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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM 10-K
☒ ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
For the fiscal year ended December 31, 2023
OR
☐ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
For the transition period from __________ to __________
COMMISSION FILE NUMBER 001-12307
ZIONS BANCORPORATION, NATIONAL ASSOCIATION
(Exact name of registrant as specified in its charter)
United States of America87-0189025
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM 10-K
ý ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
For the fiscal year ended December 31, 2017
OR
¨TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
For the transition period from ___________ to ___________
COMMISSION FILE NUMBER 001-12307
ZIONS BANCORPORATION
(Exact name of Registrant as specified in its charter)
UTAH87-0227400
(State or other jurisdiction of

incorporation or organization)
(Internal Revenue ServiceIRS Employer

Identification Number)
One South Main, 15th Floor
Salt Lake City, Utah
8413384133-1109
(Address of principal executive offices)(Zip Code)
Registrant’s telephone number, including area code: (801) 844-8208
Securities registered pursuant to Section 12(b) of the Act:
Registrant’s telephone number, including area code: (801) 844-7637
Securities registered pursuant to Section 12(b) of the Act:
Title of Each ClassTrading SymbolsName of Each Exchange on Which Registered
Common Stock, without par value $0.001ZIONThe NASDAQ Stock Market LLC
Warrants to Purchase Common Stock (expiring May 22, 2020)The NASDAQ Stock Market LLC
Warrants to Purchase Common Stock (expiring November 14, 2018)The NASDAQ Stock Market LLC
Depositary Shares each representing a 1/40th ownership interest in a share of Series A Floating-Rate Non-Cumulative Perpetual Preferred Stock
New York Stock Exchange
Depositary Shares each representing a 1/40th ownership interest in a share of of:
Series A Floating-Rate Non-Cumulative Perpetual Preferred StockZIONPThe NASDAQ Stock Market LLC
Series G Fixed/Floating-Rate Non-Cumulative Perpetual Preferred StockNew YorkZIONOThe NASDAQ Stock ExchangeMarket LLC
Depositary Shares each representing a 1/40th ownership interest in a share of Series H 5.75% Non-Cumulative Perpetual Preferred StockNew York Stock Exchange
6.95% Fixed-to-Floating Rate Subordinated Notes due September 15, 2028New YorkZIONLThe NASDAQ Stock Exchange
Securities registered pursuant to Section 12(g) of the Act: None.
Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes ý No ¨
Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. Yes ¨ No ý
Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. Yes ý No ¨
Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Web site, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit and post such files). Yes ý No ¨
Indicate by check mark if disclosure of delinquent filers pursuant to Item 405 of Regulation S-K (Section 229.405 of this chapter) is not contained herein, and will not be contained, to the best of registrant’s knowledge, in definitive proxy or information statements incorporated by reference in Part III of this Form 10-K or any amendment to this Form 10-K. ¨
Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, or a smaller reporting company. See the definitions of “large accelerated filer,” “accelerated filer,” and “smaller reporting company” in Rule 12b-2 of the Exchange Act. Large accelerated filer ý            Accelerated filer ¨
Non-accelerated filer ¨Smaller reporting company ¨
Emerging growth company ¨
Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes ¨ No ý
Aggregate Market Value of Common Stock Held by Non-affiliates at June 30, 2017$8,745,683,795
Number of Common Shares Outstanding at February 9, 2018196,514,295 shares
Documents Incorporated by Reference: Portions of the Company’s Proxy Statement – Incorporated into Part IIILLC

Securities registered pursuant to Section 12(g) of the Act: None.
FORM 10-K Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes ☒ No ¨
Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. Yes ¨ No ☒
Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days. Yes ý No ¨
Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files). Yes ý No ¨
Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and “emerging growth company” in Rule 12b-2 of the Exchange Act.
Large accelerated filer ý Accelerated filer ☐ Non-accelerated filer ☐ Smaller reporting company ☐ Emerging growth company ☐
If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. ¨
Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report. ý
If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the registrant included in the filing reflect the correction of an error to previously issued financial statements. ☐
Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based compensation received by any of the registrant’s executive officers during the relevant recovery period pursuant to §240.10D-1(b). ☐
Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes ¨ No ý
Aggregate Market Value of Common Stock Held by Non-affiliates at June 30, 2023                     $3,892,923,377
Number of Common Shares Outstanding at February 5, 2024                              148,155,311 shares
Documents Incorporated by Reference:
Part III: Items 10-14 — Proxy Statement for the 2024 Annual Meeting of Shareholders to be held April 26, 2024.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

PART I
FORWARD-LOOKING INFORMATION
This annual report includes forward-looking statements within the meaning of Section 21E of the Securities Exchange Act of 1934, as amended, or the Exchange Act. Statements in this Annual Report on Form 10-K that are based on other than historical data are forward-looking within the meaning of the Private Securities Litigation Reform Act of 1995. Forward-looking statements provide current expectations or forecasts of future events and include, among others:
statements with respect to the beliefs, plans, objectives, goals, targets, commitments, designs, guidelines, expectations, anticipations, and future financial condition, results of operations and performance of Zions Bancorporation (“the Parent”) and its subsidiaries (collectively “the Company,” “Zions,” “we,” “our,” “us”); and
statements preceded by, followed by, or that include the words “may,” “could,” “should,” “would,” “believe,” “anticipate,” “estimate,” “expect,” “intend,” “target,” “commit,” “design,” “plan,” “projects,” and the negative thereof and similar words and expressions.
These forward-looking statements are not guarantees of future performance, nor should they be relied upon as representing management’s views as of any subsequent date. Forward-looking statements by their nature address matters that are, to different degrees, uncertain, such as statements about future financial and operating results, the potential timing or consummation of the proposed transaction described in the presentation and receipt of regulatory approvals or determinations, or the anticipated benefits thereof, including without limitation, future financial and operating results. Actual results may differ materially from those presented, either expressed or implied, including, but not limited to, those presented in Management’s Discussion and Analysis (“MDA”). Important risk factors that may cause such material differences include, but are not limited to:
the Company’s ability to successfully execute its business plans, manage its risks, and achieve its objectives, including its restructuring and efficiency initiatives and its capital plan;
changes in local, national and international political and economic conditions, including without limitation the political and economic effects of the economic and fiscal imbalance in the United Sates and other countries, potential or actual downgrades in ratings of sovereign debt issued by the United States and other countries, and other major developments, including wars, military actions, and terrorist attacks;
changes in financial and commodity market prices and conditions, either internationally, nationally or locally in areas in which the Company conducts its operations, including without limitation rates of business formation and growth, commercial and residential real estate development, real estate prices, and oil and gas-related commodity prices;
changes in markets for equity, fixed income, commercial paper and other securities, commodities, including availability, market liquidity levels, and pricing;
any impairment of our goodwill or other intangibles, or any adjustment of valuation allowances on our deferred tax assets due to adverse changes in the economic environment, declining operations of the reporting unit, or a change to the corporate statutory tax rate or other similar changes if and as implemented by local and national governments, or other factors;
changes in interest rates, the quality and composition of the loan and securities portfolios, demand for loan products, deposit flows and competition;
the impact of acquisitions, dispositions, and corporate restructurings;
increases in the levels of losses, customer bankruptcies, bank failures, claims, and assessments;
changes in fiscal, monetary, regulatory, trade and tax policies and laws, and regulatory assessments and fees, including policies of the U.S. Department of Treasury, the OCC, the Board of Governors of the Federal Reserve System, the FDIC, the SEC, and the CFPB;

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the impact of executive compensation rules under the Dodd-Frank Act and banking regulations, which may impact the ability of the Company and other American financial institutions to retain and recruit executives and other personnel necessary for their businesses and competitiveness;
the impact of the Dodd-Frank Act and Basel III, and rules and regulations thereunder, on our required regulatory capital and liquidity levels, governmental assessments on us (including, but not limited to, the Federal Reserve reviews of our annual capital plan), the scope of business activities in which we may engage, the manner in which we engage in such activities, the fees we may charge for certain products and services, and other matters affected by the Dodd-Frank Act and these international standards;
continuing consolidation in the financial services industry;
new legal claims against the Company, including litigation, arbitration and proceedings brought by governmental or self-regulatory agencies, or changes in existing legal matters;
success in gaining regulatory approvals, when required;
changes in consumer spending and savings habits;
increased competitive challenges and expanding product and pricing pressures among financial institutions;
inflation and deflation;
technological changes and the Company’s implementation of new technologies;
the Company’s ability to develop and maintain secure and reliable information technology systems;
legislation or regulatory changes which adversely affect the Company’s operations or business;
the Company’s ability to comply with applicable laws and regulations;
changes in accounting policies or procedures as may be required by the FASB or regulatory agencies; and
costs of deposit insurance and changes with respect to FDIC insurance coverage levels.
Except to the extent required by law, the Company specifically disclaims any obligation to update any factors or to publicly announce the result of revisions to any of the forward-looking statements included herein to reflect future events or developments.
AVAILABILITY OF INFORMATION
We also make available free of charge on our website, www.zionsbancorporation.com, annual reports on Form 10-K, quarterly reports on Form 10-Q, and current reports on Form 8-K and amendments to those reports filed or furnished pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as well as proxy statements, as soon as reasonably practicable after we electronically file such material with, or furnish it to, the U.S. Securities and Exchange Commission.
GLOSSARY OF ACRONYMS AND ABBREVIATIONS
ACL
ACLAllowance for Credit LossesCCARFRBComprehensive Capital Analysis and ReviewFederal Reserve Board
AFSAvailable-for-SaleCET1FTPFunds Transfer Pricing
AIArtificial IntelligenceGAAPGenerally Accepted Accounting Principles
ALCOAsset/Liability CommitteeGCFGeneral Collateral Funding
ALLLAllowance for Loan and Lease LossesGDPGross Domestic Product
AmegyAmegy Bank, a division of Zions Bancorporation, National AssociationHECLHome Equity Credit Line
AOCIAccumulated Other Comprehensive IncomeHTMHeld-to-Maturity
ASCAccounting Standards CodificationIPOInitial Public Offering
ASUAccounting Standards UpdateIRSInternal Revenue Service
ATMAutomated Teller MachineISDAInternational Swaps and Derivative Association
BOLIBank-Owned Life InsuranceKBWKeefe, Bruyette & Woods, Inc.
bpsBasis PointsKRXKBW Regional Bank Index
BTFPBank Term Funding ProgramLIBORLondon Interbank Offered Rate
CB&TCalifornia Bank & Trust, a division of Zions Bancorporation, National AssociationLIHTCLow-Income Housing Tax Credit
CECLCurrent Expected Credit LossMD&AManagement’s Discussion and Analysis
CET1Common Equity Tier 1 (Basel III)MunicipalitiesState and Local Governments
ALCOCFPBAsset/Liability CommitteeCFPBConsumer Financial Protection BureauNAICSNorth American Industry Classification System
ALLLCISOAllowance for Loan and Lease LossesChief Information Security OfficerCLTVNASDAQNational Association of Securities Dealers Automated Quotations
CLTVCombined Loan-to-Value RatioNAVNet Asset Value
AmegyCMBSAmegyCommercial Mortgage-Backed SecurityNBAZNational Bank of Arizona, a division of ZB, N.A.Zions Bancorporation, National Association
CMCCMCCapital Management CommitteeNIMNet Interest Margin
AOCICODMAccumulated Other Comprehensive IncomeChief Operating Decision MakerCompanyNMZions Bancorporation and its subsidiariesNot Meaningful
ASCCOSOAccounting Standards CodificationCOSOCommittee of Sponsoring Organizations of the Treadway Commission
ASUAccounting Standards UpdateNSBCRACommunity Reinvestment Act
ATMAutomated Teller MachineCRECommercial Real Estate
BHC ActNevada State Bank, Holding Company ActCSACredit Support Annex
BOLIBank-Owned Life InsuranceCSVCash Surrender Value
bpsbasis pointsDFASTDodd-Frank Act Stress Test
CB&TCalifornia Bank & Trust, a division of ZB, N.A.Zions Bancorporation, National Association
CRACommunity Reinvestment ActOCCOffice of the Comptroller of the Currency
CRECommercial Real EstateOCIOther Comprehensive Income
CSACredit Support AnnexOREOOther Real Estate Owned
CSVCash Surrender ValuePAMProportional Amortization Method
CTOOChief Technology and Operations OfficerPCAOBPublic Company Accounting Oversight Board
CVACredit Valuation AdjustmentPEIPrivate Equity Investment
Dodd-Frank ActDodd-Frank Wall Street Reform and Consumer Protection Act

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PPNRPre-provision Net Revenue
DTA
DTADeferred Tax AssetNIMPPPNet Interest MarginPaycheck Protection Program
EaRDTLDeferred Tax LiabilityROCRisk Oversight Committee
EaREarnings at RiskNREROUNational Real EstateRight-of-Use
EITFEPSEmerging Issues Task ForceEarnings per ShareNSBRSUNevada State Bank, a division of ZB, N.A.Restricted Stock Unit
ERMEnterprise Risk ManagementNSFRRULCNet Stable Funding RatioReserve for Unfunded Lending Commitments
ERMCEnterprise Risk Management CommitteeOCCS&POffice of the Comptroller of the CurrencyStandard and Poor’s
EVEETOEnterprise and Technology OperationsSBAU.S. Small Business Administration
EVEEconomic Value of Equity at RiskOCISBICOther Comprehensive IncomeSmall Business Investment Company
Exchange ActFAMCSecurities Exchange Act of 1934OREOOther Real Estate Owned
FAMCFederal Agricultural Mortgage Corporation, or “Farmer Mac”OTTISECOther-Than-Temporary ImpairmentSecurities and Exchange Commission
FASBFinancial Accounting Standards BoardPAGASOFRPrivate Attorney General ActSecured Overnight Financing Rate
FDICFederal Deposit Insurance CorporationParentTCBWZions Bancorporation
FDICIAFederal Deposit Insurance Corporation Improvement ActPCAOBPublic Company Accounting Oversight Board
FHLBFederal Home Loan BankPCIPurchased Credit-Impaired
FHLMCFederal Home Loan Mortgage Corporation, or “Freddie Mac”PEIPrivate Equity Investment
FINRAFinancial Industry Regulatory AuthorityPPNRPre-provision Net Revenue
FRBFederal Reserve BoardROCRisk Oversight Committee
FSOCFinancial Stability Oversight CouncilRSURestricted Stock Unit
FTPFunds Transfer PricingRULCReserve for Unfunded Lending Commitments
GAAPGenerally Accepted Accounting PrinciplesS&PStandard and Poor's
GLB ActGramm-Leach-Bliley ActSABStaff Accounting Bulletin
HCRHorizontal Capital ReviewSBASmall Business Administration
HECLHome Equity Credit LineSBICSmall Business Investment Company
HQLAHigh-Quality Liquid AssetsSECSecurities and Exchange Commission
HTMHeld-to-MaturitySIFISystemically Important Financial Institution
IMGInternational Manufacturing GroupSNCShared National Credit
KBWKeefe, Bruyette & Woods, Inc.TCBOThe Commerce Bank of Oregon, a division of ZB, N.A.
LCRLiquidity Coverage RatioTCBWThe Commerce Bank of Washington, a division of ZB, N.A.Zions Bancorporation, National Association
LGDFDICIALoss Given DefaultFederal Deposit Insurance Corporation Improvement ActTDRTroubled Debt Restructuring
LIBORFHLBLondon Interbank Offered RateFederal Home Loan BankThe ActU.S.Tax Cuts and Jobs Act of 2017United States
LNCFICOLarge and NoncomplexFair Isaac CorporationU.S.VectraUnited States
LSALoss Sharing AgreementUSA Patriot ActUniting and Strengthening of America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001
MD&AManagement’s Discussion and AnalysisVectraVectra Bank Colorado, a division of ZB, N.A.Zions Bancorporation, National Association
MunicipalitiesFINRAState and Local GovernmentsFinancial Industry Regulatory AuthorityVIEVariable Interest Entity
NASDAQFintechNational Association of Securities Dealers Automated QuotationsFinancial Technology CompanyZB, N.A.ZB, National Association
NAVNet Asset ValueZions BankZions Bank, a division of ZB, N.A.
NBAZZions Bancorporation, National Bank of Arizona, a division of ZB, N.A.Association
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ITEM 1.BUSINESS
ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
PART I
FORWARD-LOOKING INFORMATION
This annual report includes “forward-looking statements” as that term is defined in the Private Securities Litigation Reform Act of 1995. These statements are based on management’s current expectations and assumptions regarding future events or determinations, all of which are subject to known and unknown risks, uncertainties, and other factors that may cause our actual results, performance or achievements, industry trends, and results or regulatory outcomes to differ materially from those expressed or implied. Forward-looking statements include, among others:
Statements with respect to the beliefs, plans, objectives, goals, targets, commitments, designs, guidelines, expectations, anticipations, and future financial condition, results of operations and performance of Zions Bancorporation, National Association and its subsidiaries (collectively “Zions Bancorporation, N.A.,” “the Bank,” “we,” “our,” “us”); and
Statements preceded or followed by, or that include the words “may,” “might,” “can,” “continue,” “could,” “should,” “would,” “believe,” “anticipate,” “estimate,” “forecasts,” “expect,” “intend,” “target,” “commit,” “design,” “plan,” “projects,” “will,” and the negative thereof and similar words and expressions.
Forward-looking statements are not guarantees, nor should they be relied upon as representing management’s views as of any subsequent date. Actual results and outcomes may differ materially from those presented. Although the following list is not comprehensive, important factors that may cause material differences include:
The quality and composition of our loan and securities portfolios and the quality and composition of our deposits;
Changes in general industry, political and economic conditions, including continued elevated inflation, economic slowdown or recession, or other economic challenges; changes in interest and reference rates, which could adversely affect our revenue and expenses, the value of assets and liabilities, and the availability and cost of capital and liquidity; deterioration in economic conditions that may result in increased loan and leases losses;
The impact of bank closures or adverse developments at other banks on general investor sentiment regarding the stability and liquidity of banks;
Competitive pressures and other factors that may affect aspects of our business, such as pricing and demand for our products and services, our ability to recruit and retain talent, and the impact of technological advancements, digital commerce, artificial intelligence, and other innovations affecting the banking industry;
Our ability to complete projects and initiatives and execute on our strategic plans, manage our risks, control compensation and other expenses, and achieve our business objectives;
Our ability to develop and maintain technology, information security systems and controls designed to guard against fraud, cybersecurity, and privacy risks;
Our ability to provide adequate oversight of our suppliers or prevent inadequate performance by third parties upon whom we rely for the delivery of various products and services;
Natural disasters, pandemics, catastrophic events and other emergencies and incidents and their impact on our and our customer’s operations and business and communities, including the increasing difficulty in, and the expense of, obtaining property, auto, business, and other insurance products;
Governmental and social responses to environmental, social, and governance issues, including those with respect to climate change;
Securities and capital markets behavior, including volatility and changes in market liquidity and our ability to raise capital;
The possibility that our recorded goodwill could become impaired, which may have an adverse impact on our earnings and shareholders’ equity, but not on our regulatory capital;
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
The effects of newly enacted and proposed regulations affecting us and the banking industry, as well as changes and uncertainties in applicable laws, and fiscal, monetary, regulatory, trade, and tax policies, and actions taken by governments, agencies, central banks, and similar organizations, including those that result in decreases in revenue; increases in bank fees, insurance assessments and capital standards; and other regulatory requirements;
Adverse news and other expressions of negative public opinion whether directed at us, other banks, the banking industry, or otherwise that may adversely affect our reputation and that of the banking industry generally;
Protracted congressional negotiations and political stalemates regarding government funding and other issues, including those that increase the possibility of government shutdowns, downgrades in United States (“U.S.”) credit ratings, or other economic disruptions; and
The effects of wars and geopolitical conflicts, such as the ongoing war between Russia and Ukraine and the conflicts in the Middle East, and other local, national, or international disasters, crises, or conflicts that may occur in the future.
We caution against the undue reliance on forward-looking statements, which reflect our views only as of the date they are made. Except to the extent required by law, we specifically disclaim any obligation to update any factors or to publicly announce the revisions to any forward-looking statements to reflect future events or developments.
ITEM 1. BUSINESS
DESCRIPTION OF BUSINESS
Zions Bancorporation, National Association (“the Parent”Zions Bancorporation, N.A.,” “the Bank,” “we,” “our,” “us”) is a financial holding company organized under the lawsbank headquartered in Salt Lake City, Utah with annual net revenue (net interest income and noninterest income) of the State$3.1 billion in 2023, and total assets of Utah in 1955, and registered under the Bank Holding Company Act (“BHC Act”), as amended. The Parent owns and operates a commercial bank with a total of 433 branchesapproximately $87 billion at year-end 2017. The Parent and its subsidiaries (collectively “the Company”)December 31, 2023. We provide a fullwide range of banking products and related services, primarily in the states of Arizona, California, Colorado, Idaho, Nevada, New Mexico, Oregon, Texas, Utah, Washington, and Wyoming. The Company conducts its bankingWe had more than one million customers at year-end 2023, served by 407 branches and various online, mobile, and digital offerings. We had 9,679 full-time equivalent employees at December 31, 2023.
We conduct our operations primarily through seven separately managed and branded segments,geographically defined bank divisions, which we sometimes refer to as

Table “affiliates,” or “affiliate banks,” each with its own local branding and management team. These affiliate banks comprise our primary business segments as referred to throughout this document. We emphasize local authority, responsibility, pricing, and customization of Contents

“affiliates” orcertain products that are designed to maximize customer satisfaction and strengthen community relations. Our affiliate banks are supported by referencean enterprise operating segment (referred to their respective brands. Full-time equivalent employees totaled 10,083 at December 31, 2017.as the “Other” segment) that provides governance and risk management, allocates capital, establishes strategic objectives, and includes centralized technology, back-office functions, and certain lines of business not operated through our affiliate banks. For furthermore information about the Company’s industryour segments, see “Business Segment Results” in Management’s Discussion and Analysis (“MD&A”) on page 46 in MD&A42 and Note 2022 of the Notes to Consolidated Financial Statements. For information about the Company’s foreign operations, see “Foreign Exposure and Operations” on page 53 in MD&A. The “Executive Summary” on page 33 in MD&A provides further information about the Company.
PRODUCTS AND SERVICES
The Company focusesWe focus on serving customers in the communities in which we operate. Our experienced bankers strive to develop long-lasting relationships with our customers by providing community banking services by continuously strengthening its core business lines of (1) small and medium-sized business and corporate banking; (2) commercial and residential development, construction and term lending; (3) retail banking; (4) treasury cash management and relatedcompetitive products and services; (5) residential mortgage servicingaward-winning service. Building and lending; (6) trustsustaining these relationships is essential to understanding and wealth management; (7) limited capital markets activities, including municipal finance advisory and underwriting; and (8) investment activities. It operates primarily through seven geographic regions, each with its own local branding, chief executive officer and management team.
In addition to providing a wide varietymeeting our customers’ needs. Some of commercialthe products and services the Company provideswe provide, whether delivered digitally or by other means, include:
Commercial and small business banking. We serve a wide range of personalcommercial customers, generally small- and medium-sized businesses. Products and services we provide to our commercial and small business banking customers include:
Commercial and industrial and owner-occupied lending and leasing;
Municipal and public finance services;
Depository account and cash management services;
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Commercial and small business cards, as well as merchant processing services;
Corporate trust services; and
Correspondent banking and international lending services.
Capital markets and investment banking. We provide customized financing solutions to help our customers raise capital efficiently, execute strategic transactions, and manage exposure to financial markets. Capital markets products and services include:
Loan syndications;
Foreign exchange services and interest rate derivatives;
Fixed income securities underwriting;
Advisory and capital raising;
Commercial mortgage-backed security (“CMBS”) conduit lending; and
Power and project financing.
Commercial real estate lending. We provide lending products secured by commercial real estate to borrowers that include:
Term and construction/land development financing, including the following collateral types:
Commercial multi-family, industrial, and office; and
Residential single-family, community development, and affordable housing.
Retail banking. We provide quality retail banking products and services to individuals, including home mortgages, bankcard, other installment loans, homeour customers that include:
Residential mortgages;
Home equity lines of credit;
Personal lines of credit checking accounts, savings accounts, certificates of deposit ofand installment consumer loans;
Depository account services;
Consumer cards; and
Personal trust services.
Wealth management. We offer various typeswealth management products and maturities, trust services, safe deposit facilities, and Internet and mobile banking. The Company provides services to key market segments through its Private Client Servicescustomers. Our planning-driven offerings, combined with high-touch service and Executive Banking Groups. It offers self-directed brokerage services through Zions Direct and also offers comprehensive and personalizedsophisticated asset management capabilities, have resulted in continued growth in assets under management. Additional offerings to our wealth management customers include:
Investment management services;
Fiduciary and investmentestate services; and
Advanced business succession and estate planning services.
The Company has built specialized lines of business in capital markets and public finance, and is a leader in small business administration (“SBA”) lending. The Company is one of the nation’s largest providers of SBA 7(a) and SBA 504 financing to small businesses. It owns an equity interest in FAMC and is its top originator of secondary market agricultural real estate mortgage loans. The Company provides finance advisory and corporate trust services for municipalities. The Company also provides bond transfer, stock transfer, and escrow services nationally in its corporate trust business.
COMPETITION
The Company operatesWe operate in a highly competitive environment. The Company’sOur most direct competition for loans, deposits, and depositsother banking services generally comes from other commercial banks, credit unions, financial technology companies (“fintechs”), and thrifts, includingprivate credit or debt funds. Some of these financial institutions that do not have a physical presence in our market footprint, but solicit business via the Internetinternet and other means. In addition, the Company competesWe also compete with finance companies, mutual funds,fund companies, insurance companies, brokerage firms, securities dealers, investment banking companies, financial technology and other non-traditionalnontraditional lending and banking companies, and a variety of other types of companies. These companiesSome of our competitors may have fewer regulatory constraints, greater ability to develop, implement, and some have lower costoffer technologies and other innovative financial services, and lower-cost structures, or taxtaxes, and regulatory burdens.
The primary factors in competing for businessOur key differentiators include the quality of service delivered, our local community knowledge, convenience of branch and office locations, online banking functionality and other delivery methods,a wide range of products and services offered, and pricing. The Company mustthe overall relationships with our customers. We strive to compete effectively alongin all of these dimensionsareas to remain successful.
SUPERVISION AND REGULATION
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This section describes the material elements of selected laws and regulations applicable to the Company. The descriptions are not intended to be complete and are qualified in their entirety by reference to the full text of the statutes and regulations described. Changes in applicable laws or regulations, and in their application by regulatory agencies, cannot be predicted, but they may have a material effect on the business and results of the Company.
On November 20, 2017, we announced a proposal to streamline our corporate structure by merging the Parent into its bank subsidiary, ZB, N.A. and, in connection with the proposed restructuring, our intention to file an application

ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

with the Financial Stability Oversight Council (“FSOC”) seeking a determination that the resulting banking organization is not "systemically important" as defined by provisions of the Dodd-Frank Act. The merger is contingent upon approval by the Office of the Comptroller of the Currency (“OCC”), Federal Deposit Insurance Corporation (“FDIC”), and the Company’s shareholders. Assuming the restructuring is completed and the application to FSOC is approved, the resulting banking organization would no longer be subject to duplicative examinations and other overlapping regulatory requirements, or the enhanced prudential standards established by the Board of Governors of the Federal Reserve System under Section 165 of the Dodd-Frank Act. The Company’s primarily regulator would be the OCC. The Company would continue to be subject to examinations by the CFPB with respect to consumer financial regulations.
There can be no assurance that the restructuring will be completed or that the FSOC application will be approved. Accordingly, the discussion below is based on the regulatory regime currently applicable to us and our current holding company structure. For a description of the material elements of the current regulatory regime applicable to us that would be eliminated if our proposals are successful, see “Regulatory Relief if Proposed Restructuring is Completed and FSOC Application is Approved” below.SUPERVISION AND REGULATION
The banking and financial services business in which we engage is highly regulated. Such regulation is intended among other things, to improvepromote the stability of banking and financial companies and to protect the interests of customers, including both loan customers and depositors, and taxpayers. Thesecommunities. Although banks and their customers benefit from many of these regulations, arein some cases, they may not however, generallybe aligned with, or intended to protect, the interests of our shareholders or creditors,creditors. Banking laws and in fact may have the consequence of reducing returns to our shareholders. This regulatory framework has been materially revised and expanded since the 2008-2009 financial crisis and recession. In particular, the Dodd-Frank Act and regulations promulgated pursuant to it have given financial regulators expanded powers over nearly every aspectmany aspects of the Company’s business. These include, among other things, new, higher regulatory capital requirements; regulation of dividends and other forms of capital distributions to shareholders through annual stress testing and capital planning processes; heightened liquidity and liquidity stress testing requirements,financial services industry, which include specific definitions of the types of investment securities that qualify as “high-quality liquid assets” and which effectively limit the portion of the Company’s balance sheet that can be used to meet the credit needs of its customers; specific limitations on mortgage lending products and practices; specific limits on certain consumer payment fees; and subjecting compensation practices to specific regulatory oversight and restrictions. Individually and collectively, these additional regulations have imposed and will continue to impose higher costs on the Company, and have reduced, and may continue to reduce, returns earned by shareholders. Some aspects of the Dodd-Frank Act continue to be subject to rulemaking, the majority of the rules that have been adopted may be subject to interpretationFurthermore, changes in applicable laws or clarification,regulations, and accordingly, the impact of suchin their application by regulatory changesagencies cannot be presently determined. Recent political developments, including the change in the executive administration of the United States,predicted and may have increased uncertainty to the implementation, scope,a material effect on our business and timing of regulatory reforms, including those related to the implementation of the Dodd-Frank Act. The Company is committed to both satisfying heightened regulatory expectations and providing attractive shareholder returns. However, given the still-changing regulatory environment and such uncertainty, the results of these efforts cannot yet be known.
In the first quarter of 2017, the President of the United States issued an executive order identifying “core principles” for the administration’s financial services regulatory policy and directing the Secretary of the Treasury, in consultation with the heads of other financial regulatory agencies, to evaluate how the current regulatory framework promotes or inhibits the principles and what actions have been, and are being, taken to promote the principles. In response to the executive order, on June 12, 2017, October 6, 2017 and October 26, 2017, respectively, the U.S. Department of the Treasury issued the first three of four reports recommending a number of comprehensive changes in the current regulatory system for U.S. depository institutions, the U.S. capital markets and the U.S. asset management and insurance industries. These recommendations, if implemented, could reduce some of the burdens and costs of the current regulatory framework.results.
General
The Parent is a bank holding company and a financial holding company as provided by the BHC Act, as modified by the GLB Act and the Dodd-Frank Act. These and other federal statutes provide the regulatory framework for


bank holding companies and financial holding companies, which have as their umbrella regulator the FRB. The supervision of ZB, N.A. and other regulated subsidiaries is conducted by each subsidiary’s primary functional regulator and the laws and regulations administered by those regulators. The GLB Act allows our subsidiary bank to engage in certain financial activities through financial subsidiaries. To qualify for and maintain status as a financial holding company, or to do business through a financial subsidiary, the Parent and its subsidiary bank must satisfy certain ongoing criteria. The Company currently engages in only limited activities for which financial holding company status is required.
ZB, N.A. isWe are subject to the provisions of the National Bank Act and other statutes governing national banks, as well as the rules and regulations of the OCC,Office of the Comptroller of the Currency (“OCC”), the Consumer Financial Protection Bureau (“CFPB”), and the FDIC. It is also subject to examination and supervision by the OCC and examination by the CFPB in respectFederal Deposit Insurance Corporation (“FDIC”). We, as well as some of federal consumer financial regulations. In addition, Zions Bancorporation is subject to examination by the Federal Reserve Bank of San Francisco. Some of our nonbank subsidiaries, are also subject to regulation by the Federal Reserve Board (“FRB”) and other federal and state agencies. These regulatory agencies may exert considerable influence over our activities through their supervisory and examination roles. Our brokerage and investment advisory subsidiaries are regulated by the SEC,Securities and Exchange Commission (“SEC”), Financial Industry Regulatory Authority (“FINRA”) and/or, and state securities regulators.
The Dodd-FrankNational Bank Act
The most recent financial crisis led to numerous new laws inOur corporate affairs are governed by the United States and internationally for financial institutions. The Dodd-Frank Act, which was enacted in July 2010, is one of the most far reaching legislative actions affecting the financial services industry in decades and significantly restructured the financial regulatory regime in the United States. Implementation of the Dodd-FrankNational Bank Act, and related rulemaking activities continued in 2017.
The Dodd-Frank Act and regulations adopted underare administered by the Dodd-Frank Act broadly affect the financial services industry by creating new resolution authorities, requiring ongoing stress testing of our capital and liquidity, mandating higher capital and liquidity requirements, requiring divestiture of certain equity investments, increasing regulation of executive and incentive-based compensation, requiring banks to pay increased fees to regulatory agencies, and requiring numerous other provisions aimed at strengthening the sound operation of the financial services sector. Among other things affecting capital standards, the Dodd-Frank Act provides that:
the requirements applicable to large bank holding companies (those with consolidated assets of greater than $50 billion) be more stringent than those applicable to other financial companies;
standards applicable to bank holding companies be no less stringent than those applied to insured depository institutions; and
bank regulatory agencies implement countercyclical elements in their capital requirements.
Regulations promulgated under the Dodd-Frank Act require us to maintain greater levels of capital and liquid assets than was generally the case before the crisis and limit the forms of capital that we will be able to rely upon for regulatory purposes. In addition, in its supervisory role withOCC. With respect to our stress testing and capital planning, our ability to deliver returns to our shareholders through dividends and stock repurchases is subject to prior non-objection by the FRB. The stress testing and capital plan processes also could substantially reduce our flexibility to respond to market developments and opportunities in such areas as capital raising and acquisitions.
The Dodd-Frank Act’s provisions and related regulations also affect the feessecurities matters, we must pay to regulatory agencies and the pricing of certain products and services, including the following:
The assessment base for federal deposit insurance was changed to consolidated assets less tangible capital instead of the amount of insured deposits.
The federal prohibition on the payment of interest on business transaction accounts was repealed.
The FRB was authorized to issue and did issue regulations governing debit card interchange fees.
The Dodd-Frank Act also created the CFPB, which is responsible for promulgating regulations designed to protect consumers’ financial interests and examining large financial institutions for compliance with, and enforcing, those


regulations. The Dodd-Frank Act adds prohibitions on unfair, deceptive or abusive acts and practices to the scope of consumer protection regulations overseen and enforced by the CFPB. The Dodd-Frank Act subjected national banks to the possibility of further regulation by restricting the preemption of state laws by federal laws. Restricting the scope of federal preemption could burden national banks with the requirement that they also comply with certain state laws covering matters already covered by federal law. In addition, the Dodd-Frank Act gives greater power to state attorneys general to pursue legal actions against banking organizations for violations of federal law.
The Dodd-Frank Act contains numerous provisions that limit or place significant burdens and costs on activities traditionally conducted by banking organizations, such as originating and securitizing mortgage loans and other financial assets, arranging and participating in swap and derivative transactions, proprietary trading and investing in private equity and other funds. For the affected activities, these provisions may result in increased compliance and other costs, increased legal risk, and decreased scope of product offerings and earning assets.
The Company isare not subject to the provisionsSecurities Act of the Volcker Rule, issued pursuant to the Dodd-Frank Act. The Company has divested all1933 (“Securities Act”), but $3 million of private equity investments (“PEIs”) not permitted under the Volcker Rule. Such investments also provide for $4 million of potential capital calls, which the Company would fund, as allowed by the Volcker Rule, if and as the capital calls are made until the investments are sold. Nevertheless, because the remaining investments are comprised of funds that are in the later stages of their lifecycle, significant future funding requests are not anticipated. The Company continues to pursue the disposition of all non-compliant PEIs. In February 2017, the Federal Reserve Bank of San Francisco approved the Company’s application for an extended transition period of up to five years in which to dispose of its remaining PEIs in light of their illiquid nature.
The Company and other companies subject to the Dodd-Frank Act are subject to a numberOCC regulations governing securities offerings. Our common stock and certain other securities are registered under the Securities and Exchange Act of requirements regarding1934 (“Exchange Act”), which vests the time, mannerOCC with the power to administer and formenforce certain sections of compensation giventhe Exchange Act applicable to its key executives and other personnel receiving incentive compensation, which are being imposed through the supervisory process as well as published guidance and proposed rules. These restrictions imposednational banks, though we continue to make filings required by the Dodd-FrankExchange Act include documentation and governance, deferral, risk-balancing, and clawback requirements. Any deficiencies in compensation practices that are identified may be incorporated into the organization’s supervisory ratings, which can affect its ability to make acquisitions or engage in other activities, or could result in regulatory enforcement actions.
During the second quarter of 2016, the U.S. financial regulators, including the FRB andwith the SEC proposed revised rules on incentive-based payment arrangements at specified regulated entities having at least $1 billion in total assets (including Zions). The proposed revised rules would establish general qualitative requirementsas a voluntary filer. These statutory and regulatory frameworks are not as well-developed as the corporate and securities law frameworks applicable to all covered entities, additional specific requirements for entities with total consolidated assetsmany other publicly held companies.
The National Bank Act provides that under certain circumstances the common stock of at least $50 billion, such as Zions, and further, more stringent requirements for those with total consolidated assets of at least $250 billion. The general qualitative requirements include: (i) prohibiting incentive arrangements that encourage inappropriate risks by providing excessive compensation; (ii) prohibiting incentive arrangements that encourage inappropriate risks that could lead to a material financial loss; (iii) establishing requirements for performance measures to appropriately balance risk and reward; (iv) requiring board of director oversight of incentive arrangements; and (v) mandating appropriate record-keeping. For larger financial institutions, including Zions, the proposed revised regulations would also introduce very prescriptive requirements relating to the types and percentages, the timing of the realization, and the risk of forfeiture of incentive compensation awarded to “senior executive officers” and “significant risk-takers.” The regulators have not yet issued any final rules.
Some aspects of the Dodd-Frank Act continue to be subject to rulemaking, and many of the rules that have been adoptednational bank is assessable, i.e., holders may be subject to interpretation or clarification. In 2017,a levy for more funds if so determined by the U.S. House of Representatives approved a billOCC. The OCC has confirmed that would significantly amend the post-financial crisis regulatory framework implemented under the Dodd-Frankapplicable provisions of the National Bank Act, and a bipartisan group of senators also introduced legislation that would revise various post-financial crisis regulatory requirements and provide targeted relief to certain financial institutions, which may include Zions. If passed, this legislative initiative could result in the Company no longer being deemed a systemically important financial institution (“SIFI”) or subjectassessability is limited to the enhanced prudential supervision standards applicablepar value of a national bank’s stock. Our common stock has a par value of $0.001. In addition, according to SIFIs. The


likelihoodthe OCC, it has not exercised its authority to levy assessments since 1933 and impact of any regulatoryviews the assessability authority as a mechanism for addressing capital deficiency that has long been overtaken by developments in statute and legislative changes are difficultregulation, including supervisory and enforcement authorities requiring an institution to predict and cannot be presently determined.maintain capital at a particular level.
Capital Standards - Basel Framework
In 2013,At December 31, 2023, we exceeded all capital adequacy requirements under the FRB, FDIC, and OCC published final rules (the “Basel III capital rules”) establishing a new comprehensive capital framework for U.S. banking organizations. The Basel III capital rules, effectively replaced the Basel I capital rules and implemented the Basel Committee’s December 2010 framework, commonly referred to as Basel III, for strengthening international capital standards as well aswhich include certain provisions of the Dodd-Frank Act. The Basel III capital rules substantially revised the risk-based capital and leverage ratio requirements applicable to bank holding companies and depository institutions, includingprescribed by the Company, compared to the Basel I U.S. risk-based capital rules. The Basel III capital rules became effective for the Company on January 1, 2015 and were subject to phase-in periods for certain of their components. In November 2017, the FRB, FDIC and OCC published a final rule for non-advanced approaches banks that extends the regulatory capital treatment applicable during 2017 under the regulatory capital rules for certain items.
OCC. The Basel III capital rules define the components of capital and address other issuesfactors, such as risk weights, affecting the numerator in banking institutions’ regulatory capital ratios. The Basel III capital rules also address risk weights and other issues affecting the denominator in banking institutions’ regulatory capital ratios and replaced the risk-weighting approach derived from Basel I capital accords of the Basel Committee, with a more risk-sensitive approach based, in part, on the standardized approach in the Basel Committee’s 2004 Basel II capital accords. The Basel III capital rules also implemented the requirements of Section 939A of the Dodd-Frank Act to remove references to credit ratings from the federal banking agencies’ rules.
The Basel III capital rules among other things, (i) introduced a new capital measure called “Common Equity Tier 1” (“CET1”), (ii) specified that Tier 1 capital consists of CET1 and “Additional Tier 1 capital” instruments meeting specified requirements, (iii) applied most deductions/adjustmentsrequire us to regulatory capital measures to CET1 and not to the other components of capital, thus potentially requiring higher levels of CET1 in order to meet minimum ratios, and (iv) expanded the scope of the deductions/adjustments from capital as compared to prior regulations.
Under the Basel III capital rules, themaintain certain minimum capital ratios, are as follows:
4.5% CET1 to risk-weighted assets;
6.0% Tier 1 capital (i.e., CET1 plus Additional Tier 1) to risk-weighted assets;
8.0% Total capital (i.e., Tier 1 plus Tier 2) to risk-weighted assets; and
4.0% Tier 1 capital to average consolidated assetswell as reported on consolidated financial statements (known as the “leverage ratio”).
When fully phased-in the Basel III capital rules will also require the Company and its subsidiary bank to maintain a 2.5% “capital conservation buffer”buffer,” which is designed to absorb losses during periods of economic stress, composed entirely of CET1, on top of the minimum risk-weighted asset ratios, effectively resulting in minimum ratios of (i) CET1 to risk-weighted assets of at least 7.0%, (ii)common equity Tier 1 capital to risk-weighted assets of at least 8.5%, and (iii) Total capital to risk-weighted assets of at least 10.5%(“CET1”). BankingFinancial institutions with a ratio of CET1 to risk-weighted assets above the minimum, but below the capital conservation buffer, will face constraints on dividends, equity repurchases, and compensation based on the amount of the shortfall. The implementationseverity of the capital conservation buffer began on January 1, 2016 at the 0.625% level and progressively increases over time, as determined by regulation.
The Basel III capital rules also prescribed a standardized approach for calculating risk-weighted assets that expanded the risk-weighting categories from Basel I-derived categories (0%, 20%, 50% and 100%) to a much larger and more risk-sensitive number of categories, dependingconstraint depends on the natureamount of the assets, generally ranging from 0% for U.S. Governmentshortfall and agency securities, to 600% for certain equity exposures,the institution’s “eligible retained income,” which is defined as four quarters of trailing net income, net of distributions and resultingassociated tax effects not already reflected in higher risk weights for a variety of asset categories. In addition, the Basel IIInet income. For more information about our capital rules provided more advantageous risk weights for derivatives and repurchase-style transactions cleared through a qualifying central counterparty and increased the scope of eligible guarantors and eligible collateral for purposes of credit risk mitigation.ratios, see “Capital Management” in MD&A on page 72.

