5 unchanged sentences
In the U.S., the Bank’s corporate headquarters and main administrative offices are located in California.
−Removed: branches and offices are located in California, Texas, New York, Washington, Georgia, Massachusetts, Illinois and Nevada.
−Removed: In Asia, the Bank has full-service branches in Hong Kong, Shanghai, Shantou and Shenzhen;
−Removed: representative offices in Beijing, Chongqing, Guangzhou, Xiamen and Singapore;
−Removed: and administrative support offices in Beijing and Shanghai.
−Removed: East West Bank has a commercial banking license in China through its subsidiary, East West Bank (China) Limited, which makes it unique among U.S.-based regional banks.
−Removed: This license allows the Bank to open branches, make loans and collect deposits in China.
+Added: branches are located in California, Texas, New York, Washington, Georgia, Massachusetts and Nevada.
+Added: In Asia, the Bank has branches in China and Hong Kong, and representative offices in China and Singapore.
+Added: East West Bank has a commercial banking license in China through its subsidiary, East West Bank (China) Limited (“EWCN”), which makes it unique among U.S.-based regional banks.
+Added: This license allows the Bank to have branches, make loans and accept deposits in China.
The Bank continues to develop its international banking presence in Asia with its network of overseas branches and representative offices.
2 unchanged sentences
and Asia, helping U.S.-based businesses expand in Asia, and assisting companies based in Asia pursue business opportunities in the U.S.
−Removed: The Bank believes its customers benefit from the Bank’s understanding of the Asian market through its physical presence, corporate and organizational ties in Asia, as well as the Bank’s international banking products and services.
+Added: The Bank believes its customers benefit from its deep understanding of the Asian market, which is supported by its physical presence, strong corporate and organizational ties in the region, and its international banking products and services.
The Bank believes this approach, combined with its senior management and Board of Directors’ ties to Asian business opportunities and Asian American communities, provides the Bank with a competitive advantage.
7 unchanged sentences
and Asia, the Bank provides a wide range of personal and commercial banking services to individuals and businesses.
−Removed: The Bank provides services to its customers in English and in over 10 other languages.
+Added: The Bank provides services to its customers in English, Spanish and various Asian languages and dialects.
In addition to offering traditional deposit products that include personal and business checking and savings accounts, money market, and time deposits, the Bank also offers foreign exchange, treasury management and wealth management services.
3 unchanged sentences
The integration of digital with brick-and-mortar channels has been an area of investment for the Bank, for both commercial and consumer banking.
−Removed: Our strategic priorities include the use of technology to innovate and expand commercial payments, treasury management products and services, and consumer banking.
+Added: Our strategic priorities include the use of technology to innovate and expand commercial payments, treasury management, and consumer banking products and services.
We have developed mobile and online banking platforms, which are continually enhanced to enrich our customer’s user experience, and which offer a full suite of banking services tailored to our customers’ unique needs.
3 unchanged sentences
The Consumer and Business Banking segment primarily provides financial products and services to consumer and commercial customers through the Company’s domestic branch network and digital banking platforms.
−Removed: The Commercial Banking segment primarily generates domestic commercial loans and deposits.
−Removed: The remaining centralized functions, including the corporate treasury activities of the Company and eliminations of inter-segment amounts, are aggregated and included in the Treasury and Other segment.
+Added: The Commercial Banking segment primarily generates commercial loans and deposits.
+Added: The remaining centralized functions, including the corporate treasury activities of the Company, tax credit investment activity, eliminations of inter-segment amounts, and centrally managed departments, are aggregated and included in the Treasury and Other segment.
For complete discussion and disclosure, see Item 7.
11 unchanged sentences
To achieve these objectives, our human resource programs have been designed to incorporate our core values of absolute integrity, customer orientation, creativity, respect and fairness, teamwork, expertise and professionalism, and selflessness.
−Removed: Embracing these core values position our employees to better serve our customers and pave the way for their future career advancement.
+Added: Embracing these core values positions our employees to better serve our customers and pave the way for their future career advancement.
We are committed to strengthening our recruiting process and growing internal talent to prepare for our next phase of growth.
We also seek to recognize our employees for their contributions and service to the Bank.
−Removed: As of December 31, 2024, we had approximately 3,100 full-time equivalent employees.
+Added: As of December 31, 2025, we had 3,350 full-time equivalent employees.
The majority of our workforce consisted of full-time employees who were located in our core markets in California, Texas, and New York.
−Removed: The Company’s full-time equivalent employees also included 230 employees located in China, Hong Kong, and Singapore.
+Added: The Company’s full-time equivalent employees also included approximately 300 employees located in China, Hong Kong, and Singapore.
None of our employees are subject to a collective bargaining agreement.
1 unchanged sentence
An experienced, dedicated and well-qualified workforce is essential in delivering high quality and reliable banking services to our customers and in managing the Company.
−Removed: We endeavor to attract, develop, and retain motivated individuals as part of our ongoing commitment in building a stronger workforce to serve our customers and communities.
