Associated Banc-Corp

AI Artificial Intelligence

· The use of AI in connection with our business and operations contains inherent risks that may expose us to material harm and any actual or perceived failure to comply with evolving regulatory frameworks around the development and use of AI could adversely affect our business, results of operations, and financial condition.

Artificial Intelligence

CFPB and other federal regulatory guidance reiterates that creditors are not excused from the adverse action notice requirements under ECOA if they rely on complex algorithmic underwriting models. States have started to regulate the use of AI technologies. Of note, the California Privacy Protection Agency has finalized regulations under the CCPA regarding the use of automated decision making. California also enacted new laws that further regulate use of AI technologies and provide consumers with additional protections around companies’ use of AI technologies, such as requiring companies to disclose certain uses of generative AI, and other states have also passed AI-focused legislation. In addition, the New York State Department of Financial Services issued an industry letter on combating cybersecurity risks associated with AI.

On January 23, 2025, President Trump issued an Executive Order aimed at reducing barriers to AI innovation in the U.S. economy. The Order requires relevant persons and bodies within the federal government to develop an AI action plan to carry out this objective and revokes an AI-related Executive Order issued in 2023 by President Biden, as well as all corresponding policies, regulations, orders, directives and other actions taken in response to such Order.

We operate in many different businesses in diverse markets and rely on the ability of our employees and systems to process transactions. Operational risk is the risk of loss resulting from our operations, including but not limited to, the risk of fraud by employees or persons outside the Corporation, the execution of unauthorized transactions, errors relating to transaction processing and technology, breaches of our internal control systems or failures of those of our suppliers or counterparties, compliance failures, cyber-attacks or other security breaches, technology failures, or unforeseen problems encountered while implementing new computer systems or upgrades to existing systems, business continuation and disaster recovery issues, and other external events. In recent periods, the OCC has observed an increased incidence of check fraud, wire fraud, peer-to-peer payment fraud, and the use of AI technology to facilitate the perpetration of social engineering and impersonation schemes and identity theft. Insurance coverage may not be available for such losses, or where available, such losses may exceed insurance limits. This risk of loss includes the potential legal actions that could arise as a result of an operational deficiency or as a result of noncompliance with applicable regulatory standards, adverse business decisions or their implementation, and customer attrition due to potential negative publicity. The occurrence of any of these events could cause us to suffer financial loss, face regulatory action and suffer damage to our reputation.

Cyber-attacks continue to evolve and become more pervasive throughout the financial services sector. In particular, there has been an observed increase in the number of distributed denial of service and ransomware attacks against the financial sector, for which the increase is believed to be partially attributable to politically motivated attacks as well as financial demands coupled with extortion. Further, threat actors continue to exploit publicly known software vulnerabilities and weak authentication controls used by large numbers of banking organizations in order to conduct malicious cyber activities. These types of attacks have resulted in increased supply chain and third-party risk. Such cybersecurity threats may see their frequency increased, and effectiveness enhanced, by the use of AI.

The use of AI in connection with our business and operations contains inherent risks that may expose us to material harm and any actual or perceived failure to comply with evolving regulatory frameworks around the development and use of AI could adversely affect our business, results of operations, and financial condition.

Our business increasingly relies on AI, machine learning and automated decision making to improve our services and our customers’ experience. The regulatory framework around the development and use of these emerging technologies is rapidly evolving, and many federal, state and foreign government bodies and agencies have introduced and/or are currently considering additional laws and regulations. The implementation standards and enforcement practices are likely to remain uncertain for the foreseeable future, and we cannot yet determine the impact future laws, regulations, standards, or perception of their requirements may have on our business.

If any of our employees or service providers use any third-party AI-powered software in connection with our business or the services they provide to us, it may lead to the inadvertent disclosure or incorporation of our confidential information into publicly available training sets, which may impact our ability to realize the benefit of, or adequately maintain, protect and enforce our intellectual property or confidential information, harming our competitive position and business. Any output created by us using AI tools may not be subject to copyright protection, which may adversely affect our intellectual property rights in, or ability to commercialize or use, any such content.