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

The Basel III capital rules provided for a number of deductions from and adjustments to CET1. These include, for example, the requirement that mortgage servicing rights, deferred tax assets (“DTAs”) dependent upon future taxable income, and significant investments in common equity issued by nonconsolidated financial entities be deducted from CET1 to the extent that any one such category exceeds 10% of CET1 or all such categories in the aggregate exceed 15% of CET1. The application of this part of the rule did not result in any deductions from CET1 for us.
Under prior Basel I capital standards, the effects of accumulated other comprehensive income (“AOCI”) items included in capital were excluded for purposes of determining regulatory capital and capital ratios. As a “non-advanced approaches banking organization,” we made a one-time permanent election as of January 1, 2015 to continue to exclude these items, as allowed under the Basel III capital rules.
Basel III also required additional regulatory capital disclosures to be made that are commonly referred to as “Pillar 3” disclosures. These disclosures require the Company to make prescribed regulatory disclosures on a quarterly basis regarding its capital structure adequacy and risk-weighted assets. The Company began publishing these Pillar 3 disclosures in 2015, and such disclosures are available on the Company’s website.
The Basel Committee has issued a series of updates that propose other changes to capital regulations. In one of these, the Basel Committee finalized a revised framework for calculating minimum capital requirements for market risk, which is expected to increase market risk capital requirements for most banking organizations. The Basel Committee has set an effective date for reporting under the revised framework for market risk capital of December 31, 2019. The U.S. federal bank regulatory agencies have not yet proposed rules implementing these revisions for U.S. banking organizations. The Company met all capital adequacy requirements under the Basel III capital rules as of December 31, 2017.
Capital Planning and Stress Testing
The Company is required by the Dodd-Frank Act to participate in annual stress tests known as the Dodd-Frank Act Stress Test (“DFAST”) and the FRB’s Horizontal Capital Review, also referred to as Comprehensive Capital Analysis and Review (“HCR/CCAR”). The Company submitted its 2017 capital plan and stress test results to the FRB on April 5, 2017. In its capital plan, the Company was required to forecast, under a variety of economic scenarios for nine quarters, its estimated regulatory capital ratios, and its generally accepted accounting principles (“GAAP”) tangible common equity ratio. On June 28, 2017, we announced that the FRB notified us that it did not object to the capital actions outlined in our 2017 capital plan. The plan included (1) the increase of the quarterly common dividend to $0.24 per share by the second quarter of 2018, following the path of $0.12 per share in the third quarter of 2017, $0.16 per share in the fourth quarter of 2017, $0.20 per share in the first quarter of 2018 and $0.24 per share in the second quarter of 2018; and (2) up to $465 million in total repurchases of common equity.
On June 22, 2017, we filed a Form 8-K with the SEC presenting the results of the 2017 DFAST. The results of the stress test demonstrated that the Company has sufficient capital to withstand a severe hypothetical economic downturn. Detailed disclosure of the stress test results can also be found on our website. In addition, we submitted on October 5, 2017, our mid-cycle company-run DFAST, based upon the Company’s June 30, 2017 financial position. Zions’ mid-cycle DFAST results, based on the hypothetical severely adverse scenario, indicate the Company would maintain capital ratios at sufficient levels throughout the nine-quarter forecasting horizon. As discussed in the mid-cycle press release, published October 5, 2017, Zions’ hypothetical severely adverse scenario was designed to create a stressful idiosyncratic environment, including a 10% unemployment rate and a 35% decline in commercial property values. During the nine-quarter projection period, the minimum CET1 ratio was 9.9%.
Zions has participated in the annual HCR/CCAR/DFAST exercise since 2014. Prior to 2017, the FRB could object to Zions’ capital plan on either quantitative or qualitative grounds. On January 30, 2017, the FRB announced a final rule for the 2017 cycle, removing from the qualitative assessment of the exercise those bank holding companies that have total consolidated assets of at least $50 billion but less than $250 billion, on-balance sheet foreign exposure of less than $10 billion, and nonbank assets of less than $75 billion (referred to as large and non-complex (“LNC”)


firms). However, the FRB may still object to a capital plan based on the results of its quantitative assessment. As an LNC firm, Zions will still be subject to regular supervisory assessments to examine the Company’s capital planning processes. Our annual capital plan is due by April each year, and the FRB will publish results of its supervisory HCR/CCAR review of our capital plan by June 30 of each year.
On February 17, 2014, the FRB published final rules to implement Section 165, Enhanced Supervision and Prudential Standards for Nonbank Financial Companies Supervised by the Board of Governors and Certain Bank Holding Companies, of the Dodd-Frank Act. The Company believes that it is in compliance with these rules.
Liquidity
Historically, regulation and monitoring of bank and bank holding company liquidity has been addressed as a supervisory matter, both in the United States and internationally, without required formulaic measures. However, in January 2016, Zions became subject to final rules adopted by the FRB and other banking regulators (“Final Liquidity Coverage Ratio (“LCR”) requirement Rule”) implementing a U.S. version of the Basel Committee’s LCR requirement. The LCR is intended to ensure that banks hold sufficient amounts of so-called HQLA to cover the anticipated net cash outflows during a hypothetical acute 30-day stress scenario. Zions is subject to the modified LCR, which is the ratio of an institution’s amount of HQLA (the numerator) over 70% of projected net cash out-flows over the 30-day horizon (the denominator), in each case, as calculated pursuant to the Final LCR Rule. The Final LCR Rule requires institutions subject to the modified LCR to maintain the modified ratio equal to at least 100% in order to satisfy this regulatory requirement. Only specific classes of assets, including U.S. Treasury securities, other U.S. government obligations and agency mortgage-backed securities, qualify under the rule as HQLA, with classes of assets deemed relatively less liquid and/or subject to greater degree of credit risk subject to certain haircuts and caps for purposes of calculating the numerator under the Final LCR Rule. The total assumed projected net cash outflows amount is determined under the rule by applying certain hypothetical outflow and inflow rates, which reflect certain standardized stressed assumptions, against the balances of the banking organization’s funding sources, obligations, transactions and assets over the 30-day stress period. Inflows that can be included to offset outflows are limited to 75% of outflows (which effectively means that banking organizations must hold HQLA equal to 25% of outflows even if outflows perfectly match inflows over the stress period).
The Basel III framework also included a second standard, referred to as the net stable funding ratio (“NSFR”), which is designed to promote more medium- and long-term funding of the assets and activities of banks over a one-year time horizon. In May 2016, the FRB and other federal banking regulators issued a proposed rule that would implement the NSFR for large U.S. banking organizations. Under the proposed rule, the most stringent requirements would apply to bank holding companies with $250 billion or more in total consolidated assets or $10 billion or more in on-balance sheet foreign exposure, and would require such organizations to maintain a minimum NSFR of 1.0 on an ongoing basis, calculated by dividing the organization’s available stable funding by its required stable funding. Bank holding companies with less than $250 billion, but more than $50 billion, in total consolidated assets and less than $10 billion in on-balance sheet foreign exposure, such as Zions, would be subject to a modified NSFR requirement which would require such bank holding companies to maintain a minimum NSFR of 0.7 on an ongoing basis. Under the proposed rule, a banking organization’s available stable funding would be calculated by applying specified standard weightings to its equity and liabilities based on their expected stability over a one-year time horizon and its required stable funding would be calculated by applying specified standardized weightings to its assets, derivative exposures and commitments based on their liquidity characteristics over the same one-year time horizon. The U.S. federal bank regulatory agencies have not released the final rule. We do not expect this to have a material impact on the Company.
Financial Privacy and Cyber Security
The federal banking regulators have adopted rules that limit the ability of banks and other financial institutions to disclose non-public information about consumers to non-affiliated third parties. These limitations require disclosure of privacy policies to consumers and, in some circumstances, allow consumers to prevent disclosure of certain personal information to a non-affiliated third party. These regulations affect how consumer information is transmitted through diversified financial companies and conveyed to outside vendors. In addition, consumers may


also prevent disclosure of certain information among affiliated companies that is assembled or used to determine eligibility for a product or service, such as that shown on consumer credit reports and asset and income information from applications. Consumers also have the option to direct banks and other financial institutions not to share information about transactions and experiences with affiliated companies for the purpose of marketing products or services. Federal law makes it a criminal offense, except in limited circumstances, to obtain or attempt to obtain customer information of a financial nature by fraudulent or deceptive means.
In October 2016, the federal banking regulators jointly issued an advance notice of proposed rulemaking on enhanced cyber risk management standards that are intended to increase the operational resilience of large and interconnected entities under their supervision. The advance notice of proposed rulemaking addressed five categories of cyber standards: (1) cyber risk governance; (2) cyber risk management; (3) internal dependency management; (4) external dependency management; and (5) incident response, cyber resilience, and situational awareness. The comment period expired in February 2017; however, the regulators have not yet issued any revised proposed rules or final rules.
Prompt Corrective Action
The Federal Deposit Insurance Corporation Improvement Act (“FDICIA”) requires each federal banking agency to take prompt corrective action to resolve theidentified problems of insured depository institutions, including, but not limited to, those that fall below one or more prescribed minimum capital ratios. Pursuant to FDICIA, the FDIC promulgated regulations defining the following five categories in which an insured depository institution will be placed, based on the level of its capital ratios: well-capitalized, adequately capitalized, under-capitalized, significantly under-capitalized, and critically under-capitalized.
Under the prompt corrective action provisions of FDICIA as modified by the Basel III capital rules, an insured depository institution will generally will be classified as well-capitalized if it has a CET1 ratio of at least 6.5%, a Tier 1 risk-based capital ratio of at least 8%, a total risk-based capital ratio of at least 10%, and a Tier 1 leverage ratio of at least 5%, and an. An insured depository institution will generally will be classified as under-capitalized if itsit has a CET1 ratio is under 3%, its total risk-based capital ratio is less than 8%4.5%, itsa Tier 1 risk-based capital ratio is less than 6%, or itsa total risk-based capital ratio less than 8%, and a Tier 1 leverage ratio is less than 4%.
An institution that based upon its capital levels, is classified as “well-capitalized,” “adequatelywell-capitalized, adequately capitalized, or “under-capitalized,”under-capitalized, may be treated as though it were in the next lower capital category if the appropriate federal banking agency, after notice and opportunity for hearing, determines that an unsafe or unsound condition or an unsafe or unsound practice warrants such treatment. At each successive lower capital category, an insured depository institution is subject to more restrictions and prohibitions, including restrictions on growth, restrictions on interest rates paid on deposits, the acceptance of brokered deposits, and restrictions or prohibitions on the payment of dividends and restrictions on the acceptance of brokered deposits.dividends. Furthermore, if a bank is classified in one of the under-capitalized categories, it is required to submit a capital restoration plan to the Federal bank regulator,federal banking regulator.
The following schedule presents minimum capital ratio and capital conservation buffer requirements, our capital ratios at December 31, 2023, and the holding company must guaranteeminimum requirements to be well-capitalized:
Schedule 1
MINIMUM CAPITAL RATIO AND CAPITAL CONSERVATION BUFFER REQUIREMENTS
December 31, 2023
Minimum requirement to be well-capitalized
Minimum capital requirementCapital conservation bufferMinimum capital ratio requirement with capital conservation bufferCurrent capital
ratio
CET1 to risk-weighted assets4.5 %2.5 %7.0 %10.3 %6.5 %
Tier 1 capital (i.e., CET1 plus additional Tier 1 capital) to risk-weighted assets6.0 2.5 8.5 10.9 8.0 
Total capital (i.e., Tier 1 capital plus Tier 2 capital) to risk-weighted assets8.0 2.5 10.5 12.8 10.0 
Tier 1 capital to average consolidated assets (known as the “Tier 1 leverage ratio”)4.0 N/A4.0 8.3 5.0 
Recent Regulatory Developments
Basel III Endgame
On July 27, 2023, bank regulators issued a proposal to implement the performanceBasel Committee on Banking Supervision’s finalization of the post-crisis bank regulatory capital reforms. The proposal, commonly referred to as the “Basel III Endgame,” would significantly revise the capital requirements applicable to large banking organizations, defined as those with total assets of $100 billion or more. The proposal is subject to a three-year phase-in period for certain aspects of the proposal, and would be effective beginning July 1, 2025. At December 31, 2023, we had $87.2 billion in total assets and do not currently qualify as a large banking organization. We are evaluating the potential future impact of the proposal, as we expect it is more likely than not we would become subject to this proposal in the future, were it to be finalized in its current form.
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Under the proposal, if at such time we were to increase our total assets to $100 billion or more, we would, among other things, be required to (1) include certain components of accumulated other comprehensive income (“AOCI”) in regulatory capital and be subject to increased limitations on deferred tax assets (“DTAs”) as a percent of CET1, (2) hold capital for operational risk and market risk, and (3) calculate risk-based capital ratios under both the standardized approach and the expanded risk-based approach.
Long-term Debt
On August 29, 2023, bank regulators issued a proposal that plan.would expand a long-term debt requirement to all banks with total assets of $100 billion or more. The proposed rule would require these banks to have a minimum outstanding amount of eligible long-term debt that is the greatest of (1) 6% of total risk-weighted assets, (2) 2.5% of total leverage exposure, and (3) 3.5% of average total assets. In the event we were to increase our total assets to $100 billion or more, we would have a three-year implementation period to issue debt and meet the other requirements under the proposal. At December 31, 2023, if enacted as proposed, the estimated amount of incremental debt that would be implied by the proposal (based on our asset size at year end) would be approximately $3.5 billion over the three year phase-in period. We expect that the issuance of incremental debt would replace other sources of funding.
Resolution Planning
Additionally, on August 29, 2023, the FDIC issued a proposal that would revise the requirements for resolution planning (“living wills”) for banks in two asset categories. Under the proposal, banks with total assets of $100 billion or more would be required to submit more detailed living wills, while banks with total assets between $50 billion and $100 billion would submit more limited information filings, in each case filed biennially beginning in 2025.
FDIC Special Assessment
In November 2023, the FDIC issued a final rule to implement a special assessment pursuant to a systemic risk determination to recover the costs associated with protecting uninsured depositors following the closures of Silicon Valley Bank and Signature Bank in early 2023. Using an assessment base equal to the estimated amount of uninsured deposits above $5 billion at December 31, 2022, the FDIC is expected to collect the special assessment from banks at an annual rate of approximately 13.4 basis points (“bps”) for an anticipated eight quarterly assessment periods, beginning with the first quarterly assessment period of 2024. At December 31, 2023, our estimated impact of the special assessment was approximately $90 million, which we recorded in deposit insurance and regulatory expense during the fourth quarter of 2023.
Capital Planning and Stress Testing
We utilize stress testing as an important mechanism to inform our decisions on the appropriate level of capital, based upon actual and hypothetically stressed economic conditions, which are comparable in severity to the scenarios published by the Federal Reserve Board (“FRB”). Our recent internal stress test included hypothetical scenarios that reflected (1) high inflation, (2) increased losses on commercial loans due to inflation and supply chain disruptions, (3) declining commercial property values, (4) increased losses on consumer loans due to falling home prices, (5) rising unemployment, and (6) other current economic, financial, and social disruptions. The results of our stress test indicated that we would maintain capital ratios in excess of regulatory minimum and capital conservation buffer requirements throughout the nine-quarter horizon for the hypothetical stress test.
Liquidity
We utilize internal liquidity stress tests as a primary tool for establishing and managing liquidity guidelines including, but not limited to, holdings of investment securities and other liquid assets, levels of readily available contingency funding, concentrations of funding sources, and the maturity profile of liabilities. At December 31, 2023, we had sources of liquidity that exceeded our uninsured deposits without the need to sell any investment securities. We continue to actively manage our deposit base and associated deposit costs in response to the higher interest rate environment. For more information about our liquidity profile, see “Liquidity Risk Management” in MD&A on page 67.
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Financial Privacy and Cybersecurity
The federal legislature and federal banking regulators have implemented laws and rules governing the use of consumer information by banks and other financial institutions, including provisions of the Gramm-Leach-Bliley Act. These laws and rules limit the ability of banks and other financial institutions to disclose nonpublic information about consumers to unaffiliated third parties, require financial institutions to disclose privacy policies to consumers and, in some circumstances, allow consumers to prevent disclosure of certain personal information to an unaffiliated third party. These laws and regulations also affect how consumer information is transmitted through diversified financial companies and conveyed to outside vendors. In addition, consumers may prevent disclosure of certain information among affiliated companies that is assembled or used to determine eligibility for a product or service, such as that shown on consumer credit reports and asset and income information from applications. Consumers also have the option to direct banks and other financial institutions not to share information about transactions and experiences with affiliated companies for the purpose of marketing products or services. Federal law makes it a criminal offense, except in limited circumstances, to obtain or attempt to obtain customer information of a financial nature by fraudulent or deceptive means.
Federal and state regulators have been increasingly active in implementing privacy and cybersecurity standards and regulations. For example, recently effective SEC rules now require timely disclosure of material cybersecurity incidents and description of cybersecurity risk management, strategy, and governance. Additionally, during the past several years, a growing number of states, including those in which we conduct business, have enacted, or are considering enacting, laws and regulations granting consumers enhanced privacy rights and control over personal information, establishing or modifying data breach notification requirements, and requiring certain financial institutions to implement detailed and prescriptive cybersecurity programs. Data and cybersecurity laws and regulations are evolving rapidly and remain a focus of state and federal regulators.
Other Regulations and Proposals
The Company isWe are subject to a wide range of other requirements and restrictions contained in both the laws of the United Statesfederal and the states in which its banksstate laws. These regulations and other subsidiaries operate. These regulationsproposals include, but are not limited to, the following:
Requirements that the Parent serve as a source of strength for its subsidiary bank. The FRB has a policy that a bank holding company is expected to act as a source of financial and managerial strength to its subsidiary bank and, under appropriate circumstances, to commit resources to support the subsidiary bank. The Dodd-Frank Act codified this policy as a statutory requirement.
Limitations on dividends payable by subsidiaries. A significant portion of the Parent’s cash, which is usedto shareholders. Our ability to pay dividends on both our common and preferred stock and to pay principal and interest on our debt obligations, is derived from dividends paid to the Parent by its subsidiary bank. These dividends are subject to various legal and regulatory restrictions. See Note 1415 of the Notes to Consolidated Financial Statements.Statements for additional information.
Limitations on dividends payable to shareholders. The Parent’s ability to pay dividends on both its common and preferred stock may be subject to regulatory restrictions, including the requirement that they be included in a


stress test and capital plan to which the FRB has not objected. See discussion under “Liquidity Management Actions” on page 74.
Safety and soundness requirements. Federal law requires that our bank be operated in a safe and sound manner. We are subject to additional safety and soundness standards prescribed in the FDICIA, including standards related to internal controls, information systems, internal audit, loan documentation, credit underwriting, interest rate exposure, asset growth and compensation, as well as other operational and management standards deemed appropriate by the federal banking agencies. The safety and soundness requirements give bank regulatory agencies significant latitude in their supervisory authority over us.
Requirements for approval of acquisitions and activities and restrictions on other activities. PriorThe National Bank Act requires regulatory and shareholder approval of all mergers between a national bank and another national or state bank and does not allow for the FRB is required under the BHC Act fordirect merger into a financial holding company to acquire or hold more than a 5% voting interestnational bank of an unaffiliated nonbank. See further discussion in any bank, to acquire substantially all the assets of a bank or to merge with another financial or bank holding company. The BHC Act also requires approval for certain non-banking acquisitions, restricts the activities of bank holding companies that are not financial holding companies to banking, managing or controlling banks and other activities that the FRB has determined to be so closely related to banking as to be a proper incident thereto, and restricts the non-banking activities of a financial holding company to those that are permitted for financial holding companies or that have been determined by the FRB to be financial in nature, incidental to financial activities, or complementary to a financial activity. Laws“Risk Factors.” Other laws and regulations governing national banks contain similar provisions concerning acquisitions and activities.
Limits on interchange fees imposed under the Dodd-Frank Act, including a set of rules requiring that interchange transaction fees for electronic debit transactions be reasonable and proportional to certain costs associated with processing the transactions. In addition, the Federal Reserve has proposed revising Regulation II to lower debit interchange fees by almost 30% and institute a biennial review of the cap without accompanying public comment. If this proposal passes, it could reduce our fee income by approximately $10 million or more per year.
Limitations on the dollar amount of loans made to a borrower and its affiliates.
Limitations on transactions with affiliates. The Dodd-Frank Act significantly expanded the coverage and scope of the limitations on affiliate transactions within a banking organization.
Restrictions on the nature and amount of any investments and ability to underwrite certain securities.types of securities (e.g., common equity).
Requirements for opening and closing of branchesbranches.
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A number of federal and the acquisition of other financial entities.
Fairstate consumer protection laws, including fair lending and truth in lending requirements, to provide equal access to credit and to protect consumers in credit transactions.
Broker-dealer In addition, as a bank with $10 billion or more in assets, we are subject to examination and investment advisory regulations. One of our subsidiaries is a broker-dealer that is authorizedprimary enforcement authority with respect to engage in securities underwriting and other broker-dealer activities. This company is registered with the SEC and is a member of FINRA. Another subsidiary is a registered investment adviser under the Investment Advisers Act of 1940, as amended, and as such is supervisedconsumer financial laws by the SEC. Certain of our subsidiaries are also subject toCFPB, which has broad rule making, supervisory, and enforcement powers under various U.S. federal and state laws and regulations.consumer financial protection laws. These lawsrules and regulations generally grant supervisory agencies broad administrative powers, includingoften have the powereffect of reducing bank revenues and returns earned by shareholders. As an example, the CFPB recently proposed extending certain truth in lending requirements to limit or restrict the carryingoverdraft fees and placing other restrictions on of businessvarious fees routinely charged by banks in exchange for failureproviding financial services to comply with such laws.customers.
Provisions of the GLB Act and other federal and state laws dealing with privacy for non-public personal information of individual customers.
Community Reinvestment Act (“CRA”) requirements. The CRA requires banks to help serve the credit needs in their communities, including providing credit to lowlow- and moderate incomemoderate-income individuals. If our bank subsidiary failswe fail to adequately serve itsour communities, penalties may be imposed including denials of applications to add branches, relocate, add subsidiaries and affiliates, and merge with or purchase other financial institutions. Banking agencies recently finalized rules that completely overhaul the evaluation framework used by regulators to assess a bank’s performance under and compliance with these requirements, which may make it more difficult for banks to achieve satisfactory ratings. The potential impact of these new rules on the Bank and the industry as a whole is currently under review.
Requirements regarding the time, manner, and form of compensation given to key executives and other personnel receiving incentive compensation, including requirements related to the SEC’s 2022 rule on pay versus performance disclosures, and recently finalized rules regarding the clawback of executive pay in certain circumstances involving accounting restatements. These restrictions include documentation and governance, deferral, risk-balancing, and the aforementioned clawback requirements. Any deficiencies in compensation practices may be incorporated into supervisory ratings, which can affect our ability to make acquisitions or engage in certain other activities, or could result in regulatory enforcement actions.
Anti-money laundering regulations. The Bank Secrecy Act, Title III of the Uniting and Strengthening of America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (“USA Patriot Act”), and other federal laws require financial institutions to assist U.S. Governmentgovernment agencies in detecting and preventing money laundering and other illegal acts by maintaining policies, procedures and controls designed to detect and report money laundering, terrorist financing, and other suspicious activity.
The Parent is subject to the disclosure and regulatory requirementsTax laws of the Securities Act of 1933, as amended,U.S., its states, and the Securities Exchange Act of 1934, as amended, both as administered by the SEC. As a company listed on the NASDAQ Global Select Market, the Parent is subject to NASDAQ listing standards for quoted companies.other jurisdictions where we conduct business.
The Company isWe are also subject to the Sarbanes-Oxley Act of 2002, certain provisions of the Dodd-Frank Act, and other federal and state laws and regulations which address, among other issues,matters, corporate governance, auditing and accounting, executive


compensation,internal controls over financial reporting, and enhanced and timely disclosure of corporate information. NASDAQ
Sustainability standards and related concerns, including those related to global climate change, continue to evolve and have become more prominent in recent years. We are closely monitoring developments in standards published by sustainability interest groups and organizations, as well as proposed regulatory initiatives and expectations relating to these issues. Although we believe the way we do business has alsobeen and is consistent with many of these standards and expectations, we strive to enhance our business practices by incorporating sustainability recommendations that we believe will benefit our investors, customers, employees, and communities.
In addition to proposed and evolving rulemaking by federal regulators, such as the SEC’s proposed rule on climate-related disclosures and the bank regulatory agencies’ recently issued principles designed to provide a framework for large financial institutions to manage exposure to climate-related financial risks, many states have adopted, corporate governance rules, whichor are intendedconsidering, laws that address climate and social issues. For example, the state of California recently passed sweeping climate-related disclosure laws that will require large entities doing business in the state, including the Bank, to allow shareholdersmeasure and investorsdisclose greenhouse gas emissions and report on their climate-related risks. These laws will increase our compliance costs and may include provisions that conflict with other state and federal regulations, or limit our ability to more easily and efficiently monitor the performanceconduct business in certain jurisdictions. We publish an annual Corporate Responsibility Report that provides a summary of companies and their directors.how we address these issues. The report is available on our website.
The
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Corporate Governance
Our Board of Directors of the Parent(“Board”) has overseen management’s establishment of a comprehensive system of corporate governance and risk management practices. This system includes frameworks, policies, and guidelines such as the following:
Corporate Governance Guidelines, aGuidelines;
A Code of Business Conduct and Ethics for Employees, a DirectorsEmployees;
A Director’s Code of Conduct, aConduct;
A Risk Management Framework;
A Related Party Transaction Policy, Policy;
Incentive Compensation Recoupment and Clawback Policies;
Stock Ownership and Retention Guidelines, a Compensation Clawback Policy, an insider trading policy including provisions prohibiting hedgingGuidelines;
An Insider Trading Policy; and placing restrictions on the pledging of company stock by insiders, and charters
Charters for theour Executive, Audit, Risk Oversight, Compensation, and Nominating and Corporate Governance Committees.
More information on the Company’sour corporate governance practices is available on the Company’sour website at www.zionsbancorporation.com. (The Company’szionsbancorporation.com. Our website is not part of this Annual Report on Form 10-K).10-K.
HUMAN CAPITAL MANAGEMENT
We are proud of our employees who bring their unique, diverse talents to work each day. We are committed to identifying, recognizing, and creating fulfilling opportunities for our employees, and rewarding them for their contributions to our success.
During 2023, we continued to enhance certain benefits for our employees to adapt to the changing practices of the labor market. Recent changes include more flexibility with paid time off, more health care plan alternatives, and greater access to mental health benefits.
We had 9,679 full-time equivalent employees at December 31, 2023. The following schedule presents certain demographic attributes of our workforce as self-identified by our employees:
Schedule 2
December 31, 2023
WomenPeople of ColorDisabledVeterans
Employee Roles
Management52%29%9%2%
Non-management60%40%10%2%
All employees58%38%10%2%
The Company has adopted policies, proceduresfollowing objectives and controlsinitiatives are integral to address compliance withour human capital management efforts:
Cultivating an environment where people are respected and valued, and where individual and cultural differences are embraced
We believe that (1) our performance is stronger when we are able to draw upon the requirementstalents and experience of the banking, securitiesa diverse team of employees, and other laws(2) in-person exchange of ideas and regulations described above or otherwise applicableviewpoints, in both formal and informal settings, improves productivity and supports a strong corporate culture while still offering flexibility to the Company. The Company intends to make appropriate revisions to reflect any changes required.
Regulators, Congress, state legislatures, and international consultative bodies continue to enact rules, laws, and policies to regulate the financial services industry and public companies and to protect consumers and investors. The nature of these laws and regulations and the effect of such policies on future business and earnings of the Company cannot be predicted.
GOVERNMENT MONETARY POLICIES
The earnings and business of the Company are affected not only by general economic conditions, but also by policies adopted by various governmental authorities. The Company is particularly affected by the monetary policies of the FRB, which affect both short-term and long-term interest rates and the national supply of bank credit.
In view of the changing conditions in the economy and the effect of the FRB’s monetary policies, it is difficult to predict future changes in loan demand, deposit levels and interest rates, or their effect on the business and earnings of the Company. FRB monetary policies have had a significant effect on the operating results of commercial banks in the past and are expected to continue to do so in the future.
REGULATORY RELIEF IF PROPOSED RESTRUCTURING IS COMPLETED AND FSOC APPLICATION IS APPROVED
As discussed above, on November 20, 2017, we announced a proposal to streamline our corporate structure by merging the Parent into its bank subsidiary, ZB, N.A. In connection with the proposed restructuring, we also intend to file an application with FSOC (the “FSOC Appeal”) that, if successful, could potentially eliminate “enhanced” regulation of the “Company” as a SIFI.
If completed, the proposed restructuring would eliminate the bank holding company structure and associated regulatory framework and would result in ZB, N.A. becoming the top-level publicly-traded entity within our corporate structure. If the proposed restructuring and FSOC Appeal are successful, the Company expects that:
The Company would no longer be subject to duplicative examinations by both the FRB and OCC and instead would no longer be subject to examinations by the FRB. The Company would continue to be subject to examinations by the CFPB with respect to consumer financial regulations.
The Company would no longer be subject to “enhanced prudential supervision” by the FRB under Section 165 of the Dodd-Frank Act. There are a number of regulatory requirements that are applied to the Company under “enhanced prudential supervision,” which includes the annual HCR/CCAR process, as well as the LCR requirements applicable to “systemically important” organizations, as discussed above under “Capital Planning and Stress Testing” and “Liquidity,” respectively. The Company would continue to be subject to the OCC’sbalance personal needs.

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We endeavor to provide opportunities for growth, development, and leadership to every employee. We are committed to continue this focus on ensuring that we have a workplace where all are treated fairly in accordance with their qualifications and abilities, and that the Bank is a place where everyone counts.
heightened standardsWe strive to build a workplace where we embrace differences — in points of view and in national origin, language, race, disability, ethnicity, gender, age, religion, sexual orientation, gender identity, socioeconomic status, veteran status, and family structures. Our Everyone Counts Council coordinates the related efforts of our affiliates and enterprise groups, and advises executive management on goals and recommendations for national banksongoing improvement. Our efforts include employee business forums, mental health initiatives, and a broad range of employee and regional events. Throughout the organization, the employee business forums foster a sense of community and enable greater connectivity and support among employees through meetings and discussions, which are open to all employees and offer networking and connections to the communities in which we operate.
We use analytics, recruiting outreach efforts, and manager training to reach a diverse, qualified group of potential applicants to secure a high-performing workforce drawn from all segments of society. To identify qualified candidates, our recruiting team partners with assetscommunity organizations, schools, and governmental entities that support marginalized and underserved communities in our footprint. Our annual Corporate Responsibility Report, which is published on our website, highlights several achievements in this area, such as our Banker Development Program, which attracts and advances undergraduates and early career professionals.
Attracting, developing, and retaining talent for long-term success
We are committed to (1) attracting, developing, and retaining the most qualified individuals who reflect the diversity of $50 billionthe available workforce and markets in which we operate, (2) helping our employees grow in their careers, and (3) actively building a pipeline of talent for future leadership opportunities. As we attract and hire talent, we proactively consider the demand for competencies that will be needed within the workforce of the future.
Consistent with our strategic objectives, we invest in training our employees and providing them the tools and resources to build their capabilities. We offer more than 1,500 virtual, in-person, expert-led, and pre-recorded or self-paced learning options for employees to create custom learning plans for personal and professional development. In 2023, we hosted more than 1,000 training experiences to support employees, build new skills, or to assist in career advancement. We offer new manager programs, tuition reimbursement, education sponsorship opportunities, job shadowing, coaching, and formal mentoring programs. Our talent development program and individual development plans focus on education, experience, and exposure to help create well-rounded, highly skilled, and successful employees.
We are also mindful of the DFAST process,continued competition for talent in the labor market. We continue to analyze relevant metrics related to employee recruiting and turnover, which has and will continue to impact wages and flexible work arrangements.
Recognizing, engaging, and rewarding our employees
Our comprehensive rewards and recognition programs are designed to reward high performance, improve retention, and enhance the employee experience through recognition and growth opportunities. We provide meaningful upside opportunities for those who take accountability for business objectives that help us deliver superior results while reducing risk.
We routinely assess pay equity among employees across our organization by analyzing potential disparities in pay based on gender, minority status, and other factors. These actions help us compensate employees fairly. On a biennial basis, we enlist the services of an independent third party to review our pay equity. Results of the most recent review revealed that after adjusting for relevant variables such as described above under “Capital Planningeducation, experience, performance, and Stress Testing.”geography, there were no meaningful differences in pay levels among men, women, and people of color. We remain committed to fair and equitable compensation for all our employees.
The Company would no longer beOur employees provide regular feedback through enterprise outreach and engagement forums, which include quarterly leadership calls, biannual employee opinion surveys, and targeted focus groups. These forums for
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employee input continue to help strengthen working relationships with managers, improve clarity of organizational purpose and goals, and reinforce our Guiding Principles and Code of Business Conduct and Ethics.
We value work-life balance and strive to create a work environment that supports our employees with mental, physical, social, and financial wellness. Some of our key benefits include the following:
Corporate match for our 401(k) plan of 4.5% of an employee’s salary and incentive compensation;
Annual profit-sharing contributions;
Health care plan options including behavioral health, wellness, and autism spectrum disorder services;
Expanded mental health coverage, including coaching and clinical therapy sessions;
Preventive prescription drug coverage not subject to the prior non-objection requirement under HCR/CCARdeductibles;
Paid parental leave program;
Adoption assistance program; and
Paid time off for declaring any dividends or share repurchases, but would continue to be subject to the limitations on dividendsvarious community service activities and share repurchases pursuant to the National Bank Act and the OCC’s regulations.other volunteer opportunities.
In addition, if the restructuring is completed, the Company generally would no longer be subject to the Securities Law of 1933, but would remain subject to the requirements of the Securities Exchange Act of 1934, including the reporting requirements thereunder. However, the Company would be subject to OCC regulations governing securities offerings and make any filings required under the Securities Exchange Act with the OCC instead of the SEC.
ITEM 1A. RISK FACTORS
The Company’s growth strategy is driven by key factors while adhering to defined risk parameters. The key elements of Zions’ strategy reflect its prudent risk-taking philosophy. The Company generatesWe generate revenue and grow our businesses by taking prudent and appropriately priced and managed risks. These factorsrisks are outlined in the Company’sour Risk AppetiteManagement Framework.
The Company’s Our Board of Directors has established an Audit Committee, a Compensation Committee, a Risk Oversight Committee of the Board, approved an Enterprise Risk Management Framework,(“ROC”), and appointed an Enterprise Risk Management Committee (“ERMC”) to oversee and implement the Risk Management Framework. The ERMC is comprised of senior management of the Company and is chaired by the Chief Risk Officer. The Company’s most significant risk exposure has traditionally come from the acceptance of credit risk inherent in prudent extension of credit to relationship customers. In addition to credit risk, theseThese committees also monitor the following level one risk areas: market andcredit risk, interest rate risk,and market risk; liquidity risk, strategic/risk; strategic and business risk, operational/risk; operational risk; technology risk, model risk,risk; cybersecurity risk; capital/financial reporting risk,risk; legal/compliance risk (including regulatory risk),; and reputational risk, as outlined in the Company’sour risk taxonomy. In 2017,We have developed policies, procedures, and controls designed to address these risks, but there can be no certainty that our actions will be effective to prevent or limit the Company also designated cyber risk a level one risk in its risk taxonomy, which places it at the highest level of oversight with its other top risks. Additional governance and oversight includes Board-approved policies and management committees with direct focus on these specific risk categories. Incorporated into eacheffects of these level one risks mentioned previously is third party vendor risk, which the Company views as critical in the management and oversight of vendor management.
on our business or performance. Although not comprehensive, the following describes several risk factors that are significantmaterial to the Company:us are described below.
Credit RiskCREDIT RISK
Credit quality has adversely affected us in the past and may adversely affect us in the future.
Credit risk is one of our most significant risks. ARising interest rates, increased market volatility, or a decline in the strength of the U.S. economy in general or the local economies in which we conduct operations could result in, among other things, deterioration in credit quality and/orand reduced demand for credit, including a resultant adverse effect on the income from our loan portfolio,and investment portfolios, an increase in charge-offs, and an increase in the allowance for loan and leasecredit losses (“ALLL”ACL”).
We have concentrationsconcentration of risk from counterparties and risk in our loan portfolio, including, but not limited to, loans secured by real estate, oil and gas-related lending, and leveraged and enterprise value lending, and oil and gas-related lending, which may have unique risk characteristics that may adversely affect our results. While oil and gas prices have stabilized over the last year and our lending exposure to this segment has been reduced, the oil and gas industry is still subject to volatility.
Concentration or counterpartyConcentrations of risk from counterparties could adversely affect the Company. Concentrationus, and risk across our loan and investment securities portfolios could pose significant additional credit risk to the Companyus due to similar exposures which perform in a similar fashion. Counterparty riskbetween the two asset types. Concentrations with counterparties on derivative or securities financing transactions could also pose additional credit risk.
We engage in commercial constructionreal estate (“CRE”) term and land acquisition and development lending, as well as commercial termconstruction lending, primarily in our westernWestern states footprint. The Company, as a whole, has relatively larger concentrations of such lending than many other peer institutions. In addition, we have a concentrationCertain CRE collateral types, particularly office CRE, continue to experience increased vacancy rates, declining property values, and pressures from rising interest rates, which could result in increased delinquencies and defaults. We also engage in oil and gas-related lending, primarily in Texas. Both commercial real estate (“CRE”) and oilwe provide leveraged and gas-related lending areenterprise value loans across our entire footprint. Certain of these loans may be subject to specific


risks, including governmental and social responses to environmental issues and climate change, volatility, and potential significant and prolonged declines in
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collateral-values and activity levels. In addition,Any decline in these portfolios could cause increased credit losses and reduced loan demand, which could adversely affect our real estate lending is concentrated in the western states,business and values there may behave differently than in other partsthat of the United States.our customers. We may have other unidentified concentrated or correlated risks in our loan portfolio.
Our business is highly correlated to local economic conditions in a specific geographic region of the United States.U.S.
AsWe provide a regional bank holding company, the Company provides a fullwide range of banking products and related services through itsour local management teams and unique brands in Arizona, California, Colorado, Idaho, Nevada, New Mexico, Oregon, Texas, Utah, Washington, and Wyoming. Approximately 76% of the Company’s total net interest income relates toAt December 31, 2023, loan balances associated with our banking operations in Utah, Idaho, Texas, and California forcomprised 77%, 69%, and 70% of the years ended December 31, 2017,commercial, CRE, and December 31, 2016,consumer lending portfolios, respectively. As a result of this geographic concentration, our financial results dependperformance depends largely upon economic conditions in these market areas. Accordingly, adversedeterioration in economic conditions, affectingincluding those caused by climate change or natural disasters, may specifically affect these three states, and could result in particular couldhigher credit losses and significantly affect our consolidated operations and financial results.
For example,information about our lending exposure to various industries and how we manage credit risk, could be elevated to the extent that our lending practicessee “Credit Risk Management” in these three states focusMD&A on borrowers or groups of borrowers with similar economic characteristics, which are similarly affected by the same adverse economic events. At December 31, 2017, loan balances associated with our banking operations in Utah, Texas, and California comprised 80% of the Company’s commercial lending portfolio, 74% of the CRE lending portfolio, and 71% of the consumer lending portfolio.page 54.
Loans originated by our banking operations in Utah, Texas, and California are primarily to borrowers in those respective states, with the exception of the National Real Estate group, which co-originates or purchases primarily owner-occupied first-lien CRE loans from financial institutions throughout the country.INTEREST RATE AND MARKET RISK
We have been and could continue to be negatively affected by adverse economic conditions.
Adverse economic conditions negatively affect the Company’s assets,pose significant risks to our business, including itsour loan and securitiesinvestment portfolios, capital levels, results of operations, and financial condition. The most recent financial crisis resultedA slowing economy and uncertainty related to inflationary pressures, including related changes in significant regulatory changes that continue to affect the Company. Although economic conditions have improved since the most recent financial crisis, it is possible that economic conditions may weaken. Economicmonetary and fiscal conditions in the United Statespolicies and other countries may directly or indirectly adversely impact economic and market conditions faced by the Company and its customers. Any sustained weakness or further weakening in economic conditions would adversely affect the Company.
Market and Interest Rate Risks
Failure to effectively manage our interest rate risk and prolonged periods of lowactions, rising interest rates, could adversely affect us.and decreased values of our fixed-rate assets, can increase these risks and lead to lower demand for loans, higher credit losses, and lower fee income, among other negative effects.
Net interest income is the largest component of the Company’s revenue. Interest rate risk is managed by the Asset Liability Management Committee, which is established by the Company’s Board of Directors. Failure to effectively manage our interest rate risk could adversely affect our results.
Net interest income is the Company.largest component of our revenue. Factors beyond the Company’sour control can significantly influence the interest rate environment and increase the Company’sour risk. These factors include changes in the prevailing interest rate environment, competitive pricing pressures for our loans and deposits, adverse shifts in the mix of deposits and other funding sources, and volatile market interest rates resulting from general economic conditions and the policies of governmental and regulatory agencies, in particular the FRB. Most components of our balance sheet are sensitive to rising and falling rates, and mismatches in rate sensitivity between assets and liabilities may result in unanticipated changes in both asset and liability values and related income and expense. Additionally, asset and liability values may be significantly impacted by customer behavior, as customers may choose to withdraw certain deposits or prepay certain loans at any time, which may significantly affect our expected cash flows.
The Company remains in an “asset-sensitive”For information about how we manage interest rate risk position, which means that net interest income would be expected to increase if interest rates increase, and to decline if interest rates decrease. Most recently,market risk, see “Interest Rate and Market Risk Management” in MD&A on page 63.
LIQUIDITY RISK
Changes in levels and sources of liquidity and capital, including the FRB decided to maintainresulting effects of recent events in the target range for the federal funds rate at 1.25% to 1.5%, and indicated that it will determine the timing and size of future rate adjustments by assessing realized and expected economic conditions relative to the objectives of maximum employment and 2% inflation.
Financial market participants have recently contemplated the possibility of negative interest rates. With the exception of brief money market disruptions in which some U.S. Treasury bills traded at negative rates, the U.S. has


not previously experienced a negative rate environment, although other developed economies have had prolonged periods of negative rates. Therefore, there are many unknown factors which could impact the Company in a negative rate environment. The ability to effectively charge customers interest on deposits will be determined largely by competition for deposits, but the Company’s deposit systems may require modification to allow for negative deposit rates. Asset allocation strategies would be reconsidered were the FRB to charge for excess reserves.
Our estimates of our interest rate risk position related to noninterest-bearing demand deposits are dependent on assumptions for which there is little historical experience, and the actual behavior of those deposits in a changing interest rate environment may differ materially from our estimates, which could materially affect our results of operations.
We have experienced a low interest rate environment for the past several years. Our views with respect to, among other things, the degree to which we are “asset-sensitive,” including our interest rate risk position for noninterest-bearing demand deposits, are dependent on modeled projections that rely on assumptions regarding changes in balances of such deposits in a changing interest rate environment. Because there is no modern precedent for the prolonged, extremely low interest rate environment that has prevailed for the last several years, there is little historical experience upon which to base such assumptions. If interest rates continue to increase, our assumptions regarding changes in balances of noninterest-bearing demand deposits and regarding the speed and degree to which other deposits are repriced may prove to be incorrect, and business decisions made in reliance on our modeled projections and underlying assumptions could prove to be unsuccessful. Because noninterest-bearing demand deposits are a significant portion of our deposit base, realized results which are different from our modeled projections and the underlying assumptions could materially affect our results of operations.
Liquidity Risk
As a regulated entity, we are subject to capital and liquidity requirements thatbanking industry, may limit our operations and potential growth.
We areOur primary source of liquidity is deposits from our customers, which may be impacted by market-related forces such as increased competition for these deposits and a bank holding company and, as such, we and our subsidiary bank are subjectvariety of other factors. Deposits across the banking industry have fluctuated in recent quarters in large part due to the comprehensive, consolidated supervisionincreased interest rate environment and regulationprominent bank closures. We, like many other banks, experienced deposit outflows as customers spread deposits among several different banks to maximize their amount of FDIC insurance, moved deposits to institutions offering higher rates or removed deposits from the FRB, the OCC andU.S. financial system entirely. Since the FDIC including risk-basedinsurance limit is not inflation-indexed and leverage capital ratio requirements,has not increased since 2008, the percent of our and Basel III liquidity requirements. Capital needsother regional bank uninsured deposits has steadily increased, and may rise above normal levels when we experience deteriorating earnings and credit quality, and our banking regulators may increase our capital requirements based on general economic conditions and our particular condition, risk profile and growth plans. In addition, we may be requiredcontinue to increase without additional congressional action to increase the FDIC insurance limits.
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Although our capitaldeposit levels even inhave increased during the absencelatter half of actual adverse economic conditions or forecasts2023, our cost of funds has also increased, primarily as a result of stress testingdeclining noninterest-bearing deposits, growth in interest-bearing deposits, and capital planning baseda higher interest rate environment. The potential for greater volatility and further increased costs remains, particularly if there is negative news surrounding the banking industry or perceived risks regarding bank safety and soundness. In such an environment, some depositors may be more likely to believe that there is greater safety in maintaining large, uninsured deposits at banks deemed “too big to fail,” which may contribute to further deposit runoff and increased deposit costs of community and regional institutions, including the Bank. If we are unable to continue to fund assets through customer bank deposits or access other funding sources on hypothetical future adversefavorable terms, or if we experience continued increases in borrowing costs or FDIC insurance assessments, or otherwise fail to manage liquidity effectively, our liquidity, operating margins, financial condition, and results of operations may be materially and adversely affected.
The Federal Reserve’s tightened monetary policy has contributed to a decline in the value of our fixed-rate loans and investment securities that are pledged as collateral to support short-term borrowings. Other economic scenarios. Compliance with the capital requirements, including leverage ratios,conditions may limit operations that require the intensive usealso affect (or continue to affect) our liquidity and efforts to manage associated risks. The Federal Home Loan Bank (“FHLB”) system and Federal Reserve have been, and continue to be, a significant source of capitaladditional liquidity and funding. Changes in FHLB or Federal Reserve funding programs could adversely affect our ability to expand or maintain present business levels. For a summaryliquidity and management of the capital rules to which we are subject, see “Capital Standards – Basel Framework” on page 10 of this Annual Report on Form 10-K.
Liquidity regulations, including regulations establishing a minimum Liquidity Coverage Ratio and requiring monthly liquidity stress testing applicable to the Company may impact profitability.
The Company is subject to liquidity regulations, including a requirement that it conduct monthly liquidity stress tests that require it to maintain a modified LCR of at least 100%. The Company’s calculation of the modified LCR indicates that the Company is in compliance with the requirement. Such stress testing is subject to ongoing model and assumptions changes which could affect results.
In order to meet the requirements of these new regulations, the Company expects to continue to hold a higher portion of its assets in HQLA and a lower portion of its assets in loans than was generally the case prior to such regulation. HQLA generally have lower yields than loans of the type made by the Company.associated risks.
We and/orand the holders of our securities could be adversely affected by unfavorable rating actions from rating agencies.
Our ability toWe access the capital markets is important to augment our overall funding profile.funding. This access is affected by the ratings assigned to us by rating agencies to us and particular classes of securities that we and our banking subsidiary


issue.agencies. The rates that we pay on our securities are also influenced by, among other things, the credit ratings that we and/orand our securities receive from recognized rating agencies. Ratings downgrades to us or our securities could increase our costs or otherwise have a negative effect on our results of operations orliquidity position, financial condition, or the market prices of our securities.
Strategic/Business RisksFor information about how we manage liquidity risk, including rating agency actions, see “Liquidity Risk Management” in MD&A on page 67.
STRATEGIC AND BUSINESS RISK
Problems encountered by other financial institutions could adversely affect financial markets generally and have indirect adverse effects on us.
The commercial soundness and stability of many financial institutions may be closely interrelated as a result of credit, trading, clearing, or other relationships between the institutions. As a result, concerns about, or a default or threatened default by, one institution could lead to significant market-wide liquidity and credit problems, losses, or defaults by other institutions. This is sometimes referred to as “systemic risk” and may adversely affect financial intermediaries, such as clearing agencies, clearing houses, banks, securities firms, and exchanges, with which we interact on a daily basis, and therefore, could adversely affect us. Information securityThis phenomenon has been evident in the recent events affecting the banking industry (such as the prominent bank closures), as financial institutions like us have been impacted by concerns regarding the soundness or creditworthiness of other financial institutions or reports of the risk of systemic deterioration in asset classes, such as commercial real estate. This has caused substantial and vendor management processes arecascading disruptions within the financial markets and deposits environment, increased expenses, reduced bank fees, and adversely impacted the market price and volatility of our common stock.
We may not be able to hire or retain qualified personnel or effectively promote our corporate culture, and recruiting and compensation costs may increase as a result of changes in place to actively identify, managethe workplace, marketplace, economy, and monitor actual and potential impacts.regulatory environment.
The regulation of incentive compensation under the Dodd-Frank Act may adversely affect ourOur ability to execute our strategy, provide services, and remain competitive may suffer if we are unable to recruit or retain our highest performing employees.
The bankqualified people, or if the costs of employee compensation and benefits increase substantially. Bank regulatory agencies have published regulations and guidance and proposed regulations whichthat limit the manner and amount of compensation that banking organizations provide to employees. These regulations and guidance may adversely affect our ability to attract and retain key personnel. Some of these limitations may not apply to institutions with which we compete for
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talent, in particular, as we are more frequently competing for personnel with financial technology providers and other entities that may not have the same limitations on compensation as we do. If we were to suffer such adverse effects with respect to our employees, our business, financial condition and results of operations could be adversely or materially affected.
Our ability to retain talent may also be adversely affected perhaps materially.by changes in the economy and workforce trends, priorities, migration, modes of delivery and other considerations, such as the increased ability of employees to work from anywhere in many industries.This growth in remote work and other changing priorities and benefits has led to an increase in compensation and related expenses and workplace challenges, such as fewer opportunities for face-to-face interactions, training and mentoring new employees, promoting a cohesive corporate culture, and increased competition for experienced labor, especially in high-demand and highly skilled categories. Inflationary pressures have also increased our compensation costs and are likely to continue to do so in the future.
We have made, and are continuing to make, significant changes to the Company that include, among other things, organizational restructurings, efficiency initiatives, and replacement or upgrades of certain core technologicaltechnology systems to improve our operating efficiency and control environment, and operating efficiency.environment. The ultimate success and completion of these changes, and their effecteffects on the Company,us, may vary significantly from initial planning,intended results, which could materially adversely affect the Company.us.
Over the last several years, the Company has completed numerous improvement projects, including combining the legal charters of our seven affiliate banks into one, consolidating 15 loan operations sites into two, upgrading our accounting systems, installing a credit origination work flow system, streamlining our small business and retail lending, mortgage, wealth management and foreign exchange businesses, and investingWe continue to invest in data quality and information security. Ongoing investment continues in a multi-year project to replace our core loan and deposit systems, a collection of customer-facing digital capabilities and a variety of otherstrategic projects designed to improve our products and services and to simplify how we do business.
These initiatives and other significant changes continue to be implemented; some of the projects are fully completed,implemented and some projects are in their early stages.various stages of completion. By their very nature, projections of duration, cost, expected savings, expected efficiencies, and related items are subject to change and significant variability. There can be no certainty that we will achieve the expected benefits or other intended results associated with these projects.
We could be adversely affected by our ability to develop, adopt, implement, and deliver technology advancements.
Our ability to remain competitive is increasingly dependent upon our ability to maintain critical technological capabilities, and to identify and develop new, value-added products for existing and future customers. These technological competitive pressures arise from both traditional banking and nontraditional sources. Larger banks may have greater resources and economies of scale attendant to maintaining existing capabilities and developing digital and other technologies. Fintechs and other technology platform companies continue to emerge and compete with traditional financial institutions across a wide variety of products and services. Industry experimentation with, and adoption of, artificial intelligence (“AI”), the expansion of blockchain technologies, and digital currencies, including the potential creation and adoption of central bank digital currencies, present similar risks. Our failure to remain technologically competitive could impede our competitive market position and reduce customer satisfaction, product accessibility, and relevance.
OPERATIONAL RISK
Our operations could be disrupted by the effects of new and ongoing projects and initiatives.
We may encounter significant adverse developments in the completionoperational disruptions arising from our numerous projects and implementation of these changes.initiatives. These may include significant time delays, cost overruns, loss of key people, technological problems, and processing failures. We may also experience operational disruptions due to capacity constraints, service level failures and other adverse developments.inadequate performance, and certain replacement costs. Any or all of these issues could result in disruptions to our systems, processes, control environment, procedures, employees, and employees, which may adversely impact our customers and our ability to conduct business.
We have plans, policies and procedures designed to prevent or limit the negative effect of these potential adverse developments. However, there can be no assurance that any such adverse developments will not occur or, if they do occur, that they will be adequately remediated.customers. The ultimate effect of any adverse developmentsignificant disruption to our business could subject us to additional regulatory scrutiny or expose us to civil litigation and possible financial liability, any of which could materially affect the Company,us, including itsour control environment, operating efficiency, and results of operations.