+Added: We endeavor to attract, develop, and retain motivated individuals as part of our ongoing commitment in building a strong workforce to serve our customers and communities.
In 2025, we were able to continue our quality hiring efforts with nearly 600 external new hires.
1 unchanged sentence
We recognize the importance of employee development and career growth in supporting employee retention, which is one of the Company's strategic objectives.
−Removed: In 2024, 16% of our employees have advanced their careers within the Bank through over 510 internal promotions or new opportunities, which highlights our commitment to rewarding results-driven performance.
+Added: In 2025, approximately 16% of our employees advanced their careers within the Bank through 550 internal promotions or new opportunities, which highlights our commitment to rewarding results-driven performance.
We also provide a variety of resources to help employees grow in their current roles and acquire new skills for future advancement through continuing education and tuition reimbursement.
We celebrate our employees’ dedicated years of service to the Bank through our Milestone Anniversary Program, which offers rewards and recognition through gifts and events upon attaining certain service milestones.
−Removed: As of December 31, 2024, 335 of our employees have celebrated 20 years or more of service.
−Removed: Our dedication to results-driven performance earned us the recognition of the top-ranked performing bank in the $50 billion and above asset category in Bank Director’s 2024 Ranking Banking study, and among the top 10 in Forbes’ 2024 America’s Best Bank list.
−Removed: We have also been included in Newsweek’s 100 Most Loved Workplaces since 2022.
−Removed: The Company’s compensation and employee benefits expense of $551 million and $509 million, comprised 57% and 50% of total noninterest expense in 2024 and 2023, respectively.
+Added: As of December 31, 2025, over 350 of our employees had celebrated 20 years or more of service.
+Added: Our dedication to results-driven performance earned us the recognition of the top-ranked performing bank in the $50 billion and above asset category in Bank Director’s 2025 Ranking Banking study, and top three in the American Banker’s 2025 list of top-performing banks with more than $50 billion of assets.
Employee compensation packages include a competitive base salary and, subject to Company and individual performance, may include an annual cash and/or stock incentive bonus.
As part of our commitment to fair and equitable compensation programs, we regularly assess the current business environment and labor markets to review our compensation and benefits program for pay equity.
−Removed: The Bank also matches 75% of the U.S.
−Removed: employees’ contributions up to the first 6% of their eligible compensation and maintains a deferred compensation plan.
+Added: The Bank maintains a deferred compensation plan and matches 75% of the U.S.
+Added: employees’ contributions up to the first 6% of their eligible compensation.
+Added: MD&A — Results of Operations — Noninterest Expense in this Form 10-K for further discussion of compensation and employee benefits expense.
To foster a strong sense of ownership and to align the interests of our employees with our stockholders, restricted stock units (“RSUs”) are awarded to eligible employees under our stock incentive programs.
9 unchanged sentences
We also offer an Employee Assistance Program, which aids benefits-eligible employees and their household members with personal and professional issues.
−Removed: We apply a consistent approach towards employee policies, opportunities, benefits, and protections to all employees regardless of their locations, except if there are contradictions between individual state laws.
+Added: We apply a consistent approach towards employee policies, opportunities, benefits, and protections to all employees regardless of their locations, except if there are contradictions with applicable laws and regulations.
Commitment to Community
13 unchanged sentences
2012 - 2022 Executive Vice President and Chief Financial Officer of Associated Banc-Corp and Associated Bank, N.A.
−Removed: Kim 60 Executive Vice President, General Counsel and Corporate Secretary of the Company and the Bank since 2020;
−Removed: Executive Vice President, General Counsel and Secretary of Cathay General Bancorp and Cathay Bank.
Deborah Leerhsen
21 unchanged sentences
The Bank is regulated, supervised, and examined by the Federal Reserve, the California Department of Financial Protection and Innovation (“DFPI”), and, with respect to consumer laws, the Consumer Financial Protection Bureau (“CFPB”).
−Removed: As the insurer of the Bank’s deposits, the FDIC has back-up examination and other regulatory authority of the Bank as well.
−Removed: In addition, the Bank and its wholly-owned subsidiary, East West Bank (China) Limited, are regulated by foreign regulatory agencies in international jurisdictions where we have a presence, including China, Hong Kong and Singapore.
+Added: East West Bank is a California state-chartered bank, and its deposits are insured by the FDIC.
+Added: As the insurer of the Bank’s deposits, the FDIC also has back-up examination and other regulatory authority over the Bank.
+Added: In addition, the Bank and its foreign subsidiaries and branches are regulated by the foreign regulatory agencies in the international jurisdictions where we have a presence, including the People’s Bank of China, China’s National Financial Regulatory Administration, the Hong Kong Monetary Authority, the Hong Kong Securities and Futures Commission, and the Monetary Authority of Singapore.
East West also has a wholly-owned nonbank subsidiary, East West Markets, LLC ("East West Markets"), which is an SEC-registered broker-dealer and a member of the Financial Industry Regulatory Authority, Inc.
1 unchanged sentence
The Company is also subject to the disclosure and regulatory requirements under the Securities Act of 1933, as amended (the “Securities Act”), and Section 21E of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), and the rules and regulations adopted by the SEC thereunder.
