Investor Presentaiton
Basel III Endgame
3Q 2023 Preliminary Results
Impact of Newly Proposed Regulation
Actively assessing proposed regulation and engaged in industry response
Elimination of
AOCI
Opt-Out
Expanded Risk-
Based Approach
(ERBA) and
Supplementary
Leverage Ratio
(SLR)
Long-Term Debt
Requirements
Category III and IV banks required to include AOCI impacts in regulatory capital
•
Three-year phase-in period beginning in 3Q '25
After-tax AOCI accretion of approximately $500M per year(1)
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•
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Additional RWA components scoped-in for Ally including Operational and Market risk
ERBA would result in minimal RWA ↑ with offsetting items (↑ Ops risk, ↓ Retail exposures)
SLR not expected to be binding
Rule applies to insured depository institutions (IDI) and bank holding companies (BHC)
6% of RWA expected to be binding constraint for both IDI (Ally Bank) and BHC (AFI)
IDI required to issue internal debt to the BHC
Eligible grandfathered debt estimated at $6.2B at AFI and zero at Ally Bank
(1) Projected accretion of AOCI, net of hedge, based on 9/29/23 forward curve; assumes scheduled principal payments, contractual maturities, and projected prepayments using internal assumptions.
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