We could be adversely affected by failure in our internal controls.
Because of their inherent limitations, our internal controls may not prevent or detect the risk of operational failures, misstatements in our financial statements, or capital arising from inadequate or failed internal processes or systems, human errors or misconduct, or other adverse external events. A failure in our internal controls could have a
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significant negative impact not only on our earnings, but also on the perception that customers, regulators, and investors may have of us and adversely affect our business and our stock price.
Operational/Technology RisksWe could be adversely affected by internal and external fraud schemes.
CatastrophicAttempts to commit fraud both internally and externally are becoming increasingly more sophisticated and may increase in an adverse economic environment. We have experienced losses in the past as a result of these attempts and schemes and may not be able to identify, prevent, or otherwise mitigate all instances of fraud in the future that have the potential to result in material losses. These attempts may go undetected by the systems and procedures that we have in place to monitor our operations.
Climate-related and other catastrophic events including, but not limited to, hurricanes, tornadoes, earthquakes, fires, floods, and prolonged drought, and pandemics may adversely affect us, our customers, and the general economy, financial and capital markets, and specific industries, and the Company.industries.
The Company hasoccurrence of pandemics, natural disasters, and other climate-related or catastrophic events could materially and adversely affect our operations and financial results. We have significant operations and a significant customer basecustomers in Utah, Texas, California, and other regions where natural and other disasters mayhave occurred, and are likely to continue to occur. These regions are known for being vulnerable to natural disasters and other risks, such as hurricanes, tornadoes, earthquakes, fires, floods, prolonged droughts, and prolonged drought.other weather-related events, some of which may be exacerbated by climate change and become more frequent and intense. These types of natural catastrophic events at times have posed physical risks to our property and have disrupted the local economy, the Company’sour business, and customers, including decreased access to insurance and have posed physical risks to the Company’s property.other services. In addition, catastrophic events occurring in other regions of the world may have an impact on us and our customers.
We use models in the Company’smanagement of the Bank. There is risk that these models are inaccurate in various ways, which may cause us to make suboptimal decisions.
We rely on models in the management of the Bank. For example, we use models to inform our estimate of the allowance for credit losses, to manage interest rate and liquidity risk, to project stress losses in various segments of our loan and investment portfolios, and to project net revenue under stress. Models are inherently imperfect and cannot perfectly predict outcomes. Management decisions that are largely informed by such models, therefore, may be suboptimal. For example, with the recent prominent bank closures during the first half of 2023, customer deposit behavior deviated from modeled behaviors, and as a result, we redeveloped our deposit models, which are currently used by management. For more information about our deposit models, see “Interest Rate and Market Risk Management” in MD&A on page 63.
We outsource various operations to third-party vendors, which could adversely impact our business and operational performance.
We rely on various vendors to perform operational activities to conduct our business. Although there are benefits in entering into these relationships, there are risks associated with such activities.Our operational controls and third-party management programs may not provide adequate oversight and control. Inadequate performance by third parties can adversely affect our ability to deliver products and services to our customers and conduct our business. Replacing or finding alternatives for vendors who do not perform adequately can be difficult and costly, and may also adversely impact our customers and other operations, particularly when circumstances require us to make changes under tight time constraints. Many of our vendors have experienced adverse effects upon their operations, supply chains, personnel, and businesses arising from inflationary pressures, wars and geopolitical conflicts, cyber vulnerabilities, and other events, all of which can impact our operations as well.
For information about how we manage operational risk, see “Operational, Technology, and Cybersecurity Risk Management” in turnMD&A on the Company. Although we have business continuity and disaster recovery programs in place, a significant catastrophic event could materially adversely affect the Company’s operating results.page 70.
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TECHNOLOGY RISK
We could be adversely affectedimpacted by system vulnerabilities, failures, or outages impacting operations and customer services such as online and mobile banking.
We rely on various information technology systems that work together in supporting internal operations and customer services. Vulnerabilities in, or a failure in ouror outage of, one or many of these systems could impact the ability to perform internal controls.
A failure in our internal controls couldoperations and provide services to customers, such as online banking, mobile banking, remote deposit capture, treasury and payment services, and other services dependent on system processing. These risks increase as systems and software approach the end of their useful life or require more frequent updates and modifications. We cannot guarantee that such occurrences will not have a significant negative impact not onlyoperational or customer impact.
For information regarding risks associated with the replacement or upgrades of our core technology systems, see “Strategic and Business Risk” in Risk Factors on our earnings, but alsopage 16. For information about how we manage technology risk, see “Operational, Technology, and Cybersecurity Risk Management” in MD&A on the perception that customers, regulators and investors may have of the Company. We continue to devote a significant amount of effort, time and resources to improving our controls and ensuring compliance with complex accounting standards and regulations. These efforts also include the management of controls to mitigate operational risks for programs and processes across the Company.page 70.
We could be adversely affected by financial technology advancements and other non-traditional lending and banking sources.
The ability to successfully remain competitive is dependent upon our ability to maintain a critical technological capability and to identify and develop new, value-added products for existing and future customers. Failure to do so could impede our time to market, reduce customer product accessibility, and weaken our competitive position.
Cyber RiskCYBERSECURITY RISK
We are subject to a variety of information system failure and cyber securitycybersecurity risks that could adversely affect our business and financial performance.
We rely heavily on communications and information systems to conduct our business. We process and maintain on our systems certain information that is confidential, proprietary, personal, or otherwise sensitive, including financial and other confidential business information. We, our customers, and other financial institutions with which we interact, are subject to ongoing, continuous attempts by threat actors, such as organized cybercrime, hackers, and state-sponsored organizations to penetrate key systems by individual hackers, organized criminals, and in some cases, state-sponsored organizations.systems. Information security risks for us and other large financial institutions such as Zions have increased significantly in recent years, in part because of the proliferation of new technologies, such as Internet and mobile banking to conduct financial transactions,the ubiquity of internet connections, and the increased sophistication and activities of cyber criminals. Any failure, interruptionthreat actors. The types of attacks these threat actors may use include, but are not limited to: exploiting customer or breach in securitysystem vulnerabilities or misconfigurations, deceiving employees through email phishing or social engineering, and compromising any of our suppliers.
Third parties, including our suppliers and their subcontractors, also present operational and information security risks to us, including security incidents or failures of their own systems could resultand downstream systems. In incidents involving third parties, we may not be informed promptly of any effect on our services or our data, or be able to participate in failuresany related investigation, notification, or disruptionsremediation that occurs. The possibility of third-party or employee error, failure to follow security procedures, or malfeasance also presents these risks.
As cybersecurity threats continue to evolve, we will be required to expend additional resources to continue to modify or enhance our defenses or to investigate or remediate any information security vulnerabilities. We, and our third-party suppliers, have experienced cybersecurity incidents in the past that have not had material impact to our customer relationship management, general ledger, deposit, loan and other systems, misappropriation of funds, and theft, disclosuredata, customers, or misuse of proprietary Company or customer data. While we have significant internal resources, policies and procedures designed to prevent or limit the effect of the possible failure, interruption or security breach of our information systems,operations, but there can be no assurance that any such failure, interruption, or significant security breach will not occur in the future, or, if they do occur, that theyany future occurrences will be adequately addressed. As cyber threatsIt is impossible to determine the severity or potential effects of these incidents with any certainty.
System enhancements and updates may also create risks associated with implementing new systems and integrating them with existing ones. Due to the complexity and interconnectedness of information technology systems, the process of enhancing our defenses itself can create a risk of systems disruptions and security issues. We may face additional risks to the extent our hardware and software providers are unable to deliver patches and updates to mitigate vulnerabilities or we are unable to implement patches in a timely manner, particularly when a vulnerability is being actively exploited by threat actors. We have devoted and will continue to evolve, we may be required to expenddevote significant additional resources to continuethe security of our computer systems, but they may still be vulnerable to modifythese threats and our efforts may subsequently be deemed to have been inadequate by regulators or enhance our layers of defense or to investigate or remediate any information security vulnerabilities.courts. The occurrence of any failure, interruption or security breach ofincident to our information systems or those of our third-party suppliers could interfere with or disrupt our
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operations and services, damage our reputation, result in a loss of customer business, subject us to additional regulatory scrutiny, or expose us to civil litigation and possible financial liability.liability, or otherwise result in material adverse consequences on us.
Model RiskFor information about how we manage cybersecurity risk, see Part I, Item 1C. Cybersecurity on page 24.
We increasingly use models in the management of the Company, and in particular in the requiredCAPITAL/FINANCIAL REPORTING RISK
Internal stress testing and capital plan. There is risk that these models are incorrect or inaccurate in various ways, which can cause us


to make non-optimal decisions, and this risk causes the Company to hold additional capitalmanagement, as a buffer against that risk.
We attempt to carefully develop, document, back test, and validate the models used in the managementwell as provisions of the Company, including, for example, models used in the management of interest rateNational Bank Act and liquidity risk, and those used in projecting stress losses in various segments of our credit and securities portfolios, and projecting net revenue under stress. Models are inherently imperfect for a number of reasons, however, and cannot perfectly predict outcomes. Management decisions based in part on such models, therefore, can be suboptimal. In addition, in determining the Company’s capital needs under stress testing, we attempt to specifically quantify the amounts by which model results could be incorrect, and we hold material additional amounts of capital as a buffer against this “model risk.”
Capital/Financial Reporting Risks
Stress testing and capital management under the Dodd-Frank ActOCC regulations, may limit our ability to increase dividends, repurchase shares of our stock, and access the capital markets.
Under HCR/CCAR, we are requiredWe utilize stress testing as an important mechanism to submit toinform our decisions on the FRB each year ourappropriate level of capital, plan for the applicable planning horizon, along with the results of required stress tests. Each annual capital plan will, among other things, specify our planned capital actions with respect to dividends, preferred stock redemptions, common stock repurchases or issuances,based upon actual and similar matters and will be subject to the objection or non-objection by the FRB. Moreover, the HCR/CCAR process requires us to analyze the pro forma impact on our financial condition of various hypothetical future adversehypothetically stressed economic scenarios selected by us and the FRB. We must maintain or raise capital sufficient to meet our risk management and regulatory expectations under such hypothetical scenarios. In connection with the annual HCR/CCAR process, we also participate in the DFAST on a semiannual basis. Under DFAST, a standardized strategy for capital actions (dividend payments held constant and other current capital obligations met) is implemented by all participating banks. As required by the Dodd-Frank Act, we also submit stress tests to the OCC for our subsidiary bank because it has assets in excess of $10 billion. Under both HCR/CCAR and DFAST, the FRB uses its proprietary models to analyze the Company’s stressed capital position. The severity of the hypothetical scenarios devised by the FRB and OCC and employed in these stress tests is undefined by law or regulation, and is thus subject solely to the discretion of the regulators.conditions. The stress testing and capital planning processesother applicable regulatory requirements may, among other things, require us to increase our capital levels, limit our dividends or other capital distributions to shareholders, modify our business strategies, or decrease our exposure to various asset classes.
Under stress testingthe National Bank Act and OCC regulations, certain capital management standards implemented by bank regulatory agencies under the Dodd-Frank Act, we may declare dividends, repurchase common stock, redeem preferred stock and debt, access capital markets for certain types of capital, make acquisitions, and enter into similar transactions, only if included in a capital plan to which the FRB has not objected. Any similar transactions not contemplated in our annual capital plan, other than those with an inconsequential impact on actual or projected capital, may require a new stress test and capital plan, which isincluding share repurchases, are subject to FRB non-objection.the approval of the OCC. These requirements may significantly limit our ability to respond to and take advantage of market developments.
EconomicRegulatory requirements, economic and other circumstances may require us to raise capital at times or in amounts that are unfavorable to the Company.us.
The Company and its subsidiary bank mustWe maintain certain risk-based and leverage capital ratios, as required by itsour banking regulators, which can change depending upon general economic conditions, hypothetical future adverse economic scenarios, andas well as the particular conditions, risk profiles, and our growth plans of the Company and its subsidiary bank.plans. Compliance with capital requirements may limit the Company’sour ability to expand and has required, and may require, the Company or its subsidiariesus to raise additional capital or may require additional capital investment from the Parent.retain earnings that could otherwise be distributed to shareholders. These uncertainties and risks, including those created by legislative and regulatory change and uncertainties, such as recent regulatory proposals that would significantly revise the capital requirements and expand long-term debt requirements applicable to large banking organizations, may increase the Company’sour cost of capital and other financing costs. For more information about these regulatory proposals, see “Recent Regulatory Developments” in Supervision and Regulation on page 8.
We could be adversely affected by accounting, financial reporting, and regulatory and compliance risk.
The Company isWe are exposed to accounting, financial reporting, and regulatory/regulatory compliance risk. The Company provides to its customers, invests in, and uses for its own capital, funding, and risk management needs, a number of complex


financial products and services. Estimates,Significant estimates, judgments, and interpretations of complex and changing accounting and regulatory policies are required in order to provide andproperly account for thesethe products and services.services we provide to our customers. Changes in our accounting policies or in accounting standards could materially affect how we report our financial results and conditions. The level of regulatory/regulatory compliance oversight has been heightened in recent periods as a result of rapid changes in regulations that affect financial institutions. The administration of some of these regulations and related changes has required the Companycontinues to comply before their formal adoption. Therefore, identification,be heightened. Identification, interpretation, and implementation of complex and changing accounting standards, as well as compliance with regulatory requirements, pose an ongoing risk.
Our results of operations depend upon the performance of our subsidiaries.
We are a holding company that conducts substantially all of our operations through our banking subsidiary and other subsidiaries. The Parent receives substantially all of its revenues from dividends from its subsidiaries and primarily from its subsidiary bank. These dividends are a principal source of funds to pay dividends on our common and preferred stock and interest and principal on our debt. We and certain of our subsidiaries experienced periods of unprofitability or reduced profitability during the most recent recession of 2007-2009. The ability of the Company and its subsidiary bank to pay dividends is restricted by regulatory requirements, including profitability and the need to maintain required levels of capital. Lack of profitability or reduced profitability exposes us to the risk that regulators could restrict the ability of our subsidiary bank to pay dividends. It also increases the risk that the Company may have to establish a “valuation allowance” against its net DTA or have that asset disallowed for regulatory capital purposes.
The ability of our subsidiary bank to pay dividends or make other payments to us is also limited by its obligations to maintain sufficient capital and by other general regulatory restrictions on its dividends. If it does not satisfy these regulatory requirements, we may be unable to pay dividends or interest on our indebtedness. The OCC, the primary regulator of our subsidiary bank, has issued policy statements generally requiring insured banks to pay dividends only out of current earnings. In addition, if, in the opinion of the applicable regulatory authority, a bank under its jurisdiction is engaged in or is about to engage in an unsafe or unsound practice, which could include the payment of dividends, such authority may take actions requiring that such bank refrain from the practice. Payment of dividends could also be subject to regulatory limitations if a subsidiary bank were to become “under-capitalized” for purposes of the applicable federal regulatory “prompt corrective action” regulations.
The value of our goodwill may decline in the future.
As of December 31, 2017, the Company had $1 billion of goodwill that was allocated to Amegy, CB&T and Zions Bank. If the fair value of a reporting unit is determined to be less than its carrying value, the Companywe may have to take a charge related to the impairment of itsour goodwill. Such a charge would occur if the Company were to experience increasescould result from, among other factors, weakening in the book value ofeconomic environment, a reporting unit in excess of the increase in the fair value of equity of a reporting unit. A significant decline in the Company’s expected future cash flows, a significant adverse change in the business climate, slower economic growth or a significant and sustained decline in the priceperformance of the Company’s common stock, anyreporting unit, or all of which could be materially impacted by many of the risk factors discussed herein, may necessitate the Company taking chargesnew legislative or regulatory changes not anticipated in the future related to the impairment of its goodwill. Future regulatory actions could also have a material impact on assessments of the appropriateness of the goodwill carrying value. If the Company was to conclude that a future write-down of its goodwill is necessary, it would record the appropriate charge, which could have a material adverse effect on the Company’s results of operations.management’s expectations.
The CompanyWe may not be able to utilize the significant DTA recorded on its balance sheet.fully realize our deferred tax assets, which could adversely affect our operating results and financial performance.
The Company’s balance sheet includes a significant DTA. We had net DTAs of $93 million atAt December 31, 2017, compared with $250 million at December 31, 2016.2023, we had a net deferred tax asset of $1.0 billion. The largest componentsaccounting treatment for realization of this asset result from additions to our ALLL for purposes of GAAP in excess of loan losses actually taken fordeferred tax purposes.assets is complex and requires judgment. Our ability to continue to record this DTA is dependent onfully realize our deferred tax asset could be reduced in the Company’s ability to realize its value through net operating loss carrybacksfuture if our estimates of future taxable income from our operations, future reversals of existing deferred tax liabilities (“DTLs”), or future projected earnings. Losstax planning strategies do not support the realization of part or all of this asset would adversely impact tangible capital. In addition, inclusion of this asset in determining regulatory capital is subject to certain limitations. Currently, no DTAs are disallowed for regulatory purposes either on a consolidated basis or at the Company’s subsidiary bank.our deferred tax asset.

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Changes in applicable tax laws, regulations, macroeconomic conditions, or market conditions may adversely affect our financial results, and there can be no assurance that we will be able to fully realize our deferred tax assets.
Legal/Compliance RisksFor information about how we manage capital, see “Capital Management” in MD&A on page 72.
The Dodd-Frank Act imposesLEGAL/COMPLIANCE RISK
Laws and regulations applicable to us and the financial services industry impose significant limitations on our business activities and subjectssubject us to increased regulation and additional costs.
The Dodd-Frank Act has material implications for the Company and the entire financial services industry. The Dodd-Frank Act places significant additional regulatory oversight and requirements on financial institutions, particularly those with more than $50 billion of assets, including the Company. In addition, among other things, the Dodd-Frank Act:
affected the levels of capital and liquidity with which the Company must operate and how it plans capital and liquidity levels;
subjected the Company to new and/or higher fees paid to various regulatory entities, including but not limited to deposit insurance fees to the FDIC;
impacted the Company’s ability to invest in certain types of entities or engage in certain activities;
impacted a number of the Company’s business strategies;
required us to incur the cost of developing substantial heightened risk management policies and infrastructure;
regulated the pricing of certain of our products and services and restricted the revenue that the Company generates from certain businesses;
subjected the Company to capital planning actions, including stress testing or similar actions and timing expectations for capital raising;
subjected the Company to supervision by the CFPB, with very broad rule-making and enforcement authorities;
granted authority to state agencies to enforce state and federal laws against national banks;
subjected the Company to new and different litigation and regulatory enforcement risks; and
limited the manner and amount in which compensation is paid to executive officers and employees generally.
The CompanyWe, and the entire financial services industry, have incurred, and will continue to incur, substantial costs related to personnel, systems, consulting, and other costsactivities in order to comply with newbanking regulations. See “Supervision and Regulation” on page 7 for further information about the regulations promulgated under the Dodd-Frank Act, particularly with respectapplicable to stress testing and risk management. Some aspects of the Dodd-Frank Act continue to be subject to rulemaking, many of the rules that have been adopted will take effect over several additional years, and many of the rules that have been adopted may be subject to interpretation and clarification, and accordingly, the impact of such regulatory changes cannot be presently determined. Individually and collectively, regulations adopted under the Dodd-Frank Act may materially adversely affect the Company’sus and the financial services industry’s business, financial condition (includingindustry generally.
Regulators, the Company’s abilityU.S. Congress, state legislatures, and other governing or consultative bodies continue to compete effectively with less regulatedenact rules, laws, and policies to regulate the financial services providers),industry and results of operations.
Other legislativepublic companies, including laws that are designed to promote, protect, or penalize certain activities or industries and regulatory actions taken now ortheir access to financial services. We are, and may in the future may have a significant adversebecome, subject to these laws by offering our products and services to certain industries or in certain locations. The nature of these laws and regulations and their effect on our operationsfuture business and earnings.
In addition to the Dodd-Frank Act described previously, bank regulatory agencies and international regulatory consultative bodies have proposed or are considering new regulations and requirements, some of which mayperformance cannot be imposed without formal promulgation. Our deposits are insured by the FDIC up to legal limits and, accordingly, we are subject to FDIC insurance assessments.predicted.
There can be no assurance that any or all of these regulatory changes or actions will ultimately be adopted.enacted. However, if adopted,enacted, some of these proposals could adversely affect the Companyus by, among other things: impacting after-tax returns earned by financial services firms in general; limiting the Company’sour ability to grow; increasing FDIC insurance assessments, taxes or fees on some of the Company’sour funding or activities; limiting the range of products and services that the Companywe could offer; and requiring the Companyus to raise capital at inopportune times.
Recent politicalPolitical developments including the change in the executive administration of the United States, couldmay also result in substantial changes in tax, international trade, immigration, and other policies. The extent and timing of any such changes are uncertain, as are the potential direct and indirect impacts, whether beneficial or adverse.


Regulations and laws may be modified or repealed, and new legislation may be enacted that will affect us and our subsidiaries.
The ultimate impact of these proposals cannot be predicted as it is unclear which, if any, may be adopted.enacted.
Tax laws, regulations, and case law may change due to legislative, administrative, and judicial changes that could adversely impact our business and financial performance.
We are subject to the income tax laws of the U.S., its states, and other jurisdictions where we conduct business. These laws are complex and subject to different interpretations by the taxpayer and the various taxing authorities. In determining the provision for income taxes, management makes judgments and estimates about the application of these inherently complex laws, related regulations, and case law. In the process of preparing our tax returns, management attempts to make reasonable interpretations of the tax laws. These interpretations are subject to challenge by the tax authorities upon audit or to reinterpretation based on management’s ongoing assessment of facts and evolving case law. Changes in tax laws, regulations, or case law may result in an adverse impact to our effective tax rate, tax obligations, and financial results. Additionally, challenges made by tax authorities during an audit may result in adjustments to our tax return filings, resulting in similar adverse impacts to our financial position.
We could be adversely affected by legal and governmental proceedings.
We are subject to risks associated with legal claims, litigation, and regulatory and other government proceedings. The Company’sOur exposure to these proceedings has increased and may further increase as a result of stresses on customers, counterparties, and others arising from the past or current economic environments, more frequent claims and actions resulting from fraud schemes perpetrated by or involving our customers, new regulations promulgated under recently adoptedenacted statutes, the creation of new examination and enforcement bodies, and increasingly aggressive enforcement and legal actions against banking organizations. Anysuchmatters may result in material adverse consequences to our results of operations, financial
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condition or ability to conduct our business, including adverse judgments, settlements, fines, penalties (including(e.g., civil money penalties under applicable banking laws), injunctions, restrictions on our business activities, or other relief. We maintain insurance coverage to mitigate the financial risk of defense costs, settlements, and awards, but the coverage is subject to deductibles and limits of coverage. Our involvement in any such matters, even if the matters are ultimately determined in our favor, could also cause significant harm to our reputation and divert management attention from the operation of our business. In general, the amounts paid by financial institutions in settlement of proceedings or investigations, including those relating to anti-money laundering matters, have been increasing dramatically. This has affected and will continue to adversely affect (1) our ability to obtain insurance coverage for certain claims, (2) our deductible levels, and (3) the cost of premiums associated with our coverage. Consequently, our financial results are subject to greater risk of adverse outcomes from legal claims.
Due to the difficulty in predicting the timing of, and damages or penalties associated with, the resolution of legal claims, it is possible that adverse financial impacts from litigation could occur sporadically and could be significant. In addition, any enforcement matters could impact our supervisory and CRA ratings, which may restrict or limit our activities.
Reputational Risk
The corporate and securities laws applicable to us are not as well-developed as those applicable to a state-chartered corporation, which may impact our ability to effect corporate transactions in an efficient and optimal manner.
Our corporate affairs are governed by the National Bank Act, and related regulations are administered by the OCC. As to securities laws, the OCC maintains its own securities offering framework applicable to national banks and their securities offerings, and our compliance with the Exchange Act is governed and enforced by the OCC.
State corporate codes, including that of Utah, are widely recognized, updated by legislative action from time-to-time, and may be based on and influenced by model statutes. The federal securities law regime established by the Securities Act and the Exchange Act and the SEC’s extensive and well-developed framework thereunder are widely used by public companies. The OCC’s statutory and regulatory frameworks have been used by publicly traded banking organizations relatively rarely and are not as well-developed as the corporate and securities law frameworks applicable to other public corporations. While certain specific risks associated with operating under these frameworks are described below, unless and until these frameworks are further developed and established over time, the uncertainty of how these frameworks might apply to any given corporate or securities matters may prevent us from effecting transactions in an efficient and optimal manner or perhaps at all.
Differences between the National Bank Act and state law requirements regarding mergers could hinder our ability to execute acquisitions as efficiently and advantageously as bank holding companies or other financial institutions.
Unlike state corporate law, the National Bank Act requires shareholder approval of all mergers between a national bank and another national or state bank and does not allow for exceptions in the case of various “minor” mergers, such as a parent company’s merger with a subsidiary or an acquirer’s merger with an unaffiliated entity in which the shares issued by the acquirer do not exceed a designated percentage. The National Bank Act and related regulations may also complicate the structuring of certain nonbank acquisitions.
These differences could adversely affect the ability of the Bank and other banks registered under the National Bank Act to efficiently consummate acquisition transactions. In addition, such differences could make us less competitive as a potential acquirer in certain circumstances given that our acquisition proposal may be conditioned on shareholder approval while our competitors’ proposals will not have such a condition.
We are subject to restrictions on permissible activities that would limit the types of business we may conduct and that may make acquisitions of other financial companies more challenging.
Under applicable laws and regulations, bank holding companies and banks are generally limited to business activities and investments that are related to banking or are financial in nature. The range of permissible financial activities is set forth in the Gramm-Leach-Bliley Act and is more limited for banks than for bank holding company isorganizations. The differences relate mainly to insurance underwriting (but not insurance agency activities) and
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merchant banking (but not broker-dealer and investment advisory activities). The fact that we do not have a bank holding company could make future acquisitions of financial institutions with such operations more challenging.
REPUTATIONAL RISK
We are presented with various reputational risk issues that could stem from operational, regulatory, compliance, and legal risks.
A Reputational Risk Council was establishedAny of the aforementioned risks may give rise to monitor,adverse publicity and other expressions of negative public opinion, increased regulatory scrutiny, and damaged relationships among other reputational risks.
OTHER RISKS
The Russian invasion of Ukraine, the conflicts in the Middle East, other geopolitical conflicts, and retaliatory measures imposed by the U.S. and other countries, including the responses to such measures, may cause significant disruptions to domestic and foreign economies and markets.
The Russia-Ukraine war and the conflicts in the Middle East, along with other geopolitical conflicts, have created new risks for global markets, trade, economic conditions, cybersecurity, and similar concerns. For example, these conflicts could affect the availability and price of commodities and products, adversely affecting supply chains and increasing inflationary pressures; the value of currencies, interest rates, and other components of financial markets; and lead to increased risks of events such as cyberattacks that could result in severe costs and disruptions to governmental entities and companies and their operations. The impact of these conflicts and retaliatory measures is continually evolving and cannot be predicted with certainty. It is likely that these conflicts will continue to affect the global political order and global and domestic markets for a substantial period of time, regardless of when these conflicts end.
While these events have not materially interrupted our operations, these or future developments resulting from these conflicts, such as cyberattacks on the U.S., the Bank, our customers, or our suppliers, could make it difficult to conduct business.
Sustainability-related risk developments could lead or require us to restrict or modify some of our business activities.
Expectations of investors and regulators could, over time, lead us to restrict or modify some of our business practices. In addition, our business practices could be adversely affected by laws and regulations enacted or promulgated by federal, state, and local governments that relate to environmental and social issues. For example, in 2022 and 2023, certain states passed, or considered passing, laws prohibiting financial institutions from restricting the services that they provide to certain types of businesses if the institutions also conduct business with governmental entities in such states. Depending on how these laws are worded and implemented, they could adversely affect our ability to manage risk. These laws and develop strategiesrules related to effectively manageenvironmental and social issues may include provisions that conflict with other state and federal regulations and may increase our costs or limit our ability to conduct business in certain jurisdictions.
Heightened regulatory and social focus on climate change may place additional requirements on public companies, including financial institutions, regarding the measurement, management, and disclosure of climate-related risks and associated lending and investment activities. For example, the state of California recently passed sweeping climate-related disclosure laws that will require large entities doing business in the state, including the Bank, to measure and disclose greenhouse gas emissions and report on their climate-related risks. These new laws, which will require initial disclosures as early as 2026, impose disclosure obligations on companies that in certain respects exceed those previously proposed by the SEC. These new laws may result in higher regulatory, compliance, credit, and reputational risks and costs. In addition, the transition to a lower-carbon economy could subject us to other risks, such as through our customers’ exposure to volatility in commodity prices, increased insurance costs or inability to access insurance, and changes in the market for carbon-related products and services.
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Protracted congressional negotiations and political stalemates in Washington, D.C. regarding government funding and other issues may introduce additional volatility in the U.S. economy including capital and credit markets and the banking industry in particular.
The U.S. government is currently funded through early March 2024 as a result of a series of continuing resolutions that provide short-term appropriations. Democrat and Republican lawmakers are at a stalemate, and efforts to pass spending bills for long-term government funding have been complicated, increasing the risk which includes, but is not limited to, addressing communication logistics, legalof an eventual government shutdown. Any such shutdown may result in further U.S. credit rating downgrades or defaults, and regulatory issues.may introduce additional volatility in the U.S. economy, including capital and credit markets and the banking industry in particular; cause disruptions in the financial markets; impact interest rates; and result in other potential unforeseen consequences. In any such event, the Bank’s liquidity, operating margins, financial condition, and results of operations may be materially and adversely affected.
ITEM 1B.UNRESOLVED STAFF COMMENTS
ITEM 1B. UNRESOLVED STAFF COMMENTS
There are no unresolved written comments that were received from the SEC’sSEC or OCC staff 180 days or more before the end of the Company’sour fiscal year relating to itsour periodic or current reports filed under the Securities Exchange ActAct.
ITEM 1C. CYBERSECURITY
Cybersecurity risk is the risk of 1934.adverse impacts to the confidentiality, integrity, and availability of data owned, stored, or processed by the Bank or the accompanying information systems. The number and sophistication of attempts to disrupt or penetrate our systems, and those of our suppliers — sometimes referred to as hacking, cybersecurity fraud, cyberattacks, or other similar names — continues to grow.
Cybersecurity risk is overseen by the Board and the Bank’s multiple lines of defense, including front-line bankers and operations teams, Enterprise Risk Management (“ERM”), and internal audit. Information security risk is managed in accordance with an established ERM framework, which includes elements such as key risk indicators, enterprise standards, controls, and self-assessments that comply with established ERM policies. These elements are regularly assessed, measured, and reported to Board-level and Bank senior management-level risk committees, and those committees review such reports.
As set forth in its charter, the ROC has the responsibility to review reports from management relating to enterprise-wide risk management efforts, including cybersecurity risks. As part of that oversight, the ROC performs an annual review and approval of information security policies and programs, and receives regular updates on key risk indicators, threat trends, risk remediation activities, and operational events. The ROC periodically provides reports regarding this oversight to the Board. Management uses multiple real-time and interval-based monitoring and reporting mechanisms to detect and respond to cybersecurity incidents. Documented escalation procedures are tested regularly as part of tabletop exercises and other activities and include notification to executive management during qualifying cybersecurity incidents.
Management positions directly responsible for assessing, measuring, and managing cybersecurity risks include the Chief Information Security Officer (“CISO”) and the Chief Technology and Operations Officer (“CTOO”). The current CISO has more than 20 years of technology leadership experience, including a significant period directly leading cybersecurity efforts, and holds multiple industry certifications. The CTOO has more than 25 years of audit, risk, operations, and technology leadership experience, including prior assignments as the Bank’s Chief Audit Executive and Director of Bank Operations. The CISO and CTOO regularly report information about cybersecurity risks to the Board or a committee of the Board.
We engage multiple independent third parties or cyber experts to assess information security programs and practices, including, but not limited to, framework maturity assessments, blind penetration testing, technology health checks, cyber skill and staffing assessments, externally facilitated tabletop exercises, external cyber legal counsel briefings, and strategic assessments. Findings from these assessments are regularly reviewed with management and the ROC. Additionally, we participate in various cybersecurity industry forums and have access to law enforcement analysis regarding current threats.
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Our supply chain risk management practices include risk assessments of suppliers, including with respect to cybersecurity. We monitor our suppliers using commercially available services that provide real-time security scoring of supplier technology services, threat intelligence, financial intelligence, geopolitical risk intelligence, and other considerations related to cybersecurity. Reviews are also regularly performed to monitor changes in suppliers’ cybersecurity risk posture. Continuous threat intelligence monitoring is also performed to identify potential cybersecurity incidents involving third parties. We strive to negotiate appropriate provisions with respect to cybersecurity in our contracts with suppliers.
When a cybersecurity incident occurs, whether detected internally or from third-party cybersecurity incidents, we evaluate the incident for criticality and potential materiality and disclosure across a range of contributing indicators, including service availability, impact to operations, reputational impact, regulatory and legal considerations, data sensitivity, and direct financial impact. The potential impact of the incident, individually or in aggregate, is evaluated by the CISO continuously across these criteria. We have escalation procedures to notify members of senior and executive management, the Board (or an applicable subset), and regulators in a timely manner based on the criticality and materiality of the cybersecurity incident.
To date, risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, have not materially affected us, including our business strategy, results of operations, or financial condition. At December 31, 2023, management has assessed known cybersecurity incidents for potential materiality and disclosure using formal documented processes and has determined that there have been no material cybersecurity incidents, individually or in aggregate. We may nevertheless be unsuccessful in the future in preventing or mitigating a cybersecurity incident that could have a material adverse effect on us.
For additional discussion regarding cybersecurity risks, see “Cybersecurity Risk” in Risk Factors on page 19.
ITEM 2. PROPERTIES
At December 31, 2017, the Company2023, we operated 433407 branches, of which 275278 are owned and 158129 are leased. The CompanyWe also leases itslease our headquarters in Salt Lake City, Utah. Other operations facilities are either owned or leased. The annual rentals under long-term leases for leased premises are determined under various formulas and factors, including operating costs, maintenance, and taxes. For additional information regarding leases and rental payments, see Note 158 of the Notes to Consolidated Financial Statements.
ITEM 3. LEGAL PROCEEDINGS
The information contained in Note 1516 of the Notes to Consolidated Financial Statements is incorporated by reference herein.
ITEM 4. MINE SAFETY DISCLOSURES
None.

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PART II
ITEM 5.
ITEM 5. MARKET FOR REGISTRANT’S COMMON EQUITY, RELATED STOCKHOLDER MATTERS AND ISSUER PURCHASES OF EQUITY SECURITIES
MARKET INFORMATION
The Company’s common stock is traded on the NASDAQ Global Select Market under the symbol “ZION.” The last reported sale price of the common stock on NASDAQ on February 9, 2018 was $51.64 per share.
The following schedule sets forth, for the periods indicated, the high and low sale prices of the Company’s common stock, as quoted on NASDAQ:
 2017 2016
 High Low High Low
        
1st Quarter$48.33
 $39.09
 $26.91
 $19.65
2nd Quarter44.85
 38.43
 29.46
 23.14
3rd Quarter47.70
 41.23
 31.35
 23.02
4th Quarter52.20
 43.50
 44.15
 30.07
PREFERRED STOCK REDEMPTIONS
During 2017, we redeemed all outstanding shares of our 7.9% Series F preferred stock for a cash payment of approximately $144 million. The total one-time reduction to net earnings applicable to common shareholders associated with the preferred stock redemption was $2 million due to the accelerated recognition of preferred stock issuance costs.
During 2016 we decreased our preferred stock by $118 million, including the purchase of $26 million of our Series I preferred stock, $59 million of our Series J preferred stock, and $33 million of our Series G preferred stock, for an aggregate cash payment of $126 million. The total one-time reduction to net earnings applicable to common shareholders associated with the preferred stock redemption was $10 million. These preferred stock redemptions benefit the Company by decreasing the amount of preferred dividends paid.
EQUITY CAPITAL AND DIVIDENDS
We have 4,400,0004.4 million authorized shares of preferred stock without par value and with a liquidation preference of $1,000 per share. As of December 31, 2017,2023, 66,139, 138,390, 126,221, 98,555, and 136,368 of preferred shares series A, G, H, I, and J respectively, are outstanding. In general, preferred shareholders may receive asset distributions before common shareholders; however, preferred shareholders have only limited voting rights generally with respect to certain provisions of the preferred stock, the issuance of senior preferred stock, and the election of directors. Preferred stock dividends reduce earnings available to common shareholders and are paid quarterly or semiannually in arrears. The preferred stock redemption amount is computed at the per share liquidation preference plus any declared but unpaid dividends. All of the outstanding series of preferred stock are registered with the SEC. In addition, Series A, G, and H preferred stock are listed and traded on the New York Stock Exchange. See Note 1314 of the Notes to Consolidated Financial Statements for further information regarding the Company’sour preferred stock.
COMMON STOCK
Market Information
Our common stock is traded on the National Association of Securities Dealers Automated Quotations (“NASDAQ”) Global Select Market under the symbol “ZION.” The closing price of our common stock on NASDAQ was $38.87 per share on February 5, 2024.
Equity Capital and Dividends
As of February 9, 2018,5, 2024, there were 4,353 holders3,530 shareholders of record of the Company’sour common stock. The frequency and amount of common stock dividends paid duringIn February 2024, the last two years are as follows:
 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter
        
2017$0.08
 $0.08
 $0.12
 $0.16
20160.06
 0.06
 0.08
 0.08
The Company’s Board of Directors approveddeclared a dividend of $0.20$0.41 per common share payable on February 22, 20182024 to shareholders of record at the close of business on February 15, 2018. The Company expects to continue its policy of paying regular cash2024.

dividends on a quarterly basis, although there is no assurance as to future dividends because they depend on future earnings, capital requirements, financial condition, and regulatory approvals.
SHARE REPURCHASESShare Repurchases
During 2017the first quarter of 2023, we continued ourrepurchased 0.9 million common stock repurchase program and repurchased 7 million shares of common stock outstanding with a fair value $320for $50 million at an average price of $45.66$52.82 per share. DuringWe did not repurchase common shares during the first quartersecond, third, or fourth quarters of 2018,2023.
In February 2024, the Company repurchased an additional 2Board approved a plan to repurchase up to $35 million shares of common stockshares outstanding with a fair value of $115during the fiscal year 2024. In February 2024, we repurchased 0.9 million common shares outstanding for $35 million at an average price of $53.46 per share, leaving $120 million of repurchase capacity remaining in the 2017 capital plan (which spans the timeframe of July 2017 to June 2018).
During 2016 we repurchased 3 million shares of$39.32. For more information regarding our common stock outstanding with a fair valueactivity, see the Consolidated Statement of $90 million at an average price of $31.15 per share.Changes in Shareholders’ Equity on page 87.
The following schedule summarizes the Company’sour share repurchases for the fourth quarteryear ended December 31, 2023:
Schedule 3
2023 SHARE REPURCHASES
Period
Total number
of shares
purchased 1
Average
price paid
per share
Shares purchased as part of publicly announced plans
First quarter953,080 $52.82 946,644 
Second quarter— — — 
Third quarter— — — 
October— — — 
November
— — — 
December18,851 45.59 — 
Fourth quarter total18,851 45.59 — 
Total 2023971,931 $52.68 946,644 
1 Includes common shares acquired in connection with our stock compensation plan. Shares were acquired from employees to pay for their payroll taxes and stock option exercise cost upon the exercise of 2017:stock options.
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Period 
Total number
of shares
repurchased 1
 
Average
price paid
per share
 Shares purchased as part of publicly announced plans or programs 
Approximate dollar value
of shares that may yet be
purchased under the plan
             
October 935
 $47.19
  
   $350,000,045
 
November 1,019,801
 48.07
  1,019,240
   301,000,280
 
December 1,302,618
 50.74
  1,300,777
   235,000,750
 
Fourth quarter 2,323,354
 49.57
  2,320,017
     
1
Represents common shares acquired from employees in connection with our stock compensation plan in addition to shares acquired under previously reported share repurchase plans. Shares were acquired from employees to pay for their payroll taxes and stock option exercise cost upon the vesting of restricted stock and restricted stock units, and the exercise of stock options, under provisions of an employee share-based compensation plan.
PERFORMANCE GRAPHPerformance Graph
The following stock performance graph compares the five-year cumulative total return of Zions Bancorporation’sour common stock with the Standard &and Poor’s (“S&P”) 500 Index and the Keefe, Bruyette & Woods, Inc. (“KBW”) Regional Bank Index both of which include Zions Bancorporation.(“KRX”). The KBW Bank IndexKRX is a modified market capitalization-weighted regional bank and thrift stock index developed and published by KBW, a nationally recognized brokerage and investment banking firm specializing in bank stocks. The index is composed of 2450 geographically diverse stocks representing national money centerregional banks and leading regional financial institutions.or thrifts. The stock performance graph is based upon an initial investment of $100 on December 31, 20122018 and assumes reinvestment of dividends.

