What the changes say
- Liquidity risk is quantified through $17.0 billion of uninsured deposits and potential rapid electronic withdrawals.
- New risks broaden technology and regulatory exposure to third-party outages, marketing communications, privacy, FCRA, and BSA compliance.
- Climate impacts, larger competitors, and American National integration add business and execution risks.
- CRE exposure remains material, with $8.4 billion of loans equal to 27% of total loans and 183% of risk-based capital.
What changed since the prior 10-K
New
- NewCredit Risks
2023, approaching the Federal Reserve’s two percent inflation objective. The U.S. economy had strong GDP growth, loosening of tight labor markets and slowed inflation in 2025
Tariffs, sanctions, geopolitical tensions, unemployment, and inflation could weaken borrowers, real estate collateral, deposits, loan demand, and asset quality.
- NewLiquidity and Interest Rate Risks
In the aftermath of the significant bank failures that occurred in 2023, the federal banking agencies have enhanced their scrutiny of banks' liquidity risk management
Rapid withdrawals by uninsured depositors could force expensive or unavailable funding; uninsured and uncollateralized deposits totaled $9.4 billion, or 26.5% of deposits.
- NewOperational Risks
We rely heavily on communications and information systems and networks to conduct our business. Any failures or disruptions to our third parties’ communications and information systems and networks could materially and adversely affect our business
Failures, cyberattacks, or disruptions affecting Associated Bank or third-party technology networks could interrupt deposits, lending, customer management, and other operations.
- NewOperational Risks
Both to comply with applicable existing law and to prepare for potential expansions in laws requiring protection of personal information, we must endeavor to maintain adequate privacy and security measures, which require significant investments in resources and ongoing attention
Improper marketing emails, calls, or texts could trigger TCPA, CAN-SPAM, or consumer-protection claims, including costly class actions.
- NewOperational Risks
While we strive to ensure that all of our marketing communications comply with the requirements set forth in the CAN-SPAM Act, any violations could result in the FTC seeking civil penalties against us
Failure to meet FCRA, privacy, and data-processing obligations could bring regulatory scrutiny, litigation, and costly changes to business practices.
- NewOperational Risks
Climate-related risks could adversely affect our business and performance, including indirectly through impacts on our customers
Floods, wildfires, storms, chronic climate changes, and transition to a low-carbon economy could weaken customers and their creditworthiness.
- NewStrategic and External Risks
Due to their size, many competitors may be able to achieve economies of scale and, as a result, may offer a broader range of products and services as well as better pricing for those products and services than we can
Larger competitors may offer broader products and better pricing, weakening Associated Bank’s customer relationships, growth, profitability, and competitive position.
- NewStrategic and External Risks
We may not be able to successfully integrate American National or to realize the anticipated benefits of the acquisition
Integrating American National could cause employee, customer, deposit, loan, revenue, systems, control, and operating problems and fail to deliver expected benefits.
- NewLegal, Regulatory, Compliance and Reputational Risks
Non-compliance with the USA PATRIOT Act, BSA or other laws and regulations could result in fines or sanctions
Violations of USA PATRIOT Act or BSA requirements for customer identification, suspicious-activity reporting, and anti-money-laundering controls could result in fines or sanctions.
Dropped
- DroppedLiquidity and Interest Rate Risks
The proportion of our deposit account balances that exceed FDIC insurance limits may expose the Bank to enhanced liquidity risk in times of financial distress
- DroppedOperational Risks
We rely heavily on communications and information systems to conduct our business. We have experienced cybersecurity attacks in the past and our communications and information systems may experience an interruption or breach in security from future attacks
- DroppedOperational Risks
We and our vendors are subject to a number of U.S. federal, state, and local laws and regulations, industry standards and other requirements relating to consumer privacy and data protection. For more information, see “Privacy, Data Protection, and Cybersecurity” in the Item 1, Business section above
- DroppedOperational Risks
Any actual or perceived failure to comply with evolving regulatory frameworks around the development and use of AI could adversely affect our business, results of operations, and financial condition
- DroppedOperational Risks
Climate change and related legislative and regulatory initiatives may result in operational changes and expenditures that could significantly impact our business
- DroppedOperational Risks
The Corporation is subject to a variety of risks arising from ESG/DEI matters, which include, among other things, climate change, human capital, and human rights. Risks arising from such matters may adversely affect, among other things, our reputation and the market price of our securities
- DroppedStrategic and External Risks
Our earnings are significantly affected by the fiscal and monetary policies of the federal government and its agencies
- DroppedStrategic and External Risks
In addition, the DOJ withdrew from the 1995 Bank Merger Guidelines and announced that it would consider bank mergers under its 2023 Merger Guidelines, which includes a brief bank merger addendum
- DroppedLegal, Regulatory, Compliance and Reputational Risks
We could continue to experience adjustments in FDIC insurance assessments
- DroppedRisks Related to an Investment in Our Securities
Our ability to originate residential mortgage loans for portfolio has been adversely affected by the increased competition resulting from the unprecedented involvement of the U.S. government and GSEs in the residential mortgage market
Excess uninsured deposits could heighten liquidity risk during financial distress.