−Removed: Our common stock is listed on the Nasdaq Global Select Market under the trading symbol “EWBC” and subject to Nasdaq rules for listed companies.
−Removed: Described below are certain provisions of selected statutes and regulations applicable to East West and the Bank.
−Removed: The descriptions are not intended to be complete, nor are they meant to fully address the statutes and regulations’ effects and potential effects on East West and the Bank, and the descriptions are qualified in their entirety by reference to the full text of the statutes and regulations.
+Added: Our common stock is listed on the Nasdaq Global Select Market under the trading symbol “EWBC” and we are subject to Nasdaq rules for listed companies.
+Added: Described below are certain provisions of selected statutes and regulations that are applicable to East West and the Bank and that have a material impact on our business.
+Added: The descriptions of these statutes and regulations are not intended to be complete, nor are they meant to fully address their effects and potential effects on East West and the Bank.
+Added: The following descriptions are qualified in their entirety by reference to the full text of the statutes and regulations.
A change in applicable statutes, regulations or regulatory policies may have a material effect on the Company’s business.
18 unchanged sentences
The Bank and its Subsidiaries
−Removed: East West Bank is a California state-chartered bank and a member of the Federal Reserve System, and its deposits are insured by the FDIC.
−Removed: The Bank’s operations in the U.S.
−Removed: are primarily regulated and supervised by the Federal Reserve and the DFPI, and its activities outside the U.S.
−Removed: are regulated and supervised by its U.S.
−Removed: regulators and the applicable regulatory authority in the host country in which each overseas office is located.
−Removed: Specific federal and state laws and regulations that are applicable to banks govern, among other things, their regulatory capital levels, the scope of their business, their investments, their reserves against deposits, the timing of the availability of deposited funds, and the nature and amount of collateral for certain loans.
+Added: East West Bank is subject to regulation and supervision governing, among other things, regulatory capital levels, the scope of its business, investments, reserves against deposits, the timing of the availability of deposited funds, and the nature and amount of collateral for certain loans.
Bank regulatory agencies also have extensive discretion to impose various restrictions on management or operations and to issue policies and guidance in connection with their supervisory and enforcement activities and examination policies.
−Removed: Regulation of Foreign Subsidiaries and Branches
−Removed: The Bank’s foreign subsidiary, East West Bank (China) Limited, is subject to applicable foreign laws and regulations, such as those implemented by the People’s Bank of China and the National Financial Regulatory Administration.
−Removed: East West Bank’s Hong Kong branch is subject to applicable foreign laws and regulations, such as those implemented by the Hong Kong Monetary Authority and the Hong Kong Securities and Futures Commission.
−Removed: The Bank’s Singapore representative office is subject to applicable foreign laws and regulations, such as those implemented by the Monetary Authority of Singapore.
Regulatory Capital Requirements
8 unchanged sentences
The Bank is also subject to additional capital requirements under the Prompt Corrective Action (“PCA”) regulations that implement Section 38 of the Federal Deposit Insurance Act (“FDIA”), as discussed below under the Prompt Corrective Action section.
−Removed: Regulatory Capital-Related Developments
−Removed: From time to time, the regulatory agencies propose changes and amendments to, and issue interpretations of, risk-based capital requirements and related reporting instructions.
−Removed: Such proposals and interpretations could, if implemented, affect our regulatory capital requirements and reported capital ratios.
−Removed: On July 27, 2023, the federal banking agencies jointly released a proposed rule, known as the “Basel III Endgame,” to implement the international capital standards issued by the Basel Committee on Banking Supervision.
−Removed: The Basel III Endgame proposal would revise the capital framework applicable to large banking organizations with $100 billion or more in total consolidated assets or with significant trading activity and, if finalized, would likely result in meaningfully increased capital requirements for those organizations.
−Removed: On September 10, 2024, the Vice Chair for Supervision of the Board of Governors of the Federal Reserve System announced that he will recommend re-proposing the Basel III Endgame rules.
−Removed: Under the expected re-proposal of the rules, banks with assets between $100 billion and $250 billion would no longer be subject to the Basel III Endgame changes, other than the requirement to recognize unrealized gains and losses of their securities in regulatory capital.
−Removed: The Company had total consolidated assets of less than $100 billion as of December 31, 2024, and therefore would not be subject to the Basel III Endgame requirements as proposed or as expected to be re-proposed.
−Removed: However, any Basel III Endgame requirements that are adopted and applied to banking organizations with $100 billion or more in total consolidated assets could reduce the benefits of growth beyond that size for a banking organization that has less than $100 billion in total consolidated assets, such as the Company.
Prompt Corrective Action
25 unchanged sentences
The Dodd-Frank Act established the CFPB, which has the authority to implement, examine and enforce compliance with federal consumer financial laws that apply to banking institutions with total consolidated assets exceeding $10 billion (such as the Bank) and their affiliates.
