Affirm Holdings (AFRM): what its 10-K says it depends on

Customers

U.S. consumer loans held for investment

insures or lends to · $9.6 billionnamed as a risk

As of June 30, 2026 and June 30, 2025, we were exposed to credit risk on $9.6 billion and $7.0 billion, respectively, of loans held within our consolidated balance sheet.Market risk (Item 7A)

Amazon

earns fromnamed as a risk

The loss of, or decrease in business with, any one of our significant commercial partner relationships, such as with Amazon or Shopify, would adversely affect our business.Risk factors (Item 1A)

Also named by AES, ALK, AOS, APP, AXP, BBW, CART, CELH and 10 more

Shopify

earns fromnamed as a risk

The loss of, or decrease in business with, any one of our significant commercial partner relationships, such as with Amazon or Shopify, would adversely affect our business.Risk factors (Item 1A)

Also named by EBAY, KVYO

Intuit

earns fromnamed as a risk

Our continued success also is dependent on our ability to successfully grow and develop relationships with our commercial partners, particularly early-stage relationships with large e-commerce retailers and platforms such as Intuit.Risk factors (Item 1A)

Suppliers

Cloud computing web services provider

depends onnamed as a risk

For example, we are solely reliant on our agreement with our cloud computing web services provider for the provision of cloud infrastructure services to support our platform.Risk factors (Item 1A)

Partners and platforms

Celtic Bank

depends on · substantially all of the loansnamed as a risk

We currently rely on Celtic Bank and Lead Bank to originate substantially all of the loans facilitated through our platform.Risk factors (Item 1A)

Lead Bank

depends on · substantially all of the loansnamed as a risk

We currently rely on Celtic Bank and Lead Bank to originate substantially all of the loans facilitated through our platform.Risk factors (Item 1A)

Visa

depends onnamed as a risk

The termination of our registration due to failure to comply with the applicable requirements of Visa or other payment networks or payment processors, or any changes in the payment networks’ or payment processors’ rules that would impair our registration, could require us to stop providing payment services to Visa or other payment networks or payment processors, which could have a material adverse effect on our business, results of operations, financial condition, and future prospects.Risk factors (Item 1A)

Also named by AXP, CASH, COF, EEFT, FIS, FISV, GPN, JKHY and 6 more

Cross River Bank

depends onnamed as a risk

If Cross River Bank terminated our savings account program and we were unable to find another bank partner, we may have to close our savings account program, which could adversely affect our brand, business, results of operations, financial condition, and future prospects.Risk factors (Item 1A)

Also named by GLXY

Apple Pay

earns fromnamed as a risk

In addition, as we add new commercial partners, it could take a significant amount of time for these commercial partners, particularly larger platforms such as Apple Pay, to fully integrate our platform and for these commercial partners’ consumers to accept our pay-over-time solution.Risk factors (Item 1A)

Also named by SYF

Evolve Bank & Trust

depends onnamed as a risk

We currently rely on a small number of originating bank partners, including Celtic Bank and Lead Bank (“Primary Originating Banks”), to originate substantially all of the loans facilitated through our platform, and a small number of card issuing bank partners, including Evolve Bank & Trust and Stride Bank (“Card Issuing Banks”), to issue the Affirm Card.Risk factors (Item 1A)

Stride Bank

depends onnamed as a risk

The Stride Bank issuing program agreement has an initial five-year term which will expire in calendar year 2030.Risk factors (Item 1A)

Private credit funds (forward flow counterparties)

depends onnamed as a risk

A portion of our funding is provided by private credit funds and other institutional investors through forward flow arrangements.Risk factors (Item 1A)

Other companies

Risk sharing arrangements on loans sold

insures or lends to · $4.2 billionnamed as a risk

As of June 30, 2026 and June 30, 2025, the unpaid principal balance of loans sold subject to risk sharing arrangements was $4.2 billion and $8.6 billion, respectively, of which our maximum exposure to losses was $52.7 million and $91.1 million, respectively.Market risk (Item 7A)