PERFORMANCE GRAPH FOR ZIONS BANCORPORATION, N.A.
INDEXED COMPARISON OF 5-YEAR CUMULATIVE TOTAL RETURN
 2012 2013 2014 2015 2016 2017
            
Zions Bancorporation100.0
 140.6
 134.6
 129.8
 206.7
 246.6
KBW Bank Index100.0
 137.8
 150.7
 151.4
 194.6
 230.7
S&P 500100.0
 132.4
 150.5
 152.5
 170.8
 208.1
2782
201820192020202120222023
Zions Bancorporation, N.A.100.0 131.1 113.8 169.7 127.2 119.0 
KRX Regional Bank Index100.0 123.9 113.1 154.6 143.9 143.3 
S&P 500100.0 131.5 155.7 200.3 164.0 207.0 
SECURITIES AUTHORIZED FOR ISSUANCE UNDER EQUITY COMPENSATION PLANS
The information contained in Item 12 of this Form 10-K is incorporated by reference herein.
ITEM 6. RESERVED

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ITEM 6.SELECTED FINANCIAL DATA
FINANCIAL HIGHLIGHTS
(Dollar amounts in millions, except per share amounts)2017/2016 Change 2017 2016 2015 2014 2013
For the Year           
Net interest income+11 % $2,065
 $1,867
 $1,715
 $1,680
 $1,696
Noninterest income+5 % 544
 516
 357
 493
 327
Total revenue+9 % 2,609
 2,383
 2,072
 2,173
 2,023
Provision for loan losses-74 % 24
 93
 40
 (98) (87)
Noninterest expense+4 % 1,649
 1,585
 1,581
 1,649
 1,704
Income before income taxes+33 % 936
 705
 451
 621
 407
Income taxes+46 % 344
 236
 142
 223
 143
Net income+26 % 592
 469
 309
 398
 264
Net earnings applicable to common shareholders+34 % 550
 411
 247
 327
 294
Per Common Share           
Net earnings – diluted+31 % 2.60
 1.99
 1.20
 1.68
 1.58
Net earnings – basic+36 % 2.71
 2.00
 1.20
 1.68
 1.58
Dividends declared+57 % 0.44
 0.28
 0.22
 0.16
 0.13
Book value 1
+6 % 36.01
 34.10
 32.67
 31.35
 29.57
Market price – end  50.83
 43.04
 27.30
 28.51
 29.96
Market price – high  52.20
 44.15
 33.42
 33.33
 31.40
Market price – low  38.43
 19.65
 23.72
 25.02
 21.56
At Year-End           
Assets+5 % 66,288
 63,239
 59,665
 57,203
 56,021
Net loans and leases+5 % 44,780
 42,649
 40,650
 40,064
 39,043
Deposits-1 % 52,621
 53,236
 50,374
 47,848
 46,363
Long-term debt-28 % 383
 535
 812
 1,086
 2,263
Federal funds and other short-term borrowings+502 % 4,976
 827
 347
 244
 340
Shareholders’ equity:

          
Preferred equity-20 % 566
 710
 829
 1,004
 1,004
Common equity+3 % 7,113
 6,924
 6,679
 6,366
 5,461
Performance Ratios           
Return on average assets  0.91% 0.78% 0.53% 0.71% 0.48%
Return on average common equity  7.7% 6.0% 3.8% 5.4% 5.7%
Return on average tangible common equity  9.0% 7.1% 4.6% 6.7% 7.4%
Net interest margin  3.45% 3.37% 3.19% 3.26% 3.36%
Capital Ratios 1
           
Equity to assets  11.6% 12.1% 12.6% 12.9% 11.5%
Common equity tier 1 (Basel III), tier 1 common
(Basel I) 2
  12.1% 12.1% 12.2% 11.9% 10.2%
Tier 1 leverage 2
  10.5% 11.1% 11.3% 11.8% 10.5%
Tier 1 risk-based capital 2
  13.2% 13.5% 14.1% 14.5% 12.8%
Total risk-based capital 2
  14.8% 15.2% 16.1% 16.3% 14.7%
Tangible common equity  9.3% 9.5% 9.6% 9.5% 8.0%
Tangible equity  10.2% 10.6% 11.1% 11.3% 9.9%
Selected Information           
Weighted average diluted common shares outstanding
(in thousands)
  209,653
 204,269
 203,698
 192,789
 184,297
Company common shares repurchased - from publicly announced plans (in thousands)
  7,009
 2,889
 
 
 
Common dividend payout ratio  16.05% 14.04% 18.30% 9.56% 8.20%
Full-time equivalent employees  10,083
 10,057
 10,200
 10,462
 10,452
Commercial banking offices  431
 436
 450
 460
 469
1
At year-end.
2
For 2017, 2016, and 2015, ratios are based on Basel III. For years prior to 2015, ratios are based on Basel I.


ITEM 7.MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS
ITEM 7. MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS
GAAPKey Corporate Objectives
We conduct our operations primarily through seven separately managed and geographically defined affiliates, each with its own local branding and management team. Our affiliate banks are supported by an enterprise operating segment (referred to NON-GAAP RECONCILIATIONSas the “Other” segment) that provides governance and risk management, allocates capital, establishes strategic objectives, and includes centralized technology, back-office functions, and certain lines of business not operated through our affiliate banks.
We focus our efforts and resources to achieve our strategic growth and profitability objectives. This Form 10-K presents non-GAAP financial measures, in additionincludes providing high-quality products and services and deepening relationships with our small business, commercial, and consumer customers. Serving as a trusted advisor for our business customers and supporting their operational needs generally affords us a major source of relatively stable deposits.
We strive to GAAP financial measures, to provide investors with additional information. The adjustments to reconcile fromachieve balanced growth of customers, pre-provision net revenue (“PPNR”), profitability, and shareholder returns. We focus on five strategic growth areas: small business, commercial, affluent, capital markets, and consumer.
To facilitate the applicable GAAP financial measures to the non-GAAP financial measures are presentedachievement of our growth and profitability objectives, we invest in the following schedules. The Company considers these adjustmentsfive key areas, referred to beas “strategic enablers”:
People and Empowerment we invest in training our employees and providing them the tools and resources to build their capabilities;
Technology we invest in innovative technologies that will make us more efficient and enable us to remain competitive;
Operational Excellence we invest in and support ongoing improvements in how we safely and securely deliver value to our customers;
Risk Management we engage in risk management practices to ensure prudent risk-taking and appropriate oversight; and
Data and Analytics we invest in relevant enterprise data and analytic tools to ongoing operating resultssupport local execution and provide a meaningful base for period-to-period and company-to-company comparisons. These non-GAAP financial measures are used by management to assess the performance and financial position of the Company and for presentations of Company performance to investors. The Company further believes that presenting these non-GAAP financial measures will permit investors to assess the performance of the Company on the same basis as that applied by management.prudent decision making.
Non-GAAP financial measures have inherent limitations, and are not required to be uniformly applied by individual entities. Although non-GAAP financial measures are frequently used by stakeholders to evaluate a company, they have limitations as an analytical tool and should not be considered in isolation or as a substitute for analysis of results reported under GAAP.
The following are the non-GAAP financial measures presented in this Form 10-K and a discussion of why management uses these non-GAAP measures:
Return on Average Tangible Common Equity – this schedule also includes “net earnings applicable to common shareholders, excluding the effects of the adjustments, net of tax” and “average tangible common equity.” Return on average tangible common equity is a non-GAAP financial measure that management believes provides useful information about the Company’s use of shareholders’ equity. Management believes the use of ratios that utilize tangible equity provides additional useful information because they present measures of those assets that can generate income.
Tangible Equity Ratio, Tangible Common Equity Ratio, and Tangible Book Value per Common Share – this schedule also includes “tangible equity,” “tangible common equity,” and “tangible assets.” Tangible equity ratio, tangible common equity ratio, and tangible book value per common share are non-GAAP financial measures that management believes provides additional useful information about the levels of tangible assets and tangible equity between each other and in relation to outstanding shares of common stock. Management believes the use of ratios that utilize tangible equity provides additional useful information because they present measures of those assets that can generate income.
Efficiency Ratio – this schedule also includes “adjusted noninterest expense,” “taxable-equivalent net interest income,” “adjusted taxable-equivalent revenue,” “pre-provision net revenue (“PPNR”) ,” and “adjusted PPNR.” The methodology of determining the efficiency ratio may differ among companies. Management makes adjustments to exclude certain items as identified in the subsequent schedule which it believes allows for more consistent comparability among periods. Management believes the efficiency ratio provides useful information regarding the cost of generating revenue. Adjusted noninterest expense provides a measure as to how well the Company is managing its expenses, and adjusted PPNR enables management and others to assess the Company’s ability to generate capital to cover credit losses through a credit cycle. Taxable-equivalent net interest income allows management to assess the comparability of revenue arising from both taxable and tax-exempt sources. The efficiency ratio and adjusted noninterest expense are the key metrics to which the Company announced it would hold itself accountable in its June 1, 2015 efficiency initiative, and to which executive compensation is tied.


Schedule 1
RETURN ON AVERAGE TANGIBLE COMMON EQUITY (NON-GAAP) – ANNUAL
  Year Ended December 31,
(Dollar amounts in millions) 2017 2016 2015
Net earnings applicable to common shareholders (GAAP) $550
 $411
 $247
Adjustments, net of tax:      
Amortization of core deposit and other intangibles 4
 5
 6
Net earnings applicable to common shareholders, excluding the effects of the adjustments, net of tax (non-GAAP)(a)$554
 $416

$253
Average common equity (GAAP) $7,148
 $6,915
 $6,581
Average goodwill (1,014) (1,014) (1,014)
Average core deposit and other intangibles (5) (13) (21)
Average tangible common equity (non-GAAP)(b)$6,129
 $5,888
 $5,546
Return on average tangible common equity (non-GAAP)(a/b)9.0% 7.1% 4.6%
Schedule 2
TANGIBLE EQUITY (NON-GAAP), TANGIBLE COMMON EQUITY (NON-GAAP), AND TANGIBLE BOOK VALUE PER COMMON SHARE (NON-GAAP)
(Dollar amounts in millions, except per share amounts) December 31,
 2017 2016 2015
Total shareholders’ equity (GAAP) $7,679
 $7,634
 $7,507
Goodwill (1,014) (1,014) (1,014)
Core deposit and other intangibles (2) (8) (16)
Tangible equity (non-GAAP)(a)6,663
 6,612
 6,477
Preferred stock (566) (710) (829)
Tangible common equity (non-GAAP)(b)$6,097
 $5,902
 $5,648
Total assets (GAAP) $66,288
 $63,239
 $59,665
Goodwill (1,014) (1,014) (1,014)
Core deposit and other intangibles (2) (8) (16)
Tangible assets (non-GAAP)(c)$65,272
 $62,217
 $58,635
Common shares outstanding (thousands)(d)197,532
 203,085
 204,417
Tangible equity ratio (non-GAAP)(a/c)10.2% 10.6% 11.0%
Tangible common equity ratio (non-GAAP)(b/c)9.3% 9.5% 9.6%
Tangible book value per common share (non-GAAP)(b/d)$30.87 $29.06 $27.63


Schedule 3
EFFICIENCY RATIO
(Dollar amounts in millions) 2017 2016 2015
       
Noninterest expense (GAAP)(a)$1,649
 $1,585
 $1,581
Adjustments:      
Severance costs 7
 5
 11
Other real estate expense, net (1) (2) (1)
Provision for unfunded lending commitments (7) (10) (6)
Debt extinguishment cost 
 
 3
Amortization of core deposit and other intangibles 6
 8
 9
Restructuring costs 4
 5
 4
Total adjustments(b)9
 6
 20
Adjusted noninterest expense (non-GAAP)(a-b)=(c)$1,640
 $1,579
 $1,561
Net interest income (GAAP)(d)$2,065
 $1,867
 $1,715
Fully taxable-equivalent adjustments(e)35
 25
 18
Taxable-equivalent net interest income (non-GAAP)1
(d+e)=(f)2,100
 1,892
 1,733
Noninterest income (GAAP)(g)544
 516
 357
Combined income (non-GAAP)(f+g)=(h)2,644
 2,408
 2,090
Adjustments:      
Fair value and nonhedge derivative income (loss) (2) 2
 
Securities gains (losses), net 14
 7
 (127)
Total adjustments(i)12
 9
 (127)
Adjusted taxable-equivalent revenue (non-GAAP)(h-i)=(j)$2,632
 $2,399
 $2,217
Pre-provision net revenue (non-GAAP)(h)-(a)$995
 $823
 $509
Adjusted pre-provision net revenue (non-GAAP)(j-c)992
 820
 656
Efficiency ratio (non-GAAP)(c/j)62.3% 65.8% 70.4%
Company Overview
Zions Bancorporation (“the Parent”) and its subsidiaries (collectively “the Company,” “Zions,” “we,” “our,” “us”) together comprise a $66 billion financial holding company headquartered in Salt Lake City, Utah.
As of December 31, 2017, the Company was the 19th largest domestic bank holding company in terms of deposits and is included in the Standard and Poor’s (“S&P”) 500 and NASDAQ Financial 100 indices.
At December 31, 2017, the Company had banking operations through 433 domestic branches in eleven western states. Additionally, the Company currently has, and continues to develop its digital delivery capabilities. Revenues and profits are primarily derived from commercial customers and the Company also emphasizes mortgage banking, wealth management, municipal finance, and brokerage services.
The Company is consistently ranked among the best banks in the country to work with by its small and middle-market customers, as measured by the Greenwich Associates annual survey. Since the awards inception in 2009, only three other U.S. banks have consistently received as many Greenwich Excellence Awards as Zions Bancorporation.
The Company consistently wins awards for the best bank within its geography. Examples include the best bank awards given by local newspapers, business journals, or similar publications in Nevada, Arizona, and California: Orange County (four consecutive years) and San Diego County (seven consecutive years).
The long-term strategy of the Company is driven by key factors that include:
Continuing to execute on our community bank business model by doing business on a “local” basis, with significant local decision making for customer-facing elements of our business including product offerings, marketing, and pricing. We believe this provides a meaningful competitive advantage and an opportunity for growth over larger national banks whose loan and deposit products are often homogeneous. We are actively


engaged in community events and charitable efforts designed to give back to the people within our communities. In 2017, we believe this local, customized approach led to a strong showing with commercial customers as reflected in the Greenwich Awards referenced earlier, as well as a growth rate of loans that exceeded the domestic commercial banks’ rate by approximately three percentage points.
Achieving even greater efficiencies than currently reflected in our financial statements. We have improved the financial performance of the Company significantly during the past three years and we intend to continue to do so by creating value through the adoption of common practices, automation, and simplification of all of our front, middle and back-office processes.
We expect to achieve continued growth of revenue (net interest income plus noninterest income) in excess of noninterest expense—so-called positive operating leverage—which should result in annual PPNR growth in the high single digit rate and further improvement to the efficiency ratio.
Improving profitability ratios. Improved operating efficiency coupled with low credit costs as experienced in 2017 should lead to improved profitability ratios, such as the return on assets and equity. We expect to maintain or increase the return of shareholders’ equity due to stronger earnings and a lower risk profile than seen in stress testing results just a few years ago.
Maintaining a strong approach to risk management, having meaningfully improved our operational, credit, and financial risk management in the past several years.
Striving to be a “top employer of choice,” which means employees view Zions Bancorporation as one of the best places to work and grow.
We believe our scale gives us superior access to capital markets, more robust treasury management, and other product capabilities than smaller community banks. Looking forward for the next several years, we believe that digital delivery of products, including mobile banking, online banking and having a core processing system that is robust and prevents outages, is critical to remaining competitive. As such, we are investing a substantial amount to upgrade and replace systems and applications.
During the past several years we have taken significant actions to improve the Company’s risk profile, which include:
The reduction of an above-average concentration in CRE commitments, and within CRE, the concentration of land development commitments declined from more than 70% of total risk-based capital in 2007, to less than 5% at December 31, 2017;
Numerous changes made to the credit administration organization and processes to facilitate improved data collection on loans and monitoring of potential default and loss risk;
The higher-risk portfolio of collateralized debt obligation securities were sold and replaced with government and government agency securities;
A significant increase in the on-balance sheet storehouse of liquidity with the purchase of moderate duration securities with limited duration extension risk; i.e., management has generally purchased securities that within the context of a rising interest rate environment would not experience interest rate related losses;
The addition of five members of the Board of Directors;
The replacement and upgrade of management information and accounting systems to allow for a more complete view of the Company’s risks and opportunities;
The ongoing evaluation and classification of all known risks into approximately sixty unique risk categories, which are regularly monitored and reported in a process that flows from line-level employees through executive management to the Board of Directors;
The streamlining or elimination of redundant or inefficient processes, and the reduction of unnecessary complexity in product types;
With the improvement in the risk profile, along with improving profitability, the Company’s capital stress test results have markedly improved within the past few years, and as such, we have increased the return of capital to shareholders including increasing the common dividend from $0.16 per share in 2014 to $0.44 per share in 2017. Additionally, we repurchased $320 million of common stock during 2017. We believe we are carrying


excess capital, informed primarily by our stress test results, and have indicated that we intend to increase the leverage of the Company at a gradual pace as a result of moderate loan growth combined with total payout ratios generally similar to the current capital plan.
As part of our ongoing simplification and efficiency efforts, in December 2015, the Company consolidated its various banking charters into a single charter. Additionally, as previously discussed, in November 2017, the Company announced plans to change its structure to consolidate the holding company into the banking entity. This change, if approved by shareholders and regulators, will further reduce duplication of effort and simplify operations. For more information see, “Regulatory relief if proposed restructuring is completed and FSOC application is approved,” on page 15.
RESULTS OF OPERATIONS
Executive SummaryDuring 2023, the banking industry experienced significant changes in market conditions, including a higher interest rate environment, significant fluctuations in deposit levels, and broad weakness in bank valuations due in large part to several regional banks being closed and placed into receivership with the FDIC. We employed the following strategic actions during the year as a complement to our existing, well-established risk management practices:
The Company reportedGenerated customer deposit growth through a combination of competitive interest rates, customer outreach, and expanded utilization of reciprocal deposit programs in order to increase the availability of FDIC insurance;
Actively managed the balance sheet through an earning-asset mix change toward higher-yielding loans, while reducing the size of our lower-yielding securities and money market positions;
Increased total available liquidity sources, which far exceeded our level of uninsured deposits, and included the expanded use of existing collateralized funding lines;
Actively managed our interest rate and market risk exposures through a rebalancing of our hedges for both available-for-sale (“AFS”) securities and commercial loans;
Remained committed to controlling expenses, including active personnel management, while continuing to invest in technology;
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Maintained strong credit performance, including low net charge-offs; and
Further strengthened our regulatory capital position through increased retained earnings applicable to common shareholdersand suspended share repurchase programs (beginning the second quarter of 2023 through the end of the year).
Our Financial Performance
This section and other sections provide information about our recent financial performance. For more information about our results of operations for 2017 of $550 million or $2.60 per diluted common share2022 compared with $411 million or $1.99 per diluted common share for 2016. The improved2021, see the respective sections in MD&A included in our 2022 Form 10-K.
Net Earnings Applicable to Common Shareholders
(in millions)
Diluted EPS
Adjusted PPNR
(in millions)
Efficiency ratio
2444244524462447
Our financial performance reflects revenue growth, continued expense control and improved credit quality, particularlyfor 2023 relative to the prior year reflected an increase in the oil and gas-related loan portfolio. Net income increased in 2017 primarily due to a $198 million increase indeposits, lower net interest income, fromstabilization of the net interest margin (“NIM”), loan growth, in our lending and securities portfolios during the year,strong credit quality, as well as higher noninterest expense and short-term rate increases that positively impacted loan yields. Revenue also experienced a benefit from a $28 million increase related to noninterest income and credit costs, specifically the provision for loan losses, declined $69 million. These increasescredit losses.
Net interest income decreased $82 million, or 3%, as higher earning asset yields were partially offset by rising funding costs. The NIM decreased slightly to 3.02%, compared with 3.06%. Net interest income was also impacted by a $64 millionreduction in interest-earning assets and an increase in noninterest expenseinterest-bearing liabilities.
Performance Relative to Previously Announced Initiatives
Efficiency Initiatives
In June 2015 we announced several initiatives to improve operational and financial performance along with some key financial targets. Our initiatives are designed to improve customer experience, to simplify the corporate structure and operations, and to make the Company a more efficient organization. Following is a brief discussion regarding our performance against these key financial targets:
Achieve an efficiency ratioAverage interest-earning assets decreased $1.7 billion, or 2%, driven by declines in the low 60% range for fiscal year 2017. Our efficiency ratio for 2017 was 62.3%, which met our goal for the year, compared with 65.8% for 2016, representing a 351 bps improvement. Improvements in interest income fromaverage securities and loans,average money market investments, partially offset by an increase in adjusted noninterest expense, droveaverage loans and leases.
Total loans and leases increased $2.1 billion, or 4%, primarily due to growth in the significant improvement. See “GAAPconsumer 1-4 family residential mortgage, commercial real estate term, and commercial and industrial loan portfolios.
Average interest-bearing liabilities increased $9.7 billion, or 23%, primarily due to Non-GAAP Reconciliations” on page 29 for more information regardingincreases in average interest-bearing deposits and average borrowed funds. These increases were offset by a decrease of $10.2 billion, or 26%, in average noninterest-bearing deposits, as customers migrated to interest-bearing products in response to the calculation of the adjusted efficiency ratio and why management uses this non-GAAP measure.
higher interest rate environment.
Maintain adjusted noninterest expense at less than $1.58Total deposits increased $3.3 billion, in 2016, with a modest increase of 2-3% in 2017. We met our target for fiscal year 2016, keeping adjusted noninterest expense to $1.579 billion. In 2017, total adjusted noninterest expense was $1.640 billion. Zions made a $12 million contributionor 5%, primarily due to a charitable foundation$12.8 billion increase in interest-bearing deposits, partially offset by a $9.5 billion decrease in noninterest-bearing demand deposits. Customer deposits (excluding brokered deposits) remained relatively stable at $70.5 billion and included approximately $6.8 billion of reciprocal deposit products. The loan-to-deposit ratio remained flat at 77%.
The provision for credit losses was $132 million in 2023, compared with $122 million in 2022.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Customer-related noninterest income increased $6 million, or 1%, primarily due to increases in commercial account fees and wealth management fees, partially offset by a decrease in retail and business banking fees resulting from a change in our overdraft and non-sufficient funds practices effected during the third quarter of 2022. Increases in noncustomer-related noninterest income were due largely to an increase in dividends on FHLB stock, as well as the gain on sale of a bank-owned property in the second quarter of 2023.
Noninterest expense increased $219 million, or 12%, primarily due to an increase in deposit insurance and regulatory expense, driven largely by a $90 million accrual associated with the FDIC special assessment in the fourth quarter of 2017, which2023. Noninterest expense was related in part to the Tax Cutsalso impacted by higher salaries and Jobs Act. Excluding the impact of this one-time accelerated contribution, adjusted noninterest expense increased $49benefits (including severance) and technology, telecom, and information processing expenses.
Credit quality remained strong, as net loan and lease charge-offs were $36 million, or 3%0.06% of average loans in 2023, compared with net charge-offs of $39 million, or 0.07% of average loans, in 2022. Classified loans decreased $104 million, or 11%. Nonperforming assets increased $79 million, or 53%, which was in line with our expectations. Adjusted noninterest expense excludes those same expense items excluded in arriving at the efficiency ratio (see “GAAPprimarily due to Non-GAAP Reconciliations” on page 29 for more information regarding the calculation of the efficiency ratio).one commercial and industrial loan totaling $31 million, and two suburban office commercial real estate loans totaling $46 million.
The following schedule presents additional selected financial highlights:
Increase returns on tangible common equity to more than ten percent. Returns were 9.0%, 7.1%, and 4.6% for 2017, 2016, and 2015, respectively. Adjusting for the estimated net DTA write-off of $47 million through income tax expense associated with the decrease in the federal income tax rate from the passage of new legislation (see “Income Taxes” on page 45 for more information), and the $12 million charitable contribution, return on tangible common equity for 2017 would have been 9.9%. These year-over-year increases demonstrate our commitment to improving profitability, as we continue to work towards achieving this goal. See “GAAP to Non-GAAP Reconciliations” on page 29 for more information regarding the calculation of the adjusted efficiency ratio and why management uses this non-GAAP measure.
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Schedule 4
Achieve cumulative gross pretax cost savings of $120 million from operational expense initiatives by fiscal year 2017. Savings from technology initiatives, the consolidation of legal charters, and improved operational efficiency across the Company helped us achieve this goal by the end of 2017.
SELECTED FINANCIAL HIGHLIGHTS
Highlights in 2017
(Dollar amounts in millions, except per share amounts)2023/2022 Change202320222021
For the Year
Net interest income(3)%$2,438$2,520$2,208
Noninterest income%677632703
Total net revenue(1)%3,1153,1522,911
Provision for credit losses%132122(276)
Noninterest expense12 %2,0971,8781,741
Pre-provision net revenue 1
(19)%1,0591,3111,202
Net income(25)%6809071,129
Net earnings applicable to common shareholders(26)%6488781,100
Per Common Share
Net earnings – diluted(25)%4.355.796.79
Tangible book value at year-end 1
24 %28.3022.7939.62
Market price – end(11)%43.8749.1663.16
Market price – high(27)%55.2075.4468.25
Market price – low(60)%18.2645.2142.12
At Year-End
Assets(3)%87,20389,54593,200
Loans and leases, net of unearned income and fees%57,77955,65350,851
Deposits%74,96171,65282,789
Common equity18 %5,2514,4537,023
Performance Ratios
Return on average assets0.77%1.01%1.29%
Return on average common equity13.4%16.0%14.9%
Return on average tangible common equity 1
17.3%19.8%17.3%
Net interest margin3.02%3.06%2.72%
Net charge-offs to average loans and leases0.06%0.07%0.01%
Total allowance for credit losses to loans and leases outstanding1.26%1.14%1.09%
Capital Ratios at Year-End
Common equity Tier 1 capital10.3%9.8%10.2%
Tier 1 leverage8.3%7.7%7.2%
Tangible common equity 1
4.9%3.8%6.5%
Other Selected Information
Weighted average diluted common shares outstanding
(in thousands)
(2)%147,756150,271160,234
Bank common shares repurchased (in thousands)
(73)%9473,56313,497
Dividends declared%$1.64$1.58$1.44
Common dividend payout ratio 2
37.8%27.3%21.1%
Capital distributed as a percentage of net earnings applicable to common shareholders 3
46%50%94%
Efficiency ratio 1
62.9%58.8%60.8%
Net interest income, which is more than three-quarters of our revenue, improved by $198 million to $2.1 billion compared with 2016. The average balance of our investment securities portfolio grew $5.4 billion, and the average rate on those securities expanded 9 bps due in part to a change in asset mix. Our average lending portfolio also grew by 3% or $1.4 billion; the average yield on the loan portfolio increased 14 bps, reflecting in part several increases in short-term benchmark rates. Although there was a decrease in the average balance of long-term debt in 2017 of $286 million, this was offset by increased average Federal Home Loan Bank (“FHLB”) and other short-term borrowings, which rose by $3.6 billion. Interest expense increased $40 million compared with 2016, almost entirely driven by the increase in wholesale funding. Interest expense on deposits increased only $10 million on more than $52 billion of average deposits. Some of the same factors that led to an increase in net interest income also resulted in net interest margin (“NIM”) expansion in 2017 relative to 2016, which was 3.45% and 3.37%, respectively.
Adjusted PPNR of $992 million in 2017 was up $172 million from 2016. This increase reflects operating leverage improvement resulting from loan growth and a more profitable average earning assets mix. Adjusted noninterest expense increased to $1.640 billion (or $1.628 billion, if excluding the charitable foundation contribution related to the Tax Cuts and Jobs Act) from $1.579 billion in 2017, however, this was more than offset by improved revenue. PPNR improvements during 2017 have driven an improvement in the Company’s efficiency ratio from 65.8% in 2016 to 62.3% in 2017.
Our lending portfolio grew $2.1 billion based on year-end balances, or 5% during 2017. We have seen widespread growth across most products and geographies, with particular strength in 1-4 family residential, commercial and industrial, and municipal lending. We saw a small decline in our National Real Estate (“NRE”) portfolio, and we actively managed decreases in our oil and gas-related and CRE term portfolios. We are currently comfortable with the concentrations in both the oil and gas-related and CRE term portfolios and we do not expect the attrition trend to continue.
Asset quality has been very favorable during 2017. Credit quality in the oil and gas-related portfolio continues to strengthen and it has remained strong in the rest of the lending portfolio. Overall criticized, classified, and nonaccrual loans declined by $292 million, $444 million, and $127 million, respectively.
We continue to increase the return on- and of-capital. As previously mentioned, the Company’s return on average tangible common equity increased substantially in 2017 relative to 2016. Regarding return of capital, during the year, the Company repurchased 7 million shares of common stock for $320 million. Dividends per common share were $0.44 in 2017, up from $0.28 in 2016. In June, 2017, we announced that the Federal Reserve did not object to the capital actions in the Company’s 2017 capital plan (the binding portion of which spans the timeframe of July 2017 to June 2018). The plan included stepped quarterly common dividend increases, rising to $0.24 per share by the second quarter of 2018, and up to $465 million in common stock repurchases. 1 See “Capital Management”“Non-GAAP Financial Measures” on page 77 for more information regarding the 2018 capital plan.information.
We announced in 2013 that we had started a project2 The common dividend payout ratio is equal to replace our core loan and deposit banking systems (“Core Transformation Project”). We successfully implemented the first phase of the TCS BαNCS® core servicing system in mid-2017, replacing our consumer lending system. The second phase is focused on the replacement of our commercial and construction lending systems is expectedcommon dividends paid divided by net earnings applicable to be completed in 2019. The replacement of the deposit systemcommon shareholders.
3 This ratio is the third phase ofcommon dividends paid plus share repurchases for the project. As of December 31, 2017, the Company had $148 million of capitalized expenses associated with the Core Transformation Project. BαNCS® is a real time, parameter-driven servicing system that will provide long-term benefitsyear, divided by net earnings applicable to the Company by improving accessibility and functionality, allowing our bankers to better serve customers.common shareholders.

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Areas Experiencing Challenges in 2017
Noninterest income from customer-related fees increased approximately 3% in 2017 from the prior year period, which was less than the targeted growth goal. We experienced strength in card activity (credit, debit, merchant), growth in the Company’s trust and wealth management initiatives, and increased foreign currency and derivative transactions made on behalf of customers. This growth was partially offset by a decline in loan sales and servicing income, which was mainly due to fewer sales of residential mortgages and a lower valuation adjustment on our agricultural loan servicing assets accounted for at fair value. We are targeting mid-single digit growth of customer-related fee income.
Noninterest expense increased to $1.649 billion from $1.585 billion in 2016, equivalent to a 4% increase. Adjusting for the one-time charitable contribution mentioned earlier, adjusted noninterest expense increased 3%, which is in line with announced forecasts. Employee costs, including salaries and benefits expenses, were higher in 2017 than in the prior year, partially due to a combination of higher incentive compensation and increased costs in the Company’s benefit plans. Depreciation and amortization expense was higher by $5 million, in part, because we placed into use a newly constructed office building at our Amegy affiliate and as previously mentioned we successfully implemented the first phase of our Core Transformation Project. FDIC premiums increased $13 million over the prior year, due in part to a surcharge assessed to large banks introduced by the FDIC in the third quarter of 2016 with the purpose of recapitalizing the deposit insurance fund.
Areas of Focus for 2018
In 2018, we are focused on the ongoing initiatives related to Company profitability and returns on equity. Major areas of emphasis include the following:
Achieve positive operating leverage
Maintain annual mid-single digit loan growth rates
Achieve mid-single digit growth rates in customer-related fee income
Maintain strong expense controls: we expect adjusted noninterest expense to increase slightly--a rate of growth in the low single digit percentage range
Annual PPNR growth in the high single digit rate and further improvement to the efficiency ratio
Continue simplification of all aspects of how we do business
Implement technology upgrade strategies
Increase the return on and maintain or increase the return of capital
Continue to execute on our Community Bank Model – doing business on a “local” basis
Merge the Parent into its bank subsidiary, ZB, N.A.


Schedule 4
KEY DRIVERS OF PERFORMANCE
2017 COMPARED TO 2016
Driver 2017 2016 
Change
better/(worse)
       
  (In billions)  
Average net loans and leases $43.5
 $42.1
 3 %
Average money market investments 1.5
 3.7
 (59)
Average total securities 15.7
 10.3
 52
Average noninterest-bearing deposits 23.8
 22.5
 6
Average total deposits 52.2
 50.6
 3
  (In millions)  
Net interest income $2,065
 $1,867
 11 %
Provision for loan losses 24
 93
 74
Noninterest income 544
 516
 5
Customer-related fee income 1
 485
 473
 3
Noninterest expense 1,649
 1,585
 (4)
Net interest margin 3.45% 3.37% 8 bps
Nonaccrual loans 2
 414
 569
 27 %
Ratio of net charge-offs to average loans and leases 0.17% 0.31% 14 bps
Ratio of nonperforming lending-related assets to net loans and leases and other real estate owned 2
 0.93% 1.34% 41 bps
Ratio of total allowance for credit losses to net loans and leases outstanding 1.29% 1.48% 19 bps
1 Includes the following income statement line items: service charges and fees on deposit accounts, other service charges, commissions and fees, wealth management and trust income, capital markets and foreign exchange, and loan sales and servicing income.
2 Includes loans held for sale.
Net Interest Income and Net Interest Margin
Net interest income is the difference between interest earned on interest-earning assets and interest paid on interest-bearing liabilities. Taxable-equivalentliabilities, and represented 78% and 80% of our net revenue (net interest income plus noninterest income) during 2023 and 2022, respectively. The NIM is calculated as net interest income isas a percent of average interest-earning assets.
Schedule 5
NET INTEREST INCOME AND NET INTEREST MARGIN
Amount changePercent changeAmount changePercent change
(Dollar amounts in millions)202320222021
Interest and fees on loans$3,196$1,084 51 %$2,112$177 %$1,935
Interest on money market investments188107 NM8160 NM21
Interest on securities56351 10 512201 65 311
Total interest income3,9471,242 46 2,705438 19 2,267
Interest on deposits1,063993 NM7040 NM30
Interest on short- and long-term borrowings446331 NM11586 NM29
Total interest expense1,5091,324 NM185126 NM59
Net interest income$2,438$(82)(3)$2,520$312 14 $2,208
Average interest-earning assets$81,984$(1,654)(2)%$83,638$1,371 %$82,267
Average interest-bearing liabilities51,8769,738 23 %42,1381,388 %40,750
bpsbps
Yield on interest-earning assets 1
4.86 %158 3.28 %49 2.79 %
Rate paid on total deposits and interest-bearing liabilities 1
1.87 %164 0.23 %16 0.07 %
Cost of total deposits 1
1.46 %137 0.09 %0.04 %
Net interest margin 1
3.02 %(4)3.06 %34 2.72 %
1 Taxable-equivalent rates used where applicable.
Net interest income decreased $82 million, or 3%, in 2023, relative to the largest portionprior year, as higher earning asset yields were offset by higher funding costs. The NIM was 3.02%, compared with 3.06%.
The yield on average interest-earning assets was 4.86% in 2023, an increase of our revenue. For 2017, taxable-equivalent net158 basis points, reflecting higher interest rates and a favorable mix change to higher yielding assets. The yield on average loans and leases increased 163 basis points to 5.69% in 2023, compared with 4.06% in 2022, reflecting the higher interest rate environment. The yield on average securities increased 58 basis points to 2.64% in 2023.
The rate paid on average interest-bearing liabilities was 2.91% in 2023, compared with 0.44% in the prior year, and the cost of total deposits was 1.46%, compared with 0.09% in the prior year, also reflecting the higher interest rate environment, and the impact of the change in deposit composition away from noninterest-bearing deposits. The rate paid on total borrowed funds was 5.11%, compared with 3.27%, for the same time periods.
Net interest income was $2.1 billion, compared with $1.9 billion and $1.7 billion, in 2016 and 2015, respectively. The tax rate used for calculating all taxable-equivalent adjustments was 35% for all years presented. The increase over 2016, and the previous increase over 2015, were driven by several factors, including a larger average securities portfolio balance, loan growth, and increases in benchmark interest rates that impacted loan yields. We expect the size of the securities portfolio to be relatively stable during the next several quarters, and we are not assuming any further increases in benchmark rates in our forecasts. Therefore, we expect net interest income to increase at a moderate pace in 2018 when compared with 2017.
Net Interest Margin and Interest Rate Spreads in 2017 vs. 2016
The NIM was 3.45% and 3.37% for 2017 and 2016, respectively. Compared with 2016, changes in asset mix resulted in higher securities and loan balances, lower balances in money market investments, and higher balances of wholesale borrowings to fund overall balance sheet growth. Moving funds from money market investments to loans and securities had a positive impact on NIM, while funding balance sheet growth with wholesale borrowings reduced spreads and negatively impacted NIM, although it was accretive to net interest income. The NIM was also positively impacted by several increasesa reduction in short-term interest rates.interest-earning assets and an increase in interest-bearing liabilities. Average interest-earning assets increased $4.7decreased $1.7 billion, or 2%, from 2016, withthe prior year, driven by declines in average rates improving 14 bps. securities and average money market investments. The decrease in average securities was primarily due to principal reductions. These decreases were partially offset by an increase of $4.1 billion in average loans and leases.
Average interest-bearing liabilities increased $3.6$9.7 billion, or 23%, primarily due to increases in average interest-bearing deposits and average rates increased 8 bps over the same period.
The average loan portfolio increased $1.4borrowed funds. These increases were offset by a decline of $10.2 billion, or 3% from 2016, with26%, in average noninterest-bearing deposits, as customers migrated to interest-bearing products in response to the majority of growth coming from 1-4 family residential, commercial and industrial, and municipal lending. Yields on average balances increased overall, buoyed by increases of 16 bps and 26 bps in the commercial and CRE portfolios, respectively; yields on averagehigher interest rate environment.

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The following charts further illustrate the changes in average interest-earning assets and average interest-bearing liabilities:
17281649267453687
Average loans and leases increased $4.1 billion, or 8%, to $56.7 billion, primarily due to growth in average consumer balances were relatively flat during 2017. Much of the consumer growth was in consumer 1-4 family residential, where our yields are generally lower than onand commercial loans. Benchmark interest rates increased several times beginning inAverage securities decreased $3.8 billion, or 15%, to $21.7 billion, primarily due to principal reductions. During the fourth quarter of 2015, which has had a positive impact on NIM and spreads, as our earning assets generally reprice more quickly than our funding sources. A portion2022, we transferred approximately $10.7 billion fair value ($13.1 billion amortized cost) of our variable-rate loans were not affected by these changes primarily due to longer reset frequency, or because a substantial portion of our earning assets are tied to longer-term rates indices, which rates were impacted by a relatively flat yield curve for much of 2017. Additionally, NIM benefited from FDIC-supported loans by approximately 3 bps and 4 bps in 2017 and 2016, respectively. We expect continued strong growth in residential mortgages, with moderate growth in both CRE and commercial and industrial loans.
Average available-for-sale (“AFS”)mortgage-backed AFS securities balances increased $5.4 billion during 2017 and yields were also up 17 bps due to the effect of rising interest rates on variable-rate securities, moderationheld-to-maturity (“HTM”) category.
16492674536711649267453704
Average deposits decreased $5.6 billion, or 7%, to $72.9 billion, driven largely by the reduction in the amount of prepayments on agency-guaranteed, mortgage-backed securities, and investment in products providing a higher yield than the average portfolio. The purchases were funded by using lower-yielding average money market investments, which were reduced by $2.1 billion, and wholesale borrowing from the FHLB. The investment portfolio has now reached a generally appropriate size relative to the balance sheet.
noninterest-bearing deposits. Average noninterest-bearing demandnoninterest-bearing deposits provided us with low-cost funding and comprised 45.6% of average total deposits, which totaled $52.2 billion in 2017, compared with 44.4% of average total deposits, which totaled $50.6 billion, for 2016. Average interest-bearing deposits increased only 1% in 2017, compared with 2016. Over the past 12 months the Federal Reserve has increased the overnight benchmark Federal Funds rate by 75 bps, while the rate paid on the Company’s interest-bearing deposits increased 3 bps. We have been selectively increasing deposit pricing in certain markets and with certain clients, but we have not generally experienced signific
ant pressure to broadly increase deposit rates. Although we consider a wide variety of sources when determining our funding needs, we benefit from access to deposits from a significant number of small to mid-sized business customers, which provide us with a low cost of funds and have a positive impact on our NIM. Including wholesale borrowings, the rate paid on interest-bearing liabilities increased 8 bps primarily due to borrowings increasing as a percentage of liabilities during 2017.
The average balance of long-term debttotal deposits decreased $286 millionto 41% in 2023, compared with 2016, and although the average rate increased 61 bps51% during 2022. Our loan-to-deposit ratio was 77%, compared with 78% in the current year, because remaining debt was atprior year.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Average borrowed funds, consisting primarily of secured borrowings, increased $5.2 billion, or 149%, to $8.7 billion, due largely to a higher average rate thanshift in wholesale funding needs as a result of fluctuations in deposit levels during 2023.
For more information on our investment securities portfolio and borrowed funds and how we manage liquidity risk, refer to the rate“Investment Securities Portfolio” section on debt that matured and was available to be called; overall interest expense thereon decreased $13 million. As mentioned previously, the Company has used short-term FHLB borrowings to fund some of its balance sheet growth. Average short-term debt grew $3.6 billionpage 46 and the rate paid increased 78 bps. Further changes in short-term borrowings will be driven by balancing changes in deposits and loans as we do not foresee significant increases in investment security balances.
The spread“Liquidity Risk Management” section on average interest-bearing funds was 3.27% and 3.23% for 2017 and 2016, respectively. The spread on average interest-bearing funds for these periods was affected by the same factors that had an impact on the NIM.
We expect the mixpage 67. For further discussion of interest-earning assets to continue to change over the next several quarters due to solid consumer loan growth, accompanied by moderate growth in CRE term loans, and non-oil and gas-related commercial and industrial loans. We anticipate this growth will be partially offset by continued modest reduction in the NRE portfolio.
Interest rate spreads and margin are impacted by the mix of assets we hold, the composition of our loan and securities portfolios and the type of funding used. Assuming no additional increases in the Federal Funds rate, we expect the yield on the securities portfolio to increase slightly, as the cash flow from the portfolio is redeployed into securities with yields that are slightly accretive to the overall portfolio. We expect the yield of the loan portfolio to increase somewhat due to the effects of risingmarket rates on net interest rates in late 2017, partially offset by a continued modest change in the mix of the portfolio (increasing concentration in lower-yielding residential mortgages), as well as reduced income from higher-yielding loans purchased from the FDIC in 2009.


Our estimates of the Company’sand how we manage interest rate risk, position are highly dependent upon a number of assumptions regarding the repricing behavior of various deposit and loan types in response to changes in both short-term and long-term interest rates, balance sheet composition, and other modeling assumptions, as well as the actions of competitors and customers in response to those changes. In addition, our modeled projections for noninterest-bearing demand deposits, which are a substantial portion of our deposit balances, are particularly reliant on assumptions for which there is little historical experience duerefer to the prolonged period of very low interest rates. Further detail on interest rate risk is discussed in “Interest Rate and Market Risk Management” section on page 68.
Refer to the “Liquidity Risk Management” section beginning on page 72 for more information on how we manage liquidity risk.
Net Interest Margin and Interest Rate Spreads in 2016 vs. 2015
The NIM was 3.37% and 3.19% for 2016 and 2015, respectively. Market trends and competitive pricing led to generally flat or lower yields across loans and investments in 2016 compared with 2015. These yield adjustments were offset by changes in the Company’s asset mix, which in 2016 became less concentrated in lower-yielding money market investments, and more focused on higher-yielding agency securities and loans. Further contributing to the improvement was a decline in the Company’s cost of funds, due to higher amounts of noninterest-bearing deposits and tender offers, early calls and maturities of higher-rate debt, including the remaining trust preferred securities.
Average interest-earning assets increased $1.8 billion from 2015, with rates improving 12 bps. Average interest-bearing liabilities increased $769 million and rates decreased 11 bps over the same period.
Our average loan portfolio was $1.9 billion higher during 2016, compared with 2015, although the average interest rate earned on the loan portfolio was 8 bps lower than it was in 2015 due to competitive pricing pressure and depressed interest rates. The larger average loan base generated an additional $45 million of taxable-equivalent interest income during the year. The largest average growth in 2016 was in the CRE portfolio, which also saw the average yield decline by 22 bps. The decline in loan yields occurred as new loans were originated or existing loans reset or were modified. See “Interest Rate and Market Risk Management” on page 68 for further information regarding our interest rate sensitivity.
During 2016 we continued to purchase U.S. agency pass-through securities in order to alter the mix of our interest-earning assets that began in the second half of 2014. The average balance of AFS securities for 2016 increased by $4.4 billion or 84%, compared with 2015, and the average yield was flat at 1.93%. Average balances of money market investments over the same period declined $4.6 billion, with an average yield during 2016 of 0.59%. This asset movement had the largest impact on the improvement in NIM during 2016.
Average noninterest-bearing demand deposits provided us with low cost funding and comprised 44.4% of average total deposits for 2016, compared with 43.9% for 2015. Average interest-bearing deposit balances increased by 3% in 2016 compared with 2015; additionally, the rate paid was flat at 18 bps.
The average balance of long-term debt was $313 million lower for 2016 compared with 2015. The reduced balance was the result of tender offers, early calls and maturities. The average interest rate on long-term debt for 2016 decreased by 157 bps compared with 2015. This was due to the maturity of higher cost long-term debt in the latter part of 2015, which had a greater impact on the average rate during 2016.
The lower cost of funds in 2016, compared with 2015, and improved yields on average interest-earning assets, contributed to the higher NIM and to an improvement in spread from 2.99% in 2015 to 3.23% in 2016.63.
The following schedule summarizes the average balances, the amount of interest earned or incurred,paid, and the applicable yields for interest-earning assets and the costs of interest-bearing liabilities that generate taxable-equivalent net interest income.liabilities:

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Schedule 5
DISTRIBUTION OF ASSETS, LIABILITIES, AND SHAREHOLDERS’ EQUITY6
AVERAGE BALANCE SHEETS, YIELDS, AND RATES
Year Ended December 31,
202320222021
(In millions)Average balanceInterest
Yield/
Rate 1
Average balanceInterest
Yield/
Rate 1
Average balanceInterest
Yield/
Rate 1
ASSETS
Money market investments:
Interest-bearing deposits$2,163 $112 5.18 %$3,066 $27 0.87 %$8,917 $12 0.14 %
Federal funds sold and securities purchased under agreements to resell1,358 76 5.57 2,482 54 2.16 2,129 0.40 
Total money market investments3,521 188 5.33 5,548 81 1.45 11,046 21 0.19 
Securities:
Held-to-maturity10,731 240 2.24 1,999 47 2.36 562 17 2.97 
Available-for-sale10,900 331 3.03 23,132 461 1.99 18,365 292 1.59 
Trading account53 2.86 322 16 4.79 246 11 4.43 
Total securities21,684 572 2.64 25,453 524 2.06 19,173 320 1.67 
Loans held for sale39 5.95 39 2.57 65 2.35 
Loans and leases: 2
Commercial30,519 1,679 5.50 29,225 1,194 4.09 29,580 1,185 4.01 
Commercial real estate13,023 908 6.98 12,251 544 4.44 12,136 418 3.44 
Consumer13,198 639 4.84 11,122 398 3.58 10,267 354 3.44 
Total loans and leases56,740 3,226 5.69 52,598 2,136 4.06 51,983 1,957 3.76 
Total interest-earning assets81,984 3,988 4.86 83,638 2,742 3.28 82,267 2,299 2.79 
Cash and due from banks662 621 605 
Allowance for credit losses on loans and debt securities(632)(514)(612)
Goodwill and intangibles1,062 1,022 1,015 
Other assets5,579 4,908 4,122 
Total assets$88,655 $89,675 $87,397 
LIABILITIES AND SHAREHOLDERS’ EQUITY
Interest-bearing deposits:
Savings and money market$34,135 $650 1.90 $37,045 $61 0.16 $36,717 $21 0.06 
Time9,028 413 4.58 1,594 0.58 2,020 0.41 
Total interest-bearing deposits43,163 1,063 2.46 38,639 70 0.18 38,737 30 0.08 
Borrowed funds:
Federal funds purchased and security repurchase agreements3,380 169 4.98 1,531 38 2.49 797 0.07 
Other short-term borrowings4,741 241 5.08 1,263 46 3.65 — 0.04 
Long-term debt592 36 6.09 705 31 4.28 1,211 28 2.36 
Total borrowed funds8,713 446 5.11 3,499 115 3.27 2,013 29 1.45 
Total interest-bearing funds51,876 1,509 2.91 42,138 185 0.44 40,750 59 0.14 
Noninterest-bearing demand deposits29,703 39,890 37,520 
Other liabilities1,797 1,735 1,259 
Total liabilities83,376 83,763 79,529 
Shareholders’ equity:
Preferred equity440 440 497 
Common equity4,839 5,472 7,371 
Total shareholders’ equity5,279 5,912 7,868 
Total liabilities and shareholders’ equity$88,655 $89,675 $87,397 
Spread on average interest-bearing funds1.95 %2.84 %2.65 %
Impact of net noninterest-bearing sources of funds1.07 %0.22 %0.07 %
Net interest margin$2,479 3.02 %$2,557 3.06 %$2,240 2.72 %
Memo: total cost of deposits1.46 %0.09 %0.04 %
Memo: total deposits and interest-bearing liabilities81,579 1,509 1.87 %82,028 185 0.23 %78,270 59 0.07 %
 2017 2016
(Dollar amounts in millions)
Average
balance
 
Amount of
interest 1
 
Average
rate
 
Average
balance
 
Amount of
interest 1
 
Average
rate
ASSETS           
Money market investments$1,539
 $19
 1.23% $3,664
 $21
 0.59%
Securities:           
Held-to-maturity776
 31
 3.95
 675
 30
 4.40
Available-for-sale14,907
 313
 2.10
 9,546
 184
 1.93
Trading account64
 2
 3.75
 83
 3
 3.76
Total securities15,747
 346
 2.20
 10,304
 217
 2.11
Loans held for sale87
 3
 3.56
 140
 5
 3.36
Loans and leases 2
           
Commercial22,116
 964
 4.36
 21,748
 913
 4.20
Commercial Real Estate11,184
 504
 4.50
 11,131
 472
 4.24
Consumer10,201
 391
 3.84
 9,183
 351
 3.83
Total Loans and leases43,501
 1,859
 4.27
 42,062
 1,736
 4.13
Total interest-earning assets60,874
 2,227
 3.66
 56,170
 1,979
 3.52
Cash and due from banks786
     675
    
Allowance for loan losses(548)     (601)    
Goodwill1,014
     1,014
    
Core deposit and other intangibles5
     13
    
Other assets2,985
     2,779
    
Total assets$65,116
     $60,050
    
LIABILITIES           
Interest-bearing deposits:           
Saving and money market$25,453
 39
 0.15
 $25,672
 37
 0.15
Time2,966
 20
 0.69
 2,333
 12
 0.49
Foreign
 
 
 128
 
 0.28
Total interest-bearing deposits28,419
 59
 0.21
 28,133
 49
 0.18
Borrowed funds:           
Federal funds purchased and other short-term borrowings4,096
 44
 1.05
 456
 1
 0.27
Long-term debt417
 24
 5.79
 703
 37
 5.18
Total borrowed funds4,513
 68
 1.49
 1,159
 38
 3.25
Total interest-bearing liabilities32,932
 127
 0.38
 29,292
 87
 0.30
Noninterest-bearing deposits23,781
     22,462
    
Other liabilities624
     625
    
Total liabilities57,337
     52,379
    
Shareholders’ equity:           
Preferred equity631
     756
    
Common equity7,148
     6,915
    
Controlling interest shareholders’ equity7,779
     7,671
    
Noncontrolling interests
     
    
Total shareholders’ equity7,779
     7,671
    
Total liabilities and shareholders’ equity$65,116
     $60,050
    
Spread on average interest-bearing funds    3.27
     3.23
Taxable-equivalent net interest income and net yield on interest-earning assets  $2,100
 3.45
   $1,892
 3.37
1 Taxable-equivalent rates used where applicable. See “GAAP to Non-GAAP Reconciliations” on page 29 for more information regarding taxable-equivalent net interest income.
2 Net of unearned incomeunamortized purchase premiums, discounts, and deferred loan fees net of relatedand costs. Loans include nonaccrual and restructured loans.

