Ally Financial Inc. 10-Q

Item 4. Controls and Procedures Evaluation of Disclosure Controls and Procedures We maintain disclosure controls and procedures, as defined in Rule 13a-15(e) under the Securities Exchange Act of 1934, as amended (the Exchange Act), designed to ensure that information required to be disclosed in reports filed under the Exchange Act is recorded, processed, summarized, and reported within the specified time periods. Our disclosure controls and procedures are also designed to ensure that information required to be disclosed in the reports we file and submit under the Exchange Act is accumulated and communicated to management, including our Chief Executive Officer (Principal Executive Officer) and Chief Financial Officer (Principal Financial Officer), to allow for timely decisions regarding required disclosure. There are inherent limitations to the effectiveness of any system of internal control including the possibility of human error or the circumvention or overriding of controls through individual actions or collusion. A control system, no matter how well designed and operated, can provide only reasonable, not absolute, assurance that the control system’s objectives will be met. As of the end of the period covered by this report, our Principal Executive Officer and Principal Financial Officer evaluated, with the participation of our management, the effectiveness of our disclosure controls and procedures (as defined in Rule 13a-15(e) under the Exchange Act) and concluded that our disclosure controls and procedures were effective. Changes in Internal Control over Financial Reporting In the normal course of business, we review our controls and procedures and make enhancements or modifications intended to support the quality of our financial reporting. During the first quarter of 2026, we implemented a new Enterprise Resource Planning (“ERP”) system, which replaced the former financial application. This change was not undertaken in response to any identified deficiency in our internal control over financial reporting. We adjusted internal control frameworks for related processes to reflect changes to information systems and business processes that occurred as part of the implementation. We also added, modified, and eliminated certain controls to account for new and modified technology and business processes. While this new platform will help us continue to expand our capabilities, there are inherent risks in implementing any new system. We will continue to monitor the newly implemented platform to ensure that the system is performing as intended. There were no other changes in our internal control over financial reporting (as defined in Rule 13a-15(f) of the Exchange Act) that occurred during the quarter ended March 31, 2026, that have materially affected, or were reasonably likely to materially affect, our internal control over financial reporting. 108 Table of Contents PART II — OTHER INFORMATION Ally Financial Inc. • Form 10-Q Item 1. Legal Proceedings Refer to Note 23 to the Condensed Consolidated Financial Statements (incorporated herein by reference) for a discussion related to our legal proceedings, which supplements the discussion of legal proceedings set forth in Note 29 to the Consolidated Financial Statements in our 2025 Annual Report on Form 10-K. Item 1A. Risk Factors There have been no material changes to the Risk Factors described in our 2025 Annual Report on Form 10-K.