If we do not have sufficient rights to use the data or other material or content on which our AI solutions rely, or if we experience cybersecurity incidents in connection with our use of AI, we may incur liability through the violation of applicable laws and regulations, such as fair lending laws and regulations, third-party intellectual property, privacy or other rights, or contracts to which we are a party. We may not be able to sufficiently mitigate or detect any of the foregoing limitations or risks given our and other market participants' lack of experience with using AI, the pace of technological change, and rapid adoption of AI by our business partners and competitors. This exposes us to potential damage to our reputation, adverse impacts on our business operations, and violation of legal and regulatory obligations.

Any of the foregoing, together with developing guidance and/or decisions in this area, may affect our use of AI and our ability to provide and improve our services, require additional compliance measures and changes to our operations and processes, and result in increased compliance costs and potential increases in civil claims against us. Any actual or perceived failure to comply with evolving regulatory frameworks around the development and use of AI, machine learning and automated decision making or to address any ethical, reputational, technical, operational, legal, competitive or regulatory issues could adversely affect our business, results of operations, and financial condition.

The current Administration continues to implement significant changes to the size and scope of the federal government and reform its operations to achieve stated goals that include reducing the federal budget deficit and national debt, improving the efficiency of government operations, and promoting innovation and economic growth. To date, these efforts have been carried out through a mix of executive actions aimed at eliminating or modifying federal agency and federal program funding, reducing the size of the federal workforce, reducing or altering the scope of activities conducted by, and possibly eliminating, various federal agencies and bureaus, and encouraging the use of AI and other advanced technologies within the public and private sectors. These changes, if implemented and taken as a whole, may have varied effects on the economy that are difficult to predict. For instance, the delivery of government services and the distribution of federal program funds and benefits may be disrupted or, in some cases, eliminated as a result of fraud investigations, funding cuts or recasting of federal agency mandates.

Similar wording appears in 4 other banks' reports.

The financial services industry is continually undergoing rapid technological change with frequent introductions of new technology-driven products and services, including, for example, the growing use of AI, machine learning and automated decision making, as well as blockchain technology to provide alternative high speed payment systems. The effective use of technology increases efficiency and enables financial institutions to better serve customers and to reduce costs. Our future success depends, in part, upon our ability to address the needs of our customers by using technology to provide products and services that will satisfy customer demands, as well as to create additional efficiencies in our operations. Many of our competitors have substantially greater resources to invest in technological improvements. We may not be able to effectively implement new technology-driven products and services or be successful in marketing these products and services to our customers. Failure to successfully keep pace with technological change affecting the financial services industry could have a material adverse impact on our business and, in turn, our financial condition and results of operations.

Similar wording appears in 16 other banks' reports.

AI Artificial Intelligence

•Any actual or perceived failure to comply with evolving regulatory frameworks around the development and use of AI could adversely affect our business, results of operations, and financial condition.

Artificial Intelligence

CFPB and other federal regulatory guidance reiterates that creditors are not excused from the adverse action notice requirements under ECOA simply because they rely on complex algorithmic underwriting models. States have also started to regulate the use of AI technologies. Of note, the California Privacy Protection Agency is currently in the process of finalizing regulations under the CCPA regarding the use of automated decision making. California also enacted new laws that further regulate use of AI technologies and provide consumers with additional protections around companies’ use of AI technologies, such as requiring companies to disclose certain uses of generative AI, and other states have also passed AI-focused legislation. In addition, the New York State Department of Financial Services issued an industry letter on combating cybersecurity risks associated with AI.

Additionally, on January 23, 2025, President Trump issued an Executive Order aimed at reducing barriers to AI innovation in the U.S. economy. The Order requires relevant persons and bodies within the federal government to develop an AI action plan to carry out this objective, and revokes an AI-related Executive Order issued in 2023 by President Biden, as well as all corresponding policies, regulations, orders, directives and other actions taken in response to such Order.

