Standard

Date of Adoption

Description

Effect on Financial Statements or
Other Significant Matters

ASU 2021-08,
Business
Combinations
(Topic 805)

January 1, 2023

Early adoption is
permitted.

At the acquisition date, an acquirer must account for any acquired revenue contracts in
accordance with Topic 606 as if it had originated the contracts (i.e. measure contract
assets and liabilities, generally consistent with acquiree's financial statements).

The guidance should be applied on a prospective basis.

The adoption of this guidance did not have an impact on Key’s financial condition or results of operations.

ASU 2022-01,
Derivatives and
Hedging (Topic 815)

January 1, 2023

Early adoption is
permitted.

This guidance allows entities to apply the same portfolio hedging method to both
prepayable and nonprepayable financial assets. It also allows multiple hedged layers to
be designated for a single closed portfolio of financial assets or one or more beneficial
interests secured by a portfolio of financial instruments. If a breach is anticipated, an entity is required to partially or fully dedesignate a hedged layer or layers until a breach is no longer anticipated. There are additional requirements and enhanced disclosures related to basis adjustments.

The guidance should be applied on a prospective, retrospective or modified retrospective basis depending on the amendment.

The adoption of this guidance did not have an impact on Key’s financial condition or results of operations.

ASU 2022-02,
Financial Instruments —Credit Losses (Topic
326)

January 1, 2023

Early adoption is
permitted

The amendments eliminate TDR guidance and
instead require entities to apply the loan refinancing and restructuring guidance to
determine whether a modification results in a new loan or is a continuation of an existing
loan.

Entities must disclose current-period gross write-offs on an amortized cost basis by credit
quality indicator and class of financing receivable by year of origination.

The guidance should be applied on a prospective basis except for amendments related to recognition and measurement of TDRs, where a modified retrospective transition method is optional.

As part of the adoption of this guidance, Key elected to discontinue use of a discounted cash flow (DCF) methodology and apply its portfolio-based allowance approach to non-collateral dependent modified loans. The adoption did not result in a material impact on Key’s financial condition or results of operations.

Additionally, disclosures for gross charges-offs and loan modifications made to borrowers experiencing financial difficulty have been included in Note 4 (Asset Quality).

ASU 2023-02, Investments—Equity Method and Joint Ventures (Topic 323)

January 1, 2023

Early adoption is
permitted.

Reporting entities may elect to account for their tax equity investments, not limited to LIHTC structures, using the proportional amortization method as long as certain criteria are met. Entities must make an accounting policy election to apply the proportional amortization method on a tax-credit-program-by-tax-credit-program basis. Also, LIHTC investments not accounted for using the proportional amortization method will no longer be allowed to use the delayed equity contribution guidance. Further, accounting guidance in ASC 323-740 is now only applicable to tax equity investments accounted for using the proportional amortization method.

The guidance should be applied on a modified retrospective or retrospective basis.

The guidance did not have a material impact on Key’s financial condition or results of operations.

Key adopted this guidance on a modified retrospective basis.