Reworded
- 80% rewrittenLegal, Regulatory, Compliance and Reputational Risks
The Bank faces risks related to the adoption of future legislation and potential changes in federal regulatory agency leadership, policies, and priorities
The discussion now says 2026 midterm elections could change banking legislation prospects and refers to leadership changes under the current Administration.
- 78% rewrittenRisks Related to an Investment in Our Securities
An investment in our common stock is not an insured deposit
No substantive change; the risk still says common stock is uninsured and investors could lose some or all of their investment.
- 77% rewrittenLegal, Regulatory, Compliance and Reputational Risks
We are subject to extensive government regulation and supervision
The text changes Associated Bank to the Bank and says regulatory changes are expected to continue under the current Administration.
- 74% rewrittenLegal, Regulatory, Compliance and Reputational Risks
Fee revenues from overdraft protection programs constitute a significant portion of our noninterest income and may become subject to increased supervisory scrutiny
Reported overdraft-fee revenue increased from approximately $16 million in 2024 to $16.1 million in 2025, while citing previous CFPB and OCC leadership.
Was: Fee revenues from overdraft protection programs constitute a significant portion of our noninterest income and have become subject to increased supervisory scrutiny
- 69% rewrittenStrategic and External Risks
Acquisitions may be delayed, impeded, or prohibited due to regulatory issues
The acquisition discussion now specifically identifies the proposed American National transaction, while removing the statement that approvals have become substantially harder.
- 69% rewrittenCredit Risks
Changes and instability in economic conditions, geopolitical matters and financial markets, including a contraction of economic activity, could adversely impact our business, results of operations and financial condition
No substantive change; the risk continues to cover economic contraction, interest rates, Federal Reserve policy, asset quality, deposits, and loan demand.
- 64% rewrittenCredit Risks
CRE lending may expose us to increased lending risks
CRE loans remained $8.4 billion, but declined to 27% of loans and 183% of risk-based capital; repayment risks from property operations and regulation were added.
- 62% rewrittenLiquidity and Interest Rate Risks
Changes in interest rates could reduce the value of our investment securities holdings which would increase our accumulated other comprehensive loss and thereby negatively impact stockholders' equity
The portfolio measure changed from $8.5 billion including FHLB and Federal Reserve Bank stocks with 5.3-year duration to $5.4 billion of AFS securities with 3.2-year duration.