Competitors

PayPal

competes withnamed as a risk

Our primary competition consists of: legacy payment methods, such as credit and debit cards, including those provided by card issuing banks such as Synchrony, J.P. Morgan Chase, Citibank, Bank of America, Capital One, Bread Financial and American Express; mobile wallets and other pay-over-time solutions offered by companies such as PayPal, Block and Klarna; and pay-over-time offerings by legacy financial and payments companies, including those mentioned above.Risk factors (Item 1A)

Also named by DASH, EBAY, FERG, NYT, SYF

Synchrony

competes withnamed as a risk

Our primary competition consists of: legacy payment methods, such as credit and debit cards, including those provided by card issuing banks such as Synchrony, J.P. Morgan Chase, Citibank, Bank of America, Capital One, Bread Financial and American Express; mobile wallets and other pay-over-time solutions offered by companies such as PayPal, Block and Klarna; and pay-over-time offerings by legacy financial and payments companies, including those mentioned above.Risk factors (Item 1A)

Klarna

competes withnamed as a risk

Our primary competition consists of: legacy payment methods, such as credit and debit cards, including those provided by card issuing banks such as Synchrony, J.P. Morgan Chase, Citibank, Bank of America, Capital One, Bread Financial and American Express; mobile wallets and other pay-over-time solutions offered by companies such as PayPal, Block and Klarna; and pay-over-time offerings by legacy financial and payments companies, including those mentioned above.Risk factors (Item 1A)

Block

competes withnamed as a risk

Our primary competition consists of: legacy payment methods, such as credit and debit cards, including those provided by card issuing banks such as Synchrony, J.P. Morgan Chase, Citibank, Bank of America, Capital One, Bread Financial and American Express; mobile wallets and other pay-over-time solutions offered by companies such as PayPal, Block and Klarna; and pay-over-time offerings by legacy financial and payments companies, including those mentioned above.Risk factors (Item 1A)

Places

California

concentrated in · approximately 11% of loan receivablesnamed as a risk

As of both June 30, 2026 and June 30, 2025, approximately 11% of loan receivables related to consumers residing in the state of California.Market risk (Item 7A)

Also named by A, AAON, ALK, ALLY, AN, ARE, AVAV, AWK and 88 more

Texas

concentrated in · approximately 11% and 10% of loan receivablesnamed as a risk

As of June 30, 2026 and June 30, 2025, approximately 11% and 10% of loan receivables related to consumers residing in the state of Texas, respectively.Market risk (Item 7A)

Also named by ABR, ALLY, AN, ASO, ASTS, ATO, AXP, AZO and 70 more

Regulators

State attorneys general

subject to · seven state attorneys generalnamed as a risk

In December 2025, a coalition of seven state attorneys general initiated coordinated inquiries into BNPL providers' business practices and compliance with consumer protection laws.Risk factors (Item 1A)

Also named by DKNG, MAR, OMF, RBLX

Consumer Financial Protection Bureau (CFPB)

subject tonamed as a risk

The CFPB, through enforcement authority, could increase our compliance costs, potentially hinder our ability to respond to marketplace changes, impose requirements to alter products and services that would make them less attractive to consumers and impair our ability to offer products and services profitably.Business (Item 1)

Also named by ABNB, ALLY, AN, AUB, AXP, BAC, CASH, CFG and 61 more

Federal Deposit Insurance Corporation (FDIC)

subject tonamed as a risk

There can be no assurance that the FDIC or the Nevada Financial Institutions Division will approve our application, or that any approval will not be subject to conditions that are more burdensome than anticipated, including heightened capital requirements, leverage ratio minimums, activity restrictions, or ongoing supervisory commitments.Risk factors (Item 1A)