−Removed: The CFPB focuses its supervisory, examination, and enforcement efforts on, among other things:
+Added: The CFPB has historically focused its supervisory, examination, and enforcement efforts on, among other things:
• risks to consumers and compliance with federal consumer financial laws when evaluating the policies and practices of a financial institution;
6 unchanged sentences
Failure to comply with federal and state laws prohibiting unfair, abusive, or fraudulent business practices, untrue or misleading advertising and unfair competition, can subject the Bank to various penalties, including, but not limited to, enforcement actions, injunctions, fines or criminal penalties, punitive damages, restitution to consumers, and the loss of certain contractual rights or business opportunities and may also result in significant reputational harm.
−Removed: On October 22, 2024, the CFPB released a final rule to implement Section 1033 of the Dodd-Frank Act.
−Removed: Under the final rule, financial institutions are required, upon request, to make available to a consumer or third party authorized by the consumer certain information the Bank has concerning a consumer financial product or service covered by the rule, such as a credit card or a deposit account.
−Removed: In issuing this rule, the CFPB said that the rule will move the U.S.
−Removed: closer to an “open banking” system that will allow consumers to switch banks or other providers more easily.
−Removed: The final rule also requires, among other things, covered data providers, such as the Bank, to establish a developer interface that satisfies certain performance and data security specifications through which the data provider can receive requests for, and provide, specific types of data covered by the rule in an electronic, usable form to authorized third parties directly or through data aggregators.
−Removed: Under the final rule, the Bank will be prohibited from charging fees for maintaining the developer interface or providing access to such data.
−Removed: The Bank may also act as an authorized third party to request and access covered data from other financial institutions that are covered data providers.
−Removed: The final rule places data security, authorization, and other obligations on those authorized third parties, including limitations on secondary uses of the data received.
−Removed: Industry organizations have challenged the final rule in court and the litigation is ongoing.
−Removed: If the challenge is not successful, as a data provider, the Bank must comply with the rule beginning April 1, 2027.
−Removed: We are monitoring the status of the litigation and evaluating the impact of this rule.
−Removed: The final outcome of any proposed and final rules issued by the CFPB is uncertain as they may conflict with the rulemaking agenda and vision for the bureau under the Trump administration.
Federal Home Loan Bank and the Federal Reserve’s Reserve Requirements
3 unchanged sentences
The Federal Reserve requires all depository institutions to maintain reserves at specified levels against their transaction accounts either in the form of vault cash or an interest-bearing account at the Federal Reserve Bank (“FRB”), or a pass-through account as defined by the Federal Reserve.
−Removed: Effective March 26, 2020, the Federal Reserve reduced reserve requirement ratios to zero percent, eliminating the reserve requirement for all depository institutions.
+Added: Reserve requirements are currently set at zero percent.
The Bank is a member bank and stockholder of the FRB of San Francisco.
13 unchanged sentences
In addition, a bank generally may not extend credit to an affiliate unless the extension of credit is secured by specified amounts of collateral.
−Removed: The Dodd-Frank Act expanded the coverage and scope of the limitations on affiliate transactions, including by treating derivative transactions resulting in a bank’s credit exposure to an affiliate as covered transactions.
+Added: The Dodd-Frank Act expanded the coverage and scope of the limitations on affiliate transactions by treating derivative transactions resulting in a bank’s credit exposure to an affiliate as covered transactions.
In addition, the Volcker Rule under the Dodd-Frank Act establishes certain prohibitions, restrictions and requirements (known as “Super 23A” and “Super 23B”) on transactions between a covered fund and a banking entity that serves as an investment manager, investment adviser, organizer and offeror, or sponsor with respect to that covered fund, regardless of whether the banking entity has an ownership interest in the fund.
4 unchanged sentences
Under the CRA, an IDI has a continuing and affirmative obligation to help serve the credit needs of its communities, including low- and moderate-income borrowers and neighborhoods.
−Removed: The Federal Reserve periodically evaluates a state member bank’s performance under applicable performance criteria and assign a rating of “outstanding,” “satisfactory,” “needs to improve” or “substantial noncompliance.” The Federal Reserve takes this performance into account when reviewing applications by banks and their parent companies to expand branches, relocate, add subsidiaries and affiliates, expand into new financial activities and merge with or acquire other financial institutions.
+Added: The Federal Reserve periodically evaluates a state member bank’s performance under applicable performance criteria and assigns a rating of “outstanding,” “satisfactory,” “needs to improve” or “substantial noncompliance.” The Federal Reserve takes this performance into account when reviewing applications by banks and their parent companies to expand branches, relocate, add subsidiaries and affiliates, expand into new financial activities and merge with or acquire other financial institutions.
Unsatisfactory CRA performance may result in the denial of such applications.
−Removed: Based on the most recent CRA examination as of March 8, 2021, the Bank was rated “outstanding”.
−Removed: On October 24, 2023, the federal banking agencies issued a final rule revising their framework for evaluating banks’ records of community reinvestment under the CRA.
−Removed: The final rule provides that banks with assets of at least $2 billion, such as the Bank, are considered large banks and their retail lending, retail services and products, community development financing, and community development services are subject to periodic evaluation.