We operate in many different businesses in diverse markets and rely on the ability of our employees and systems to process transactions. Operational risk is the risk of loss resulting from our operations, including but not limited to, the risk of fraud by employees or persons outside the Corporation, the execution of unauthorized transactions, errors relating to transaction processing and technology, breaches of our internal control systems or failures of those of our suppliers or counterparties, compliance failures, cyber-attacks, technology failures, or unforeseen problems encountered while implementing new computer systems or upgrades to existing systems, business continuation and disaster recovery issues, and other external events. In recent periods, the OCC has observed an increased incidence of check fraud, wire fraud, peer-to-peer payment fraud, and the use of AI technology to facilitate the perpetration of social engineering and impersonation schemes and identity theft. Insurance coverage may not be available for such losses, or where available, such losses may exceed insurance limits. This risk of loss also includes the potential legal actions that could arise as a result of an operational deficiency or as a result of noncompliance with applicable regulatory standards, adverse business decisions or their implementation, and customer attrition due to potential negative publicity. The occurrence of any of these events could cause us to suffer financial loss, face regulatory action and suffer damage to our reputation.

Any actual or perceived failure to comply with evolving regulatory frameworks around the development and use of AI could adversely affect our business, results of operations, and financial condition.

Our business increasingly relies on AI, machine learning and automated decision making to improve our services and our customer’s experience. The regulatory framework around the development and use of these emerging technologies is rapidly evolving, and many federal, state and foreign government bodies and agencies have introduced and/or are currently considering additional laws and regulations. For example, in July 2024, the federal banking agencies, including the OCC and the FDIC, issued a final rule that requires, among other things, financial institutions to ensure that their automated valuation models for property valuation follow certain quality control standards, including a requirement that such valuation models comply with nondiscrimination laws. The implementation standards and enforcement practices are likely to remain uncertain for the foreseeable future, and we cannot yet determine the impact future laws, regulations, standards, or perception of their requirements may have on our business.

Any of the foregoing, together with developing guidance and/or decisions in this area, may affect our use of AI and our ability to provide and improve our services, require additional compliance measures and changes to our operations and processes, and result in increased compliance costs and potential increases in civil claims against us. Any actual or perceived failure to comply with evolving regulatory frameworks around the development and use of AI, machine learning and automated decision making could adversely affect our business, results of operations, and financial condition.

The Trump Administration has commenced efforts to implement significant changes to the size and scope of the federal government and reform its operations to achieve stated goals that include reducing the federal budget deficit and national debt, improving the efficiency of government operations, and promoting innovation and economic growth. To date, these efforts have been carried out through a mix of executive actions aimed at eliminating or modifying federal agency and federal program funding, reducing the size of the federal workforce, reducing or altering the scope of activities conducted by, and possibly eliminating, various federal agencies and bureaus, and encouraging the use of AI and other advanced technologies within the public and private sectors. These changes, if implemented and taken as a whole, may have varied effects on the economy that are difficult to predict. For instance, the delivery of government services and the distribution of federal program funds and benefits may be disrupted or, in some cases, eliminated as a result of funding cuts or recasting of federal agency mandates. Further, a substantial reduction of the federal workforce could adversely affect regional and local economies, both directly and indirectly, in geographies with significant concentrations of federal employees and contractors. It is possible that such comprehensive changes to the federal government may be materially adverse to the regional and local economies where we

Similar wording appears in 6 other banks' reports.

