First Horizon (FHN): what its 10-K says it depends on

Customers

Financial services industry borrowers

concentrated in · approximately 25% of the C&I portfolionamed as a risk

Taken together, approximately 25% of the C&I portfolio was sensitive to impacts on the financial services industry.Risk factors (Item 1A)

Mortgage companies

insures or lends to · 13%named as a risk

Two large components of the C&I portfolio at year end were loans to mortgage companies and loans to finance and insurance companies.Risk factors (Item 1A)

Partners and platforms

Federal Home Loan Bank

depends onnamed as a risk

We have and use credit facilities with one of the Federal Home Loan Banks.Risk factors (Item 1A)

Also named by C, CUBI, EFSC, FITB, FSUN, HBAN, SF, UNM

Federal Reserve discount window

depends onnamed as a risk

We also have and use access to the discount window at the Federal Reserve.Risk factors (Item 1A)

Other companies

Multi-family commercial real estate

insures or lends to · 33%named as a risk

Another part of our CRE portfolio consists of multi-family properties, a sector which has also been subject to recent stress.Risk factors (Item 1A)

Office commercial real estate

insures or lends to · 20named as a risk

The COVID pandemic disrupted traditional office space demand and utilization.Risk factors (Item 1A)

U.S. government shutdown

named as a risk

Most recently, in October 2025, the U.S. government entered into a prolonged shutdown, which ended on November 12, 2025, as well as a briefer partial shutdown in February 2026, negatively impacting companies, likely including some of our commercial clients, who do substantial business with, or related to, the U.S. government.Risk factors (Item 1A)

Also named by NTAP, TDY

Competitors

Truist Bank

competes with

Key traditional competitors in many of our markets include Bank of America N.A., Fifth Third Bank National Association, First-Citizens Bank & Trust Company (dba First Citizens Bank), Hancock Whitney Bank, Huntington National Bank, JPMorgan Chase Bank National Association, Regions Bank, Pinnacle Bank, PNC Bank National Association, Truist Bank, and Wells Fargo Bank N.A., among many others including many community banks and credit unions.Business (Item 1)

Also named by FCNCA, GSBD, TSLX

Regions Bank

competes with

Key traditional competitors in many of our markets include Bank of America N.A., Fifth Third Bank National Association, First-Citizens Bank & Trust Company (dba First Citizens Bank), Hancock Whitney Bank, Huntington National Bank, JPMorgan Chase Bank National Association, Regions Bank, Pinnacle Bank, PNC Bank National Association, Truist Bank, and Wells Fargo Bank N.A., among many others including many community banks and credit unions.Business (Item 1)

Also named by RF

Pinnacle Bank

competes with

Key traditional competitors in many of our markets include Bank of America N.A., Fifth Third Bank National Association, First-Citizens Bank & Trust Company (dba First Citizens Bank), Hancock Whitney Bank, Huntington National Bank, JPMorgan Chase Bank National Association, Regions Bank, Pinnacle Bank, PNC Bank National Association, Truist Bank, and Wells Fargo Bank N.A., among many others including many community banks and credit unions.Business (Item 1)

Hancock Whitney Bank

competes with

Key traditional competitors in many of our markets include Bank of America N.A., Fifth Third Bank National Association, First-Citizens Bank & Trust Company (dba First Citizens Bank), Hancock Whitney Bank, Huntington National Bank, JPMorgan Chase Bank National Association, Regions Bank, Pinnacle Bank, PNC Bank National Association, Truist Bank, and Wells Fargo Bank N.A., among many others including many community banks and credit unions.Business (Item 1)

Places

Florida

concentrated in · 26%named as a risk

Many of our fastest growing markets, including most significantly those in Florida, have been and can be impacted significantly by hurricanes and other severe coastal weather events.Risk factors (Item 1A)

Also named by ABR, ALLY, AN, AXP, AZO, BBY, BJ, BRO and 54 more

Florida, Tennessee and Texas consumer real estate

concentrated in · about 63% of the consumer real estate portfolionamed as a risk

At year end, about 63% of the consumer real estate portfolio related to clients in three states: Florida, Tennessee, and Texas.Risk factors (Item 1A)

North Carolina

concentrated in · 12%

Geographically, a significant majority of our loans originate from five states: Florida, Tennessee, Texas, North Carolina, and Louisiana.Business (Item 1)

Also named by ABR, AUB, DUK, FCNCA, GLW, IMKTA, MLM, PNFP and 5 more

Tennessee

concentrated in · 34%

Most of those locations (412) were banking centers located in southern states, including Tennessee (137), North Carolina (78), Florida (74), and Louisiana (55).Business (Item 1)