−Removed: Under the final rule, depending on a large bank’s geographic distribution of lending, the evaluation of retail lending may include assessment areas in which the bank extends loans but does not operate any deposit-taking facilities, in addition to assessment areas in which the bank has deposit taking facilities.
−Removed: Industry organizations have challenged the final rule in court, and on March 29, 2024, the United States District Court for the Northern District of Texas granted an injunction and stay of the final rule.
−Removed: The final outcome of such challenges remains uncertain.
+Added: On October 24, 2023, the federal banking agencies issued a final rule revising their framework for evaluating banks’ records of community investment under the CRA.
+Added: On July 16, 2025, the agencies issued a proposal to rescind the October 2023 final rule and reinstate the CRA framework that existed prior to the October 2023 final rule.
+Added: The Bank received a rating of “Outstanding” in its most recent performance evaluation, which was conducted as of August 12, 2024 using the CRA framework that existed prior to the October 2023 final rule.
FDIC Deposit Insurance Assessments
4 unchanged sentences
The assessment rate is calculated based on an institution’s risk profile, including capital adequacy, asset quality, management, earnings, liquidity and sensitivity to market risk ratings, certain financial measures to assess an institution’s ability to withstand asset related stress and funding related stress, and a measure of loss severity that estimates the relative magnitude of potential losses to the FDIC in the event of the Bank’s failure.
−Removed: In October 2022, the FDIC adopted a final rule, applicable to all IDIs, to increase the initial base deposit insurance assessment rate schedules uniformly by two basis points (“bps”) to increase the likelihood that the DIF reserve ratio reaches the statutory minimum of 1.35 percent by the statutory deadline of September 30, 2028.
−Removed: The increase in rates took effect in the first quarterly assessment period of 2023 and will remain in effect unless and until the reserve ratio of the DIF meets or exceeds 2 percent.
−Removed: In November 2023, the FDIC approved a final rule to implement a special deposit insurance assessment to recover losses to the DIF arising from the protection of uninsured depositors following the receiverships of failed institutions in the spring of 2023.
−Removed: Under the final rule, the assessment base for the special assessment is equal to an IDI’s estimated uninsured deposits, reported for the quarter ended December 31, 2022, minus the first $5 billion in estimated uninsured deposits.
−Removed: The FDIC will collect the special assessment over eight initial quarterly assessment periods starting with the first quarter of 2024, at a quarterly rate of 3.36 bps.
−Removed: The Company recognized the entire initial FDIC special assessment charge (the “FDIC charge”) of approximately $70 million in the fourth quarter of 2023.
−Removed: However, depending on future adjustments to the DIF’s estimated loss, the FDIC retained the ability to cease collection early, extend the special assessment collection period, or impose a one-time final shortfall assessment.
−Removed: During 2024, the FDIC updated its estimate of the DIF’s losses and projected that the special assessment would be collected for an additional two quarters beyond the initial eight-quarter collection periods, at an estimated quarterly rate of 1.69 bps.
−Removed: Accordingly, the Company recognized an additional FDIC charge of $9 million in 2024.
+Added: A 2022 FDIC rule increased the initial base deposit insurance assessment rate schedules uniformly by two basis points (“bps”) beginning in the first quarterly assessment period of 2023, and this increase will remain in effect until the reserve ratio of the DIF meets or exceeds 2 percent.
+Added: In November 2023, the FDIC approved a final rule to implement a special deposit insurance assessment for eight quarters, starting with the first quarter of 2024, to recover losses to the DIF arising from bank failures that occurred in the Spring of 2023.
+Added: The Company recognized the entire initial FDIC special assessment charge (the “FDIC charge”) of approximately $70 million in the fourth quarter of 2023, and recognized additional charges of $9 million in 2024 due to changes in the FDIC’s estimate of the DIF losses.
+Added: In December 2025, the FDIC updated the estimated DIF losses and projected that the amount collected through the initial eight-quarter collection period would recover the entire amount of estimated losses.
+Added: Accordingly, the Company recorded $9 million of FDIC special assessment reversals in 2025.
The FDIC may terminate a depository institution’s deposit insurance upon a finding that the institution’s financial condition is unsafe or unsound, that the institution has engaged in unsafe or unsound practices, or that the institution has violated any applicable rule, regulation, condition, or order imposed by the FDIC.
18 unchanged sentences
The Bank’s privacy practices and the effectiveness of its systems to protect consumer privacy are subjects covered in the Federal Reserve’s periodic compliance examinations.
−Removed: The Federal Reserve and state regulators, as well as the SEC, CFPB and other self-regulatory organizations, regularly issue guidance on cybersecurity practices and procedures that is intended to enhance cybersecurity risk management among financial institutions and their holding companies and affiliates.
−Removed: For example, the interagency council of the federal banking agencies, the Federal Financial Institutions Examination Council (“FFIEC”), has issued several policy statements and other guidance for banks in light of the growing risk posed by cybersecurity threats.