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2015 2014 2013
Average
balance
 
Amount of
interest 1
 
Average
rate
 
Average
balance
 
Amount of
interest 1
 
Average
rate
 
Average
balance
 
Amount of
interest 1
 
Average
rate
                 
$8,252
 $23
 0.28% $8,218
 $21
 0.26% $8,850
 $23
 0.26%
                 
581
 30
 5.08
 609
 32
 5.27
 762
 38
 4.91
5,181
 100
 1.93
 3,472
 75
 2.17
 3,107
 72
 2.32
64
 2
 3.46
 61
 2
 3.22
 32
 1
 3.29
5,826
 132
 2.26
 4,142
 109
 2.64
 3,901
 111
 2.84
125
 5
 3.61
 128
 5
 3.63
 147
 5
 3.64
                 
21,419
 903
 4.22
 21,125
 922
 4.36
 20,186
 940
 4.65
10,178
 454
 4.46
 10,337
 484
 4.68
 10,386
 557
 5.36
8,574
 334
 3.91
 8,060
 328
 4.06
 7,537
 321
 4.25
40,171
 1,691
 4.21
 39,522
 1,734
 4.39
 38,109
 1,818
 4.77
54,374
 1,851
 3.40
 52,010
 1,869
 3.59
 51,007
 1,957
 3.84
642
     894
     1,014
    
(607)     (690)     (830)    
1,014
     1,014
     1,014
    
21
     31
     44
    
2,601
     2,623
     2,683
    
$58,045
     $55,882
     $54,932
    
                 
                 
$24,619
 38
 0.16
 $23,532
 37
 0.16
 $22,891
 40
 0.17
2,274
 10
 0.43
 2,490
 12
 0.46
 2,792
 16
 0.57
379
 1
 0.18
 642
 1
 0.18
 1,662
 3
 0.20
27,272
 49
 0.18
 26,664
 50
 0.19
 27,345
 59
 0.22
                 
235
 
 0.14
 223
 
 0.11
 278
 
 0.11
1,016
 69
 6.75
 1,803
 123
 6.82
 2,265
 186
 8.21
1,251
 69
 5.51
 2,026
 123
 6.09
 2,543
 186
 7.32
28,523
 118
 0.41
 28,690
 173
 0.60
 29,888
 245
 0.82
21,366
 
   19,610
     17,972
    
592
     554
     584
    
50,481
     48,854
     48,444
    

                
983
     1,004
     1,360
    
6,581
     6,024
     5,130
    
7,564
     7,028
     6,490
    

     
     (2)    
7,564
     7,028
     6,488
    
$58,045
     $55,882
     $54,932
    

   2.99
     2.99
     3.02
  $1,733
 3.19
   $1,696
 3.26
   $1,712
 3.36


Schedule 6 analyzes the year-to-yearThe following schedule presents year-over-year changes in net interest income on a fully taxable-equivalent basis for the years indicated. For purposes of calculating the yields in these schedules,this schedule, the average loan balances also include the principal amounts of nonaccrual and restructured loans. However, interestInterest payments received on nonaccrual loans is included inare not recognized into interest income, onlybut are applied as a reduction to the extent that cash payments have been received and not applied to principal reductions.outstanding. In addition, interest on restructuredmodified loans is generally accrued at reducedthe modified rates.
Schedule 6
ANALYSIS OF INTEREST CHANGES DUE TO VOLUME AND RATE
 2017 over 2016 2016 over 2015
 Changes due to Total changes Changes due to Total changes
(In millions)Volume 
Rate1
  Volume 
Rate1
 
INTEREST-EARNING ASSETS           
Money market investments$(12) $10
 $(2) $(13) $11
 $(2)
Securities:           
Held-to-maturity4
 (3) 1
 4
 (4) 
Available-for-sale111
 18
 129
 84
 
 84
Trading account(1) 
 (1) 1
 
 1
Total securities114
 15
 129
 89
 (4) 85
Loans held for sale(2) 
 (2) 1
 
 1
Loans and leases2
           
Commercial16
 35
 51
 13
 (3) 10
Commercial Real Estate2
 30
 32
 40
 (22) 18
Consumer38
 2
 40
 23
 (6) 17
Total loans and leases56
 67
 123
 76
 (31) 45
Total interest-earning assets156
 92
 248
 153
 (24) 129
INTEREST-BEARING LIABILITIES           
Interest-bearing deposits:           
Saving and money market
 2
 2
 
 (1) (1)
Time3
 5
 8
 
 2
 2
Foreign
 
 
 (1) 
 (1)
Total interest-bearing deposits3
 7
 10
 (1) 1
 
Borrowed funds:           
Federal funds purchased and other short-term borrowings31
 12
 43
 1
 
 1
Long-term debt(15) 2
 (13) (16) (16) (32)
Total borrowed funds16
 14
 30
 (15) (16) (31)
Total interest-bearing liabilities19
 21
 40
 (16) (15) (31)
Change in taxable-equivalent net interest income$137
 $71
 $208
 $169
 $(9) $160
1 Taxable-equivalent rates used where applicable.
2 Net of unearned income and fees, net of related costs. Loans include nonaccrual and restructured loans.
In the analysis of changes in taxable-equivalent net interest changes dueincome attributed to volume and rate, changes due to the volume/rate variance are allocated to volume with the following exceptions: when volume and rate both increase, the variance is allocated proportionately to both volume and rate; when the rate increases and volume decreases, the variance is allocated to rate.
Schedule 7
ANALYSIS OF CHANGES IN TAXABLE-EQUIVALENT NET INTEREST INCOME
2023 over 20222022 over 2021
Changes due toTotal changesChanges due toTotal changes
(In millions)Volume
Rate1
Volume
Rate1
INTEREST-EARNING ASSETS
Money market investments:
Interest-bearing deposits$(8)$93 $85 $(8)$23 $15 
Federal funds sold and securities purchased under agreements to resell(25)47 22 44 45 
Total money market investments(33)140 107 (7)67 60 
Securities:
Held-to-maturity195 (2)193 34 (4)30 
Available-for-sale(244)114 (130)86 83 169 
Trading account(8)(7)(15)
Total securities(57)105 48 124 80 204 
Loans held for sale— — — — 
Loans and leases2
Commercial56 429 485 (59)68 
Commercial real estate36 328 364 123 126 
Consumer84 157 241 30 14 44 
Total loans and leases176 914 1,090 (26)205 179 
Total interest-earning assets86 1,160 1,246 91 352 443 
INTEREST-BEARING LIABILITIES
Interest-bearing deposits:
Saving and money market(6)595 589 39 40 
Time163 241 404 (2)— 
Total interest-bearing deposits157 836 993 (1)41 40 
Borrowed funds:
Federal funds purchased and security repurchase agreements72 59 131 — 37 37 
Other short-term borrowings171 24 195 34 12 46 
Long-term debt(6)11 (11)14 
Total borrowed funds237 94 331 23 63 86 
Total interest-bearing liabilities394 930 1,324 22 104 126 
Change in taxable-equivalent net interest income$(308)$230 $(78)$69 $248 $317 
1 Taxable-equivalent rates used where applicable.
2 Net of unearned income and fees, net of related costs. Loans include nonaccrual and modified loans.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Provision for Credit Losses
The allowance for credit losses (“ACL”) is the combination of both the allowance for loan and lease losses (“ALLL”) and the reserve for unfunded lending commitments (“RULC”). The ALLL represents the estimated current expected credit losses related to the loan and lease portfolio as of the balance sheet date. The RULC represents the estimated reserve for current expected credit losses associated with off-balance sheet commitments. Changes in the ALLL and RULC, net of charge-offs and recoveries, are recorded as the provision for loan and lease losses and the provision for unfunded lending commitments, respectively, on the consolidated statement of income. The ACL for debt securities is estimated separately from loans and is included in “Investment securities” on the consolidated balance sheet.
817818
The provision for credit losses, which is the combination of both the provision for loan and lease losses and the provision for unfunded lending commitments.commitments, was $132 million in 2023, compared with $122 million in 2022.
The ACL was $729 million at December 31, 2023, compared with $636 million at December 31, 2022. The increase in the ACL reflects incremental reserves associated with portfolio-specific risks including commercial real estate, as well as deterioration in economic forecasts. The ratio of ACL to total loans and leases was 1.26% at December 31, 2023, compared with 1.14% at December 31, 2022. The provision for loansecurities losses is the amount of expense that, in our judgment, is required to maintain the ALLL at an adequate level based on the inherent risks in the loan portfolio. The provision for unfunded lending commitments is used to maintain the reserve for unfunded lending commitments (“RULC”) at an adequate level based on the inherent risks associated with such commitments. In determining adequate levels of the ALLLwas less than $1 million during 2023 and RULC, we perform periodic evaluations of our various loan portfolios, the levels of actual charge-2022.

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1429
offs,The bar chart above illustrates the broad categories of change in the ACL from the prior year period. The second bar represents changes in economic forecasts and current economic conditions, which increased the ACL by $33 million from the prior year period.
The third bar represents changes in credit trends,quality factors and external factors. includes risk-grade migration, portfolio-specific risks, and specific reserves against loans, which, when combined, increased the ACL by $84 million, driven largely by an increased focus on certain portfolio-specific risks, including commercial real estate.
The fourth bar represents loan portfolio changes, driven primarily by changes in loan balances and composition, the aging of the portfolio, and other qualitative risk factors; all of which resulted in a $24 million decrease in the ACL.
See “Credit Risk Management” on page 54 and Note 6of the Notes to Consolidated Financial Statements and “Credit Risk Management” on page 56 for more information on how we determine the appropriate level forof the ALLL and the RULC.
The provision for loan losses was $24 million in 2017, compared with $93 million in 2016. Credit quality was strong throughout 2017, with significant improvement in the oil and gas-related portfolio. Classified and nonaccrual loans in the total portfolio declined by $444 million and $127 million, respectively. Net charge-offs totaled $73 million in 2017, compared with $132 million in the prior year. These improvements in both credit quality and net charge-offs resulted in the lower provision. The Company has roughly $8 billion of loan balances in the geographic area impacted by Hurricane Harvey. During the third quarter of 2017, we added a qualitative allowance of $34 million based on multiple top-down and bottom-up analyses to estimate potential losses. During the fourth quarter, subsequent analysis indicated our losses may not be as large as we first believed and we released roughly one-third of the associated allowance.
The provision for unfunded lending commitments was $(7) million in 2017, compared with $(10) million in 2016. The negative provision in 2016 was primarily due to improved credit quality assessments related to these obligations for credits outside the oil and gas-related portfolio along with declining oil and gas-related exposure. In 2017, improved credit quality, especially in the oil and gas-related portfolio, resulted in a further release of the RULC. From quarter to quarter, the provision for unfunded lending commitments may be subject to sizable fluctuations due to changes in the timing and volume of loan commitments, originations, fundings, and changes in credit quality.
The allowance for credit losses (“ACL”), which is the combination of both the ALLL and the RULC, decreased by $56 million during 2017. Even with loan growth and the above-mentioned hurricane impact, strong credit quality and decreased net charge-offs in the total loan portfolio were responsible for much of this reduction. Further, declining oil and gas-related exposure and increasing non-oil and gas-related commercial and industrial and 1-4 family residential mortgage exposure improved the risk profile of the portfolio.
Noninterest Income
Noninterest income represents revenuesrevenue we earn forfrom products and services that generally have no associated interest rate or yield. For 2017,yield and is classified as either customer-related or noncustomer-related. Customer-related noninterest income was $544 million compared with $516 million in 2016 and $357 million in 2015. We believe a subtotal of customer-related fees provides a better view of income over which we have more direct control. It excludes items such as securities gains and losses, dividends, insurance-related income, and mark-to-market adjustments on certain derivatives,derivatives.
Total noninterest income increased $45 million, or 7%, in 2023, relative to the prior year. Noninterest income accounted for 22% and securities gains20% of net revenue during 2023 and losses.
Schedule 72022, respectively. The following schedule presents a comparison of the major components of noninterest income for the past three years.income:
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Schedule 78
NONINTEREST INCOME
(Dollar amounts in millions)2023Amount changePercent change2022Amount changePercent change2021
Commercial account fees$174 $15 %$159 $22 16 %$137 
Card fees101 (3)(3)104 95 
Retail and business banking fees66 (7)(10)73 (1)(1)74 
Loan-related fees and income79 (1)(1)80 (15)(16)95 
Capital markets fees81 (2)(2)83 13 19 70 
Wealth management fees58 55 10 50 
Other customer-related fees61 60 11 54 
Customer-related noninterest income620 %614 39 %575 
Fair value and nonhedge derivative income (loss)(4)(20)NM16 14 14 
Dividends and other income57 40 NM17 (26)(60)43 
Securities gains (losses), net19 NM(15)(86)NM71 
Noncustomer-related noninterest income57 39 NM18 (110)(86)128 
Total noninterest income$677 $45 %$632 $(71)(10)%$703 
(Dollar amounts in millions)2017 Percent change 2016 Percent change 2015
          
Service charges and fees on deposit accounts$171
  % $171
 2 % $168
Other service charges, commissions and fees217
 4
 208
 11
 187
Wealth management and trust income42
 14
 37
 19
 31
Loan sales and servicing income25
 (29) 35
 13
 31
Capital markets and foreign exchange30
 36
 22
 (15) 26
Customer-related fees485
 3
 473
 7
 443
Dividends and other investment income40
 67
 24
 (20) 30
Securities gains (losses), net14
 100
 7
 106
 (127)
Other5
 (58) 12
 9
 11
Total noninterest income$544
 5
 $516
 45
 $357
Customer-related Noninterest Income

Consistent with our key corporate objectives, we continue to deepen existing relationships with our commercial, small business, capital markets, affluent, and retail customers by providing high-quality treasury management products, capital market solutions, wealth management advisory services, and depository account services.

Other service charges, commissions and fees, which are comprised of ATM fees, insurance commissions, bankcard merchant fees, debit and credit card interchange fees, cash management fees, and other miscellaneous fees, increased by $9 million compared with 2016. The increase relates mainly to higher credit card interchange fees and exchange and other fees. In 2016, other service charges, commissions and fees increased by $21 million compared with 2015. The increase was primarily a result of the same items mentioned previously, as well as fees generated on sales of interest rate swaps to clients.
During the first quarter of 2016, we reclassified bankcard rewards expense fromTotal customer-related noninterest expense into noninterest income in order to offset the associated revenue from interchange fees to align with industry practice. This reclassification within other service charges, commission and fees lowered noninterest income in the first quarter of 2016 and also decreased other noninterest expense by the same amount. For comparative purposes, we also reclassified prior period amounts. This reclassification had no impact on net income.
Wealth management and trust income increased by $5 million. The change was due to trust income, with improvement in both corporate and personal trust revenue due to platform and product simplifications. Wealth management and trust income increased $6 million, between 2016or 1%, in 2023, relative to the prior year. Key drivers impacting customer-related revenue included:
Commercial account fees increased $15 million or 9%, driven by increases in treasury management sweep income, account analysis fees, and 2015 forbankcard merchant fees.
Wealth management fee income increased $3 million, or 5%, reflecting growth in assets and increased wealth and advisory services. Our assets under management were $13.3 billion at December 31, 2023.
Retail and business banking fees decreased $7 million, or 10%, primarily due to changes in our overdraft and non-sufficient funds practices, which were effected in the same reasons.third quarter of 2022.
Card fees decreased $3 million, or 3%, due to declines in commercial and business bankcard interchange fees.
Capital markets fees decreased $2 million, or 2%, primarily due to reduced customer swap and loan syndication fees.
Noncustomer-related Noninterest Income
Total noncustomer-related noninterest income increased $39 million in 2023. Dividends and other investment income increased $16$40 million, primarily due to $14 million of gains across many of our cost and equity method investments. After consolidating seven banking charters into one in December 2015, ourhigher dividends on FHLB stock ownership with the FHLB system has decreased significantly and dividends thereon have also fallen. Due toresulting from increased use of FHLB borrowing during 2017, the Company has purchasedaverage FHLB activity stock as needed; however, the dividends received have not equaled the level seen prior to 2016. The consolidation also causedand an increase in the Company’s ownershipassociated dividend rate, when compared with the prior year, as well as a gain on sale of Federal Reserve stock. Dividends on FRB stock were relatively flat between 2017a bank-owned property in the second quarter of 2023. Net securities gains increased $19 million, due largely to higher losses recorded during the prior year in our Small Business Investment Company (“SBIC”) investment portfolio. Fair value and 2016.
Loan sales and servicingnonhedge derivative income decreased $10$20 million, in 2017, compared with 2016. During 2017, we ceased selling servicing-released mortgage loansprimarily due to Freddie Mac, and therefore no longer received the associated servicing premiums for doing so, which decreased income by $11 million. In general, servicing income increased slightly in 2017. We also had particularly large valuationlarger gains during 2016the prior year related to credit valuation adjustments (“CVA”) on agricultural loan servicing assets accounted for at fair value, which did not repeat to the same extent in the current year. Loan sales and servicing income increased $4 million in 2016, compared with 2015, due mainly to these valuation gains on servicing assets.client-related interest rate swaps.
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Noninterest Expense
Noninterest expense increased by $64 million or 4% to $1,649 million in 2017, compared with $1,585 million in 2016 and $1,581 million in 2015. Excluding the effect of a charitable foundation contribution of $12 million related to the Tax Cuts and Jobs Act, noninterest expense increased in line with communicated forecasts. The Company remains focused on expense control efforts, while we continue to invest in our technology initiatives. Employee expenses were up, partially due to a combination of higher incentive compensation in 2017 as a result of improved Company performance and increased costs in the Company’s benefit plans. Expenses increased only $4 million between 2016 and 2015, with few major fluctuations in any category.
Schedule 8following schedule presents a comparison of the major components of noninterest expense for the past three years.expense:

Schedule 89
NONINTEREST EXPENSE
(Dollar amounts in millions)2023Amount changePercent change2022Amount changePercent change2021
Salaries and employee benefits$1,275 $40 %$1,235 $108 10 %$1,127 
Technology, telecom, and information processing240 31 15 209 10 199 
Occupancy and equipment, net160 152 (1)(1)153 
Professional and legal services62 57 (15)(21)72 
Marketing and business development46 18 39 (4)(9)43 
Deposit insurance and regulatory expense169 119 NM50 16 47 34 
Credit-related expense26 (4)(13)30 15 26 
Other real estate expense, net— (1)NMNM— 
Other119 14 13 105 18 21 87 
Total noninterest expense$2,097 $219 12 %$1,878 $137 %$1,741 
Adjusted noninterest expense (non-GAAP)$1,986 $110 %$1,876 $139 %$1,737 
(Dollar amounts in millions)2017 Percent change 2016 Percent change 2015
          
Salaries and employee benefits$1,011
 3 % $983
 1 % $973
Occupancy, net129
 3
 125
 4
 120
Furniture, equipment and software130
 4
 125
 2
 123
Other real estate expense(1) (50) (2) 100
 (1)
Credit-related expense29
 12
 26
 (10) 29
Provision for unfunded lending commitments(7) (30) (10) 67
 (6)
Professional and legal services54
 (2) 55
 10
 50
Advertising22
 
 22
 (12) 25
FDIC premiums53
 33
 40
 18
 34
Amortization of core deposit and other intangibles6
 (25) 8
 (11) 9
Other223
 5
 213
 (5) 225
Total noninterest expense$1,649
 4
 $1,585
 
 $1,581
Noninterest expense increased $219 million, or 12%, in 2023, relative to the prior year, primarily due to a $119 million increase in deposit insurance and regulatory expense, driven largely by a $90 million accrual associated with the FDIC special assessment during the fourth quarter of 2023, as well as an increased FDIC insurance base rate beginning in 2023.
In November 2023, the FDIC issued a final rule to implement a special assessment pursuant to a systemic risk determination to recover the costs associated with protecting uninsured depositors following the closures of Silicon Valley Bank and Signature Bank in early 2023. Using an assessment base equal to the estimated amount of uninsured deposits above $5 billion at December 31, 2022, the FDIC is expected to collect a tax-deductible special assessment from banks at an annual rate of approximately 13.4 bps for an anticipated eight quarterly assessment periods, beginning with the first quarter of 2024.
Salaries and employee benefits increased by $28 million, or 3%, in 2017, compared with 2016, as illustrated in Schedule 9. Baseexpense represented approximately 61% and 66% of total noninterest expense during 2023 and 2022, respectively. The following schedule presents the major components of salaries were up in 2017, as employee salary expense rose roughly in line with inflation. Employee bonuses were up, partially due to lower incentive compensation for management in 2016 and larger commission expense in the current year. Benefits expense increased $9 million, or 6%, in 2017, primarily due to higher costs in the Company’s self-funded medical plans and an increase in profit sharing expense. Salaries and employee benefits increased by $10 million, or 1%, in 2016, compared with 2015 due to several reasons. Our investment in major systems projects led to headcount increases in more highly compensated roles, we had higher costs in our medical plans and also higher-than-expected retirement expense due to several large lump-sum payouts during the year.expense:
Schedule 910
SALARIES AND EMPLOYEE BENEFITS
(Dollar amounts in millions)2023Amount/quantity changePercent change2022Amount/quantity changePercent change2021
Salaries and bonuses$1,057 $29 %$1,028 $93 10 %$935 
Employee benefits:
Employee health and insurance100 93 10 12 83 
Retirement and profit sharing51 (1)(2)52 (5)(9)57 
Payroll taxes and other fringe benefits67 62 10 19 52 
Total employee benefits218 11 207 15 192 
Total salaries and employee benefits$1,275 $40 %$1,235 $108 10 %$1,127 
Full-time equivalent employees at December 31,9,679 (310)(3)%9,989 304 %9,685 
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(Dollar amounts in millions)2017 Percent change 2016 Percent change 2015
          
Salaries and bonuses$851
 2 % $832
  % $829
Employee benefits:         
Employee health and insurance69
 11
 62
 7
 58
Retirement41
 14
 36
 9
 33
Payroll taxes and other50
 (6) 53
 
 53
Total benefits160
 6
 151
 5
 144
Total salaries and employee benefits$1,011
 3
 $983
 1
 $973
Full-time equivalent employees at December 3110,083
 
 10,057
 (1) 10,200
OccupancyTotal salaries and benefits expense was up $4 million in 2017. We placed a newly constructed office building into operation during the first quarter and depreciation expense was consequently higher than in 2016. Rental income was higher in the current year because we are leasing space to tenants, but other costs surrounding the building implementation offset this benefit. Expense increased $5$40 million, or 4%3%, primarily due to the ongoing impact of inflationary and competitive labor market pressures on wages and benefits, a decline in 2016deferred salaries related to fewer loan originations and reduced software development activities, and an increase in severance expense. These increases were partially offset by a decrease in incentive compensation accruals. We had 9,679 full-time equivalent employees at December 31, 2023, a decrease of approximately 3% relative to the prior year.
Technology, telecom, and information processing expense increased $31 million, or 15%, primarily due to increases in software amortization expenses associated with the replacement of our core loan and deposit banking system, as well as other related application software, license, and maintenance expenses, reflecting our ongoing investments in strategic technology initiatives designed to improve our products and services and to simplify how we do business. For further discussion on the replacement of our core loan and deposit banking system, see “Premises, Equipment, and Software” on page 52.
The efficiency ratio was 62.9%, compared with 2015. The increase was58.8%, primarily due to a decline in adjusted taxable-equivalent revenue. For information on non-GAAP financial measures, see page 77.
Technology Spend
Consistent with our strategic objectives, we invest in technologies that will make us more efficient and enable us to remain competitive. We generally consider these investments as technology spend, which represents expenditures associated with technology-related investments, operations, systems, and infrastructure, and includes current period expenses presented on the consolidated statement of income, as well as capitalized investments, net of related amortization and depreciation, presented on the consolidated balance sheet. Technology spend is reported as a combination of small items including higher rentthe following:
Technology, telecom, and information processing expense lease depreciation, — includes expenses related to application software licensing and building security.maintenance, related amortization, telecommunications, and data processing;
During 2017, we successfully implemented the first release of the TCS BαNCS® core servicing system. FurnitureOther technology-related expense — includes related noncapitalized salaries and employee benefits, occupancy and equipment, and professional and legal services; and
Technology investments — includes capitalized technology infrastructure equipment, hardware, and purchased or internally developed software, less related amortization or depreciation.
The following schedule presents the composition of our technology spend:
Schedule 11
TECHNOLOGY SPEND
December 31Amount
change
Percent
change
(In millions)20232022
Technology, telecom, and information processing expense$240 $209 $31 15 %
Other technology-related expense232 206 26 13 
Technology investments82 90 (8)(9)
Less: related amortization and depreciation(71)(54)(17)31 
Total technology spend$483 $451 $32 %
Total technology spend increased $32 million, or 7%, relative to the prior year, driven largely by the aforementioned increases in technology, telecom, and information processing expense, increased $5 millionas well as higher technology-related compensation and investments in 2017 mainly due to amortization of capitalized software. Expense was relatively flat between 2016 and 2015.resiliency.

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
FDIC premiums were $53 million, $40 million, and $34 million, in 2017, 2016, and 2015, respectively. Increases were due to higher deposit bases in each of the years and the FDIC’s increase in deposit insurance assessments that occurred in the third quarter of 2016. These increases were somewhat offset by a reduction in the Company’s overall rate resulting from the consolidation of the individual bank charters and the Bank’s lower risk profile.
Other noninterest expense was $223 million in 2017, compared with $213 million in 2016 and $225 million in 2015. The increase in 2017 was mainly due to the one-time charitable contribution made at the end of the year. The main driver for lower expense in 2016, compared with 2015, was lower levels of legal related expense.
In 2016, we held adjusted noninterest expense below $1.58 billion, and expected an increase of between 2% and 3% in 2017. Excluding the impact of the previously discussed one-time charitable contribution of $12 million, the actual increase in adjusted noninterest expense was 3%, which was in line with our forecast. The expense items we exclude from noninterest expense to arrive at adjusted noninterest expense are the same as those excluded in arriving at the efficiency ratio (see “GAAP to Non-GAAP Reconciliations” on page 29 for more information regarding the calculation of the efficiency ratio).
Income Taxes
IncomeThe following schedule summarizes the income tax expense was $344 million in 2017, $236 million in 2016, and $142 million in 2015. Our effective income tax rates includingfor the effects of noncontrolling interests, were 36.8% in 2017, 33.5% in 2016, and 31.5% in 2015. periods presented:
Schedule 12
INCOME TAXES
(Dollar amounts in millions)202320222021
Income before income taxes$886 $1,152 $1,446 
Income tax expense206 245 317 
Effective tax rate23.3 %21.3 %21.9 %
The effective tax expense rates for all tax yearsthe periods presented above were reduceddecreased by nontaxable municipal interest income and nontaxable income from certain bank-owned life insurance.insurance (“BOLI”), and were increased by the nondeductibility of certain FDIC premiums, certain executive compensation, and other fringe benefits. The increase in the effective tax rate in 2017for 2023 was further impacted by the following items:
Reevaluation of state tax positions that resulted in a one-time $18 million benefit.
Excess tax benefit of $9 million from the implementation of new accounting guidanceprimarily due to higher FDIC premium expense (regular FDIC insurance premiums are non-deductible) and interest expense related to share-based compensation.
Estimated net DTA write-off of $47 million through income tax expense associated with the decrease in the federal income tax rate from the passage of new legislation.
Further, the tax rate in 2015 decreased significantly as a result of the Company’stax-exempt income. Additionally, investments in alternative energy and technology initiatives. The Company continued to invest in technology initiatives, low-income housing, and increased investment in municipal securities during 20162023, 2022, and 2017, generating2021, generated tax credits and nontaxable income that benefited the effective tax rate for each respective year.
On December 22, 2017, H.R. 1, known as the Tax Cuts and Jobs Act (“the Act”), was signed into law. The Act makes significant changes to the U.S. Internal Revenue Code of 1986, including a decrease in the current corporate federal income tax rate to 21% from 35%, effective January 1, 2018. As stated above, the estimated provisional impact of the Act on the net DTA resulted in a non-cash charge of $47 million through income tax expense. The Company anticipates that additional adjustments to net DTA and income tax expense may be made in 2018 as deferred tax estimates are finalized for inclusion in the 2017 federal and state tax returns to be filed, consistent with the measurement period afforded by SEC Staff Accounting Bulletin No. 118 (“SAB 118”).
We had a net DTA balance of $93 million$1.0 billion and $1.1 billion at December 31, 2017, compared with $250 million at December 31, 2016.2023 and 2022, respectively. The decrease in the net DTA resulted primarily from the reduction in the federal income tax rate from the Act, accelerated tax deductions on certain technology initiatives and depreciable property, the payment of deferred compensation, andwas driven largely by a decrease in unrealized losses in AOCI associated with investment securities and derivative instruments and a reduction of certain capitalized expenses for tax purposes. These decreases were partially offset by an increase in the allowanceprovision for loan losses. A decrease in deferred tax liabilitiescredit losses during 2017, which related primarily to the deferred gain on a prior period debt exchange, offset some of the overall net decrease.2023.
We did not record any additionalhad no valuation allowance for GAAP purposes as ofat December 31, 2017.2023 and December 31, 2022. See Note 1820 of the Notes to Consolidated Financial Statements for more information about the factors that impacted our effective tax rate, significant components of our DTAs and “Critical Accounting PoliciesDTLs, and Significant Estimates” on page 80unrecognized tax benefits for additional information.


uncertain tax positions.
Preferred Stock Dividends and Redemption
In 2017 we incurred preferredPreferred stock dividends of $40 million, a decrease of $8 million from 2016. In 2016 we incurred preferred stock dividends of $48 million, a decrease of $14 million from 2015. We completed a tender offer in the fourth quarter of 2015 to purchase $176 million of our Series I preferred stock. We also completed tender offers of $144 million of Series F, and $118 million of Series I, J, and G in the second quarters of 2017, and 2016, respectively. Preferred dividends are expected to be $8totaled $32 million in the first2023, and third quarters of 2018, and $10$29 million in the secondboth 2022 and fourth quarters of 2018.2021. See further details in Note 1314 of the Notes to Consolidated Financial Statements.
BUSINESS SEGMENT RESULTSBusiness Segment Results
Following the close of business on December 31, 2015, we completed the merger of our subsidiary banks with Zions First National Bank. Subsequently, Zions First National Bank changed its legal name to ZB, National Association. We continue to manage our banking operations underthrough seven affiliate banks located in different geographic markets, each with its own local branding and management team. These affiliate banks comprise our existing brand names andprimary business segments includingand include: Zions Bank, Amegy Bank, California Bank & Trust (“CB&T”), Amegy Bank (“Amegy”), National Bank of Arizona (“NBAZ”), Nevada State Bank (“NSB”), Vectra Bank Colorado (“Vectra”), and The Commerce Bank of Washington. Performance assessmentWashington (“TCBW”). We emphasize local authority, responsibility, pricing, and resource allocationcustomization of certain products that are based upon this geographical structure.designed to maximize customer satisfaction, strengthen community relations, and improve profitability and shareholder returns. Our affiliate banks are supported by an enterprise operating segment (referred to as the “Other” segment) that provides governance and risk management, allocates capital, establishes strategic objectives, and includes centralized technology, back-office functions, and certain lines of business not operated through our affiliate banks.
As discussed in the “Executive Summary” on page 33, most of the lending and other decisions affecting customers are made at the local level. The accounting policies of the individual segments are the same as those of the Company. We allocate the cost of centrally provided services to the business segments based upon estimated or actual usage of those services. Due toWe also allocate capital based on the charter consolidation, we have moved torisk-weighted assets held at each business segment. We use an internal Funds Transfer Pricingfunds transfer pricing (“FTP”) allocation systemprocess to report results of operations for business segments. This process continuesis subject to be refined.
The operating segment identified as “Other” includes the Parent, certain nonbank financial service subsidiaries, centralized back-office functions,change and eliminations of transactions between segments. The Parent’s operations are significantrefinement over time. For more performance information related to our business segments, including the Other segment. See Note 20 of the Notes to Consolidated Financial Statements contains for more information on the Other segment. The Company’s net interest income is substantially affected by the Parent’s interest expense on long-term debt. The Parent’s financial statements insegment, see Note 22 of the Notes to Consolidated Financial Statements provide moreStatements.
The following schedule summarizes selected financial information about the Parent’s activities. We have announcedof our intention to merge the parent company into ZB, N.A. The merger is not expected to have an impact to the results of the Other operating segment.
During 2017, our banking operations experienced improved financial performance. Common areas of financial performance experienced at various levels of the segments include:
increased loan balances across almost all geographies;
improvementsbusiness segments. Ratios are calculated based on amounts in credit quality resulted in reductions of the ALLL; and
growth in customer deposit balances across almost all segments.thousands.

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Schedule 1013
SELECTED SEGMENT INFORMATION
(Dollar amounts in millions)Zions BankCB&TAmegy
202320222021202320222021202320222021
KEY FINANCIAL INFORMATION
Total average loans$14,298$13,277$13,198$14,128$13,129$12,892$12,851$12,110$12,189
Total average deposits20,23324,31723,58814,25316,16015,79613,56915,73515,496
Income before income taxes311387380282314405218311362
CREDIT QUALITY
Provision for credit losses$20$43$(26)$44$49$(78)$15$5$(96)
Net loan and lease charge-offs (recoveries)1929103532
Ratio of net charge-offs to average loans and leases0.13 %0.22 %— %0.07 %0.02 %— %0.04 %0.02 %0.02 %
Allowance for credit losses$157$155$142$162$122$90$139$122$128
Ratio of allowance for credit losses to net loans and leases, at year-end1.10 %1.17 %1.08 %1.15 %0.93 %0.70 %1.08 %1.01 %1.05 %
Nonperforming assets$26$36$84$82$25$41$35$59$90
Ratio of nonperforming assets to net loans and leases and other real estate owned0.18 %0.26 %0.65 %0.58 %0.18 %0.32 %0.27 %0.46 %0.77 %
(Dollar amounts in millions)Zions Bank Amegy CB&T
201720162015 201720162015 201720162015
KEY FINANCIAL INFORMATION          
Total average loans$12,481
$12,538
$12,118
 $11,021
$10,595
$10,148
 $9,539
$9,211
$8,556
Total average deposits15,986
15,991
15,688
 11,096
11,130
11,495
 11,030
10,827
10,063
Income before income taxes346
371
275
 240
94
44
 257
220
150
CREDIT QUALITY           
Provision for loan losses$19
$(22)$(28) $25
$163
$91
 $(5)$(9)$(4)
Net loan and lease charge-offs34
13
10
 41
123
22
 1
(1)10
Ratio of net charge-offs to average loans and leases0.27%0.11%0.09% 0.37%1.16%0.22% 0.01%(0.01)%0.12%
Allowance for loan losses$130
$145
$180
 $247
$263
$223
 $69
$74
$81
Ratio of allowance for loan losses to net loans and leases, at year-end1.04%1.15%1.47% 2.17%2.49%2.20% 0.69%0.79 %0.92%
Nonperforming lending-related assets$85
$105
$109
 $236
$360
$116
 $47
$42
$42
Ratio of nonperforming lending-related assets to net loans and leases and other real estate owned0.68%0.83%0.89% 2.07%3.39%1.14% 0.47%0.45 %0.48%
Accruing loans past due 90 days or more$11
$10
$4
 $1
$7
$3
 $9
$19
$24
Ratio of accruing loans past due 90 days or more to net loans and leases0.09%0.08%0.04% 0.01%0.06%0.02% 0.09%0.20 %0.27%
(Dollar amounts in millions)NBAZNSBVectraTCBW
202320222021202320222021202320222021202320222021
KEY FINANCIAL INFORMATION
Total average loans$5,318$4,911$4,849$3,392$2,987$3,015$4,004$3,632$3,414$1,705$1,630$1,569
Total average deposits7,0088,0357,2886,9647,4366,6913,4824,1094,3861,1961,5711,537
Income before income taxes107111126237689345567384541
CREDIT QUALITY
Provision for credit losses$4$11$(27)$42$4$(35)$7$9$(12)$2$1$(3)
Net loan and lease charge-offs (recoveries)1(1)(1)3(2)1291
Ratio of net charge-offs to average loans and leases0.02 %(0.02)%(0.02)%0.09 %(0.07)%0.03 %0.05 %0.25 %— %— %— %0.06 %
Allowance for credit losses$54$40$38$66$27$26$45$36$37$11$9$8
Ratio of allowance for credit losses to net loans and leases, at year-end1.02%0.81%0.79%1.95%0.90%0.86%1.12%0.99%1.08%0.65%0.55%0.51%
Nonperforming assets$12$6$11$46$9$24$16$14$18$8$$1
Ratio of nonperforming assets to net loans and leases and other real estate owned0.21%0.12%0.24%1.34%0.27%0.85%0.40%0.36%0.53%0.46%—%0.06%
(Dollar amounts in millions)NBAZ NSB Vectra TCBW
201720162015 201720162015 201720162015 201720162015
KEY FINANCIAL INFORMATION            
Total average loans$4,267
$4,086
$3,811
 $2,357
$2,284
$2,344
 $2,644
$2,469
$2,400
 $926
$791
$707
Total average deposits4,762
4,576
4,311
 4,254
4,137
3,891
 2,756
2,720
2,792
 1,107
1,007
879
Income before income taxes106
89
47
 46
52
27
 49
54
19
 29
24
18
CREDIT QUALITY               
Provision for loan losses$(8)$(3)$8
 $(11)$(28)$(28) $1
$(8)$5
 $2
$
$(3)
Net loan and lease charge-offs(2)
10
 (3)(5)(17) 2

4
 


Ratio of net charge-offs to average loans and leases(0.04)%%0.26% (0.13)%(0.21)%(0.74)% 0.09%0.01%0.16% 0.02%0.02%(0.05)%
Allowance for loan losses$28
$35
$38
 $11
$19
$43
 $24
$25
$33
 $9
$7
$8
Ratio of allowance for loan losses to net loans and leases, at year-end0.63 %0.81%0.97% 0.48 %0.81 %1.87 % 0.87%0.99%1.34% 0.83%0.83%1.08 %
Nonperforming lending-related assets$17
$31
$47
 $17
$20
$19
 $10
$15
$23
 $6
$
$1
Ratio of nonperforming lending-related assets to net loans and leases and other real estate owned0.39 %0.73%1.20% 0.73 %0.84 %0.84 % 0.35%0.59%0.92% 0.56%0.02%0.18 %
Accruing loans past due 90 days or more$1
$
$
 $
$
$
 $
$
$1
 $
$
$
Ratio of accruing loans past due 90 days or more to net loans and leases0.02 %%%  % % % %0.01%0.04% %% %