19 Phases 1 + 2: Consumer & Small Business Banking Our efforts to upgrade the customer experience are largely completed, with expected results on track 2022 2023 2024 ▪ Highest mobile banking satisfaction score since internal tracking began in 20184 ▪ Total checking household growth of 1.5% in 3Q (annualized) ▪ On track to deliver ~$2B in cumulative incremental consumer & small business deposit balances by YE 20255 ▪ Highest annual net promoter score since internal tracking began in 20173 1 All updates as of or for the period ended September 30, 2024 unless otherwise noted. 2 Based on JD Power 2024 U.S. Retail Banking Satisfaction study conducted January 2023 through January 2024. For award information, visit jdpower.com/awards. 3 Annual net promoter score as measured by a customer’s likelihood to recommend Associated Bank to family and friends as indicated in our internal Consumer Relationship Survey. 2024 YTD through September 30, 2024. 4 Based on year-over-year customer satisfaction scores from internal transactional surveys. 2024 data through September 30, 2024. 5 Incremental balance growth expected above our standard run rate, which is impacted by market conditions. Launched New Brand Campaign Platinum Choice Checking and Mass Affluent Banker Program New & Enhanced Digital Banking Platform No-fee Overdraft Protection Transfers Enhanced Deposit Account Opening - Digital Unlimited Savings Transfers Money Monitor with Actionable Insights $50 (& $100) Grace Zone Activation Zone, for faster account set-up New IVA Phone System Debit Card Controls Digital Opening & Servicing for Small Business Loans Early Pay Adie, 24/7 virtual assistant Easy Direct Deposit Switching Enhanced Deposit Account Opening - Branches Business & Personal Account Benefits and Digital Integration Credit Monitor Impact1 ▪ Named #1 for Retail Banking Customer Satisfaction in the Upper Midwest by J.D. Power2

11 Phases 1 + 2: Consumer & Small Business Banking Our efforts to upgrade the customer experience are largely completed, with expected results on track 2022 2023 2024 ▪ Highest quarterly net consumer checking household growth in over a decade ▪ Highest annual net promoter score4 since internal tracking began in 2017 ▪ 26% increase in YTD deposit balances per new consumer checking household vs. 2023 ▪ Named #1 for Retail Banking Customer Satisfaction in the Upper Midwest by J.D. Power3 1 All updates as of or for the period ended June 30, 2024 unless otherwise noted. 2 Incremental balance growth expected above our standard run rate, which is impacted by market conditions. 3 For J.D. Power 2024 award information, visit jdpower.com/awards. 4 Annual net promoter score as measured by a customer’s likelihood to recommend Associated Bank to family and friends as indicated in our internal Consumer Relationship Survey. 2024 YTD through June 30, 2024. Launched New Brand Campaign Platinum Choice Checking and Mass Affluent Banker Program New & Enhanced Digital Banking Platform No-fee Overdraft Protection Transfers Enhanced Deposit Account Opening - Digital Unlimited Savings Transfers Money Monitor with Actionable Insights $50 (& $100) Grace Zone Activation Zone, for faster account set-up New IVA Phone System Debit Card Controls Digital Opening & Servicing for Small Business Loans Early Pay Adie, 24/7 virtual assistant Easy Direct Deposit Switching Enhanced Deposit Account Opening - Branches Business & Personal Account Benefits and Digital Integration Credit Monitor Impact1 ▪ On track to deliver ~$2B in cumulative incremental consumer & small business deposit balances by YE 20252

21 26% Consumer Checking Household Acquisition 1Q 2023 to 1Q 2024 9% Consumer Checking Household Attrition 1Q 2023 to 1Q 2024 Net Growth Consumer & Business Checking Households 1Q 2024 #1 for Retail Banking Customer Satisfaction in the Upper Midwest Region (J.D. Power)1 We are continuing to make digital-forward investments to deliver a better experience for our customers 1 For J.D. Power 2024 award information, visit jdpower.com/awards. Building on our Strong Momentum With 12 major customer-facing upgrades since launching our platform in Fall 2022, our quarterly cadence of enhancements planned for 2024 includes: ▪ ADIE Virtual Assistant ▪ Omnichannel branch sales platform ▪ Credit score & identity protection ▪ Private Wealth client experience ▪ Personalized digital marketplace Digital Roadmap Updates Enhancing the Customer Experience with Digital

AI Artificial Intelligence

•Any actual or perceived failure to comply with evolving regulatory frameworks around the development and use of artificial intelligence could adversely affect our business, results of operations, and financial condition.