+Added: The interagency council of the federal banking agencies, the Federal Financial Institutions Examination Council (“FFIEC”), as well as the SEC, regularly issue guidance on cybersecurity practices and procedures that is intended to enhance cybersecurity risk management among financial institutions and their holding companies and affiliates.
+Added: For example, the FFIEC has issued several policy statements and other guidance for banks in light of the growing risk posed by cybersecurity threats.
The FFIEC has continued to focus on such matters as compromised customer credentials, cyber resilience and business continuity planning.
2 unchanged sentences
Effective December 2023, the SEC also has imposed Form 8-K disclosure obligations for a material cybersecurity incident, among other cybersecurity related disclosure obligations.
+Added: On April 8, 2025, the U.S.
+Added: Department of Justice (the “DOJ”) final rule implementing Executive Order 14117 (“Preventing Access to Americans’ Bulk Sensitive Personal Data and U.S.
+Added: Government-Related Data by Countries of Concern”) took effect, with certain specified compliance requirements taking effect on October 6, 2025.
+Added: The final rule prohibits or restricts certain transactions involving access by “countries of concern” or “covered persons” to “government-related data” or “bulk U.S.
+Added: sensitive personal data.” The list of countries of concern includes, among others, the People’s Republic of China, including Hong Kong and Macau.
+Added: The final rule imposes certain diligence, security, audit and record-keeping requirements, and the Bank and its subsidiary, EWCN, have taken the necessary steps to comply with the rule, including by restricting access to data by subsidiaries, affiliates, and vendors.
Consumer data privacy and data protection are also the subject of state laws.
−Removed: For example, the Bank is subject to the California Consumer Privacy Act (“CCPA”).
−Removed: This statute grants consumers several rights, including the right to request disclosure of information collected about them and whether that information has been sold or shared with others, the right to request correction of information, the right to request deletion of personal information (subject to certain exceptions), and the right to opt out of the sale of their personal information.
+Added: For example, the Bank is subject to the California Consumer Privacy Act.
+Added: Among other provisions, this statute grants consumers several rights, including the right to request to access, correct, and delete their personal information (subject to certain exceptions), and the right to opt out of the sale of their personal information and sharing of personal information for certain targeted advertising purposes.
However, a consumer does not have these rights with respect to information that is collected, processed, sold, or disclosed pursuant to the GLBA or the California Financial Information Privacy Act.
−Removed: The CCPA was amended by the California Privacy Rights Act.
−Removed: A new agency, the California Privacy Protection Agency, was established to enforce California privacy law.
−Removed: The Personal Information Protection Law (“PIPL”), the Cybersecurity Law and the Data Security Law form a regulatory framework for privacy and data protection in China.
−Removed: The PIPL establishes guiding principles on the protection of a Chinese citizen’s personal information and applies to entities operating in China.
−Removed: In limited circumstances, the PIPL also applied to certain processing activities of Chinese citizen’s personal information outside China.
−Removed: The Cybersecurity Law focuses on cybersecurity concerns and requires network operators to implement measures to safeguard the security of networks and systems in China.
−Removed: The Data Security Law complements the PIPL and Cybersecurity Law by addressing broader data security issues, emphasizing the protection of critical data infrastructure and promoting a risk-based approach to data security to address China’s national security concerns.
−Removed: On September 30, 2024, China released the Network Data Security Management Regulation, which becomes effective on January 1, 2025.
−Removed: The Network Data Security Management Regulation was formulated under the framework pillars of the PIPL and the Cybersecurity Law and provides practical implementation requirements and guidance on various aspects of data compliance, covering both personal information and certain non-personal information categories.
−Removed: New supporting guidelines and standards are expected as China's cybersecurity, data security, and personal information protection framework continues to evolve.
−Removed: All these changes have potential impact on the business and operations of our Bank and its subsidiary, East West Bank (China) Limited.
−Removed: Climate-Related Risk Management
−Removed: In recent years, the federal banking agencies increased their focus on climate-related risks affecting the operations of banks, the communities they serve and the broader financial system.
−Removed: The agencies enhanced their supervisory expectations regarding banks’ climate risk management practices, including by adopting guidance that encourages large banking organizations to, among other things:
−Removed: evaluate the potential impact of climate-related risks on the bank’s financial condition, operations and business objectives as part of its strategic planning process;
−Removed: account for the effects of climate change in stress testing scenarios and systemic risk assessments;
−Removed: revise expectations for credit portfolio concentrations based on climate-related factors;
−Removed: and prepare for the transition risks to the bank associated with the adjustment to a low-carbon economy and related changes in laws, regulations, governmental policies, technology, and consumer behavior and expectations.
−Removed: States such as California are taking similar actions on climate-related financial risks.
−Removed: In October 2023, California Governor Gavin Newsom signed into law Senate Bill 253, the Climate Corporate Data Accountability Act (“CCDAA”) and Senate Bill 261, the Climate-Related Financial Risk Act (“CRFRA”).
−Removed: The CCDAA is applicable to U.S.-organized entities that do business in California with annual revenue in excess of $1 billion.