Also named by CTRE, IMKTA, PNFP, RF, VMC

Louisiana

concentrated in · 12%

Geographically, a significant majority of our loans originate from five states: Florida, Tennessee, Texas, North Carolina, and Louisiana.Business (Item 1)

Also named by ATO, ETR, L, NRP, QXO

Southeastern and south-central U.S.

concentrated innamed as a risk

To a significant degree our banking business is exposed to economic, regulatory, natural disaster, and other risks that primarily impact the southeastern and south-central U.S. where we do most of our traditional lending and deposit taking business.Risk factors (Item 1A)

Texas

concentrated in

Geographically, a significant majority of our loans originate from five states: Florida, Tennessee, Texas, North Carolina, and Louisiana.Business (Item 1)

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

Hazards

Hurricanes

concentrated innamed as a risk

In recent years it has been widely reported that the economic costs of hurricane and other severe weather events in the U.S. gulf and southern Atlantic coastal areas have been rising significantly, triggering concerns regarding the availability, reliability, and cost of adequate property insurance.Risk factors (Item 1A)

Also named by AIG, AN, ASO, BAC, BBY, BJ, BPOP, BRO and 89 more

Commodities and inputs

Crude oil

exposed to its price · approximately 2% of our total loansnamed as a risk

At year end, approximately 2% of our total loans were directly related to the oil and gas industry.Risk factors (Item 1A)

Also named by AESI, ALK, APA, ARLP, BDX, CFR, CL, CLMT and 48 more

Property insurance

exposed to its pricenamed as a risk

Instability in property insurance has made, and will continue to make, our business decisions more difficult, while also increasing our risks of loan loss.Risk factors (Item 1A)

Also named by MAA, TNL

Regulators

Federal Deposit Insurance Corporation (FDIC)

subject to · 3.36 basis points per quarter

Also, for eight quarters starting in 2024, the FDIC has imposed a special assessment, of 3.36 basis points per quarter, intended to replenish the DIF in the aftermath of three large regional bank failures that occurred in March and May of 2023.Business (Item 1)

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

Consumer Financial Protection Bureau (CFPB)

subject to

In addition, the CFPB adopts and administers significant rules affecting consumer lending and consumer financial services.Business (Item 1)

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

Federal Reserve

subject to

We and our subsidiaries are subject to the regulation and supervision of, and to examination by, the Federal Reserve under the BHCA.Business (Item 1)

Also named by AGNC, AUB, AXP, BAC, CASH, COF, DX, EFSC and 24 more

Tennessee Department of Financial Institutions (TDFI)

subject to

First Horizon Bank, our most significant subsidiary, is a Tennessee banking corporation subject to the regulation and supervision of, and to examination by, the Tennessee Department of Financial Institutions ("TDFI").Business (Item 1)

Also named by PNFP

Laws and programs

Federal Reserve Category IV enhanced prudential standards

subject to · $100 billionnamed as a risk

For us, significant impacts of crossing the $100 billion threshold, under current regulatory standards, include becoming subject to Category IV enhanced prudential standards and becoming at-risk for being subject to a liquidity coverage ratio requirement.Risk factors (Item 1A)

Tennessee Bank Structure Act of 1974

subject to · approximately 13%

As of June 30, 2025, the FDIC reports that the Bank held approximately 13% of such deposits.Business (Item 1)

California Consumer Privacy Act

subject tonamed as a risk

One prominent example is the California Consumer Privacy Act, which applies to for-profit businesses that conduct business in California and meet certain revenue and data collection thresholds, including the Bank.Risk factors (Item 1A)

Also named by AAP, AIOT, AKAM, ALL, APP, AYI, BAC, BBSI and 69 more

Community Reinvestment Act (CRA)

subject to

In its most recent publicly reported CRA assessment, for 2024, the Bank received ratings of "High Satisfactory" in Lending and in Service, "Outstanding" in Investment, and "Satisfactory" overall.Business (Item 1)

Also named by ALLY, AMP, AUB, CFG, CFR, EFSC, EWBC, FCNCA and 20 more

CFPB Personal Financial Data Rights rule

subject to

The CFPB will implement its data portability rule in phases, with banks that hold at least $10 billion in total assets, but less than $250 billion, required to comply by April 1, 2027.Business (Item 1)

Also named by CFG, USB

FDIC resolution plan rule

subject to

The Bank’s initial information filing submission is due on or before April 1, 2026.Business (Item 1)

Also named by ALLY

Debit card interchange fee regulation

subject to

Regulations cap interchange fees which the Bank may charge merchants for debit card transactions.Business (Item 1)