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COMMITMENTS, GUARANTEES AND CONTINGENT LIABILITIES | 9 Months Ended
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Sep. 30, 2025
Commitments, Guarantees, and Contingent Liabilities [Abstract] |
COMMITMENTS, GUARANTEES AND CONTINGENT LIABILITIES | COMMITMENTS, GUARANTEES, AND CONTINGENT LIABILITIES Commitments and Guarantees We utilize various financial instruments, including loan commitments, commercial letters of credit, and standby letters of credit, to support our customers’ financing needs. These instruments expose us to varying degrees of credit, liquidity, and interest rate risk that are not fully reflected on the consolidated balance sheet. The associated credit risk is evaluated and recorded as a reserve for unfunded lending commitments, which is presented separately on the consolidated balance sheet. The following schedule presents the contractual amounts related to off-balance sheet financial instruments used to support our customers’ financing needs:
(In millions) | September 30, 2025 |  | December 31, 2024
Unfunded lending commitments 1 | $ | 29,383 |  |  | $ | 28,767 |
Standby letters of credit: |  |  |
Financial | 622 |  |  | 574 |
Performance | 293 |  |  | 262 |
Commercial letters of credit | 39 |  |  | 15 |
Total unfunded commitments | $ | 30,337 |  |  | $ | 29,618 |
1 Net of participations. For more information about these commitments and guarantees including their terms and collateral requirements, see Note 16 of our 2024 Form 10-K. Legal Matters We are involved in various legal proceedings or governmental inquiries, which may include litigation in court, arbitral proceedings, investigations, examinations, and other actions initiated or considered by governmental and self-regulatory agencies. Litigation may pertain to lending, deposit and other customer relationships, supplier and contractual issues, employee matters, intellectual property matters, personal injuries and torts, regulatory and legal compliance, and other matters. While most matters involve individual claims, we are also subject to putative class action claims and similar broader claims. Proceedings, investigations, examinations, and other actions initiated or considered by governmental and self-regulatory agencies may relate to our banking, investment advisory, trust, securities, and other products and services; and our customers’ involvement in money laundering, fraud, securities violations and other illicit activities or our policies and practices concerning such customer activities. Additionally, these actions may pertain to our compliance with the broad range of banking, securities and other applicable laws and regulations. At any given time, we may be responding to subpoenas, requests for documents, data, and testimony relating to these matters and engaging in discussions to resolve them. At September 30, 2025, we were subject to the following material litigation: •Two civil cases, Lifescan, Inc. and Johnson & Johnson Health Care Services v. Jeffrey C. Smith, et. al., brought against us in the United States District Court for the District of New Jersey in December 2017, and Roche Diagnostics and Roche Diabetes Care Inc. v. Jeffrey C. Smith, et. al., brought against us in the United States District Court for the District of New Jersey in March 2019. In these cases, certain manufacturers and distributors of medical products seek to hold us liable for allegedly fraudulent practices of a borrower of the Bank who filed for bankruptcy protection in 2017. Discovery is substantially complete for most parties. However, final rulings on certain dispositive motions remain outstanding, and other dispositive motions have yet to be filed or ruled upon. A court-ordered mediation is expected to occur in late 2025. Both cases have been set for trial in April 2027. •Cayon and Reesor v. Zions Bancorporation, N.A. is an arbitration matter pending before Judicial Arbitration and Mediation Services. The claimants have asserted claims for unpaid overtime, meal and rest break violations, and failure to reimburse work-related expenses. They have also initiated a related action under the California Private Attorneys General Act (“PAGA”). The parties have reached a preliminary agreement to resolve the individual and collective claims raised in the arbitration and the related PAGA action. The settlement remains subject to final documentation and court approval. Based on our current knowledge, we believe that our estimated liability for litigation and other legal actions and claims, as reflected in our accruals and determined in accordance with applicable accounting guidance, is adequate. We also believe that any liabilities in excess of the amounts currently accrued, if any, arising from litigation and other legal actions and claims for which an estimate is possible, will not have a material impact on our financial condition, results of operations, or cash flows. However, given the significant uncertainties involved in these matters, and the potentially large or indeterminate damages sought in some cases, an adverse outcome in one or more of these matters could materially affect our financial condition, results of operations, or cash flows for any given reporting period. Any estimate or determination regarding the future resolution of litigation, arbitration, governmental or self-regulatory examinations, investigations or similar matters is inherently uncertain and involves significant judgment. This is particularly true in the early stages of a legal matter, when legal issues and facts have not been fully articulated, reviewed, analyzed, and vetted through discovery, trial or hearing preparation, substantive and productive mediation or settlement discussions, or other actions. It is also especially true for class actions and similar claims involving multiple defendants, matters with complex procedural requirements or substantive issues, novel legal theories, and examinations, investigations, and other actions conducted or brought by governmental and self-regulatory agencies, where the normal adjudicative process is not applicable. As a result, we are often unable to determine whether a favorable or unfavorable outcome is remote, reasonably likely, or probable, or to estimate the amount or range of a probable or reasonably likely loss, until relatively late in the course of a legal matter, sometimes not until a number of years have elapsed. Consequently, our judgments and estimates relating to claims will change over time in light of developments, and actual outcomes will differ from our estimates. These differences may be material. For more information regarding our accounting for legal matters, see Note 16 of our 2024 Form 10-K.

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