−Removed: Subject to the adoption of implementing regulations by the California Air Resources Board (“CARB”), these entities will need to file annual reports publicly disclosing their direct greenhouse gas (“GHG”) emissions from operations (“Scope 1 emissions”), indirect GHG emissions from energy use (“Scope 2 emissions”) and indirect upstream and downstream supply-chain GHG emissions (“Scope 3 emissions”).
−Removed: The reporting requirements related to Scope 1 and 2 emissions will begin in 2026, while the reporting requirements of Scope 3 emissions will begin in 2027.
−Removed: The CRFRA requires U.S.-organized entities that do business in California, with annual revenues over $500 million to prepare biennial reports disclosing climate-related financial risk and the measures they have adopted to reduce and adapt to that risk.
−Removed: The initial round of the climate risk disclosure reports will be due by January 1, 2026.
−Removed: On September 27, 2024, California Governor Gavin Newsom signed Senate Bill 219 (“SB 219”) into law, which extended the date for the CARB to adopt the regulation for the CCDAA to July 1, 2025.
−Removed: SB 219 also clarified that reports under the CCDAA would be permitted to be consolidated at the parent company level and that subsidiaries subject to the law would not be required to file separate reports in addition to a parent-level report.
−Removed: The reporting requirements for Scope 1 and Scope 2 emissions under the CCDAA remain in 2026;
−Removed: reporting entities will be required to report Scope 3 emissions at a date in 2027 to be specified by the CARB.
−Removed: The first deadline for required reports under CRFRA remains on or before January 1, 2026.
−Removed: The Company is a reporting entity under both laws and may incur compliance, maintenance, and remediation costs to conform to such requirements.
+Added: California also adopted new rules effective January 1, 2026, with different timing requirements depending on obligations related to cyber audits, risk assessments, and automated decision-making.
+Added: Despite these evolving requirements, the Bank is not in the business of selling consumer or customer data.
+Added: The Bank’s subsidiary, EWCN, operates under China’s privacy, cybersecurity, and data security regulatory framework, which includes the Personal Information Protection Law, the Cybersecurity Law as amended effective January 1, 2026, the Data Security Law, and the Network Data Security Management Regulation that was effective January 1, 2025.
+Added: EWCN has taken the necessary steps to comply with these laws, including adherence to local laws and regulations related to cross-border data sharing, and maintains policies, controls, and governance procedures designed to comply with these requirements, and also conducts periodic reviews of its data handling and network security practices.
+Added: As China’s regulatory framework continues to evolve, EWCN will monitor developments and update its compliance program as applicable.
+Added: Climate-Related Laws and Regulations
+Added: During 2025, the federal banking agencies reduced their emphasis on climate-related risks by acknowledging that existing safety and soundness standards already require effective risk management practices.
+Added: However, certain states, such as California, have continued to highlight climate-related financial risks as part of their sustainability objectives.
+Added: In October 2023, California Senate Bill No.
+Added: 253, the Climate Corporate Data Accountability Act (“SB 253”) and Senate Bill No.
+Added: 261, the Climate-Related Financial Risk Act (“SB 261”) were signed into law.
+Added: SB 253 requires U.S.
+Added: companies with annual revenues exceeding $1 billion that do business in California to report their Scope 1 and 2 greenhouse gas (“GHG”) emissions annually starting in 2026;
+Added: and Scope 3 GHG emissions starting in 2027.
+Added: SB 261 applies to U.S.
+Added: companies with annual revenues over $500 million that do business in California and requires disclosure of climate-related financial risks and mitigation measures taken to address such risks with the first report due on January 1, 2026, and biennially thereafter.
+Added: On December 9, 2025, California Air Resources Board communicated an August 10, 2026 deadline for the initial Scope 1 and Scope 2 GHG emissions reports required under SB 253, while reporting under SB 261 is deferred pending the outcome of litigation challenging the legislation.
+Added: The Company is a reporting entity under both SB 253 and SB 261 and has engaged a third-party firm to support compliance with these laws.
Resolution Planning
−Removed: On June 20, 2024, the FDIC released a final rule that requires covered IDIs to develop and submit detailed plans demonstrating how they could be resolved in an orderly and timely manner in the event of receivership.
+Added: FDIC rules require covered IDIs to develop and submit detailed plans demonstrating how they could be resolved in an orderly and timely manner in the event of receivership.
IDIs with total assets of $100 billion or more are required to submit full resolution plans, and IDIs with total assets between $50 billion and $100 billion, including the Bank, are required to submit more limited informational filings.
−Removed: Going forward, the Bank will be required to submit informational filings every three years and interim supplements annually.
−Removed: Under the final rule, if the FDIC deemed a resolution plan or informational filing not credible and the IDI failed to resubmit a credible plan, the IDI could become subject to an enforcement action.
−Removed: The Company has established a management-level working group to meet the requirements under the final rule for timely submission on or before October 1, 2025.
−Removed: Potential Regulatory Reforms
−Removed: On August 29, 2023, the federal banking agencies jointly released a proposed rule that would require bank holding companies and non-consolidated banks with total assets of $100 billion or more to issue and maintain minimum amounts of long-term debt.