Also named by BAC, BNY, CASH, CFG, CFR, COF, FCFS, FCNCA and 27 more

Nevada Financial Institutions Division

subject tonamed as a risk

In January 2026, we submitted applications to the Nevada Financial Institutions Division and the FDIC to establish Affirm Bank, a proposed industrial loan company chartered in the State of Nevada.Risk factors (Item 1A)

Also named by SCHW

Financial Conduct Authority (FCA)

subject to

On July 25, 2026, new FCA regulations for the BNPL market came into force, bringing the previously unregulated deferred-payment credit (“DPC”) sector under the remit of the FCA and its DPC rules.Business (Item 1)

Also named by AJG, AMG, AMP, BGC, BRO, CBOE, COF, CPAY and 17 more

Financial Crimes Enforcement Network (FinCEN)

subject to

Affirm Payments is also registered with the U.S. Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") as a money services business.Business (Item 1)

Also named by ABNB, ADP, BMNR, COIN, CORZ, EEFT, FISV, SNEX and 2 more

Australian Securities and Investments Commission (ASIC)

subject to

We operate through our Australian subsidiary, Affirm Australia Pty. Ltd., which holds an Australian credit license permitting lending activities and is regulated by the Australian Securities and Investments Commission (“ASIC”).Business (Item 1)

Also named by AJG, SPGI, TW, XYZ

Laws and programs

Section 27 of the Federal Deposit Insurance Act

subject to · up to 36%named as a risk

We rely on our originating bank partners’ authority under federal law to establish interest rates and charge interest on the loans our originating bank partners originate through our platform.Business (Item 1)

Equal Credit Opportunity Act (ECOA)

subject tonamed as a risk

We face the risk that one or more of the variables included in our loan decisioning model may be deemed a proxy for a protected characteristic such as race, ethnicity, or sex in violation of anti-discrimination laws, and therefore need to be revised or eliminated to ensure compliance with ECOA and recent state legislation related to AI/ML decisions.Risk factors (Item 1A)

Also named by TOST

State interest rate limits (usury laws)

subject tonamed as a risk

If any of the loans facilitated through our platform were found to impose rates higher than the maximum rate for the applicable state, such loans could be in violation of state interest limitation laws, which could result in such loans being unenforceable or reduce or extinguish the principal and/or interest (paid or to be paid) on such loans, or result in fees, damages, and penalties to us or our originating bank partners.Business (Item 1)

FTC Holder in Due Course Rule

subject tonamed as a risk

This, in turn, can result in claims or defenses against our originating bank partners and us, or a loan purchaser, or in loans being uncollectible due to the Federal Trade Commission’s Holder in Due Course Rule (“Holder Rule”), or equivalent state laws.Risk factors (Item 1A)

Tariffs on global trade

exposed to its pricenamed as a risk

In addition, a material modification in the production levels (including supply chain issues impacting component parts of products sold by our commercial partners), the imposition of tariffs on global trade and/or financial operations of any significant commercial partner could affect the results of our operations, financial condition, and future prospects.Risk factors (Item 1A)

Canada Retail Payment Activities Act

subject to

The Retail Payment Activities Act (S.C. 2021, c. 23, s. 177) came into full effect on September 8, 2025, requiring payment service providers and BNPL firms performing regulated payment functions to register with the Bank of Canada and to comply with operational risk management, funds-safeguarding, and reporting obligations.Business (Item 1)

New York Buy-Now-Pay-Later Act

subject to

For example, New York enacted the Buy-Now-Pay-Later Act (N.Y. Banking Law Article 14-B, §§ 735-749), and Illinois recently enacted the Buy-Now-Pay-Later Loan Consumer Protection Act (SB 3561).Business (Item 1)

Illinois Buy-Now-Pay-Later Loan Consumer Protection Act

subject to

For example, New York enacted the Buy-Now-Pay-Later Act (N.Y. Banking Law Article 14-B, §§ 735-749), and Illinois recently enacted the Buy-Now-Pay-Later Loan Consumer Protection Act (SB 3561).Business (Item 1)