- 60% rewrittenCredit Risks
Changes in U.S. trade policies, including the imposition of tariffs and retaliatory tariffs, may adversely impact our business, financial condition, and results of operations
- 54% rewrittenStrategic and External Risks
We operate in a highly competitive industry and market area
- 49% rewrittenLegal, Regulatory, Compliance and Reputational Risks
Changes in requirements relating to the standard of conduct for broker-dealers under applicable federal and state law may adversely affect our business
- 47% rewrittenLegal, Regulatory, Compliance and Reputational Risks
The Bank is periodically examined for mortgage-related issues, including mortgage loan and default services, fair lending, and mortgage banking
- 47% rewrittenLegal, Regulatory, Compliance and Reputational Risks
Negative publicity could damage our reputation
- 44% rewrittenStrategic and External Risks
Consumers may decide not to use banks to complete their financial transactions
- 29% rewrittenLiquidity and Interest Rate Risks
We are subject to interest rate risk
- 28% rewrittenOperational Risks
Unauthorized disclosure of sensitive or confidential client or customer information (including personal information), whether through a cyber-attack, other breach of our computer systems or otherwise, could severely harm our business
Was: Unauthorized disclosure of sensitive or confidential client or customer information, whether through a cyber-attack, other breach of our computer systems or otherwise, could severely harm our business
- 25% rewrittenOperational Risks
Changes in the federal, state, or local tax laws may negatively impact our financial performance
- 25% rewrittenOperational Risks
Severe weather, natural disasters, public health issues, civil unrest, acts of war or terrorism, and other external events could significantly impact our ability to conduct business
- 23% rewrittenLiquidity and Interest Rate Risks
The impact of interest rates on our mortgage banking business can have a significant impact on revenues
- 23% rewrittenStrategic and External Risks
Fiscal challenges facing the U.S. government could negatively impact financial markets which in turn could have an adverse effect on our financial position or results of operations
- 22% rewrittenOperational Risks
We are dependent upon third parties for certain information system, data management and processing services, and to provide key components of our business infrastructure
- 22% rewrittenOperational Risks
We are subject to certain industry standards regarding our credit card-related services. Failure to meet those standards may significantly impact our ability to offer these services
- 21% rewrittenOperational Risks
From time to time, the Corporation engages in acquisitions, including acquisitions of depository institutions. The integration of core systems and processes for such transactions often occurs after the closing, which may create elevated risk of cyber incidents
All 66 risk factors
Headings as the filing states them, in filing order.
Credit Risks
- 01Changes and instability in economic conditions, geopolitical matters and financial markets, including a contraction of economic activity, could adversely impact our business, results of operations and financial condition69% rewritten
- 022023, approaching the Federal Reserve’s two percent inflation objective. The U.S. economy had strong GDP growth, loosening of tight labor markets and slowed inflation in 2025New
- 03Changes in U.S. trade policies, including the imposition of tariffs and retaliatory tariffs, may adversely impact our business, financial condition, and results of operations60% rewritten
- 04Our allowance for credit losses on loans may be insufficient
- 05We are subject to lending concentration risks
- 06CRE lending may expose us to increased lending risks64% rewritten
- 07We depend on the accuracy and completeness of information furnished by and on behalf of our customers and counterparties
- 08Lack of system integrity or credit quality related to funds settlement could result in a financial loss
- 09We are subject to environmental liability risk associated with lending activities
Liquidity and Interest Rate Risks
- 10Impairment of our access to liquidity could affect our ability to meet our obligations
- 11In the aftermath of the significant bank failures that occurred in 2023, the federal banking agencies have enhanced their scrutiny of banks' liquidity risk managementNew
- 12Adverse changes to our credit ratings could limit our access to funding and increase our borrowing costs
- 13We are subject to interest rate risk29% rewritten
- 14The impact of interest rates on our mortgage banking business can have a significant impact on revenues23% rewritten
- 15Changes in interest rates could reduce the value of our investment securities holdings which would increase our accumulated other comprehensive loss and thereby negatively impact stockholders' equity62% rewritten
- 16Changes in interest rates could reduce the value of our residential mortgage-related securities and MSRs, which could negatively affect our earnings
- 17We rely on dividends from our subsidiaries for most of our cash flow
Operational Risks
- 18We face significant operational risks due to the high volume and the high dollar value nature of transactions we process
- 19Unauthorized disclosure of sensitive or confidential client or customer information (including personal information), whether through a cyber-attack, other breach of our computer systems or otherwise, could severely harm our business28% rewritten
- 20From time to time, the Corporation engages in acquisitions, including acquisitions of depository institutions. The integration of core systems and processes for such transactions often occurs after the closing, which may create elevated risk of cyber incidents21% rewritten
- 21We rely heavily on communications and information systems and networks to conduct our business. Any failures or disruptions to our third parties’ communications and information systems and networks could materially and adversely affect our businessNew
- 22We are subject to certain industry standards regarding our credit card-related services. Failure to meet those standards may significantly impact our ability to offer these services22% rewritten