−Removed: The Company has total consolidated assets of less than $100 billion and would not be subject to the long-term debt requirements if they are finalized as proposed.
−Removed: However, by imposing additional costs on bank holding companies with $100 billion or more in total consolidated assets, this rule proposal could reduce the benefits of growth beyond that size for a bank holding company that has less than $100 billion in total consolidated assets, such as the Company.
−Removed: On July 30, 2024, the FDIC issued a proposed rule that would revise the FDIC’s regulations governing the classification and treatment of brokered deposits.
−Removed: The proposal would require many IDIs to classify a greater amount of their deposits obtained with the involvement of third parties as brokered deposits.
−Removed: An increase in brokered deposits on the Company’s balance sheet could, among other consequences, increase the Company’s deposit insurance assessment costs.
−Removed: On September 17, 2024, the U.S.
−Removed: Department of Justice (the “DOJ”) withdrew its 1995 Bank Merger Guidelines and announced that it will instead evaluate the competitive impact of bank mergers using its 2023 Merger Guidelines that the DOJ applies to mergers in all industries.
−Removed: Compared to the 1995 Bank Merger Guidelines, the 2023 Merger Guidelines set forth more stringent market concentration limits and add several largely qualitative bases on which the DOJ may challenge a merger.
−Removed: While the effect of these changes in the DOJ’s bank merger antitrust policy for particular transactions remains unclear, these changes may make it more difficult and/or costly for banks to obtain regulatory approval for an acquisition or otherwise result in more onerous conditions to obtain approval for an acquisition.
−Removed: On January 20, 2025, President Trump released an executive memo, “Regulatory Freeze Pending Review,” halting all rulemaking processes at executive agencies.
−Removed: The memo, which does not apply to independent agencies including several federal financial regulators, directs all executive agencies not to propose or issue any rule without the approval of an appointed agency head or the President.
−Removed: The memo also directs executive agencies to withdraw any rules that have been submitted to the Office of the Federal Register but have not been published.
−Removed: In addition, the memo directs executive agencies to consider postponing the effective dates of rules that have been finalized and published in the Federal Register, but have not become effective yet.
−Removed: The Company expects the Trump administration will seek to implement a regulatory reform agenda that is significantly different than that of the Biden administration, which will impact the rulemaking, supervision, examination and enforcement priorities of the federal banking agencies, even if those agencies are not directly subject to the executive memo.
+Added: If the FDIC deemed a resolution plan or informational filing not credible and the IDI then failed to resubmit a credible plan, the IDI could become subject to an enforcement action.
+Added: The Bank completed and submitted its informational filing on October 1, 2025.
+Added: 2025 Legislative Developments
+Added: In June 2025, California enacted Senate Bill No.
+Added: 132 (“SB 132”), requiring banks and financial institutions to adopt a single sales factor for income apportionment, effective for tax years beginning on or after January 1, 2025.
+Added: Prior to SB 132, financial institutions had been required to use an equally weighted three-factor apportionment formula, which considered property, payroll and sales equally in apportioning income for California tax purposes.
+Added: In July 2025, the One Big Beautiful Bill Act (“OBBBA”) was signed into law, introducing significant tax changes.
+Added: The OBBBA extends or makes permanent various tax provisions that were originally enacted in the 2017 Tax Cuts and Jobs Act and were set to expire at the end of 2025.
+Added: The OBBBA features modified versions of individual and business tax relief proposals, and other new tax relief measures.
+Added: In addition, it includes various revenue-raising measures, including changes to certain Inflation Reduction Act clean energy tax credits and various limits on business and individual tax deductions, that are intended to offset part of the cost of the legislation.
+Added: The Company has been evaluating the impact of the OBBBA on its business and consolidated financial statements.
+Added: In July 2025, the Guiding and Establishing National Innovation for U.S.
+Added: Stablecoins Act, or the “GENIUS Act,” was signed into law, establishing a federal licensing and supervisory framework for payment stablecoins and their issuers.
+Added: The GENIUS Act may accelerate and increase the competition that non-traditional financial institutions pose to banks’ payment services, but may also create opportunities for banks to hold stablecoin reserve assets, custody stablecoins, or issue stablecoins.
+Added: Several key provisions of the GENIUS Act require federal regulatory agencies to adopt implementing regulations, and the Act will take effect the earlier of 18 months after its enactment or 120 days after the agencies issue final implementing regulations.
Future Legislation, Regulation and Supervision Activities
−Removed: New statutes, regulations and policies that contain wide-ranging proposals for altering the structures, regulations and competitive relationships of financial institutions and public companies operating in the U.S.
−Removed: are regularly adopted.
+Added: New statutes, regulations and policies that contain wide-ranging proposals for altering the structures, regulations and competitive relationships of financial institutions and public companies are regularly adopted.
Such changes to applicable statutes, regulations, and policies may change the Company’s operating environment in substantial and unpredictable ways, increase the Company’s cost of conducting business, impede the efficiency of internal business processes, subject the Company to increased supervision activities and disclosure and reporting requirements, and restrict or expand the activities in which the Company may engage.
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