Affordable Housing Partnership, Tax Credit and Community Reinvestment Act Investments, Net

9 Months Ended

Sep. 30, 2025

Investments in Qualified Affordable Housing Partnerships, Tax Credit and Other Investments, Net and Variable Interest Entities [Abstract]

Affordable Housing Partnership, Tax Credit and Community Reinvestment Act Investments, Net

The CRA encourages banks to meet the credit needs of their communities, particularly low- and moderate-income individuals and neighborhoods. The Company invests in certain affordable housing projects in the form of ownership interests in limited partnerships or limited liability companies that qualify for CRA consideration and tax credits. These entities are formed to develop and operate apartment complexes designed as high-quality affordable housing for lower income tenants throughout the U.S. To fully utilize the available tax credits, each of these entities must meet the affordable housing regulatory requirements for a 15-year minimum compliance period. The Company also invests in small business investment companies and new markets tax credit projects that qualify for CRA consideration, as well as eligible projects that qualify for production, historic and renewable energy tax credits. Investments in new markets tax credits promote development in low-income communities; investments in production and renewable energy tax credits help promote the development of renewable energy sources; and investments in historic tax credits promote the rehabilitation of historic buildings and economic revitalization of the surrounding areas.

The majority of affordable housing partnership, tax credit and CRA investments discussed above are variable interest entities where the Company is a limited partner in these investments, and an unrelated third party is typically the general partner or managing member who has control over the significant activities of these investments. While the Company’s interest in some of the investments may exceed 50% of the outstanding equity interests, the Company does not consolidate these investments due to the general partner’s or managing member’s ability to manage the entity, which is indicative of the general partner’s or managing member’s power over the entity. The Company’s maximum exposure to loss in connection with these partnerships consists of the unamortized investment balance and any tax credits claimed that may become subject to recapture.

The Company elects to account for its tax credit investments using the proportional amortization method (“PAM”) on a program-by-program basis if certain conditions are met. For the Company’s accounting policies on PAM, see Note 1 — Summary of Significant Accounting Policies — Significant Accounting Policies — Income Taxes to the Consolidated Financial Statements in the Company’s 2024 Form 10-K. For discussion on the Company’s impairment evaluation and monitoring process for tax credit investments, refer to Note 2 — Fair Value Measurement and Fair Value of Financial Instruments — Affordable Housing Partnership, Tax Credit and CRA Investments, Net to the Consolidated Financial Statements in this Form 10-Q.

The following table presents the investments and unfunded commitments of the Company’s affordable housing partnership, tax credit, and CRA investments, net as of September 30, 2025 and December 31, 2024:



	September 30, 2025					December 31, 2024
($ in thousands)	Assets			Liabilities - Unfunded Commitments (1)		Assets			Liabilities - Unfunded Commitments (1)

PAM:
Affordable housing partnership investments	$	476,731		$	178,953	$	500,217		$	280,919
Tax credit and CRA investments	145,876			58,090		160,429			21,202
Equity method of accounting and other:
Tax credits and CRA investments	359,640		(2)	143,816		265,994		(2)	105,743
Total	$	982,247		$	380,859	$	926,640		$	407,864

(1)Included in Accrued expenses and other liabilities on the Consolidated Balance Sheet.

(2)Includes $37 million and $29 million of equity securities without readily determinable fair values as of September 30, 2025 and December 31, 2024, respectively.

The following table presents additional information related to the investments in affordable housing partnership, tax credit and CRA investments for the three and nine months ended September 30, 2025 and 2024:



	Three Months Ended September 30,				Nine Months Ended September 30,
($ in thousands)	2025		2024		2025		2024
Tax credits and benefits (1):
PAM:
Affordable housing partnership investments	$	19,493	$	17,352	$	60,101	$	51,383
Tax credit and CRA investments	30,780		27,321		88,527		80,774
Equity method of accounting and other:
Tax credit and CRA investments	23,810		14,918		60,911		49,055
Total tax credits and benefits	$	74,083	$	59,591	$	209,539	$	181,212

Amortization:
PAM (2):
Affordable housing partnership investments	$	15,276	$	11,245	$	46,110	$	34,888
Tax credit and CRA investments	22,126		21,819		67,296		65,135
Equity method of accounting and other:
Tax credit and CRA investments (3)	15,693		5,600		57,671		34,859
Total amortization	$	53,095	$	38,664	$	171,077	$	134,882

(1)Included in Income tax expense on the Consolidated Statement of Income.

(2)For affordable housing partnership, tax credit and CRA investments that are qualified for accounting under PAM, amortization is included in Income tax expense on the Consolidated Statement of Income.

(3)For tax credit and CRA investments that are not accounted for under PAM, amortization is included in Amortization of tax credit and CRA investments as part of Noninterest expense on the Consolidated Statement Income.

The Company also held equity securities without readily determinable fair values totaling $117 million and $118 million included in Other Assets on the Consolidated Balance Sheet, as of September 30, 2025 and December 31, 2024, respectively.