- 23Both to comply with applicable existing law and to prepare for potential expansions in laws requiring protection of personal information, we must endeavor to maintain adequate privacy and security measures, which require significant investments in resources and ongoing attentionNew
- 24While we strive to ensure that all of our marketing communications comply with the requirements set forth in the CAN-SPAM Act, any violations could result in the FTC seeking civil penalties against usNew
- 25We are dependent upon third parties for certain information system, data management and processing services, and to provide key components of our business infrastructure22% rewritten
- 26The potential for business interruption exists throughout our organization
- 27Changes in the federal, state, or local tax laws may negatively impact our financial performance25% rewritten
- 28Impairment of investment securities, goodwill, other intangible assets, or DTAs could require charges to earnings, which could result in a negative impact on our results of operations
- 29Failure to appropriately administer or manage our investment management and asset servicing businesses properly could put the related earnings at risk
- 30Climate-related risks could adversely affect our business and performance, including indirectly through impacts on our customersNew
- 31Severe weather, natural disasters, public health issues, civil unrest, acts of war or terrorism, and other external events could significantly impact our ability to conduct business25% rewritten
Strategic and External Risks
- 32Significant changes to the size, structure, powers and operations of the federal government may cause economic disruptions that could, in turn, adversely impact our business, results of operations and financial condition
- 33Our financial condition and results of operations could be negatively affected if we fail to grow or fail to manage our growth effectively
- 34We operate in a highly competitive industry and market area54% rewritten
- 35Due to their size, many competitors may be able to achieve economies of scale and, as a result, may offer a broader range of products and services as well as better pricing for those products and services than we canNew
- 36Fiscal challenges facing the U.S. government could negatively impact financial markets which in turn could have an adverse effect on our financial position or results of operations23% rewritten
- 37Consumers may decide not to use banks to complete their financial transactions44% rewritten
- 38Our profitability depends significantly on economic conditions in the states within which we do business
- 39The earnings of financial services companies are significantly affected by general business and economic conditions
- 40New lines of business or new products and services may subject us to additional risk
- 41Failure to keep pace with technological change could adversely affect our business
- 42We may be adversely affected by risks associated with potential and completed acquisitions
- 43Acquisitions may be delayed, impeded, or prohibited due to regulatory issues69% rewritten
- 44We may not be able to successfully integrate American National or to realize the anticipated benefits of the acquisitionNew
Legal, Regulatory, Compliance and Reputational Risks
- 45We are subject to extensive government regulation and supervision77% rewritten
- 46The Bank faces risks related to the adoption of future legislation and potential changes in federal regulatory agency leadership, policies, and priorities80% rewritten
- 47Non-compliance with the USA PATRIOT Act, BSA or other laws and regulations could result in fines or sanctionsNew
- 48Changes in requirements relating to the standard of conduct for broker-dealers under applicable federal and state law may adversely affect our business49% rewritten
- 49The Bank is periodically examined for mortgage-related issues, including mortgage loan and default services, fair lending, and mortgage banking47% rewritten
- 50We may experience unanticipated losses as a result of residential mortgage loan repurchase or reimbursement obligations under agreements with secondary market purchasers
- 51Fee revenues from overdraft protection programs constitute a significant portion of our noninterest income and may become subject to increased supervisory scrutiny74% rewritten
- 52We are subject to examinations and challenges by tax authorities
- 53We are subject to claims and litigation pertaining to fiduciary responsibility
- 54We may be a defendant in a variety of litigation and other actions, which may have a material adverse effect on our financial condition and results of operations
- 55Negative publicity could damage our reputation47% rewritten
- 56Ethics or conflict of interest issues could damage our reputation
Risks Related to an Investment in Our Securities
- 57The price of our securities can be volatile
- 58There may be future sales or other dilution of our equity, which may adversely affect the market price of our securities
- 59We may reduce or eliminate dividends on our common stock
- 60Common stock is equity and is subordinate to our existing and future indebtedness and preferred stock and effectively subordinated to all the indebtedness and other non-common equity claims against our subsidiaries
- 61Our articles of incorporation, bylaws, and certain banking laws may have an anti-takeover effect
- 62An investment in our common stock is not an insured deposit78% rewritten
General Risk Factors
- 63Changes in our accounting policies or in accounting standards could materially affect how we report our financial results
- 64Our internal controls may be ineffective
- 65We may not be able to attract and retain skilled people
- 66Loss of key colleagues may disrupt relationships with certain customers
Other Associated Banc-Corp 10-Ks
- FY2024 10-K risk factors68 risks
Commercial loans represent 64% of loans, while CRE exposure totals $8.4 billion, or 195% of risk-based capital.
Filed Feb 12, 2025
About this page
The headings are the filing's own. The one-line readings and the overview are automated and can be wrong: read Item 1A of the 10-K for the exact wording.