All references below to domestic deposits by state are based on FDIC deposit market share data for full-service institutions with at least three branches at June 30, 2023.
Zions Bank
Zions Bank is headquartered in Salt Lake City, Utah, and is primarily responsible for conductingconducts operations in Utah, Idaho, and Wyoming. If it were a separately chartered bank, it would beAs measured by domestic deposits in these states, Zions Bank was the 2nd largest full-service commercial bank in Utah and the 4thfifth largest in Idaho, as measured by domestic deposits in these states.Idaho.
Within Zions Bank, the NRE group is a wholesale business that generally sources loans from other community banks across the country. Such loans are generally low loan-to-value owner-occupied loans, but also include non-owner-occupied CRE term loans.
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Zions Bank’s income before income taxes decreased by $25$76 million, or 7%20%, during 2017 primarily as2023. The decrease was due to a result of an$45 million decrease in net interest income and a $62 million increase in noninterest expense, partially offset by a $23 million decrease in the provision for loan losses.credit losses and an $8 million increase in noninterest income. The loan portfolio decreased by $92increased $852 million during 2017, which consisted2023, including increases of $557 million and $424 million in consumer and commercial loans, respectively, and a decrease of $284 million in commercial loans and increases of $111 million and $81$129 million in CRE and consumer loans, respectively. Within commercial lending, commercial owner-occupied loans decreased by $128 million, which was mainly the result of a reduction in the NRE loan portfolio.loans. The ratio of allowance for loan lossesACL to net loans and leases decreased to 1.04%1.10% at December 31, 20172023, compared with 1.17%. Nonperforming assets decreased $10 million, or 28%, from the prior year. Total deposits decreased 3% in 2023.
California Bank & Trust
California Bank & Trust is headquartered in San Diego, California. As measured by domestic deposits in the state, CB&T was the 17th largest full-service commercial bank in California.
CB&T’s income before income taxes decreased $32 million, or 10%, during 2023. The decrease was due to a $48 million increase in noninterest expense, partially offset by an $8 million increase in noninterest income, a $5 million decrease in the provision for credit losses, and a $3 million increase in net interest income. The loan portfolio increased $291 million during 2023, including increases of $243 million and $164 million in consumer and CRE loans, respectively, and a decrease of $116 million in commercial loans. The ratio of ACL to net loans and leases increased to 1.15% at December 31, 2016.2023, compared with 0.93%. Nonperforming lending-related assets declined 19%increased $57 million from the prior year, due primarily to decreasesdriven largely by two suburban office commercial real estate loans totaling $46 million. Total deposits increased 2% in nonaccrual loans in the commercial and industrial portfolio. Deposits decreased 4% from 2016 to 2017.2023.
Amegy Bank
Amegy Bank is headquartered in Houston, Texas. If it were a separately chartered bank, it would be the 8th largest full-service commercial bank in Texas asAs measured by domestic deposits in the state.state, Amegy was the 9th largest full-service commercial bank in Texas.
Amegy’s income before income taxes increased by $146decreased $93 million, or 155%30%, during 2017.2023. The increase in income before income taxes is mainlydecrease was due to a $138$60 million decrease in net interest income, a $49 million increase in noninterest expense, and a $10 million increase in the provision for loan losses. Amegy has been able to achievecredit losses, partially offset by a $26 million increase in noninterest income. The loan portfolio growth, resulting in an $835increased $237 million increase from the prior year. During 2017, CRE loans decreased by $64during 2023, including increases of $171 million and commercial$156 million in CRE and consumer loans, increased by $395respectively, and a decrease of $90 million and $504 million, respectively.in commercial loans. The credit quality of Amegy’s loan portfolio improved during 2017, mainly due to improvements in the oil and gas-related portfolio; the ratio of the ALLLACL to net loans and leases decreasedincreased to 2.17%1.08% at December 31, 2017 from 2.49% a year earlier. During 2017, nonperforming lending-related2023, compared with 1.01%. Nonperforming assets decreased $124$24 million, or 34%. Deposits decreased by 8% from 2016 to 2017.
California Bank & Trust
California Bank & Trust is headquartered in San Diego, California. If it were a separately chartered bank, it would be the 15th largest full-service commercial bank in California as measured by domestic deposits. Its core business is built on relationship banking by providing commercial, real estate and consumer lending, depository services, international banking, cash management, and community development services.
CB&T’s income before income taxes increased by $37 million, or 17%41%, during 2017 primarily from an increase in net interest income due to loan growth. CB&Ts loan portfolio increased by $581 million in 2017 from the prior year. During 2017, CRE loans decreased by $212 million and commercial and consumer loansTotal deposits increased by $710 million, and $83 million, respectively. The credit quality of CB&T’s loan portfolio continues to be strong, and the ratio of ALLL to net loans and leases declined to 0.69% at December 31, 2017 from 0.79% a year earlier. Deposits increased by 3% from 2016 to 2017.9% in 2023.
National Bank of Arizona
National Bank of Arizona is headquartered in Phoenix, Arizona. If it were a separately chartered bank, it would be the 5th largest full-service commercial bank in Arizona asAs measured by domestic deposits in the state.state, NBAZ was the fifth largest full-service commercial bank in Arizona.
NBAZ’s income before income taxes increased by $17decreased $4 million, or 19%4%, during 20172023. The decrease was due to a $5$22 million improvementincrease in noninterest expense and an $8 million decrease in noninterest income, partially offset by a $19 million increase in net interest income and a $7 million decrease in the provision for loan losses, in addition to increased net interest income from loan growth and improved fee revenue.credit losses. The loan portfolio increased $509 million during 2017 by $1442023, including increases of $259 million, driven by a $206$177 million, increase in commercial loans and a $51 million increase in consumer loans, partially offset by a decrease of $113$73 million in CRE, loans.consumer, and commercial loans, respectively. The credit quality of NBAZ’s loan portfolio continues to improve, and the ratio of ALLLACL to net loans


and leases declinedincreased to 0.63%1.02% at December 31, 20172023, compared with 0.81%. Nonperforming assets increased $6 million from 0.81% a year earlier. Deposits increased by 2% from 2016 to 2017.the prior year. Total deposits decreased 6% in 2023.
Nevada State Bank
Nevada State Bank is headquartered in Las Vegas, Nevada. If it were a separately chartered bank, it would be the 4th largest full-service commercial bank in Nevada asAs measured by domestic deposits in the state.state, NSB focuses on serving small and mid-sized businesses as well as retail consumers, with an emphasis on relationship banking.was the fifth largest full-service commercial bank in Nevada.
In 2017, NSB’s income before income taxes decreased by $6$53 million, or 12%70%, primarily asduring 2023. The decrease was due to a result of the change$38 million increase in the provision for credit losses, a $20 million increase in noninterest expense, and a $3 million decrease in noninterest income, partially offset by an $8 million increase in net interest income. The loan losses. NSB’s loans
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portfolio increased by $12$158 million during 2017,2023, including an increaseincreases of $70$104 million and $56 million in consumer and CRE loans, respectively, and a decrease of $2 million in commercial loans, and $23 million in consumer loans, partially offset by a decrease of $81 million in CRE.loans. The credit quality of NSB’s loan portfolio remained strong, and the ratio of the ALLLACL to net loans and leases was 0.48% and 0.81%increased to 1.95% at December 31, 2017 and 2016, respectively.2023, compared with 0.90%. Nonperforming lending-related assets decreased 15%increased $37 million from the prior year. Deposits decreased byTotal deposits increased 1% from 2016in 2023.
In July 2022, NSB purchased three Northern Nevada City National Bank branches and their associated deposit, credit card, and loan accounts. In addition to 2017.the three branches, the purchase included approximately $430 million in deposits and $95 million in commercial and consumer loans.
Vectra Bank Colorado
Vectra Bank Colorado is headquartered in Denver, Colorado. If it were a separately a chartered bank, it would be the 10th largest full-service commercial bank in Colorado asAs measured by domestic deposits in the state.state, Vectra was the 14th largest full-service commercial bank in Colorado.
In 2017, Vectra’s income before income taxes decreased by $5$21 million, or 9%. Small improvements38%, during 2023. The decrease was due to a $17 million increase in noninterest expense, a $3 million decrease in noninterest income, and a $3 million decrease in net interest income, and noninterest income were partially offset by an increasea $2 million decrease in the provision for credit losses. The loan losses. During 2017, totalportfolio increased $114 million during 2023, including increases of $160 million and $43 million in consumer and CRE loans, increased by $242 million, including $126respectively, and a decrease of $89 million in commercial loans, $68 million in consumer loans, and $48 million in CRE loans. The credit quality of Vectra’s loan portfolio was strong, and the ratio of ALLLACL to net loans and leases decreasedincreased to 0.87%1.12% at December 31, 20172023, compared with 0.99%. Nonperforming assets increased $2 million, or 14%, from 0.99% a year earlier. Depositsthe prior year. Total deposits decreased by 4% from 2016 to 2017.9% in 2023.
The Commerce Bank of Washington
The Commerce Bank of Washington is headquartered in Seattle, Washington. ItWashington, and operates in Washington under The Commerce Bank of Washington name and in Portland, Oregon, under The Commerce Bank of Oregon name. Its business strategy focuses on serving the financial needs of commercial businesses, including professional services firms.The FDIC deposit market share data at June 30, 2023 for TCBW has been successful in serving the greater Seattle/Puget SoundWashington and Portland regions without requiring extensive investments in a traditional branch network. It has been innovative in effectively utilizing couriers, bank by mail, remote deposit image capture, and other technologies.Oregon was not meaningful.
TCBW’s income before income taxes increased $5decreased $7 million, or 21%16%, during 2017.2023. The decrease was due to a $3 million increase in noninterest expense, a $3 million decrease in net interest income, and a $1 million increase in the provision for credit losses. The loan portfolio increased by $164decreased $14 million during 2023, including increasesa decrease of $42$83 million in commercial loans, $94partially offset by increases of $68 million and $1 million in CRE and consumer loans, and $28 million in consumer loans. Nonperforming lending-related assets increased $6 million, and therespectively. The ratio of ALLLACL to net loans and leases wasincreased to 0.65% at 0.83%December 31, 2023, compared with 0.55%. Nonperforming assets increased $8 million from the prior year. Total deposits decreased 23% in 2017 and 2016. Deposits decreased by 5% from 2016 to 2017.2023.
BALANCE SHEET ANALYSIS
Interest-EarningInterest-earning Assets
Interest-earning assets are those assets that have associated interest rates or yields, associated with them. Oneand generally consist of our goals isloans and leases, securities, and money market investments. We strive to maintain a high level of interest-earning assets relative to total assets while keeping nonearning assets at a minimum. Interest-earning assets consist of money market investments, securities, loans, and leases.
Schedule 5,which we referenced in our discussion of net interest income, includesassets. For more information regarding the average balances, associated revenue generated, and the respective yields of our interest-earning assets, the amount of revenue generated by them, and their respective yields. Another goal is to maintain a higher-yielding mix of interest-earning assets, such as loans, relative to lower-yielding assets, while maintaining adequate levels of highly liquid assets. As a result of this goal we redeployed funds from lower-yielding money market investments, in addition to using wholesale borrowings, to purchase agency securities.see Schedule 6 on page 35.

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Average interest-earning assets were $60.9 billion in 2017 compared with $56.2 billion in the previous year. Average interest-earning assets as a percentage of total average assets were 93.5% in both 2017 and 2016.
Average loans were $43.5 billion in 2017 and $42.1 billion in 2016. Average loans as a percentage of total average assets were 66.8% in 2017 compared with 70.0% in 2016.
Average money market investments, consisting of interest-bearing deposits and federal funds sold and security resell agreements, decreased by 58% to $1.5 billion in 2017 compared with $3.7 billion in 2016. Average securities increased by 53% from 2016. Average total deposits increased by 3%; average total loans also increased by 3% in 2017 when compared with 2016.
AVERAGE OUTSTANDINGNET LOANS, SECURITIES, AND DEPOSITSMONEY MARKET INVESTMENTS
(at December 31)
519
Investment Securities Portfolio
We invest in securities to actively manage liquidity and interest rate risk inand to generate interest income. We primarily own securities that can readily provide us cash and liquidity through secured borrowing agreements without the need to sell the securities. We also manage the duration of our investment securities portfolio to help balance the inherent interest rate mismatch between loans and deposits, and to protect the economic value of shareholders’ equity. At December 31, 2023, the estimated duration of our securities portfolio decreased to 3.6 percent, compared with 4.1 percent at December 31, 2022, primarily due to the addition to generating revenue forof fair value hedges of fixed-rate securities during the Company. Refersecond quarter of 2023.
For information about our borrowing capacity associated with the investment securities portfolio and how we manage our liquidity risk, refer to the “Liquidity Risk Management” section on page 72 for additional information on management of liquidity67. See also Note 3 and funding and compliance with Basel III and LCR requirements. The following schedule presents a profile of our investment securities portfolio. The amortized cost amounts represent the original cost of the investments, adjusted for related accumulated amortization or accretion of any yield adjustments, and for impairment losses, including credit-related impairment. The estimated fair value measurement levels and methodology are discussed in Note 35 of the Notes to Consolidated Financial Statements.Statements for more information on fair value measurements and the accounting for our investment securities portfolio.

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Schedule 1114
INVESTMENT SECURITIES PORTFOLIO
December 31, 2023December 31, 2022
(In millions)Par ValueAmortized
cost
Fair
value
Par ValueAmortized
cost
Fair
value
Held-to-maturity
U.S. Government agencies and corporations:
Agency securities$93 $93 $87 $100 $100 $93 
Agency guaranteed mortgage-backed securities 1
11,966 9,935 10,041 12,921 10,621 10,772 
Municipal securities354 354 338 404 405 374 
Total held-to-maturity12,413 10,382 10,466 13,425 11,126 11,239 
Available-for-sale
U.S. Treasury securities585 585 492 555 557 393 
U.S. Government agencies and corporations:
Agency securities669 663 630 790 782 736 
Agency guaranteed mortgage-backed securities8,460 8,530 7,291 9,566 9,652 8,367 
Small Business Administration loan-backed securities535 571 546 691 740 712 
Municipal securities1,269 1,385 1,318 1,571 1,732 1,634 
Other debt securities25 25 23 75 75 73 
Total available-for-sale11,543 11,759 10,300 13,248 13,538 11,915 
Total HTM and AFS investment securities$23,956 $22,141 $20,766 $26,673 $24,664 $23,154 
 December 31, 2017 December 31, 2016
(In millions)Par Value 
Amortized
cost
 
Estimated
fair
value
 Par Value 
Amortized
cost
 
Estimated
fair
value
Held-to-maturity           
Municipal securities$771
 $770
 $762
 $868
 $868
 $850
Available-for-sale           
U.S. Treasury securities25
 25
 25
 
 
 
U.S. Government agencies and corporations:           
Agency securities1,830
 1,830
 1,818
 1,847
 1,846
 1,839
Agency guaranteed mortgage-backed securities9,605
 9,798
 9,666
 7,745
 7,986
 7,883
Small Business Administration loan-backed securities2,007
 2,227
 2,222
 2,066
 2,298
 2,288
Municipal securities1,193
 1,336
 1,334
 1,048
 1,182
 1,154
Other25
 25
 24
 25
 25
 24
Total available-for-sale debt securities14,685
 15,241
 15,089
 12,731
 13,337
 13,188
Money market mutual funds and other72
 72
 72
 184
 184
 184
Total available-for-sale14,757
 15,313
 15,161
 12,915
 13,521
 13,372
Total investment securities$15,528
 $16,083
 $15,923
 $13,783
 $14,389
 $14,222
1 During the fourth quarter of 2022, we transferred approximately $10.7 billion fair value ($13.1 billion amortized cost) of mortgage-backed AFS securities to the HTM category. The transfer of these securities from AFS to HTM at fair value resulted in a discount to the amortized cost basis of the HTM securities equivalent to the $2.4 billion ($1.8 billion after tax) of unrealized losses in AOCI attributable to these securities. The amortization of the unrealized losses will offset the effect of the accretion of the discount created by the transfer. At December 31, 2023, the unamortized discount on the HTM securities totaled approximately $2.1 billion ($1.5 billion after tax).
The amortized cost of total HTM and AFS investment securities decreased $2.5 billion, or 10%, during 2023, primarily due to principal reductions. Approximately 7.0% and 8.0% of the total HTM and AFS investment securities were floating-rate instruments at December 31, 2017 increased by 12% from the balance2023 and 2022, respectively. Additionally, at December 31, 2016, primarily due2023, we had a total of $3.6 billion of pay-fixed swaps held as fair value hedges against fixed-rate AFS securities that effectively convert the fixed interest income to purchasesa floating rate on the hedged portion of agency guaranteed mortgage-backedthe securities.
TheAt December 31, 2023, the AFS investment securities portfolio includes $555included approximately $216 million of net premium that iswas distributed across the various asset classes as illustratedsecurity categories. Total taxable-equivalent premium amortization for these investment securities was $75 million in the preceding schedule. The purchase premiums and discounts for both held-to-maturity (“HTM”)2023, compared with $103 million in 2022.
In addition to HTM and AFS securities, are amortizedwe also have a trading securities portfolio, comprised of municipal securities, which totaled $48 million at December 31, 2023. The trading securities portfolio at December 31, 2022 was $465 million and accreted at a constant effective yieldincluded $71 million of municipal securities and $394 million of money market mutual funds available for customer sweeps. Beginning in the first quarter of 2023, sweep-related balances were included in “Money market investments” on the consolidated balance sheet.
Refer to the contractual maturity date“Interest Rate Risk Management” section on page 63, the “Capital Management” section on page 72, and no assumption is made concerning prepayments. As principal prepayments occur, the portion of the unamortized premium or discount associated with the principal reduction is recognized as interest income in the period the principal is reduced. Premium amortization for 2017 was approximately $125 million, compared with approximately $99 million in 2016, reducing the yield on securities in those years by 92 and 109 bps, respectively. The increased premium amortization is due to both an increased amount of agency guaranteed mortgage-backed securities and SBA loan-backed securities and changes in actual prepayment rates of underlying loans.
As of December 31, 2017, under the GAAP fair value accounting hierarchy, 1% of the $15.2 billion fair value of the AFS securities portfolio was valued at Level 1, 99% was valued at Level 2, and there were no Level 3 AFS securities. At December 31, 2016, 1% of the $13.4 billion fair value of AFS securities portfolio was valued at Level 1, 99% was valued at Level 2, and there were no Level 3 AFS securities. See Note 35 of the Notes to Consolidated Financial Statements for furthermore discussion of fair value accounting.
Schedule 12 presents the maturities of the different types of investments that we owned and the corresponding average yields as of December 31, 2017 based on amortized cost. Expected maturities, rather than contractual maturities, are shown for SBA securities, agency guaranteed mortgage-backed securities, and certain agency and municipal securities. See “Liquidity Risk Management” on page 72 and Notes 1, 5 and 7 of the Notes to Consolidated Financial Statements for additional information aboutregarding our investment securities portfolio, swaps, and their management.related unrealized gains and losses.

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Schedule 12
MATURITIES AND AVERAGE YIELDS ON SECURITIES
At December 31, 2017
 Total securities Within one year  After one but within five years After five but within ten years After ten years
(Dollar amounts in millions)Amount 
Yield1
 Amount 
Yield1
 Amount 
Yield1
 Amount 
Yield1
 Amount 
Yield1
Held-to-maturity                   
Municipal securities$770
 4.0% $180
 3.4% $372
 3.9% $159
��4.8% $59
 4.7%
Available-for-sale                   
U.S. Treasury securities25
 1.3
 25
 1.3
 
   
   
  
U.S. Government agencies and corporations:                   
Agency securities1,830
 2.1
 550
 1.3
 287
 2.5
 777
 2.3
 216
 2.5
Agency guaranteed mortgage-backed securities9,798
 2.0
 1,509
 2.0
 3,997
 2.0
 2,566
 2.0
 1,726
 2.1
Small Business Administration loan-backed securities2,227
 3.0
 230
 2.9
 699
 3.0
 588
 2.9
 710
 3.1
Municipal securities1,336
 3.0
 185
 3.0
 744
 2.9
 400
 3.3
 7
 3.4
Other25
 6.2
 
   
   
   25
 6.2
Total available-for-sale debt securities15,241
 2.3
 2,499
 2.0
 5,727
 2.3
 4,331
 2.3
 2,684
 2.4
Money market mutual funds and other72
 1.2
 72
 1.2
 
   
   
  
Total available-for-sale15,313
 2.3
 2,571
 2.0
 5,727
 2.3
 4,331
 2.3
 2,684
 2.4
Total investment securities$16,083
 2.3
 $2,751
 2.1
 $6,099
 2.4
 $4,490
 2.4
 $2,743
 2.5
1 Taxable-equivalent rates used where applicable.
Exposure to StateMunicipal Investments and Local GovernmentsExtensions of Credit
We provide multiplesupport our communities by providing products and services to state and local governments (referred to collectively as “municipalities”(“municipalities”), including deposit services, loans, and investment banking services, and weservices. We also invest in securities issued by municipalities. Our municipal lending products generally include loans in which the municipalities.debt service is repaid from general funds or pledged revenues of the municipal entity, or to private commercial entities or 501(c)(3) not-for-profit entities utilizing a pass-through municipal entity to achieve favorable tax treatment.
The following schedule summarizes our total investments and extensions of credit to municipalities:
Schedule 13 summarizes15
MUNICIPAL INVESTMENTS AND EXTENSIONS OF CREDIT
December 31,
(In millions)20232022
Loans and leases$4,302 $4,361 
Held-to-maturity – municipal securities354 405 
Available-for-sale – municipal securities1,318 1,634 
Trading account – municipal securities48 71 
Unfunded lending commitments231 406 
Total$6,253 $6,877 
Our municipal loans and securities are primarily associated with municipalities located within our exposure to state and local municipalities:
Schedule 13
MUNICIPALITIES
 December 31,
(In millions)2017 2016
    
Loans and leases$1,271
 $778
Held-to-maturity – municipal securities770
 868
Available-for-sale – municipal securities1,334
 1,154
Trading account – municipal securities146
 112
Unfunded lending commitments152
 182
Total direct exposure to municipalities$3,673
 $3,094
At December 31, 2017, one municipal loan with a balance of $1 million was on nonaccrual. A significant amount of thegeographic footprint. The municipal loan and lease portfolio is primarily secured by general obligations of municipal entities. Other types of collateral also include real estate, revenue pledges, or equipment. At December 31, 2023, we had no municipal loans on nonaccrual.
Municipal securities are internally graded, similar to loans, using risk-grading systems which vary based on the size and equipment,type of credit risk exposure. The internal risk grades assigned to our municipal securities follow our definitions of Pass, Special Mention, and 79%Substandard, which are consistent with published definitions of the outstanding creditsregulatory risk classifications. At December 31, 2023, all municipal securities were originated by CB&T, Zions Bank,graded as Pass. See Notes 5 and Vectra. See Note 6 of the Notes to Consolidated Financial Statements for additional information about the credit quality of these municipal loans.loans and securities.
Loan and Lease Portfolio
We provide a wide range of lending products to commercial customers, generally small- and medium-sized businesses. We also provide various retail lending products and services to consumers and small businesses. The following schedule presents the composition of our loan and lease portfolio:

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Schedule 16
Growth in municipal exposure came primarily from increases inLOAN AND LEASE PORTFOLIO
 December 31, 2023December 31, 2022
(Dollar amounts in millions)Amount% of
total loans
Amount% of
total loans
Commercial:
Commercial and industrial 1
$16,684 28.9 %$16,377 29.5 %
Leasing383 0.7 386 0.7 
Owner-occupied9,219 16.0 9,371 16.8 
Municipal4,302 7.4 4,361 7.8 
Total commercial30,588 53.0 30,495 54.8 
Commercial real estate:
Construction and land development2,669 4.6 2,513 4.5 
Term10,702 18.5 10,226 18.4 
Total commercial real estate13,371 23.1 12,739 22.9 
Consumer:
Home equity credit line3,356 5.8 3,377 6.1 
1-4 family residential8,415 14.6 7,286 13.1 
Construction and other consumer real estate1,442 2.5 1,161 2.1 
Bankcard and other revolving plans474 0.8 471 0.8 
Other133 0.2 124 0.2 
Total consumer13,820 23.9 12,419 22.3 
Total loans and leases$57,779 100.0 %$55,653 100.0 %
1Commercial and industrial loan balances include Paycheck Protection Program (“PPP”) loans of $77 million and $197 million for the respective periods presented.
At December 31, 2023 and December 31, 2022, the ratio of loans and leases to total assets was 66% and 62%, respectively. The largest loan category was commercial and industrial loans, which constituted 29% and 30% of our total loan portfolio for the municipal AFS securities portfolio. AFS securities generally consist of securities with investment-grade ratings from onesame respective periods.
During 2023, the loan and lease portfolio increased $2.1 billion, or more major credit rating agencies.
Foreign Exposure and Operations
Our credit exposure4%, to foreign sovereign risks and total foreign credit exposure is not significant. We also do not have significant foreign exposure to derivative counterparties. We had no foreign deposits at December 31, 2017 and December 31, 2016.
Loans Held for Sale
Loans held for sale, consisting$57.8 billion. Consumer loans increased $1.4 billion, primarily of consumer mortgage and small business loans to be sold in the secondary market, were $44 million at December 31, 2017, compared with $172 million at December 31, 2016. These1-4 family residential and consumer construction loan portfolios, and commercial real estate loans areincreased $0.6 billion, primarily fixed-rate mortgages that are originated within the intentmulti-family and industrial term loan portfolios. Funding of construction lending commitments and a slower pace of loan payoffs contributed to be sold to third parties.growth in both the consumer and CRE portfolios.
Loan PortfolioThe following schedule presents the contractual maturity distribution of our loan and lease portfolio:
As
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Schedule 17
LOAN AND LEASE PORTFOLIO BY CONTRACTUAL MATURITY
December 31, 2023
(In millions)One year or lessOne year through five yearsFive years through fifteen yearsOver fifteen yearsTotal
Commercial:
Commercial and industrial$3,332 $11,113 $2,188 $51 $16,684 
Leasing27 264 92 — 383 
Owner-occupied419 1,795 5,461 1,544 9,219 
Municipal306 640 2,436 920 4,302 
Total commercial4,084 13,812 10,177 2,515 30,588 
Commercial real estate:
Construction and land development1,089 1,442 88 50 2,669 
Term2,407 5,762 2,390 143 10,702 
Total commercial real estate3,496 7,204 2,478 193 13,371 
Consumer:
Home equity credit line70 3,280 3,356 
1-4 family residential32 171 8,204 8,415 
Construction and other consumer real estate— 20 1,421 1,442 
Bankcard and other revolving plans320 154 — — 474 
Other17 82 34 — 133 
Total consumer346 274 295 12,905 13,820 
Total loans and leases$7,926 $21,290 $12,950 $15,613 $57,779 
Our loans and leases accounted for 68%have predetermined (fixed) or variable interest rates. The following schedule presents the interest rate composition of total assets comparedour loan and lease portfolio with 67% at the end of 2016. Schedule 14 presents our loans outstanding by type of loan as of the five most recent year-ends. The schedule also includes a maturity profile for the loans that were outstanding as of December 31, 2017. However, while this schedule reflects the contractual maturity date over one year, and repricing characteristicsdoes not include the effect of these loans, in a small number of cases, we have hedgedany interest rate swaps associated with the repricing characteristics ofloan portfolio. For more information on our variable-rate loans as more fully described ininterest rate risk management, see “Interest Rate Risk” on page 68.63.

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Schedule 1418
LOAN AND LEASE PORTFOLIO WITH CONTRACTUAL MATURITIES OVER ONE YEAR BY INTEREST RATE TYPE AND MATURITY
 December 31, 2017 December 31,
(In millions)One year or less One year through five years Over five years Total 2016 2015 2014 2013
Commercial:               
Commercial and industrial$8,064
 $4,375
 $1,564
 $14,003
 $13,452
 $13,211
 $13,163
 $12,459
Leasing26
 262
 76
 364
 423
 442
 409
 388
Owner-occupied463
 1,138
 5,687
 7,288
 6,962
 7,150
 7,351
 7,568
Municipal100
 191
 980
 1,271
 778
 676
 521
 449
Total commercial8,653
 5,966
 8,307
 22,926
 21,615
 21,479
 21,444
 20,864
Commercial real estate:               
Construction and land development931
 1,016
 74
 2,021
 2,019
 1,842
 1,986
 2,193
Term1,779
 3,775
 3,549
 9,103
 9,322
 8,514
 8,127
 8,203
Total commercial real estate2,710
 4,791
 3,623
 11,124
 11,341
 10,356
 10,113
 10,396
Consumer:               
Home equity credit line29
 91
 2,657
 2,777
 2,645
 2,417
 2,321
 2,147
1-4 family residential12
 97
 6,553
 6,662
 5,891
 5,382
 5,201
 4,742
Construction and other consumer real estate287
 36
 274
 597
 486
 385
 371
 325
Bankcard and other revolving plans293
 58
 158
 509
 481
 444
 401
 361
Other12
 138
 35
 185
 190
 187
 213
 208
Total consumer633
 420
 9,677
 10,730
 9,693
 8,815
 8,507
 7,783
Total net loans$11,996
 $11,177
 $21,607
 $44,780
 $42,649
 $40,650
 $40,064
 $39,043
Loans maturing:               
With fixed interest rates$1,341
 $3,704
 $4,680
 $9,725
        
With variable interest rates10,655
 7,473
 16,927
 35,055
        
Total$11,996
 $11,177
 $21,607
 $44,780
        
As of December 31, 2017, net loans and leases were $45 billion, reflecting a 5% increase from the prior year. The increase is primarily attributable to new loan originations and loan purchases.
Loan portfolio growth during 2017 was widespread across loan products and geographies with particular strength inconsumer 1-4 family residential, commercial and industrial (non-oil and gas), municipal, and commercial owner-occupied loans. The growth in the loan portfolio was primarily at Amegy, CB&T, and Vectra.
Of the significant increases within the portfolio, consumer 1-4 family residential loans increased $771 million, due largely to an increase in loan production and loan purchases, and commercial and industrial loans increased $551 million. The impact of these increases was partially offset by a decrease of $219 million in our CRE term portfolio.
Commercial owner-occupied loans also increased $326 million during 2017 and $188 million during 2016. Although we experienced continued runoff and attrition of the NRE portfolio at Zions Bank, these declines are not expected to continue at the same pace in 2018. The NRE business is a wholesale business that depends upon loan referrals from other community banking institutions. Due to generally soft loan demand nationally, many community banking institutions are retaining, rather than selling, their loan production.
We expect moderate total loan and lease growth during 2018, primarily in consumer 1-4 family residential, municipal, commercial and industrial (non-oil and gas), commercial owner-occupied (non-NRE), and CRE term loans. We expect stable to slightly increasing growth in oil and gas loans, partially offset by moderate attrition in the NRE loan portfolio.


Loans serviced for the benefit of others increased to $3.7 billion during 2017 from $3.5 billion in 2016.
December 31, 2023
Loans with contractual maturities over one year
(In millions)Predetermined (fixed) interest ratesVariable interest ratesTotal
Commercial:
Commercial and industrial$2,550 $10,802 $13,352 
Leasing356 — 356 
Owner-occupied3,178 5,622 8,800 
Municipal3,282 714 3,996 
Total commercial9,366 17,138 26,504 
Commercial real estate:
Construction and land development50 1,530 1,580 
Term1,774 6,521 8,295 
Total commercial real estate1,824 8,051 9,875 
Consumer:
Home equity credit line196 3,159 3,355 
1-4 family residential609 7,798 8,407 
Construction and other consumer real estate— 1,442 1,442 
Bankcard and other revolving plans152 154 
Other115 116 
Total consumer922 12,552 13,474 
Total loans and leases$12,112 $37,741 $49,853 
Other Noninterest-BearingNoninterest-bearing Investments
During 2017, the Company increased its short-term borrowings with the FHLB by $3.1 billion. This increase required a further investment in FHLB activity stock, which consequently increased by $124 million during the year. Aside from this increase, otherOther noninterest-bearing investments remained relatively stable as set forth in theare equity investments that are held primarily for capital appreciation, dividends, or for certain regulatory requirements. The following schedule. Schedule 15 sets forthschedule summarizes our other noninterest-bearingrelated investments.
Schedule 1519
OTHER NONINTEREST-BEARING INVESTMENTS
December 31,Amount changePercent change
(Dollar amounts in millions)20232022
Bank-owned life insurance$553 $546 $%
Federal Home Loan Bank stock79 294 (215)NM
Federal Reserve stock65 68 (3)(4)
Farmer Mac stock24 19 26 
SBIC investments190 172 18 10 
Other39 31 26 
Total other noninterest-bearing investments$950 $1,130 $(180)(16)%
Total other noninterest-bearing investments decreased $180 million, or 16%, during 2023, primarily due to a $215 million decrease in FHLB stock. We are required to invest approximately 4% of our FHLB borrowings in FHLB activity stock to maintain our borrowing capacity. The decrease in period-end FHLB activity stock was primarily due to a shift in wholesale funding needs as a result of the increase in interest-bearing deposits and the decrease in interest-earning assets.
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 December 31,
(In millions)2017 2016
    
Bank-owned life insurance$506
 $497
Federal Home Loan Bank stock154
 30
Federal Reserve stock184
 181
Farmer Mac stock43
 34
SBIC investments127
 124
Non-SBIC investment funds12
 15
Other3
 3
Total other noninterest-bearing investments$1,029
 $884
Visa Class B Shares
In 2007, we received 460,153 non-transferable Class B shares of Visa, Inc. in connection with a restructuring and public offering by Visa U.S.A. As a member of Visa U.S.A., we received the Class B shares based on our interest in Visa U.S.A. and did not pay anything to acquire the shares. On September 13, 2023, Visa, Inc. announced its intent to engage with common stockholders on a potential proposal that would result in the release of certain transfer restrictions on a portion of Visa Class B common stock. On January 23, 2024, the proposal was approved by a majority of Class A, B, and C common stockholders, which would provide us the option to convert up to 50% of our Class B shares to freely transferable Visa Class A common shares upon terms and conditions more fully described in the public filings of Visa, Inc. The closing price of a Visa Class A common share was $260.35 at December 31, 2023. In light of uncertainties associated with certain ongoing litigation matters involving Visa and the details of the aforementioned proposal, the ultimate timing and impact of us exercising this option, including any gain contingency, is unknown.
Premises, Equipment, and Software Net
Net premises, equipmentWe are in the final phase of a three-phase project to replace our core loan and software, increased $74 million, or 7%, fromdeposit banking systems. This final phase includes the prior year primarily duereplacement of our deposit banking systems through multiple affiliate bank conversions, the first of which was successfully completed in the second quarter of 2023. Our experience with the initial conversion led to enhanced processes, trainings, and product offerings, which resulted in a delay of subsequent planned conversions. We expect to complete the remaining conversions in 2024.
The following schedule summarizes the capitalized costs associated with the developmentour core system replacement project, which are depreciated using a useful life of a new corporate facility for Amegy Bank in Texas, major software purchases, and the capitalization of eligible costs related to the development of new lending, deposit and reporting systems.ten years:
Schedule 20
CAPITALIZED COSTS ASSOCIATED WITH THE CORE SYSTEM REPLACEMENT PROJECT
December 31, 2023
(In millions)Phase 1Phase 2Phase 3Total
Total amount of capitalized costs, less accumulated amortization$21 $45 $227 $293 
Deposits
Deposits both interest-bearingare our primary funding source. In recent years, we experienced a significant influx of deposits, which was impacted by considerable fiscal and noninterest-bearing, are a primary sourcemonetary policy decisions. During 2022, with the withdrawal of funding forstimulus by the Company. Averagefederal government, our deposits began to decline. This trend accelerated with prominent bank closures during the first quarter of 2023 and abated during the second quarter of 2023. As shown below, total deposits increased 5% during 2023. The following schedule presents the composition of our deposit portfolio:
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Schedule 21
DEPOSIT PORTFOLIO
December 31, 2023December 31, 2022
(Dollar amounts in millions)Amount% of
total
deposits
Amount% of
total
deposits
Deposits by type
Noninterest-bearing demand$26,244 35.0 %$35,777 49.9 %
Interest-bearing:
Savings and money market38,663 51.6 33,474 46.7 
Time5,619 7.5 1,484 2.1 
Brokered4,435 5.9 917 1.3 
Total deposits$74,961 100.0 %$71,652 100.0 %
Deposit-related metrics
Estimated amount of insured deposits$41,777 56 %$33,589 47 %
Estimated amount of uninsured deposits33,184 44 %38,063 53 %
Estimated amount of collateralized deposits 1
$3,979 %$2,861 %
Loan-to-deposit ratio77%78%
1 Includes both insured and uninsured deposits.
Total deposits increased $3.3 billion, or 5%, in 2023. Interest-bearing deposits increased $12.8 billion, or 36%, and were partially offset by 3% during 2017,a decrease of $9.5 billion, or 27%, in noninterest-bearing demand deposits, as customers migrated to interest-bearing products in response to the higher interest rate environment. Our noninterest-bearing deposits are generally more valuable in a rising interest rate environment, creating meaningful economic value that is not fully reflected on our balance sheet since core deposits and related intangible assets are not recorded at fair value for accounting purposes.
At December 31, 2023, customer deposits (excluding brokered deposits) totaled $70.5 billion and included approximately $6.8 billion of reciprocal deposit products, where we distributed our customers’ deposits in a placement network to increase their FDIC insurance, and in return, we received a matching amount of deposits from other network banks.
At December 31, 2023, the total estimated amount of uninsured deposits was $33.2 billion, or 44%, of total deposits, compared with 2016, with average interest-bearing deposits increasing by 1% and average noninterest-bearing deposits increasing by 6%. The average interest rate paid for interest-bearing deposits was 3 bps higher in 2017 compared with 2016.
Deposits at December 31, 2017, excluding time deposits of $100,000 and over and brokered deposits, decreased by 2%,$38.1 billion, or $1.0 billion, from December 31, 2016. The decrease was mainly due to a decrease in interest-bearing domestic savings and money market deposits.
Demand, savings, and money market deposits were 94% and 95%53%, of total deposits at December 31, 2017, and December 31, 2016,2022, respectively. At December 31, 2017 and December 31, 2016, total deposits included $1.6 billion and $0.9 billion, respectively, of brokered deposits.Our loan-to-deposit ratio was 77%, compared with 78% for the same respective time periods.
See Notes 11 and 12of the Notes to Consolidated Financial Statements and “Liquidity Risk Management” on page 7267 for additional information on funding and borrowed funds.

liquidity, including the ratio of available liquidity to uninsured deposits.

RISK ELEMENTSMANAGEMENT
SinceWe engage in risk is inherent in substantially all of the Company’s operations, management of riskpractices to ensure prudent risk-taking and appropriate oversight. Risk management is an integral part of itsour operations and is also a keyan essential determinant of itsour overall performance.performance as one of our key strategic objectives.
We utilize the three lines of defense approach to risk management with responsibilities for each line of defense defined in our Risk Management Framework. The first line of defense represents units and functions throughout the Bank engaged in activities related to revenue generation, expense reduction, operational support, and technology services. These units and functions are accountable for owning and managing the risks associated with these activities. The second line of defense represents functions responsible for independently assessing and overseeing risk management activities. The third line of defense is our internal audit function that provides independent assessment of the effectiveness of the first and second lines of defense.
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In support of management’s efforts, the Board of Directors has appointed a Risk Oversightestablished certain committees to oversee our risk management processes. The Audit Committee (“ROC”) that consists of appointed Board members who overseeoversees financial reporting risk, and the Company’sROC oversees the other risk management processes. The ROC meets on a regular basis to monitor and review Enterprise Risk Management (“ERM”)ERM activities. As required by its charter, the ROC performsprovides oversight for various ERM activities and approves ERM policies and activities as detailed in the ROC charter.
Management appliesWe employ various strategies to reduce the risks to which the Company’sour operations are exposed, including credit risk, market and interest rate risk, liquidity risk, strategic and market, liquidity,business risk, operational risk, technology risk, cybersecurity risk, capital/financial reporting risk, legal/compliance risk (including regulatory risk), and operational risks.reputational risk. These risks are overseen by the various management committees of which the Enterprise Risk Management Committee (“ERMC”) is the focal point for the monitoring and review of enterprise risk.point.
Credit Risk Management
Credit risk is the possibility of loss from the failure of a borrower, guarantor, or another obligor to fully perform under the terms of a credit-related contract. Credit risk arises primarily from our lending activities, as well as from off-balance sheet credit instruments.
The Board, of Directors, through the ROC, is responsible for approving the overallkey credit policies relating to the management of the credit risk of the Company. In addition, thepolicies. The ROC also oversees and monitors adherence to key creditthese policies and the credit risk appetite as defined in the Risk AppetiteManagement Framework. Additionally, theThe Board has established the Credit Administration Committee, chaired by the Chief Credit Officer and consisting of members of management, to which it has delegated the responsibility for managing credit risk for the Company and approving changes to credit policies to the Company’s credit policies.Chief Credit Officer, who chairs the Credit Risk Committee.
Centralized oversight of credit risk is provided through creditCredit policies, credit risk management, and credit examination functions.functions inform and support the oversight of credit risk. Our credit policies place emphasis onemphasize strong underwriting standards and early detection of potential problem credits in order to develop and implement action plans on a timely basis to mitigate any potential losses. These formal credit policies and procedures provide the Companyus with a framework for consistent underwriting and a basis for sound credit decisions at the local banking affiliate level. Policies include standards for sensitivity and scenario analyses that assess the resilience of the borrower, including the borrower’s ability to service the loan in a rising interest rate environment.
Our credit policies and practices are also designed to help manage potential risks, including those arising from environmental issues. Environmental risk related to our lending practices is primarily covered in our environmental credit policy and by our environmental subject matter experts and management. The extent of environmental due diligence performed by our environmental risk team is based on the risks identified at each property and the loan amount. The extension of credit to certain borrowers, or those connected with certain activities, may be restricted or require escalated approval, by policy, because of various environmental risks.
Our credit risk management function is separate from the lending function and strengthens control over, and the independent evaluation of, credit activities. In addition, we have a well-defined set of standards for evaluating our loan portfolio, and we utilize a comprehensive loan risk-grading system to determine the risk potential in the portfolio. Furthermore, the
The internal credit examination department, which is independent of the lending function, periodically conducts examinations of the Company’sour lending departments and credit activities. These examinations are designed to review credit quality, adequacy of documentation, appropriate loan risk-grading administration, and compliance with credit policies. New, expanded, or modified productsCredit examinations related to the ACL are reported to both the Audit Committee and services, as well as new lines of business, are approved by the New Initiative Review Committee.ROC.
Our credit risk management strategy includes diversificationbusiness activity is conducted primarily within the geographic footprint of our loan portfolio.banking affiliates. We attemptstrive to avoid the risk of an undue concentrationconcentrations of creditscredit in aany particular industry, collateral type, location, or with anany individual customer or counterparty. Generally, our loan portfolio is well diversified; however, due to the nature of our geographical footprint, there are certain significant concentrations primarily in CRE and oil and gas-related lending. We have adopted and adhere to concentration limits on certain commercial industries, including leveraged lending, municipal lending, oil and gas-related lending, and various types of CRE lending, particularly construction and land development and office lending. All of theseConcentration limits are continuallyregularly monitored and revised as necessary. The recent growth in construction and land development loan commitments is within the established concentration limits. Our business activity is primarily with customers located within the geographical footprint of our banking affiliates.
As we continue to monitor our concentration risk, the composition of our loan portfolio has slightly changed. Oil and gas-related loans represented 4% of the total loan portfolio at December 31, 2017, compared with 5% at December 31, 2016. Total commercial loans were 51% of the total portfolio, compared with 50% at December 31,

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2016. CRE loans declined to 25% of the total portfolio, compared with 27% at December 31, 2016. Consumer loans grew to represent 24% of the total loan portfolio at December 31, 2017, compared with 23% at December 31, 2016.
Schedule 16
LOAN PORTFOLIO DIVERSIFICATION
 December 31, 2017 December 31, 2016
(Dollar amounts in millions)Amount 
% of
total loans
 Amount 
% of
total loans
Commercial:       
Commercial and industrial$14,003
 31.3% $13,452
 31.5%
Leasing364
 0.8
 423
 1.0
Owner-occupied7,288
 16.3
 6,962
 16.3
Municipal1,271
 2.8
 778
 1.8
Total commercial22,926
 51.2
 21,615
 50.6
Commercial real estate:  
    
Construction and land development2,021
 4.5
 2,019
 4.7
Term9,103
 20.3
 9,322
 21.9
Total commercial real estate11,124
 24.8
 11,341
 26.6
Consumer:       
Home equity credit line2,777
 6.2
 2,645
 6.2
1-4 family residential6,662
 15.0
 5,891
 13.8
Construction and other consumer real estate597
 1.3
 486
 1.2
Bankcard and other revolving plans509
 1.1
 481
 1.1
Other185
 0.4
 190
 0.5
Total consumer10,730
 24.0
 9,693
 22.8
Total net loans$44,780
 100.0% $42,649
 100.0%
U.S. Government Agency Guaranteed Loans
We participate in various guaranteed lending programs sponsored by U.S. government agencies, such as the SBA,U.S. Small Business Administration (“SBA”), Federal Housing Authority, Veterans’ Administration,U.S. Department of Veterans Affairs, Export-Import Bank of the U.S., and the U.S. Department of Agriculture. As ofAt December 31, 2017, the principal balance2023, $554 million of these loans was $537 million, and the guaranteed portion of these loans was $406 million. Most of theserelated loans were guaranteed, primarily by the SBA.
SBA, and included $77 million of Paycheck Protection Program (“PPP”) loans. The following schedule presents the composition of U.S. government agency guaranteed loans.loans:
Schedule 1722
U.S. GOVERNMENT GUARANTEESAGENCY GUARANTEED LOANS
(Dollar amounts in millions)December 31, 2017 
Percent
guaranteed
 December 31, 2016 
Percent
guaranteed
        
Commercial$507
 75% $519
 75%
Commercial real estate14
 75
 18
 75
Consumer16
 92
 17
 92
Total loans$537
 76
 $554
 76


(Dollar amounts in millions)December 31,
2023
Percent
guaranteed
December 31,
2022
Percent
guaranteed
Commercial$664 80 %$753 83 %
Commercial real estate24 79 21 76 
Consumer100 100 
Total loans$692 80 %$779 83 %
Commercial Lending
The following schedule provides selected information regarding lending concentrationsexposures to certain industries in our commercial lending portfolio.portfolio:
Schedule 1823
COMMERCIAL LENDING BY INDUSTRY GROUP1
December 31, 2023December 31, 2022
(Dollar amounts in millions)AmountPercentAmountPercent
Retail trade$2,995 9.8 %$2,751 9.0 %
Real estate, rental and leasing2,946 9.6 2,802 9.2 
Finance and insurance2,918 9.5 2,992 9.8 
Healthcare and social assistance2,527 8.3 2,373 7.8 
Public Administration2,279 7.5 2,366 7.8 
Manufacturing2,190 7.2 2,387 7.8 
Wholesale trade1,850 6.0 1,880 6.2 
Transportation and warehousing1,499 4.9 1,464 4.8 
Utilities 2
1,409 4.6 1,418 4.6 
Construction1,355 4.4 1,355 4.4 
Educational services1,298 4.2 1,302 4.3 
Hospitality and food services1,180 3.9 1,238 4.1 
Mining, quarrying, and oil and gas extraction1,133 3.7 1,349 4.4 
Other Services (except Public Administration)1,047 3.4 1,041 3.4 
Professional, scientific, and technical services1,010 3.3 995 3.3 
Other 3
2,952 9.7 2,782 9.1 
Total$30,588 100.0 %$30,495 100.0 %
 December 31, 2017 December 31, 2016
(Dollar amounts in millions)Amount Percent Amount Percent
        
Real estate, rental and leasing$2,807
 12.3% $2,624
 12.1%
Retail trade 1
2,257
 9.8
 2,145
 9.9
Manufacturing2,116
 9.2
 2,161
 10.0
Finance and insurance2,026
 8.8
 1,462
 6.8
Healthcare and social assistance1,556
 6.8
 1,538
 7.1
Wholesale trade1,543
 6.7
 1,444
 6.7
Transportation and warehousing1,343
 5.9
 1,300
 6.0
Construction1,094
 4.8
 1,076
 5.0
Mining, quarrying, and oil and gas extraction1,010
 4.4
 1,403
 6.5
Accommodation and food services932
 4.1
 925
 4.3
Utilities 2
905
 4.0
 783
 3.6
Other Services (except Public Administration)896
 3.9
 881
 4.1
Professional, scientific, and technical services879
 3.8
 875
 4.0
Other 3
3,562
 15.5
 2,998
 13.9
Total$22,926
 100.0% $21,615
 100.0%
1Industry groups are determined by North American Industry Classification System (“NAICS”) codes.
1 2 Includes primarily utilities, power, and renewable energy.
3 At December 31, 2017, 84% of retail trade consists of motor vehicle and parts dealers, gas stations, grocery stores, building material suppliers, and direct-to-consumer retailers. For additional detail on our CRE retail exposure, see the Commercial Real Estate Loans section on page 61.
2
Includes primarily utilities, power, and renewable energy.
3
No other industry group exceeds 3.5%.
Oil and Gas-Related Exposure2023, no other industry group individually exceeded 3.3%.
Various industries represented in the previous schedule, including mining, quarrying and oil and gas extraction; manufacturing; and transportation and warehousing, contain certain loans we categorize as oil and gas-related. At both December 31, 2017 and 2016, we had approximately $3.9 billion of total oil and gas-related credit exposure. The distribution of oil and gas-related loans by customer market segment is shown in the following schedule:


Schedule 19
OIL AND GAS-RELATED EXPOSURE 1
(Dollar amounts in millions)December 31, 2017 % of total oil and gas- related December 31, 2016 % of total oil and gas- related
Loans and leases       
Upstream – exploration and production$730
 37% $733
 34%
Midstream – marketing and transportation617
 31
 598
 28
Downstream – refining123
 6
 137
 6
Other non-services34
 2
 38
 2
Oilfield services367
 19
 500
 23
Oil and gas service manufacturing102
 5
 152
 7
Total loan and lease balances 2
1,973
 100% 2,158
 100%
Unfunded lending commitments1,908
   1,722
  
Total oil and gas credit exposure$3,881
   $3,880
  
Private equity investments$3
   $7
  
Credit quality measures       
Criticized loan ratio25.1%   37.8%  
Classified loan ratio17.9%   31.6%  
Nonaccrual loan ratio7.7%   13.6%  
Ratio of nonaccrual loans that are current88.1%   86.1%  
Net charge-off ratio, annualized 3
%   3.0%  
1
Because many borrowers operate in multiple businesses, judgment has been applied in characterizing a borrower as oil and gas-related, including a particular segment of oil and gas-related activity, e.g., upstream or downstream; typically, 50% of revenues coming from the oil and gas sector is used as a guide.
2
Total loan and lease balances and the credit quality measures do not include oil and gas loans held for sale at period end.
3
Calculated as the ratio of annualized net charge-offs to the beginning loan balances for each respective period.
During 2017, our overall balance of oil and gas-related loans decreased by $185 million, or 9%, from year-end 2016. Oil and gas-related loans represented 4% of the total loan portfolio at December 31, 2017, compared with 5% at December 31, 2016. Unfunded oil and gas-related lending commitments increased by $186 million, or 11%. The increase in unfunded oil and gas-related lending commitments was primarily in the midstream portfolio.
Classified oil and gas-related credits decreased to $354 million at December 31, 2017, from $681 million at December 31, 2016. Oil and gas-related loan net charge-offs were $36 million for 2017, compared with $130 million for 2016. At December 31, 2017, the ACL related to the oil and gas-related portfolio was approximately 7% of oil and gas-related balances, compared with 9% at December 31, 2016.
Nonaccruing oil and gas-related loans decreased by $143 million during 2017, primarily in the oil and gas services and upstream portfolios. Approximately 88% of oil and gas-related nonaccruing loans were current as to principal and interest payments at December 31, 2017, which increased from 86% at December 31, 2016.
Risk Management of the Oil and Gas-Related Portfolio
The oil and gas-related portfolio is comprised of three primary segments: upstream, midstream, and oil and gas services. Upstream exploration and production loan borrowers have relatively balanced production between oil and gas. Midstream loans are made to companies that gather, transport, treat and blend oil and natural gas, or that provide services to similar companies. Oil and gas services loans, which include oilfield services and oil and gas service manufacturing, include borrowers that have a concentration of revenues in the oil and gas industry. However, many of these borrowers provide a broad range of products and services to the oil and gas industry and are diversified geographically.