On October 30, 2023, the current Presidential Administration issued an Executive Order on Safe, Secure and Trustworthy Development and Use of AI, emphasizing the need for transparency, accountability and fairness in the development and use of AI. The order seeks to balance innovation with addressing risks associated with AI by providing eight guiding principles and priorities, such as ensuring that consumers are protected from fraud, discrimination and privacy risks related to AI. The Executive Order also requires certain federal agencies, including the CFPB, to address potential discrimination in the housing and consumer financial markets relating to the use by financial institutions of AI technologies. Prior to the issuance of the Executive Order, the CFPB published a report addressing the use by financial institutions of AI chatbots in the provision of financial products and services, which report also highlighted the limitations and various risks posed by such activity. States have also started to regulate the use of AI technologies. For example, the California Privacy Protection Agency is currently in the process of finalizing regulations under the CCPA regarding the use of automated decision making.

Any actual or perceived failure to comply with evolving regulatory frameworks around the development and use of artificial intelligence could adversely affect our business, results of operations, and financial condition.

Our business increasingly relies on AI, machine learning and automated decision making to improve our services and our customer’s experience. The regulatory framework around the development and use of these emerging technologies is rapidly evolving, and many federal, state and foreign government bodies and agencies have introduced and/or are currently considering additional laws and regulations. As a result, implementation standards and enforcement practices are likely to remain uncertain for the foreseeable future, and we cannot yet determine the impact future laws, regulations, standards, or perception of their requirements may have on our business.

Any of the foregoing, together with developing guidance and/or decisions in this area, may affect our use of AI and our ability to provide and improve our services, require additional compliance measures and changes to our operations and processes, and result in increased compliance costs and potential increases in civil claims against us. Any actual or perceived failure to comply with evolving regulatory frameworks around the development and use of AI, machine learning and automated decision making could adversely affect our business, results of operations, and financial condition.

7 Our People - Led, Digitally Enabled Strategic Plan Launched in Sept. 2021, our strategic plan was designed to attract & deepen relationships, enhance profitability ▪ RM Growth ▪ Asset - Based Lending ▪ Equipment Finance ▪ Auto Finance ▪ Full Relationship Commercial ▪ Mass Affluent ▪ Product Enhancements ▪ Digital Sales ▪ New Online/Mobile Platform ▪ Account Opening Upgrade ▪ AI - Driven Tools ▪ Front Line Support Enhanced our Lending Capabilities Expanded our Deposit Capabilities Invested in Digital Transformation Loan Growth Outperformance vs. Industry Core Customer Deposit Growth Outperformance vs. Industry 3 - Year High in Digital Banking Customer Satisfaction 1 1 Based on quarterly top box customer satisfaction scores from internal transactional surveys. Data as of 3Q 2023.

10 We’re leveraging agile frameworks & customer feedback to more quickly deliver custom digital solutions Invested in Digital Transformation Launch of Associated Bank Digital Debit Card Controls AI - led Financial Wellness and Personal Insights Digital Account Opening Upgrades ▪ Cloud - based platform with 99.9% uptime ▪ Open architecture ▪ Improved security and self - service controls ▪ Fast, simplified & intuitive experience ▪ Flexible platform structure ▪ More robust risk controls In - Branch Account Opening Optimization ▪ Launched April 2023 ▪ Launched July 2023 Associated Bank Money Monitor ▪ Rollout targeted for 1Q 2024

17 20% Consumer Checking Household Acquisition 3Q 2022 to 3Q 2023 17% Consumer Checking Household Attrition 3Q 2022 to 3Q 2023 90% Top - Box Satisfaction with Branch Channel 1 3Q 2023 3 - Year High Top - Box Satisfaction with Digital Channel 1 3Q 2023 We are continuing to make digital - forward investments to deliver a better experience for our customers 1 Based on quarterly top box customer satisfaction scores from internal transactional surveys. Building on our Strong Momentum ▪ With 11 major customer - facing upgrades since launching our platform in Fall 2022, our quarterly cadence of enhancements planned for 2024 includes: ▪ A.I. enabled chatbot (“Adie”) ▪ Omnichannel branch sales platform ▪ Personalized digital marketplace ▪ Private wealth client experience ▪ Credit score & identity protection ▪ Advanced digital security center Digital Roadmap Updates Enhancing the Customer Experience with Digital 2

· An A.I. enabled chatbot,