institution's net income over the preceding four quarters.

This calculation is based on the Federal Reserve-regulated institution's quarterly Call Report, for a state member bank, or the FR Y-9C, for a bank-holding company or savings and loan holding company, as applicable.