We apply concentration limits and disciplined underwriting to the entire oil and gas-related loan portfolio to limit our risk exposure. As an indicator of the diversity in the size of our oil and gas-related portfolio, the average amount of our commitments is approximately $6 million, with approximately 67% of the commitments less than $30 million. Additionally, there are instances where we have commitments to companies with a common sponsor which, if combined, would result in higher commitment levels than $30 million. The portfolio contains only senior loans—no junior or second lien positions; additionally, we cautiously approach making first-lien loans to borrowers that employ excessive leverage through the use of junior lien loans or unsecured layers of debt. Approximately 88% of the total oil and gas-related portfolio is secured by reserves, equipment, real estate, and other collateral, or a combination of collateral types.
We participate as a lender in loans and commitments designated as Shared National Credits (“SNCs”), which generally consist of larger and more diversified borrowers that have better access to capital markets. SNCs are loans or loan commitments of at least $20 million that are shared by three or more federally supervised institutions. The percentage of SNCs is 79% of the upstream portfolio, 79% of the midstream portfolio, and 44% of the oil and gas services portfolio. Our bankers have direct access and contact with the management of these SNC borrowers, and as such, are active participants. In many cases, we provide ancillary banking services to these borrowers, further evidencing this direct relationship. The results of the fall 2017 SNC exam are reflected in our financial statements.
As a secondary source of support, many of our oil and gas-related borrowers have access to capital markets and private equity sources. Private sponsors tend to be large funds, often with assets under management of more than $1 billion, managed by individuals with a great deal of oil and gas expertise and experience and who have successfully managed investments through previous oil and gas price cycles. The investors in the funds are primarily institutional investors, such as large pensions, foundations, trusts, and high net worth family offices.


Commercial Real Estate Loans
Selected information indicative of credit quality regardingAt December 31, 2023 and 2022, our CRE loan portfolio is presented intotaled $13.4 billion and $12.7 billion, respectively, representing 23% of the total loan portfolio for both periods. The majority of our CRE loans are secured by real estate primarily located within our geographic footprint.
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Table of Contents
ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
The following schedule.schedule presents the geographic distribution of our CRE loan portfolio based on the location of the primary collateral:
Schedule 2024
COMMERCIAL REAL ESTATE PORTFOLIOLENDING BY LOAN TYPE AND COLLATERAL LOCATION
December 31, 2023December 31, 2022
(Dollar amounts in millions)AmountPercentAmountPercent
Arizona$1,726 12.9 %$1,521 11.9 %
California3,865 28.9 3,805 29.9 
Colorado709 5.3 637 5.0 
Nevada1,072 8.0 910 7.1 
Texas2,385 17.8 2,139 16.8 
Utah/Idaho2,214 16.6 2,397 18.8 
Washington/Oregon1,004 7.5 899 7.1 
Other396 3.0 431 3.4 
Total CRE$13,371 100.0 %$12,739 100.0 %
Term CRE loans generally mature within a three- to seven-year period and consist of full, partial, and non-recourse guarantee structures. Typical term CRE loan structures include annually tested operating covenants that require loan rebalancing based on minimum debt service coverage, debt yield, or loan-to-value tests. Construction and land development loans generally mature in 18 to 36 months and contain full or partial recourse guarantee structures with one- to five-year extension options or roll-to-perm options that often result in term loans. At December 31, 2023, approximately 83% of our CRE loan portfolio was variable-rate, and approximately 22% of these variable-rate loans were swapped to a fixed rate.
The following schedule provides information regarding lending exposures to certain collateral types in our commercial real estate lending portfolio:
Schedule 25
COMMERCIAL REAL ESTATE LENDING BY COLLATERAL TYPE
December 31, 2023December 31, 2022
(Dollar amounts in millions)AmountPercentAmountPercent
Commercial property
Multi-family$3,709 27.7 %$3,068 24.1 %
Industrial3,062 22.9 2,509 19.7 
Office1,984 14.8 2,281 17.9 
Retail1,503 11.2 1,529 12.0 
Hospitality688 5.2 695 5.4 
Land211 1.6 276 2.2 
Other 1
1,682 12.6 1,728 13.5 
Residential property 2
Single family287 2.1 340 2.7 
Land90 0.7 75 0.6 
Condo/Townhome37 0.3 13 0.1 
Other 1
118 0.9 225 1.8 
Total$13,371 100.0 %$12,739 100.0 %
1 Included in the total amount of the “Other” category was approximately $202 million and $301 million of unsecured loans at December 31, 2023 and 2022, respectively.
2 Residential property collateral type consists primarily of loans provided to commercial homebuilders for single-family housing developments, land and lots, and condo/townhome developments.
56
(Dollar amounts in millions) Collateral Location    
Loan type 
As of
date
 Arizona California Colorado Nevada Texas 
Utah/
Idaho
 Wash-ington/Oregon 
Other 1
 Total 
% of 
total
CRE
Commercial term
Balance outstanding 12/31/2017 $1,018
 $3,026
 $493
 $536
 $1,735
 $1,365
 $448
 $482
 $9,103
 81.8%
% of loan type   11.2% 33.2% 5.4% 5.9% 19.1% 15.0% 4.9% 5.3% 100.0%  
Delinquency rates: 2
 
 
 
 
 
 
 
 
    
30-89 days 12/31/2017 0.2% 0.1% 0.1% 0.2% % 0.2% % 0.8% 0.1%  
  12/31/2016 0.1% % % 0.8% % 0.1% 0.2% % 0.1%  
≥ 90 days 12/31/2017 0.2% 0.1% 0.1% % % 0.1% % 0.7% 0.1%  
  12/31/2016 0.3% 0.4% % % % 0.2% % 1.1% 0.2%  
Accruing loans past due 90 days or more 12/31/2017 $1
 $1
 $
 $
 $
 $
 $
 $
 $2
  
  12/31/2016 
 10
 
 
 
 2
 
 
 12
  
Nonaccrual loans 12/31/2017 4
 7
 1
 2
 17
 1
 4
 
 36
  
  12/31/2016 8
 11
 
 2
 1
 
 7
 
 29
  
Residential construction and land development
Balance outstanding 12/31/2017 $40
 $261
 $43
 $4
 $201
 $42
 $3
 $6
 $600
 5.4%
% of loan type   6.6% 43.5% 7.2% 0.7% 33.5% 7.0% 0.5% 1.0% 100.0%  
Delinquency rates: 2
 
 
 
 
 
 
 
 
    
30-89 days 12/31/2017 % % 0.2% % 0.7% % % % 0.2%  
  12/31/2016 % % % % 0.4% % % % 0.1%  
≥ 90 days 12/31/2017 % % % % 0.1% % % % %  
  12/31/2016 % % % % % % % % %  
Accruing loans past due 90 days or more 12/31/2017 $
 $
 $
 $
 $
 $
 $
 $
 $
  
  12/31/2016 
 
 
 
 
 
 
 
 
  
Nonaccrual loans 12/31/2017 
 
 
 
 
 
 
 
 
  
  12/31/2016 
 
 
 
 
 
 
 
 
  
Commercial construction and land development
Balance outstanding 12/31/2017 $131
 $356
 $34
 $72
 $415
 $265
 $90
 $58
 $1,421
 12.8%
% of loan type   9.2% 25.0% 2.4% 5.1% 29.2% 18.7% 6.3% 4.1% 100.0%  
Delinquency rates: 2
 
 
 
 
 
 
 
 
    
30-89 days 12/31/2017 0.1% 0.2% % % 0.2% 0.1% % % 0.1%  
  12/31/2016 % % % 1.2% % 2.4% % % 0.5%  
≥ 90 days 12/31/2017 % % % % % 1.3% % % 0.3%  
  12/31/2016 % % % % 0.4% % % % 0.2%  
Accruing loans past due 90 days or more 12/31/2017 $
 $
 $
 $
 $
 $
 $
 $
 $
  
  12/31/2016 
 
 
 
 
 
 
 
 
  
Nonaccrual loans 12/31/2017 
 
 
 
 
 4
 
 
 4
  
  12/31/2016 
 
 
 
 2
 5
 
 
 7
  
Total construction and land development 12/31/2017 $171
 $617
 $77
 $76
 $616
 $307
 $93
 $64
 $2,021
  
Total commercial real estate 12/31/2017 $1,189
 $3,643
 $570
 $612
 $2,351
 $1,672
 $541
 $546
 $11,124
 100.0%
1
No other geography exceeds $79 million for all three loan types.
2
Delinquency rates include nonaccrual loans.


ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Approximately 20% of the CRE term loans consist of mini-perm loans as of December 31, 2017. For such loans, construction has been completed and the project has stabilized to a level that supports the granting of a mini-perm loan in accordance with our underwriting standards. Mini-perm loans generally have initial maturities of three to seven years. The remaining 80% of CRE loans are term loans with initial maturities generally of 5 to 20 years. The stabilization criteria for a project to qualify for a term loan differ by product type and include criteria related to the cash flow generated by the project, loan-to-value ratio, and occupancy rates.
Approximately $144 million, or 10%, of the commercial construction and land development portfolio at December 31, 2017 consists of acquisition and development loans. Most of these acquisition and development loans are secured by specific retail, apartment, office, or other projects.
Of the total CRE loan portfolio at December 31, 2017, we categorize $1.8 billion as retail property, where the ultimate use of the property is for retailing purposes. The average loan-to-value ratio for these loans is approximately 55%, and more than 90% are occupied. Approximately 81% of our CRE retail loans are to borrowers where the underlying retail businesses are not regional shopping centers, but include neighborhood strip malls, stand-alone retail facilities, and single-tenant buildings. Of the regional shopping center exposure, approximately 94% is term debt, and the criticized loan ratio is 5.3%. We closely monitor the CRE retail portfolio for tenant bankruptcy filings and store closures, and have limited exposure to national tenants with announced bankruptcies.
Underwriting on commercial properties is primarily based on the economic viability of the project with heavysignificant consideration given to the creditworthiness and experience of the sponsor. We generally require that the owner’s equity be injected prior to bankany advances. RemarginingRe-margining requirements (required equity infusions upon a decline in value or cash flow of the collateral) are often included in the loan agreement along with guarantees of the sponsor. Recognizing that debt is paid via cash flow, the projected cash flows of the project are critical in the underwriting because these determine the ultimate value of the property and its ability to service debt. Therefore, in most projects (with the exception of multifamily and hospitality construction projects), we require substantial pre-leasing/leasing in our underwriting and we generally require a minimum projected stabilized debt service coverage ratio of 1.20 or higher, depending on the project asset class.
Within the residential construction and development sector, many of the requirements previously mentioned, such as creditworthiness and experience of the developer, up-front injection of the developer’s equity, principal curtailment requirements, and the viability of the project are also important in underwriting a residential development loan. Significant considerationConsideration is given to the forecastedexpected market acceptance of the product, location, strength of the developer, and the ability of the developer to stay within budget. Progress inspections by qualified independent inspectors are routinely performed before disbursements are made.disbursing loan funds. Advance rates will vary based on the collateral, viability of the project, and the creditworthiness of the sponsor, with exceptions granted on a case-by-case basis.
Real estate appraisals are orderedperformed in accordance with regulatory guidelines and are validated independently of the loan officer and the borrower, generally by our internal appraisal review function, which is staffed by licensed appraisers.team. In some cases, reports from automated valuation services are used or internal evaluations are performed. A new appraisal or evaluation is required when a loan deteriorates to a certain level of credit weakness.
Advance rates (i.e., loan commitments) will vary based on the viability of the project and the creditworthiness of the sponsor, but our guidelines generally limit advances to 50% for raw land, 65% for land development, 65% for finished commercial lots, 75% for finished residential lots, 80% for pre-sold homes, 75% for models and homes not under contract, and 75% for commercial properties. Exceptions may be granted on a case-by-case basis.
Loan agreements require regular reporting of financial information on the project and the sponsor in addition to lease schedules, rent rolls and, on construction projects, independent progress inspection reports. The receipt ofWe monitor this financial information is monitored and calculations are made to determineensure adherence to the covenants set forth in the loan agreement.
The existence of a guarantee that improves the likelihood of repayment is taken into consideration when analyzingevaluating CRE loans for impairment.expected losses. If theguarantor support of the guarantor is quantifiable and documented, it is includedconsidered in the


potential cash flows and liquidity available for debt repayment, and our impairmentrepayment. Our expected loss methodology takes this repayment source into consideration.
When we modify or extend a loan, we also give consideration to whether the borrower is in financial difficulty, and whether we have granted a concession. In determining if an interest rate concession has been granted, we consider whether the interest rate on the modified loan is equivalent to current market rates for new debt with similar risk characteristics. If the rate in the modification is less than current market rates, it may indicate that a concession was granted and impairment exists. However, if additional collateral is obtained, or if a guarantor exists who has the capacity and willingness to support the loan on an extended basis, we also consider the nature and amountconsiders these sources of the additional collateral and guarantees in the ultimate determination of whether a concession has been granted.
repayment. In general, we obtain and considerevaluate updated financial information for the guarantor as part of our determination to extend a loan.credit. The quality and frequency of financial reporting collected and analyzed varies depending on the contractual requirements for reporting, the size of the transaction, and the strength of the guarantor.
Complete underwriting of the guarantor includes, but is not limited to, an analysis of the guarantor’s current financial statements, leverage, liquidity, global cash flow, global debt service coverage, contingent liabilities, etc. The assessment also includes a qualitative analysis of the guarantor’s willingness to perform in the event of a problem and demonstrated history of performing in similar situations. Additional analysis may include personal financial statements, tax returns, liquidity (brokerage) confirmations, and other reports, as appropriate.
A qualitative assessment is performed on a case-by-case basis to evaluate the guarantor’s experience, performance track record, reputation, and willingness to work with us. We also utilize market information sources, rating, and scoring services in our assessment. This qualitative analysis coupled with a documented quantitative ability to support the loan may result in a higher-quality internal loan grade, which may reduce the level of allowance we estimate. Previous documentation of the guarantor’s financial ability to support the loan is discounted if there is any indication of a lack of willingness by the guarantor to support the loan.
In the event of default, we evaluate the pursuit ofpursue any and all appropriate potentialavailable sources of repayment, which may comeincluding from multiple sources, including the guarantee.collateral and guarantors. A number of factors are considered when deciding whether or not to pursue a guarantor, including, but not limited to, the value and liquidity of other sources of repayment (collateral), the financial strength and liquidity of the guarantor, possible statutory limitations, (e.g., single action rule on real estate) and the overall cost of pursuing a guarantee comparedversus the amount we are likely to recover.
Our CRE portfolio is diversified across geography and collateral type, with the ultimate amount we may be able to recover. In other instances, the guarantor may voluntarily support alargest concentration in multi-family. We provide additional analysis of our office CRE portfolio below in view of increased investor interest in that collateral type in recent periods.
Office CRE loan without any formal pursuit of remedies.portfolio
A decrease in oilAt December 31, 2023 and gas prices could potentially produce an adverse impact onDecember 31, 2022, our office CRE loan portfolio within Texas. However, based upon generally strong equitytotaled $2.0 billion and cash flow coverage levels,$2.3 billion, representing 15% and sponsor support for18% of the various properties, we do not expect a material amount of losses within this portfolio in 2018. Our largest CRE credit exposures in Texas are to the multi-family, office, and retail sectors. At December 31, 2017, thetotal CRE loan portfolio, mixrespectively. Approximately 26% of the office CRE loan portfolio is scheduled to mature in Texas was 72% commercial term, 16% commercial construction, 8% residential construction,the next 12 months. The following schedule presents the composition of our office CRE loan portfolio and 4% land development.other related credit quality metrics:
57


ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Schedule 26
OFFICE CRE LOAN PORTFOLIO
(Dollar amounts in millions)December 31, 2023December 31, 2022
Office CRE
Construction and land development$191 $208 
Term1,793 2,073 
Total office CRE$1,984 $2,281 
Credit quality metrics
Criticized loan ratio11.9 %7.2 %
Classified loan ratio8.9 %5.8 %
Nonaccrual loan ratio2.4 %— %
Delinquency ratio2.3 %1.5 %
Ratio of net loan and lease charge-offs0.2 %— %
Ratio of allowance for credit losses to office CRE loans, at period end3.80 %1.36 %
The following schedules present our office CRE loan portfolio by collateral location for the periods presented:
Schedule 27
OFFICE CRE LOAN PORTFOLIO BY COLLATERAL LOCATION
(Dollar amounts in millions)December 31, 2023
Collateral Location
Loan typeArizonaCaliforniaColoradoNevadaTexasUtah/
Idaho
Wash-ington
Other 1
Total
Office CRE
Construction and land development$— $64 $— $$22 $29 $74 $— $191 
Term281 412 92 86 179 488 226 29 1,793 
Total Office CRE$281 $476 $92 $88 $201 $517 $300 $29 $1,984 
% of total14.2 %24.0 %4.6 %4.4 %10.1 %26.1 %15.1 %1.5 %100.0 %
(Dollar amounts in millions)December 31, 2022
Collateral Location
Loan typeArizonaCaliforniaColoradoNevadaTexasUtah/
Idaho
Wash-ington
Other 1
Total
Office CRE
Construction and land development$$79 $— $$— $18 $101 $— $208 
Term295 525 97 99 217 613 195 32 2,073 
Total Office CRE$303 $604 $97 $101 $217 $631 $296 $32 $2,281 
% of total13.1 %27.0 %4.3 %4.3 %9.6 %26.8 %13.5 %1.4 %100.0 %
1 No other geography exceeds $17 million and $18 million at December 31, 2023 and December 31, 2022, respectively.
Consumer Loans
We have mainly been an originator of first and secondoriginate first-lien residential home mortgages generally considered to be of prime quality. We generally hold variable-rate loans in our portfolio and sell “conforming” fixed-rate loans to third parties, including Federal National Mortgage Association and Federal Home Loan Mortgage Corporation, for which we make representations and warranties that the loans meet certain underwriting and collateral documentation standards.
During 2023, consumer loans increased $1.4 billion, primarily in the 1-4 family residential and consumer construction loan portfolios. Increased funding of construction lending commitments contributed to growth in these portfolios, although the rate of growth slowed in the latter half of the year.
58


ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
We are engaged in Home Equity Credit Linealso originate home equity credit lines (“HECL”HECLs”) lending.. At December 31, 2017,2023 and December 31, 2022, our HECL portfolio totaled $2.8$3.4 billion compared with $2.6 billion at December 31, 2016. The following schedule describes the compositionfor both periods. Approximately 39% and 44% of our HECL portfolioHECLs are secured by lien status.


Schedule 21
HECL PORTFOLIO BY LIEN STATUS
 December 31,
(In millions)2017 2016
    
Secured by first deeds of trust$1,406
 $1,383
Secured by second (or junior) liens1,371
 1,262
Total$2,777
 $2,645
first liens for the same respective time periods.
At December 31, 2017,2023, loans representing less than 1% of the outstanding balance in the HECL portfolio were estimated to have combined loan-to-value ratios (“CLTV”) ratios above 100%. An estimated CLTV ratio is the ratio of our loan plus any prior lien amounts divided by the estimated current collateral-value.collateral value. At origination, underwriting standards for the HECL portfolio generally include a maximum 80% CLTV with higha Fair Isaac Corporation (“FICO”) credit scores at origination.score greater than 700.
Approximately 93%90% of our HECL portfolio is still in the draw period, and approximately 26%about 18% of those loans are scheduled to begin amortizing within the next five years. We regularly analyzebelieve the risk of loss and borrower default in the event of a loan becoming fully amortizing and the riskeffect of highersignificant interest rates. Therate changes is low, given the rate shock analysis indicates that the risk of loss from this factor is minimal in the current economic environment.performed at origination. The ratio of HECL net charge-offs (recoveries) for the trailing twelve months to average balances at year-end 2017December 31, 2023 and 2016 for the HECL portfolioDecember 31, 2022, was 0.02%0.05% and 0.01%(0.03)%, respectively. See Note 6 of the Notes to Consolidated Financial Statements for additional information on the credit quality of thisthe HECL portfolio.
Nonperforming Assets
Nonperforming assets include nonaccrual loans and other real estate owned (“OREO”) or foreclosed properties. The following schedule presents our nonperforming assets:
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Schedule 28
NONPERFORMING ASSETS
(Dollar amounts in millions)December 31,
20232022
Nonaccrual loans:
Loans held for sale$— $— 
Commercial:
Commercial and industrial82 63 
Leasing— 
Owner-occupied20 24 
Municipal— — 
Commercial real estate:
Construction and land development22 — 
Term39 14 
Consumer:
Real estate57 48 
Other— — 
Nonaccrual loans222 149 
Other real estate owned 1:
Commercial:
Commercial properties— 
Developed land— — 
Land— 
Residential:
1-4 family— — 
Other real estate owned— 
Total nonperforming assets$228 $149 
Accruing loans past due 90 days or more:
Commercial:$$
Commercial real estate— — 
Consumer
Total$$
Ratio of nonaccrual loans to net loans and leases 2
0.38 %0.27 %
Ratio of nonperforming assets to net loans and leases2 and other real estate owned
0.39 %0.27 %
Ratio of accruing loans past due 90 days or more to net loans and leases 2
0.01 %0.01 %
1 Does not include banking premises held for sale.
2Includes loans held for sale.
Nonperforming assets as a percentage of loans and leases and other real estate owned (“OREO”) decreasedOREO increased to 0.93%0.39% at December 31, 2017,2023, compared with 1.34%0.27% at December 31, 2016.
2022. Total nonaccrual loans at December 31, 2017 decreased $155increased $73 million, from December 31, 2016,or 49%, during 2023, primarily in the oil and gas-related loan portfolio. However, nonaccrual loans slightly increased in the commercial owner-occupied and 1-4 family residential loan portfolios. The largest total decrease in nonaccrual loans occurred at Amegy.
The balance of nonaccrual loans can decrease due to paydowns, charge-offs,one commercial and the return ofindustrial loan totaling $31 million, and two suburban office commercial real estate loans to accrual status under certain conditions. If a nonaccrual loan is refinanced or restructured, the new note is immediately placed on nonaccrual. If a restructured loan performs under the new terms for at least a period of six months, the loan can be considered for return to accrual status. See “Restructured Loans” following for more information. Company policy does not allow for the conversion of nonaccrual construction and land development loans to CRE term loans.totaling $46 million. See Note 6 of the Notes to Consolidated Financial Statements for more information on nonaccrual loans.

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

Loan Modifications
The following schedule presentsLoans may be modified in the normal course of business for competitive reasons or to strengthen our nonperforming assets:collateral position. Loan modifications may also occur when the borrower experiences financial difficulty and needs temporary or permanent relief from the original contractual terms of the loan.
Schedule 22
NONPERFORMING ASSETS
(Dollar amounts in millions)December 31,
 2017 2016 2015 2014 2013
Nonaccrual loans:         
Loans held for sale$12
 $40
 $
 $
 $
Commercial:  

     

Commercial and industrial195
 354
 164
 106
 101
Leasing8
 14
 4
 
 1
Owner-occupied90
 74
 74
 87
 137
Municipal1
 1
 1
 1
 10
Commercial real estate:         
Construction and land development4
 7
 7
 24
 29
Term36
 29
 40
 25
 60
Consumer:         
Real estate68
 49
 59
 64
 66
Other
 1
 1
 
 2
Nonaccrual loans414
 569
 350
 307
 406
Other real estate owned:         
Commercial:         
Commercial properties3
 2
 5
 11
 16
Developed land
 
 
 
 6
Land
 
 1
 2
 6
Residential:         
1-4 family1
 2
 1
 4
 8
Developed land
 
 
 2
 9
Land
 
 
 
 1
Other real estate owned4
 4
 7
 19
 46
Total nonperforming assets$418
 $573
 $357
 $326
 $452
Ratio of nonperforming assets to net loans and leases1 and other real estate owned
0.93% 1.34% 0.87% 0.81% 1.15%
Accruing loans past due 90 days or more:         
Commercial$17
 $18
 $7
 $8
 $8
Commercial real estate2
 13
 22
 20
 29
Consumer3
 5
 3
 1
 3
Total$22
 $36
 $32
 $29
 $40
Ratio of accruing loans past due 90 days or more to net loans and leases1
0.05% 0.08% 0.08% 0.07% 0.10%
1
Includes loans held for sale.
Restructured Loans
On January 1, 2023, we adopted Accounting Standards Update (“ASU”) 2022-02, Financial Instruments—Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures, which eliminated the recognition and measurement of troubled debt restructurings (“TDRs”) areand their related disclosures. ASU 2022-02 requires enhanced disclosures for loan modifications to borrowers experiencing financial difficulty. During 2023, loans that have been modified to accommodate a borrower who is experiencing financial difficulties and for whom we have granted a concession that we would not otherwise consider. TDRs decreased $25 million, or 10%, during 2017, primarily due to payments and payoffs. Commercial loans may be modified to provide the borrower more time to complete the project, to achieve a higher lease-up percentage, to sell the property, or for other reasons. Consumer loan TDRs represent loan modifications in which a concession has been granted to the borrower who is unable to refinance the loan with another lender, or who is experiencing economic hardship.


totaled $264 million.
If the restructureda modified loan is on nonaccrual and performs for at least six months according to the modified terms, and an analysis of the customer’s financial condition indicates that we are reasonably assured of repayment of the modified principal and interest, the loan may be returned to accrual status. The borrower’s payment performance prior to and following the restructuringmodification is taken into account to determine whether a loan should be returned to accrual status.
Schedule 2329
ACCRUING AND NONACCRUING TROUBLED DEBT RESTRUCTUREDMODIFIED LOANS TO BORROWERS EXPERIENCING FINANCIAL DIFFICULTY
(In millions)December 31,
2023
Modified loans – accruing$247 
Modified loans – nonaccruing17 
Total$264 
 December 31,
(In millions)2017 2016
    
Restructured loans – accruing$139
 $151
Restructured loans – nonaccruing87
 100
Total$226
 $251
In the periods following the calendar year in which aFor additional information regarding loan was restructured, a loan may no longer be reported as a TDR if it is on accrual, is in compliance with its modified terms, and yields a market rate (as determined and documented at the timemodifications to borrowers experiencing financial difficulty, including information related to TDRs prior to our adoption of the modification or restructure). SeeASU 2022-02, see Note 6 of the Notes to Consolidated Financial Statements for additional information regarding TDRs.
Schedule 24
TROUBLED DEBT RESTRUCTURED LOANS ROLLFORWARD
(In millions)2017 2016
    
Balance at beginning of year$251
 $297
New identified troubled debt restructuring and principal increases190
 154
Payments and payoffs(157) (145)
Charge-offs(25) (32)
No longer reported as troubled debt restructuring(4) (10)
Sales and other(29) (13)
Balance at end of year$226
 $251
Statements.
Allowance for Credit Losses
In analyzingThe ACL includes the adequacyALLL and the RULC. The ACL represents our estimate of current expected credit losses related to the loan and lease portfolio and unfunded lending commitments as of the ALLL, we utilize a comprehensive loan grading system to determine the risk potential in the portfolio and also consider the results of independent internal credit reviews.balance sheet date. To determine the adequacy of the allowance, our loan and lease portfolio is broken into segmentssegmented based on loan type.

Schedule 25
SUMMARY OF LOAN LOSS EXPERIENCE
(Dollar amounts in millions)2017 2016 2015 2014 2013
          
Loans and leases outstanding (net of unearned income)$44,780
 $42,649
 $40,650
 $40,064
 $39,043
Average loans and leases outstanding, (net of unearned income)$43,501
 $42,062
 $40,171
 $39,522
 $38,109
Allowance for loan losses:
        
Balance at beginning of year$567
 $606
 $605
 $746
 $896
Provision charged to earnings24
 93
 40
 (98) (87)
Adjustment for FDIC-supported/PCI loans
 
 
 (1) (11)
Charge-offs:
        
Commercial(118) (170) (111) (77) (76)
Commercial real estate(9) (12) (14) (15) (26)
Consumer(17) (16) (14) (14) (29)
Total(144) (198) (139) (106) (131)
Recoveries:
        
Commercial46
 43
 55
 41
 41
Commercial real estate14
 14
 35
 12
 25
Consumer11
 9
 10
 11
 13
Total71
 66
 100
 64
 79
Net loan and lease charge-offs(73) (132) (39) (42) (52)
Balance at end of year$518

$567

$606

$605

$746
Ratio of net charge-offs to average loans and leases0.17% 0.31% 0.10% 0.11% 0.14%
Ratio of allowance for loan losses to net loans and leases, on December 31,1.16% 1.33% 1.49% 1.51% 1.91%
Ratio of allowance for loan losses to nonaccrual loans, on December 31,129% 107% 173% 197% 184%
Ratio of allowance for loan losses to nonaccrual loans and accruing loans past due 90 days or more, on December 31,122% 101% 159% 180% 167%
Schedule 26
ALLOCATION OF THE ALLOWANCE FOR LOAN LOSSES
At December 31,
 2017 2016 2015 2014 2013
(Dollar amounts in millions)% of total loans Allocation of allowance % of total loans Allocation of allowance % of total loans Allocation of allowance % of total loans Allocation of allowance % of total loans Allocation of allowance
Loan segment                   
Commercial51.2% $371
 50.6% $420
 52.9% $454
 53.5% $413
 53.5% $469
Commercial real estate24.8
 103
 26.6
 116
 25.5
 114
 25.3
 145
 26.6
 216
Consumer24.0
 44
 22.8
 31
 21.6
 38
 21.2
 47
 19.9
 61
Total100.0% $518
 100.0% $567
 100.0%
$606
 100.0% $605
 100.0% $746
The total ALLL decreased by $49 million during 2017, primarily as a result of credit quality improvements in the oil and gas-related loan portfolio.
The RULC representsis a reserve for potential losses associated with off-balance-sheetoff-balance sheet commitments and standby letters of credit. The reserve is separately shownincluded in “Other liabilities” on the consolidated balance sheet and anysheet. Any related increases or decreases in the reserve are shown separatelyincluded in “Provision for unfunded lending commitments” on the consolidated statement of income. At December 31, 2017,
The following schedules present the reserve decreased by $7 million compared with December 31, 2016, also as a resultchanges in, and allocation of, credit quality improvements in the total loan portfolio.ACL:

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

Schedule 30
CHANGES IN THE ALLOWANCE FOR CREDIT LOSSES
Year Ended December 31,
(Dollar amounts in millions)202320222021
Loans and leases outstanding,$57,779$55,653$50,851
Average loans and leases outstanding:
Commercial30,51929,22529,580
Commercial real estate13,02312,25112,136
Consumer13,19811,12210,267
Total average loans and leases outstanding$56,740$52,598$51,983
Allowance for loan and lease losses:
Balance at beginning of year 1, 2
$572 $513 $777 
Provision for loan losses148 101 (258)
Charge-offs:
Commercial45 72 35 
Commercial real estate— — 
Consumer14 10 13 
Total62 82 48 
Recoveries:
Commercial20 32 29 
Commercial real estate— — 
Consumer11 10 
Total26 43 42 
Net loan and lease charge-offs36 39 
Balance at end of year$684 $575 $513 
Reserve for unfunded lending commitments:
Balance at beginning of year 1, 2
$61 $40 $58 
Provision for unfunded lending commitments(16)21 (18)
Balance at end of year$45 $61 $40 
Total allowance for credit losses:
Allowance for loan and lease losses$684 $575 $513 
Reserve for unfunded lending commitments45 61 40 
Total allowance for credit losses$729 $636 $553 
Ratio of allowance for credit losses to net loans and leases1.26 %1.14 %1.09 %
Ratio of allowance for credit losses to nonaccrual loans328 %427 %204 %
Ratio of allowance for credit losses to nonaccrual loans and accruing loans past due 90 days or more324 %410 %198 %
Ratio of total net charge-offs to average total loans and leases0.06 %0.07 %0.01 %
Ratio of commercial net charge-offs to average commercial loans0.08 %0.14 %0.02 %
Ratio of commercial real estate net charge-offs to average commercial real estate loans0.02 %— %(0.02)%
Ratio of consumer net charge-offs to average consumer loans0.06 %(0.01)%0.03 %
1 Beginning balances at January 1, 2020 for the allowance for loan and lease losses and reserve for unfunded lending commitments do not agree to their respective ending balances at December 31, 2019 because of the adoption of the CECL accounting standard.
2 The beginning balance at January 1, 2023 for the allowance for loan and lease losses and reserve for unfunded lending commitments do not agree to the ending balance at December 31, 2022 because of the adoption of the new accounting standard related to loan modifications to borrowers experiencing financial difficulties.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Schedule 31
ALLOCATION OF THE ALLOWANCE FOR CREDIT LOSSES
December 31,
202320222021
(Dollar amounts in millions)% of total loansAllocation of ACL% of total loansAllocation of ACL% of total loansAllocation of ACL
Loan segment
Commercial53.0 %$321 54.8 %$316 55.9 %$330 
Commercial real estate23.1 258 22.9 189 24.0 118 
Consumer23.9 150 22.3 131 20.1 105 
Total100.0 %$729 100.0 %$636 100.0 %$553 
The total ACL increased to $729 million in 2023, from $636 million in 2022. The increase in the ACL reflects incremental reserves associated with portfolio-specific risks including commercial real estate, as well as deterioration in economic forecasts. Due to the adoption of the current expected credit loss (“CECL”) standard in 2020, the ACL is not comparable to periods presented prior to that period.
See Note 6 of the Notes to Consolidated Financial Statements for additional information related to the ACL and credit trends experienced in each portfolio segment.
Interest Rate and Market Risk Management
Interest rate and market risk are managed centrally. Interest rate risk is the potential for reduced net interest income and other rate sensitiverate-sensitive income resulting from adverse changes in the level of interest rates. Market risk is the potential for loss arising from adverse changes in the fair value of fixed incomefixed-income securities, equity securities, other earning assets, and derivative financial instruments as a result of changes in interest rates or other factors. As a financial institution that engagesBecause we engage in transactions involving an array ofvarious financial products, we are exposed to both interest rate risk and market risk.
The Company’sOur Board of Directors is responsible for approvingapproves the overallkey policies relating to the management of theour financial risk, of the Company, including interest rate and market risk management. The Board has establisheddelegated the responsibility of managing our interest rate and market risk to the Asset/Liability Committee (“ALCO”) consisting, which consists of members of management, to which it has delegated the responsibility of managing interest rate and market risk for the Company.management. ALCO establishes and periodically revises policy limits and reviews with the ROC the limits and limit exceptions reported by management.
Interest Rate Risk
InterestWe strive to position the Bank for interest rate changes and manage the balance sheet sensitivity to reduce the volatility of both net interest income and economic value of equity (“EVE”). With a higher interest rate environment and the prominent bank closures during the first half of 2023, customer deposit behavior deviated from the trend of relatively low interest rates over the prior 15 years. As a result, customers have been more inclined to (1) move deposits to nonbanking products, such as money market mutual funds, that offer higher interest rates, (2) reduce their balances in noninterest-bearing accounts, or (3) move deposits to other banks deemed “too big to fail,” or those banks having a perceived lower risk is one of the most significant risksfailure. These recently observed changes in deposit behavior caused us to which we are regularly exposed. In general,redevelop our goaldeposit models used in managing interest rate risk, giving more weight to recently observed behavior. These model redevelopments increased the deposit beta for interest-bearing products and increased the percentage of noninterest-bearing deposits that migrate to interest-bearing products. Changes to models are independently reviewed by our Model Risk Management function. Management believes these redeveloped deposit models are more likely to reflect future behavior of deposits, and therefore we manage our interest rate risk exposure on that basis.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
We generally have granular deposit funding, and much of this funding has an indeterminable life with no maturity, and can be withdrawn at any time. Because most deposits come from household and business accounts, their duration is generally longer than the duration of our loan portfolio. As such, we are naturally “asset-sensitive” — meaning that our assets are expected to reprice faster or more significantly than our liabilities. We regularly use interest rate swaps, investment in fixed-rate securities, and funding strategies to manage balance sheetour interest rate risk. These strategies collectively have muted the expected sensitivity to reduceof net interest income volatility due to changes in interest rates.
Over Asset sensitivity measures depend upon the course of the last year,assumptions we have actively reduced the level of asset sensitivity through the purchase of short-to-medium duration agency pass-through securities and funding these purchases by reducing money market investments and increasing short-term borrowings. This repositioning of the investment portfolio has increased current net interest income while dampening the impact of higher rates on net interest income growth. We continue to anticipate higher net interest income in a rising rate environment as our assets reprice more quickly than our liabilities.
As most of our liabilities are comprised of indeterminate maturity and managed rate deposits, behavioral assumptionsuse for these deposits have a significant impact on our projected interest rate risk. We have historically reported two sets of deposit assumptions, fast and slow, to reflect the uncertainty of deposit behavior and its impact on interest rate risk. We have recently updated our deposit models and now disclose interest rate risk for only a single set of deposit behavioral assumptions. The newly implemented method differs from prior methods primarily in the way we treat commercial checking deposits and in the manner by which we determine the portion of deposits that are core deposits. For commercial checking deposits, we have separated the balances into a core amount that is operational or that compensates for billed services, and a complementary excess balance. The excess balance is modeled with a high attrition rate, whereas the core balance runs off more slowly. For other deposit types, the core balance is determined by the average balance over a longer-term horizon, typically 24 to 48 months, and excess balances are modeled with a high attrition rate.
Interest Rate Risk Measurement
We monitor interest rate risk through the use of two complementary measurement methods: net interest income simulation, or Earnings at Risk (“EaR”), and Economic Value of Equity at Risk (“EVE”). EaR analyzes the expected change in near term (one year) net interest income in response to changes in interest rates. In the EVE method, we measure the expected changes in the fair value of equity in response to changes in interest rates.
EaR is an estimate of the change in total net interest income that would be recognized under different rate environments over a one-year period. EaR is measured simulating net interest income under several different scenarios including parallel and nonparallel interest rate shifts across the yield curve, taking into account deposit repricing assumptions and estimates of the possible exercise of embedded options within the portfolio (e.g., a borrower’s ability to refinance a loan under a lower-rate environment). Our policy contains a trigger for a 10%


decline over one-year in rate sensitive income as well as a risk capacity of a 13% decline if rates were to immediately rise or fall in parallel by 200 bps.
EVE is calculated as the fair value of all assets minus the fair value of liabilities. We measure changes in the dollar amount of EVE for parallel shifts in interest rates. Due to embedded optionality and asymmetric rate risk, changes in EVE can be useful in quantifying risks not apparent for small rate changes. Examples of such risks may include out-of-the-money interest rate caps (or limits) on loans, which have little effect under small rate movements but may become important if large rate changes were to occur, or substantial prepayment deceleration for low-rate mortgages in a higher-rate environment. Our policy contains a trigger for an 8% decline in EVE as well as a risk capacity of a 10% decline if rates were to immediately rise or fall in parallel by 200 bps. Exceptions to the EVE limits are subject to notification and approval by the ROC.
Estimating the impact on net interest income and EVE requires that we assess a number of variables and make various assumptions in managing our exposure to changes in interest rates. The assessments address deposit withdrawals and deposit product migration (e.g., customers moving money from checking accounts to certificates of deposit), competitive pricing (e.g., existing loans and deposits are assumed to roll into new loans and deposits at similar spreads relative to benchmark interest rates), loan and security prepayments, and the effects of other similar embedded options. As a result of uncertainty about the maturityrunoff and repricing characteristics of both deposits and loans, we also calculate the sensitivity of EaR and EVE results to key assumptions. The modeled results are highly sensitive to the assumptions used for deposits that do not have specific maturities, such as checking, savings and money market accounts, and also to prepayment assumptions used for loans with prepayment options. We use historical regression analysis as a guide to set such assumptions; however, due to the current low interest rate environment, which has little historical precedent, estimated deposit behavior may not reflect actual future results. Additionally, competition for funding in the marketplace has, and may again result in changes to deposit pricing on interest-bearing accounts that are greater or less than changes in benchmarkbehavior. As interest rates such as LIBOR or the federal funds rate.
Under most rising interest rate environments,rise, we would expect some customers to move balances from demand deposits to interest-bearing accounts such as money market, savings, or certificates of deposit. TheOur models are particularly sensitive to the assumption about the rate of such migration.
In addition, weWe also assume certaina correlation, rates, often referred to as a “deposit beta,” ofwith respect to interest-bearing deposits, wherein the rates paid to customers change at a different pace when compared towith changes in average benchmark interest rates. Generally, certificates of deposit are assumed to have a high correlation, rate, while interest-on-checkinginterest-bearing checking accounts are assumed to have a lower correlation rate. Actual results may differ materially due to factors including competitive pricing, money supply, credit worthiness of the Company, and so forth; however, we use our historical experience as well as industry data to inform our assumptions.correlation. The following schedule presents deposit duration assumptions discussed previously:
The aforementioned migration and correlation assumptions result in deposit durations presented in Schedule 27.
Schedule 2732
DEPOSIT ASSUMPTIONS
December 31, 2023December 31, 2022
ProductEffective duration (unchanged)Effective duration
(+200 bps)
Effective duration (unchanged)Effective duration
(+200 bps)
Demand deposits3.5%3.2%3.6%3.5%
Money market1.5%1.4%2.3%2.0%
Savings and interest-bearing checking2.2%1.9%3.1%2.8%
  December 31, 2017
  New Deposit Method
Product Effective duration (unchanged) Effective duration (+200 bps)
     
Demand deposits 3.4% 3.3%
Money market 1.5% 1.3%
Savings and interest-on-checking 2.6% 2.4%
The effective duration of the deposits has shortened considerably due to faster deposit repricing.
As noted previously, we utilize derivatives to manage interest rate risk. The following schedule presents derivatives that are designated in qualifying hedging relationships at December 31, 2023. Included are the average outstanding derivative notional amounts for each period presented and the weighted average fixed-rate paid or received for each category of cash flow and fair value hedge. Fair value hedges of assets include $2.5 billion in notional of hedges of AFS securities designated under the portfolio layer method that were added during the second quarter of 2023. See Note 7 of the Notes to Consolidated Financial Statements for additional information regarding the impact of these hedging relationships on interest income and expense.

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

Schedule 33
AsDERIVATIVES DESIGNATED IN QUALIFYING HEDGING RELATIONSHIPS
2024202520262027
(Dollar amounts in millions)First QuarterSecond QuarterThird QuarterFourth QuarterFirst QuarterSecond QuarterThird QuarterFourth Quarter
Cash flow hedges
Cash flow hedges of assets 1
Average outstanding notional$1,017$683$350$350$350$350$350$300$108$100
Weighted-average fixed-rate received2.50 %2.55 %2.34 %2.34 %2.34 %2.34 %2.34 %2.13 %1.65 %1.65 %
Cash flow hedges of liabilities 2
Average outstanding notional$500$500$500$500$500$500$$$$
Weighted-average fixed-rate paid3.67 %3.67 %3.67 %3.67 %3.67 %3.67 %— %— %— %— %
2024202520262027202820292030203120322033
Fair value hedges
Fair value hedges of assets 3
Average outstanding notional$4,444$4,558$4,562$4,558$2,428$1,049$1,044$1,037$1,001$973
Weighted-average fixed-rate paid3.24 %3.21 %3.21 %3.21 %2.47 %1.84 %1.83 %1.83 %1.83 %1.82 %
1 Cash flow hedges of assets consist of receive-fixed swaps hedging pools of floating-rate loans. The longest dated cash flow hedge matures in February 2027. Amounts for 2027 have not been prorated to reflect this hedge maturing during the period.
2 Cash flow hedges of liabilities consists of a pay-fixed swaps hedging rolling FHLB advances. This swap matures in May of 2025.
3 Fair value asset hedges consist of pay-fixed swaps hedging fixed-rate AFS securities and fixed-rate commercial loans, as further discussed in Note 7 of the Notes to Consolidated Financial Statements. Increasing notional amounts are due to forward starting swaps.
At December 31, 2023, we had receive-fixed interest rate swaps with an aggregate notional amount of $1.5 billion designated as cash flow hedges of the variability of interest receipts on floating-rate commercial loans. During 2023, we terminated receive-fixed swaps with an aggregate notional amount of $5.0 billion. At December 31, 2023, we had $201 million of net losses deferred in AOCI related to terminated cash flow hedges. Amounts deferred in AOCI from terminated cash flow hedges will be amortized into interest income on a straight-line basis through the original maturity dates indicatedof the hedges as long as the hedged forecasted transactions continue to be expected to occur.
The following schedule summarizes amounts deferred in AOCI related to terminated cash flow hedges that will be fully reclassified into interest income by the fourth quarter of 2027:
Schedule 34
SCHEDULED OCI AMORTIZATION FOR TERMINATED CASH FLOW HEDGES
2024202520262027
(Dollar amounts in millions)First QuarterSecond QuarterThird QuarterFourth QuarterFirst QuarterSecond QuarterThird QuarterFourth Quarter
Cash flow hedges
Cash flow hedges of assets
Periodic amortization of deferred gains (losses)$(28)$(28)$(28)$(23)$(18)$(16)$(13)$(11)$(29)$(8)
Earnings at Risk (EaR) and incorporatingEconomic Value of Equity (EVE)
Incorporating our deposit assumptions and the assumptionsimpact of derivatives in qualifying hedging relationships previously described,discussed, the following schedule shows EaR,presents earnings at risk (“EaR”), or the percentage change in 12-month forward-looking net interest income, and our estimated percentage change in EVE. Both EaR and EVE are based on a static balance sheet size in the first year after theunder parallel interest rate change if interest rates were to sustain immediate parallel changes ranging from -100 bps to +300 bps. These measures highlight the sensitivity to changes in interest rates across various scenarios; the outcomes are not intended to be forecasts of expected net interest income.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Schedule 2835
INCOME SIMULATION – CHANGE IN NET INTEREST INCOME AND CHANGE IN ECONOMIC VALUE OF EQUITY
December 31, 2023December 31, 2022
Parallel shift in rates (in bps)Parallel shift in rates (in bps)
Repricing scenario-1000+100+200+300-1000+100+200+300
Earnings at Risk
(EaR)
(2.5)%— %2.4 %4.9 %7.4 %(2.4)%— %2.4 %4.8 %7.1 %
Economic Value of Equity
(EVE)
2.8 %— %(1.4)%(3.3)%(5.2)%2.0 %— %(1.1)%(2.3)%(3.7)%
  December 31, 2017
  
Parallel shift in rates (in bps)1
Repricing scenario -100 0 +100 +200 +300
           
Earnings at Risk (2.7)% % 2.8% 5.4% 7.8%
1
Assumes rates cannot go below zero in the negative rate shift.
The asset sensitivity, as measured by EaR, increased slightly during 2023, primarily due to an increase in pay-fixed interest rate swap notional, partially offset by deposit migration from low beta products (e.g., checking accounts) to high beta products (e.g., money market accounts). Under our current deposit assumptions, interest rate risk remains within policy limits. For non-maturity interest-bearing deposits with indeterminable maturities, the weighted average modeled beta is 36.2%53%. If
Prepayment assumptions are an important factor in how we manage interest rate risk. Certain assets in our portfolio, such as 1-4 family residential mortgages and mortgage-backed securities, can be prepaid at any time by the weighted average deposit beta increasedborrower, which may significantly affect our expected cash flows. At December 31, 2023, lifetime prepayment speeds on loans and mortgage-backed securities were estimated to 46.2% it would decrease the EaR in the +200bp shock from 5.4% to 2.9%.be 8.7% and 6.1%, respectively.
The EaR analysis focuses on parallel rate shocks across the term structure of benchmark interest rates. The yield curve typically does not move inIn a parallel manner. During the past year, annon-parallel rate scenario where shorter-term rates increase in short-term rates has led to a flatter yield curve as longer-term rates have not increased at the same pace as short-term rates. If we consider a flattening rate shock where the short-term rate moves +200bpslightly, but the ten-year rate only moves +30bp,increases by 200 bps, the increase in earnings is 33% lowerEaR would be approximately 50 percent larger than the change associated with the parallel +200 bps rate change.
EaR has inherent limitations in describing expected changes in net interest income in rapidly changing interest rate environments due to a lag in asset and liability repricing behavior. As such, we expect net interest income to change due to “latent” and “emergent” interest rate sensitivity. Unlike EaR, which measures net interest income over 12 months, latent and emergent interest rate sensitivity explains changes in current quarter net interest income, compared with expected net interest income in the parallel +200bpsame quarter one year forward.
Latent interest rate shock.
For comparative purposes,sensitivity refers to future changes in net interest income based upon past rate movements that have yet to be fully recognized in revenue, but will be recognized over the near term. We expect latent sensitivity to increase net interest income by approximately 1% at December 31, 2016 measures as presented in the following schedule have been recalculated using the new methodology.
2024, compared with December 31, 2023.
  December 31, 2016
  
Parallel shift in rates (in bps)1
Repricing scenario -100 0 +100 +200 +300
           
Earnings at Risk (4.9)% % 3.6% 7.6% 11.5%
1
Assumes rates cannot go below zero in the negative rate shift.
The asset sensitivity as measured by EaR declined year-over-year due to continued purchases of medium-term securities funded through reductions in money market investments and increases in short-term borrowings.
Schedule 29
CHANGES IN ECONOMIC VALUE OF EQUITY
As of the dates indicated and incorporating the assumptions previously described, the following schedule shows our estimated percentage change in EVE under parallelEmergent interest rate sensitivity refers to future changes rangingin net interest income based upon future interest rate movements and is measured from -100 bps to +300 bps. Fornon-maturity interest-bearing deposits, the weighted average modeled beta is 36.2%.latent level of net interest income. If interest rates rise consistent with the weighted average deposit beta increased to 46.2% it would decrease the EVE in the +200bp shock from 0.3% to -2.2%.
  December 31, 2017
  
Parallel shift in rates (in bps)1
Repricing scenario -100 bps 0 bps +100 bps +200 bps +300 bps
           
Economic Value of Equity 0.2% % 0.5% 0.3% 0.2%
1
Assumes rates cannot go below zero in the negative rate shift.


For comparative purposes, theforward curve at December 31, 2016 measures as presented2023, we expect emergent sensitivity to increase net interest income by approximately 1% from the latent sensitivity level, for a cumulative 2% increase in the following schedule have been recalculated using the new methodology. The changes in EVE measures are driven by the same factors as those in our income simulation.net interest income.
  December 31, 2016
  
Parallel shift in rates (in bps)1
Repricing scenario -100 bps 0 bps +100 bps +200 bps +300 bps
           
Economic Value of Equity 0.3% % 1.2% 2.9% 4.9%
1
Assumes rates cannot go below zero in the negative rate shift.
Our focus on business banking also plays a significant role in determining the nature of the Company’sour asset-liability management posture. At December 31, 2017, $19.82023, $26.3 billion of the Company’sour commercial lending and CRE loan balances were scheduled to reprice in the next six months. Of these variable-rate loans approximately 94% are tied to either the prime rate or LIBOR. For these variable-rate loans, we have executed $1.1$1.5 billion of cash flow hedges by receiving fixed rates on interest rate swaps. Additionally, asset sensitivity is reduced due to $0.2 billion of variable-rate loans being priced at floored rates at December 31, 2017, which were above the “index plus spread” rate by an average of 60 bps. At December 31, 2017,2023, we also had $3.3$3.7 billion of variable-rate consumer loans scheduled to reprice in the next six months. Of these variable-rateThe impact on asset sensitivity from commercial or consumer loans approximately $0.1 billion were priced at flooredwith floors has become insignificant as rates which were above the “index plus spread” rate by an average of 42 bps.
have risen. See Notes 3 and 7 of the Notes to Consolidated Financial Statements for additional information regarding derivative instruments.
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LIBOR Transition
The London Interbank Offered Rate (“LIBOR”) was phased out globally, and banks migrated to alternative reference rates by June 30, 2023. We implemented processes, procedures, and systems to mitigate contract risk. We believe we have remediated our LIBOR exposure through fallback language, replacement indices, and reliance upon the provisions under the LIBOR Act.
Market Risk Fixed Income
We engageare exposed to market risk through changes in thefair value. This includes market risk for trading securities and for interest rate swaps used to hedge interest rate risk. We underwrite municipal and corporate securities. We also trade municipal, agency, and treasury securities. This underwriting and trading of municipal securities. This trading activity exposes us to a risk of loss arising from adverse changes in the prices of these fixed incomefixed-income securities.
At December 31, 2017, we had a relatively small amount, $148 million, of trading assets and $95 million of securities sold, not yet purchased, compared with $115 million and $25 million, respectively, at December 31, 2016.
We are exposed to market risk through changes in fair value. We are also exposed to market risk for interest rate swaps used to hedge interest rate risk. Changes in the fair value of AFS securities and in interest rate swaps that qualify as cash flow hedges are included in AOCI for each financial reporting period. During 2017,2023, the $66 million after-tax changedecrease in AOCI attributableloss related to investment securities was driven largely by paydowns on the AFS securities. For more discussion regarding investment securities decreased by $3 million, due largelyand AOCI, see the “Capital Management” section on page 72. See also Note 5 of the Notes to changes inConsolidated Financial Statements for further information regarding the interest rate environment, compared with a $74 million decrease in the same prior year period.accounting for investment securities.
Market Risk Equity Investments
Through our equity investment activities, we own equity securities that are publicly-traded.publicly traded. In addition, we own equity securities in companies and governmental entities and companies, e.g., Federal Reserve BankFRB and anthe FHLB, that are not publicly-traded. The accounting for equitypublicly traded. Equity investments may use thebe accounted for at cost less impairment and adjusted for observable price changes, fair value, the equity method, or proportional or full consolidation methods of accounting, depending on our ownership position and degree of involvement in influencinginfluence over the investees’ affairs.business. Regardless of the accounting method, the valuevalues of our investment isinvestments are subject to fluctuation. Because the fair value of these securities may fall below our investment costs,the cost at which we acquired them, we are exposed to the possibility of loss. Equity investments in private and public companies are approved,evaluated, monitored, and evaluatedapproved by the Company’smembers of management in our Equity Investments Committee consisting of members of management.and Securities Valuation Committee.
We hold both direct and indirect investments in predominantly pre-public companies, primarily through various Small Business Investment Company (“SBIC”)SBIC venture capital funds.funds as a strategy to provide beneficial financing, growth, and expansion opportunities to diverse businesses generally in communities within our geographic footprint. Our equity exposure to these investments was approximately $127$190 million and $124$172 million at December 31, 20172023 and December 31, 2016,2022, respectively. On occasion, some of the companies within our SBIC investmentsportfolio may issue an initial public offering.offering (“IPO”). In this case, the fund is generally subject to a lockout period before liquidatingwe can liquidate the investment, which can introduce additional market risk. During the fourth quarter of 2017 we sold the remaining amount of our publicly-traded direct investment and as of December 31, 2017, we had no publicly-traded stocks as part of our direct SBIC investments.


Additionally, Amegy has an alternative investments portfolio. These investments are primarily directed towards equity buyout and mezzanine funds with a key strategy of deriving ancillary commercial banking business from the portfolio companies. Early stage venture capital funds are generally not a part of the strategy because the underlying companies are typically not creditworthy. The carrying value of Amegys equity investments was $12 million at December 31, 2017 and $13 million at December 31, 2016.
These PEIs are subject to the provisions of the Dodd-Frank Act. The Volcker Rule of the Dodd-Frank Act prohibits banks and bank holding companies from holding PEIs, except for SBIC funds and certain other permitted exclusions, beyond a required deadline. The FRB announced in December 2016 that it would allow banks to apply for an additional five-year extension beyond the July 21, 2017 deadline to comply with the Dodd-Frank Act requirement for these investments. The Company applied for and was granted an extension for its eligible PEIs. All positions in the remaining portfolio of PEIs are subject to the extended deadline or other applicable exclusions.
As of December 31, 2017, such prohibited PEIs amounted to $3 million, with an additional $4 million of unfunded commitments (see Notes 5 and 15See Note 3 of the Notes to Consolidated Financial Statements for more information). We currently do not believe that this divestiture requirement will ultimately have a material impact onadditional information regarding the valuation of our financial statements.SBIC investments.
Liquidity Risk Management
Overview
Liquidity risk is the possibility thatrefers to our ability to meet our cash, contractual, and collateral obligations, and to manage both expected and unexpected cash flows may not be adequate to fundwithout adversely impacting our ongoing operations and meet our commitments in a timely and cost-effective manner. Since liquidity risk is closely linked to both credit risk and market risk, many of the previously discussed risk control mechanisms also apply to the monitoring and management of liquidity risk.or financial strength. We manage our liquidity to provide adequate funds for our customers’ credit needs, or capital plan actions and our anticipated financial and contractual obligations, which include withdrawals by depositors, debt and capital service requirements, and lease obligations.
Overseeing liquidity management is the responsibility of ALCO, which implements a Board-approvedother corporate Liquidity and Funding Policy. This policy addresses monitoring and maintaining adequate liquidity, diversifying funding positions, and anticipating future funding needs. The policy also includes liquidity ratio guidelines, such as the “time-to-required funding” and LCR, that are used to monitor the liquidity positions of the Parent and ZB, N.A., as well as various stress test and liquid asset measurements for the Parent and ZB, N.A.
The managementactivities. Sources of liquidity include deposits, borrowings, and equity. Our investment securities are primarily held as a source of contingent liquidity. We generally own securities that can readily provide us with cash and liquidity through secured borrowing agreements with securities pledged as collateral.
Our Treasury group manages our liquidity and funding, is performed centrally for the Parent and jointly by the Parent and bank management for its subsidiary bank. The Treasury Department performs this management centrally, under the direction of the Corporate Treasurer, with oversight by ALCO. The Treasurer is responsible for recommending changes to existing funding plans as well asand our policies related to the Company’s Liquidity Policy.liquidity and funding. These recommendations must beare submitted for approval to ALCO, and changes to the Policypolicies are also must be approved by the Company’s ERMC and the Board of Directors. The Company has adopted policy limits that govern liquidity risk. The policy requires the Company toBoard. We maintain a buffer of highly liquid assets sufficient to cover cash outflows in the event of a severe liquidity crisis. The Company targets a buffer of highly liquid assets at the Parent to cover 18-24 months of cash outflows under a scenario with limited cash inflows, and maintains a minimum policy limit of not less than 12 months. The consolidated Company exceeds the regulatory requirements of the Modified LCR that mandates a buffer of HQLA to cover 70% of 30-day cash outflows under the assumptions mandated in the Final Liquidity Rule. Additionally, the Company performs monthly liquidity stress testing using a set of internally generated scenarios representing severe liquidity constraints over a 12-month horizon. ZB, N.A. maintains a buffer of highly liquid assets consisting of cash, U.S. Agency, and U.S. Government Sponsored Entity securities to cover 30-day cash outflows under liquidity stress tests and maintainsregularly test a contingency funding plan to identify sources and uses of liquidity. Our Board-approved liquidity policy requires us to monitor and maintain adequate liquidity, diversify funding sources that would be utilized over the extended 12-month horizon. Throughout 2017positions, and as of December 31, 2017, the Company compliedanticipate future funding needs. In accordance with this policy.policy, we monitor our liquidity positions by

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conducting various stress tests and evaluating certain liquid asset measurements, such as a 30-day liquidity coverage ratio.
Liquidity Regulation
U.S. banking regulators issued a final rule in 2014 that implements a quantitative liquidity requirement in the U.S. generally consistent with the LCR minimum liquidity measure established under the Basel III liquidity framework. Under this rule, we are subject to a modified LCR standard, which requires a financial institution to hold an adequate amount of unencumbered HQLA that can be converted into cash easily and immediately in private markets to meet its liquidity needs for a short-termWe perform regular liquidity stress scenario. This rule became applicable to us on January 1, 2016.
The Basel III liquidity framework includes a second minimum liquidity measure, the NSFR, which requires a financial institution to maintain a stable funding profile over a one-year period in relation to the characteristics of its on-tests and off-balance sheet activities. On October 31, 2014, the Basel Committee on Banking Supervision issued its final standards for this ratio, entitled Basel III: The Net Stable Funding Ratio. On May 3, 2016, the FRB issued a proposal requiring bank holding companies with less than $250 billion of assets, but more than $50 billion of assets, to cover 70% of 1-year cash outflows under the assumptions required in the proposed NSFR Rule. Under the proposal, bank holding companies would be required to publicly disclose information about the NSFR levels each quarter. As of December 31, 2017, the FRB has not published final rules on the NSFR. We continue to monitor this proposal and any other developments. Based on this Basel III publication and the FRB proposal, we believe we would meet the minimum NSFR if such requirement were currently effective.
The Enhanced Prudential Standards for liquidity management (Reg. YY) require us to conduct monthly liquidity stress tests. These tests incorporate scenarios designed by us, require a bufferassess our portfolio of highly liquid assets sufficient(sufficient to cover 30-day funding needs under stress scenarios). These stress tests include projections of funding maturities, uses of funds, and assumptions of deposit runoff. The assumptions consider the stress scenarios,size of deposit account, operational nature of deposits, type of depositor, and concentrations of funding sources including large depositors and aggregate levels of uncollateralized deposits exceeding insured levels. Concentrated funding sources are subjectgiven large runoff factors up to review by the FRB. The Company’s internal100% in projecting stressed funding needs. Our liquidity stress testing considers multiple timeframes ranging from overnight to 12 months. Our liquidity policy requires us to maintain sufficient on-balance sheet liquidity in the form of FRB reserve balance and other highly liquid assets to meet stressed outflow assumptions.
We have a dedicated funding desk that monitors real-time inflows and outflows of our FRB account, and we have tools, including ready access to repo markets and FHLB advances, to manage intraday liquidity. FHLB borrowings are “open-term,” allowing us the ability to retain or return funds based on our liquidity needs. We pledge a large portion of our highly liquid investment securities portfolio through the General Collateral Funding (“GCF”) repo program. Through this program, as contained in its policy complies with these requirementshigh-quality collateral is pledged, and includes monthly liquidity stress testing using a set of internally generated scenarios representing severe liquidity constraints over a 12-month horizon.program participants exchange funds anonymously, which allows for near instant access to funding during market hours.
Contractual Obligations
Schedule 30 summarizes our contractual obligations at December 31, 2017.
Schedule 30
CONTRACTUAL OBLIGATIONS
(In millions)One year or less Over one year through three years Over three years through five years Over five years 
Indeterminable maturity 1
 Total
            
Deposits$2,584
 $388
 $142
 $1
 $49,506
 $52,621
Net unfunded commitments to extend credit6,227
 5,202
 3,361
 4,793
 
 19,583
Standby letters of credit:          

Financial461
 25
 54
 181
 
 721
Performance149
 46
 1
 
 
 196
Commercial letters of credit31
 
 
 
 
 31
Commitments to make venture and other noninterest-bearing investments 2
31
 
 
 
 
 31
Federal funds and other short-term borrowings4,976
 
 
 
 
 4,976
Long-term debt
 1
 
 382
 
 383
Operating leases, net of subleases40
 75
 54
 76
 
 245
Unrecognized tax benefits
 6
 
 
 
 6
Total contractual obligations$14,499
 $5,743
 $3,612
 $5,433
 $49,506
 $78,793
1
Indeterminable maturity deposits include noninterest-bearing demand, savings and money market.
2
Commitments to make venture and other noninterest-bearing investments do not have defined maturity dates. They have therefore been considered due on demand, maturing in one year or less.


In additionAdditionally, we have pledged collateral to the commitments specifically notedFRB’s primary credit facility (or discount window) and the Bank Term Funding Program (“BTFP”), which provide additional contingent funding sources outside the normal operating hours of the FHLB and the GCF program. The BTFP offers loans of up to one year in Schedule 30, we enter into a number of contractual commitments in the ordinary course of business. These include software licensinglength to eligible depository institutions pledging U.S. Treasuries, agency debt and maintenance, telecommunications services, facilities maintenance and equipment servicing, supplies purchasing,government mortgage-backed securities, and other goods and services used inqualifying assets as collateral. Unlike other funding sources, borrowing capacity under the operation of our business. Generally, these contracts are renewable or cancelable at least annually, although in some cases to secure favorable pricing concessions, we have committed to contracts that may extend to several years.
We also enter into derivative contracts under which we are required either to receive or pay cash, depending on changes in interest rates. These contracts are carried at fair valueBTFP is based on the balance sheet withpar value, not the fair value, representingof collateral. Advances can be requested under the net present valueprogram through mid-March 2024.
During 2023, the primary sources of the expected future cash receipts and payments based on market rates of interest. The fair value of the contracts changes daily as interest rates change. See Note 7 of the Notes to Consolidated Financial Statements for further information on derivative contracts.
Liquidity Management Actions
Consolidated cash, interest-bearing deposits held as investments, and security resell agreements at the Parent and its subsidiaries decreased to $1.6 billion at December 31, 2017came from $2.5 billion at December 31, 2016. The $0.9 billion decrease during 2017 resulted primarily from (1) Net loan originations and purchases, (2) an increase in deposits, a decrease in investment securities, (3) aand net decrease in deposits, (4) repurchasemoney market investments. Uses of our common stock, (5) repayment of our long-term debt, (6) repurchasecash during the same period primarily included a decrease in short-term borrowings, an increase in loans and redemption of our preferred stock,leases, and (7) dividends paid on common and preferred stock. These decreasesCash payments for interest reflected in operating expenses were partially offset by short-term$1.4 billion and $160 million during 2023 and 2022, respectively.
The FHLB borrowings and net cash provided by operating activities.
During 2017 our HTMFRB have been, and AFS investment securities increased by $1.7 billion. This increase was primarily duecontinue to purchasesbe, a significant source of short-to-medium duration agency guaranteed mortgage-backed securities. Prior to the second quarter of 2017, we were adding to our investment portfolio during the past couple of years to increase our HQLA position in lightback-up liquidity and funding. We are a member of the new LCR rulesFHLB of Des Moines, which allows member banks to borrow against eligible loans and more broadly,securities to manage balance sheetsatisfy liquidity more effectively. However, during the second through the fourth quarters of 2017,and funding requirements. We are required to invest in FHLB and FRB stock to maintain our HTMborrowing capacity. At December 31, 2023, our total investment in FHLB and AFS investment securities decreased by $490FRB stock was $79 million and we expect the size of the investment portfolio to be generally stable during the next several quarters.
During 2017 we made cash payments totaling $153$65 million, for our long-term debt which maturedrespectively, compared with $294 million and did not incur any new long-term debt during the same time period. See Note 12 for additional detail about debt maturities and redemptions during 2017 and 2016. During 2017, we also increased our short-term debt with the FHLB by $3.1 billion, and had $3.6 billion outstanding as of December 31, 2017.
Parent Company Liquidity – The Parent’s cash requirements consist primarily of debt service, investments in and advances to subsidiaries, operating expenses, income taxes, and dividends to preferred and common shareholders. The Parent’s cash needs are usually met through dividends from its subsidiaries, interest and investment income, subsidiaries’ proportionate shares of current income taxes, and long-term debt and equity issuances.
Cash and interest-bearing deposits held as investments at the Parent decreased to $332 million at December 31, 2017 from $531$68 million at December 31, 2016. This $1992022. Average FHLB activity stock holdings in 2023 was $179 million, decrease during 2017 resulted primarily from (1) repurchase of our common stock, (2) repayment of long-term debt, (3) repurchase and redemption of our preferred stock and (4)compared with $61 million in 2022, which contributed to the increase in dividends on our common and preferred stock. This decrease in cash was partially offset by common dividends and return of common equity and preferred dividends received byFHLB activity stock during the Parent from its subsidiary bank. See Notes 12 and 13 of the Notes to Consolidated Financial Statements for additional information about our long-term debt and equity transactions.year.
During 2017, the Parent received common dividends and return of common equity totaling $534 million and preferred dividends totaling $53 million from its subsidiary bank. During 2016 the Parent received common dividends and return of common equity totaling $250 million and preferred dividends totaling $13 million from its subsidiary bank. At December 31, 2017, ZB, N.A., had $417 million available2023, loans with a carrying value of $24.8 billion and $11.5 billion, compared with $23.7 billion and $3.9 billion at December 31, 2022, were pledged at the FHLB and FRB, respectively, as collateral for the payment of dividends under current capital regulations. The dividends that ZB, N.A. can pay are restricted by current and historical earning levels, retained earnings,potential borrowings.
At December 31, 2023 and risk-basedDecember 31, 2022, investment securities with a carrying value of $20.5 billion and $13.5 billion, respectively, were pledged as collateral for potential borrowings. For the same time periods, these pledges included $9.5 billion and $8.3 billion for available use through the GCF repo program, $5.5 billion and $1.0 billion to the FRB, and $5.5 billion and $4.2 billion to secure collateralized public and trust deposits, advances, and for other regulatory capital requirements and limitations.purposes.
A large portion of these pledged assets are unencumbered, but are pledged to provide immediate access to contingency sources of funds. The following schedule presents our total available liquidity including unused collateralized borrowing capacity:

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Schedule 36
AVAILABLE LIQUIDITY
December 31, 2023December 31, 2022
(Dollar amounts in billions)FHLBFRBGCFBTFPTotalFHLBFRBGCFBTFPTotal
Total borrowing capacity$16.6 $9.8 $9.6 $5.8 $41.8 $16.6 $4.0 $8.4 $— $29.0 
Borrowings outstanding1.6 — 1.8 — 3.4 7.2 — 2.7 — 9.9 
Remaining capacity, at period end$15.0 $9.8 $7.8 $5.8 $38.4 $9.4 $4.0 $5.7 $— $19.1 
Cash and due from banks0.7 0.7 
Interest-bearing deposits 1
1.5 1.3 
Total available liquidity$40.6 $21.1 
Ratio of available liquidity to uninsured deposits122 %56 %
1 Represents funds deposited by the Bank primarily at the Federal Reserve Bank.
At December 31, 2023 and December 31, 2022, our total available liquidity was $40.6 billion, compared with $21.1 billion, respectively. At December 31, 2023, we had sources of liquidity that exceeded our uninsured deposits without the need to sell any investment securities.
Credit Ratings
General financial market and economic conditions impact our access to, and cost of, external financing. Access to funding markets for the Parent and its subsidiary bank is also directly affected by the credit ratings receivedwe receive from various rating agencies. The ratings not only influence the costs associated with the borrowings, but can also influence the sources of the borrowings. The debt ratings and outlooks issued byAll of the variouscredit rating agencies for the Company and ZB, N.A. improved during 2017 and are shown in therate our debt at an investment-grade level.
The following schedules.schedule presents our credit ratings:
Schedule 31 presents the Company’s and ZB, N.A.’s ratings as of December 31, 2017.37
Schedule 31
CREDIT RATINGS
as of January 31, 2024:
CompanyZB, N.A.CompanyZB, N.A.CompanyZB, N.A.
Rating agencyOutlookOutlook Long-term issuer/senior
debt rating
Subordinated debt ratingShort-term debt rating
KrollStableA-BBB+K2
S&PNegativePositiveBBB+PositiveBBBBBB-BBBBB+A-2NR
Moody’sFitchStableStableBBB+StableBBBBaa3Baa3P-2F2
KrollMoody’sStablePositiveBaa2PositiveNRBBBBBB+BBB-K2P2
TheUncertainties in the banking industry during 2023 resulted in ratings pressure for a number of banks, including Zions. As a result, the credit rating agencies all ratetook the Company’sfollowing actions related to our issuer, debt, and ZB, N.A.’s seniordeposit ratings:
In April 2023, Moody’s downgraded our long-term issuer rating to Baa2 from Baa1, our short-term debt at an investment-grade level. rating to P2 from P1, and changed their outlook on our long-term deposit and issuer ratings to “Stable” from “Ratings under review.”
In addition, Kroll rates the Company’s subordinated debt at an investment-grade level, whileMay 2023, S&P rates the Company’schanged their outlook on our long-term deposit and issuer ratings to “Negative” from “Stable.”
In October 2023, Fitch downgraded our short-term debt rating to F2 from F1.
In November 2023, Kroll changed their outlook on our long-term deposit and issuer ratings to “Stable” from “Positive.”
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
We may, from time to time, issue additional preferred stock, senior or subordinated notes, or other forms of capital or debt instruments, depending on our capital, funding, asset-liability management, or other needs as noninvestment-grade.market conditions warrant. These additional issuances may be subject to required regulatory approvals. We believe that our sources of available liquidity are adequate to meet all reasonably foreseeable short- and intermediate-term demands.
For more information about a recent regulatory proposal that would expand long-term debt requirements and impact our sources of available liquidity, see “Recent Regulatory Developments” on page 8 in Supervision and Regulation.
Contractual Obligations
The Parent’s cash payments for interest, reflected in operating expenses, decreased to $26 million in 2017 from $35 million in 2016 due to the maturity and repayment of long-term debt during 2017 and 2016, partially offset by the increase in interest from short-term FHLB advances. Additionally, the Parent paid approximately $129 million of total dividends on preferred stock and common stock for 2017 compared to $108 million for 2016.
Note 22 of the Notes to Consolidated Financial Statements contains the Parent’s statements of income and cash flows for 2017, 2016 and 2015, as well as its balance sheetsfollowing schedule summarizes our contractual obligations at December 31, 20172023:
Schedule 38
CONTRACTUAL OBLIGATIONS
(In millions)One year or lessOver one year through three yearsOver three years through five yearsOver five years
Indeterminable maturity 1
Total
Deposits$9,798 $155 $42 $$64,965 $74,961 
Unfunded lending commitments7,995 8,372 3,512 9,061 — 28,940 
Standby letters of credit:
Financial548 — — — — 548 
Performance206 — — — — 206 
Commercial letters of credit22 — — — — 22 
Mortgage-backed security purchase agreements 2
— — — 66 — 66 
Commitments to make venture and other noninterest-bearing investments 3
— — — — 62 62 
Federal funds and other short-term borrowings4,379 — — — — 4,379 
Long-term debt 4
— — 88 500 — 588 
Operating leases42 67 40 83 — 232 
Total contractual obligations$22,990 $8,594 $3,682 $9,711 $65,027 $110,004 
1 Indeterminable maturity deposits include noninterest-bearing demand, savings, and 2016.money market deposits.
At December 31, 2017, maturities2Represents agreements with Farmer Mac to purchase securities backed by certain agricultural mortgage loans.
3 Commitments to make venture and other noninterest-bearing investments do not have defined maturity dates. They are due upon demand and may be drawn immediately. Therefore, these commitments are shown as having indeterminable maturities.
4 The values presented do not reflect the impact of associated fair value hedges.
In addition to the commitments specifically noted in the schedule above, we enter into a number of contractual commitments in the ordinary course of business. These include software licensing and maintenance, telecommunications services, facilities maintenance and equipment servicing, supplies purchasing, and other goods and services used in the operation of our long-term seniorbusiness. Some of these contracts are renewable or cancellable annually or in shorter time intervals. To secure favorable pricing concessions, we may also commit to contracts that may extend several years.
We enter into derivative contracts that may require us to pay cash, depending on changes in interest rates. These contracts are measured at fair value on the balance sheet, reflecting the net present value of the expected future cash receipts and subordinated debt ranged from June 2023 to September 2028, with effectivepayments based on market interest rates from 4.50% to 6.95%.
rates. See Note 127 of the Notes to Consolidated Financial Statements for a complete summary of our long-term debt.further information on derivative contracts.
Subsidiary Bank Liquidity – ZB, N.A.’s primary source of funding is its core deposits, consisting of demand, savings
Operational, Technology, and money market deposits, and time deposits under $250,000. On a consolidated basis, the Company’s loan to total deposit ratio was 85.1% as of December 31, 2017, compared to 80.1% as of December 31, 2016, reflecting loan growth and a decrease in deposits during 2017.
Total deposits decreased by $615 million to $52.6 billion at December 31, 2017, compared to $53.2 billion at December 31, 2016. This decrease was a result of a $744 million decrease in savings and money market deposits and a $229 million decrease in noninterest-bearing demand deposits. The decrease was partially offset by a $358 million increase in time deposits. Also, during the first quarter of 2017, ZB, N.A. redeployed approximately $2.6 billion of cash to short-to-medium duration agency guaranteed mortgage-backed securities.
ZB, N.A.’s long-term senior debt ratings are slightly better than the Company’s long-term senior debt ratings. Moody’s rated both ZB, N.A.’s and the Company’s long-term senior debt as Baa3. However, Standard & Poor’s and Kroll both rated ZB, N.A.’s long-term senior debt one notch higher than the Company’s ratings (see Schedule 31).
The FHLB system and Federal Reserve Banks have been and are a source of back-up liquidity, and from time to time, have been a significant source of funding. ZB, N.A. is a member of the FHLB of Des Moines. The FHLB allows member banks to borrow against their eligible loans and securities to satisfy liquidity and funding requirements. The Bank is required to invest in FHLB and Federal Reserve stock to maintain their borrowing capacity.


At December 31, 2017, the amount available for additional FHLB and Federal Reserve borrowings was approximately $14.7 billion, compared with $17.1 billion at December 31, 2016. Loans with a carrying value of approximately $25.6 billion at December 31, 2017 have been pledged at the FHLB of Des Moines and the Federal Reserve as collateral for current and potential borrowings compared with $24.0 billion at December 31, 2016. At December 31, 2017, we had $3.6 billion of short-term FHLB borrowings outstanding and no long-term FHLB or Federal Reserve borrowings outstanding, compared with $500 million of short-term FHLB borrowings and no long-term FHLB or Federal Reserve borrowings outstanding at December 31, 2016. At December 31, 2017, our total investment in FHLB and Federal Reserve stock was $154 million and $184 million, respectively, compared with $30 million and $181 million at December 31, 2016. Our increased investment in FHLB stock was a result of our increase in short-term FHLB borrowings during 2017.
Our investment activities can provide or use cash, depending on the asset-liability management posture taken. During 2017, HTM & AFS investment securities’ activities resulted in a net increase in investment securities and a net $2.2 billion decrease in cash compared with a net $5.9 billion decrease in cash for 2016.
Maturing balances in our subsidiary bank’s loan portfolios also provide additional flexibility in managing cash flows. Lending activity for both 2017 and 2016 resulted in a net cash outflow of $2.1 billion.
During 2017, we paid income taxes of $246 million, compared to $214 million during 2016.Cybersecurity Risk Management
Operational Risk Management
Operational risk is the risk to current or anticipated earnings or capital arising from inadequate or failed internal processes or systems, human errors or misconduct, or adverse external events. In our ongoing efforts to identify and manage operational risk, we have an ERM department whose responsibility is to helpassists employees, management, and the Board of Directors to assess, understand, measure, manage,with assessing, measuring, managing, and monitormonitoring this risk in accordance with our
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Risk AppetiteManagement Framework. WeFor example, we have documented both controls and the Control Self-Assessmentcontrol self-assessments related to financial reporting under the 2013 framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”) and the FDICIA.
ToWe have instituted a number of measures to manage and minimize our operational risk, we have in placeincluding, but not limited to: (1) transactional documentation requirements; (2) systems and procedures to monitor transactions and positions; (3) systems and procedures to detect and mitigate attempts to commit fraud, penetrate our systems, or telecommunications, access customer data, and/or deny normal access to those systems to our legitimate customers; (4) regulatory compliance reviews; and (5) periodic reviews by the Company’sour Compliance Risk Management, Internal Audit, Operational Risk Management, and Credit Examination departments. Reconciliation procedures have been established to ensure that data processing systems consistently and accurately capture critical data. In addition, the Data Governance department has key governance surroundingprovides additional oversight of data integrity and data availability. Further, we have key programs and procedures to maintain contingencydisaster recovery and business continuity plans for operational support in the event of natural or other disasters. We also mitigate certain operational risks through the purchase of insurance, including errors and omissions and professional liability insurance.
We are continually improvingstrive to improve our oversight of operational risk management, including enhancement of risk identification, risk and control self-assessments, business process mappings, regular tests of controls, and antifraudanti-fraud measures, which are reported on a regular basis to enterprise management committees. The Operational Risk Committee reports to the ERMC, which reports to the ROC. Key measures have been established in line with our Risk Management Framework to increase oversight by ERM and Operational Risk Management through the strengthening of new initiative reviews and enhancements to theenterprise supply chain and vendor risk management. We also continue to review and enhance our Enterprise Procurement and Third Party Risk Management framework, enhancements to the Business Continuity and Disaster Recovery programs and Enterprise Security programs, and the establishment of Fraud Risk Oversight, Incident Response Oversight and Technology Project Oversight programs.
Significant enhancements have also been made to governance, technology, and reporting, including the establishment of Policy and Committee Governance programs,programs; the implementation of a governance, risk, and control solution,system to manage and integrate business processes, risks, controls, assessments, and control testing; and the creation of an Enterprise Risk Profile and an Operational Risk Profile along with business line risk profiles.Profile. In addition, the establishment of anour Enterprise Exam Management department has standardized our response and reporting, and increased our effectiveness and efficiencies with regulatory examinations,examination, communications, and issues management.

Technology Risk Management
Technology risk is the risk of adverse impact to business operations and customers due to reduced or denied availability or inadequate value delivery related to technology-related applications, infrastructure, strategy, or processes. We make significant investments to enhance our technology capabilities and to mitigate the risk from outdated and unsupported technologies (technical debt). This includes updating core banking systems, as well as introducing new digital customer-facing capabilities. Technology projects, initiatives, and operations are governed by a change management framework that assesses the activities and risk within our business processes to limit disruption and resource constraints. New, expanded, or modified products and services, as well as new lines of business, change initiatives, and other risks are regularly reviewed and approved by the Change, Initiatives, and Technology Committee. This Committee includes, among other senior executives, the Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, CTOO, and Chief Risk Officer. Initiative risk and change impact from the framework are reported to the ROC.
Technology governance exists at the operational level within our Enterprise and Technology Operations (“ETO”) division to help ensure safety, soundness, operational resiliency, and compliance with our technology policies. ETO management regularly participates in enterprise architecture review boards and technology risk committees to assess ongoing objectives related to enterprise standards compliance and strategic alignment, end-of-life, audit, risk and compliance issue management, and asset management. Thresholds are defined to escalate associated risks to the attention of the ERMC and ROC committees as appropriate.
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Cybersecurity Risk Management
The numberCybersecurity risk is the risk of adverse impacts to the confidentiality, integrity, and sophisticationavailability of attempts to disruptdata owned, stored, or penetrate our critical systems, sometimes referred to as hacking, cyber fraud, cyber attacks, cyber terrorism, or other similar names, also continue to grow. Givenprocessed by the importance and increasing sophistication of cyber attacks, the Company has designated cyberBank. For information about how we manage cybersecurity risk, a level one risk in its risk taxonomy, which places it at the highest level of oversight with its other top risks.see Part I, Item 1C. Cybersecurity on page 24.
CAPITAL MANAGEMENT
OverviewCapital Management
The Board of Directors is responsible for approving thekey policies associated with capital management. The Board has establisheddelegated responsibility of managing our capital risk to the Capital Management Committee (“CMC”), which is chaired by the Chief Financial Officer, and consistingconsists of members of management, and whose primary responsibility is to recommend and administer the approved capital policies that govern theour capital management of the Company and its subsidiary bank.management. Other major CMC responsibilities include:
Setting overall capital targets within the Board-approved capital policy,Capital Policy, monitoring performance compared to the Company’swith our Capital Policy limits, and recommending changes to capital including dividends, common stock issuances and repurchases, subordinated debt, and changes in major strategies to maintain the Company and its subsidiary bankourselves at well-capitalized levels;
Maintaining an adequate capital cushion to withstand adverse stress events while continuing to meet the borrowing needs of itsour customers, and to provide reasonable assurance of continued access to wholesale funding, consistent with fiduciary responsibilities to depositors and bondholders; and
Reviewing our credit agency ratings of the Company and ZB, N.A.ratings.
The Company has a fundamental financial objective to consistently produce superior risk-adjusted returns on its shareholders’ capital. We believe that aA strong capital position is vital to the achievement of our key corporate objectives, our continued profitability, and to promoting depositor and investor confidence. Specifically, it is the policy of the Parent and ZB, N.A. to:
MaintainWe seek to (1) maintain sufficient capital to support the current needs;
Maintain an adequate capital cushionneeds and growth of our businesses, consistent with our assessment of their potential to withstand future adverse stress events while continuing to meet borrowing needs of its customers;create value for shareholders, and
Meet fiduciary (2) fulfill responsibilities to depositors and bondholders while managing capital distributions to shareholders through dividends and repurchases of common stock so as to be consistent with Federal Reserve guidelines SR 09-04 and 12 U.S.C §§ 56 and 60.stock.
Capital Planning and Stress Testing
The CMC oversees the Company’s capitalWe utilize stress testing under a varietyas an important mechanism to inform our decisions on the appropriate level of adversecapital, based upon actual and hypothetically stressed economic and market scenarios. We have established processes to periodically conduct stress tests to evaluate potential impactsconditions, which are comparable in severity to the Company under hypothetical economic scenarios. These stress tests facilitate our contingency planning and management of capital and liquidity within quantitative limits reflecting the Board of Directors’ risk appetite. These processes are also used to complete the Company’s DFAST as requiredscenarios published by the Dodd-Frank Act,FRB. The timing and HCR/CCAR as required by the Federal Reserve.
Filing aamount of capital plan with the Federal Reserve based on stress testing and documented sound policies, processes, models, controls, and governance practices, and the subsequent review by the Federal Reserve, is an annual regulatory requirement. This capital plan, which is subject to objection by the Federal Reserve, governs all of the Company’s capital and significant unsecured debt financing actions for a period of five quarters. Among the actions governed by the capital plan are the repurchase of outstanding capital securities and the timing of new capital issuances, and whether the Company can pay or increase dividends. Any such action not included in a capital plan to which the Federal Reserve has not objected cannot be executed without submission of a revised stress test and capital plan for Federal Reserve review and non-objection; de minimis changes are allowed without a complete plan resubmission, subject to receipt of a Federal Reserve non-objection. Regulations require Company disclosure of these stress tests results.

As a bank holding company with assets greater than $50 billion, we are required by the Dodd-Frank Act to participate in annual stress tests known as the DFAST. In addition, we are required to participate in the Federal Reserve Board’s annual HCR/CCAR for large and non-complex firms (generally, bank holding companies, with assets between $50 billion and $250 billion). In our capital plan, we are required to forecast, under a variety of economic scenarios, our estimated regulatory capital ratios and our GAAP tangible common equity ratio.
A detailed discussion of HCR/CCAR/DFAST requirements is contained on page 11 of the “Capital Plan and Stress Testing” section under Part 1, Item 1 in this Annual Report on Form 10-K.
We submitted our stress test results and 2017 capital plan to the FRB on April 5, 2017. On June 28, 2017, the Board of Governors of the Federal Reserve System notified Zions Bancorporation that the Federal Reserve does not object to Zions Bancorporation’s Board-approved 2017 capital plan. Our capital plan for the period spanning July 1, 2017 through June 30, 2018 includes up to $465 million of common stock repurchases and approximately $140 million of common stock dividends as follows.
Increasing the quarterly common dividend to $0.24 per share by the second quarter of 2018 following the path of:
$0.12 per share in the third quarter of 2017
$0.16 per share in the fourth quarter of 2017
$0.20 per share in the first quarter of 2018
$0.24 per share in the second quarter of 2018
Capital actions are subject to final approval by Zions Bancorporation’s board of directors, and may be influenced by, among other things, actual earningsvarious factors, including our financial performance, business needs, prevailing and prevailinganticipated economic conditions.
On June 22, 2017, we filed a Form 8-K presentingconditions, and the results of our internal stress testing, as well as Board and OCC approval. Shares may be repurchased occasionally in the 2017 DFAST exercise. The resultsopen market or through privately negotiated transactions.
Schedule 39
SHAREHOLDERS EQUITY
(Dollar amounts in millions)December 31,
2023
December 31,
2022
Amount changePercent change
Shareholders’ equity:
Preferred stock$440 $440 $— — %
Common stock and additional paid-in capital1,731 1,754 (23)(1)
Retained earnings6,212 5,811 401 
Accumulated other comprehensive income(2,692)(3,112)420 13 
Total shareholders equity
$5,691 $4,893 $798 16 %
Total shareholders’ equity increased $798 million, or 16% to $5.7 billion at December 31, 2023, compared with $4.9 billion at December 31, 2022. Common stock and additional paid-in capital decreased $23 million. During the first quarter of Zions’ published stress tests demonstrate that2023, we repurchased 0.9 million common shares outstanding for $50 million. As the Company believes it has sufficient capital to withstand a severe hypothetical economic downturn. Detailed disclosure of the stress test results can be found onmacroeconomic environment remained uncertain, we suspended our website.
On June 29, 2016, we filed a Form 8-K announcing that the FRBshare repurchase program and did not objectrepurchase common shares during the second, third, or fourth quarters of 2023. During 2022, we repurchased 3.6 million common shares outstanding for $200 million.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
In February 2024, the Board approved a plan to our 2016 capital plan (which spansrepurchase up to $35 million of common shares outstanding during the timeframefiscal year 2024. In February 2024, we repurchased 0.9 million common shares outstanding for $35 million at an average price of July$39.32.
The AOCI loss was $2.7 billion at December 31, 2016 to June 30, 2017). The plan included (1) the increase of the quarterly common dividend to $0.08 per share beginning2023, and primarily reflects declines in the third quarterfair value of 2016, (2) upfixed-rate available-for-sale securities as a result of changes in interest rates. When compared to $180the prior year end, AOCI improved $420 million during 2023, driven largely by $208 million in total repurchases of common equity and (3) upunrealized loss amortization associated with the securities transferred from AFS to $144 million in total repurchases of preferred equity.
As planned, our quarterly dividend on common stock increased to $0.16 per shareHTM during the fourth quarter of 2017.2022, and $66 million primarily related to paydowns on AFS securities. AOCI was also impacted by a $145 million increase in unrealized gains and other adjustments associated with derivative instruments used for risk management purposes. Absent any sales or credit impairment of the AFS securities, the unrealized losses will not be recognized in earnings. We do not intend to sell any securities with unrealized losses. Although changes in AOCI are reflected in shareholders’ equity, they are excluded from regulatory capital, and therefore do not impact our regulatory ratios.
Bank regulators recently issued a proposal to implement Basel III Endgame, which would significantly revise certain capital requirements, such as the inclusion of unrealized gains and losses on AFS debt securities in regulatory capital, and would potentially impact our current and future capital planning, including share repurchase activity. For more information about the regulatory proposals, see “Recent Regulatory Developments” in Supervision and Regulation on page 8. For more discussion on our investment securities portfolio and related unrealized gains and losses, see Note 5 of the Notes to Consolidated Financial Statements.
Schedule 40
CAPITAL DISTRIBUTIONS
(In millions, except share data)20232022
Capital distributions:
Preferred dividends paid$32$29
Total capital distributed to preferred shareholders3229
Common dividends paid245240
Bank common stock repurchased 1
51202
Total capital distributed to common shareholders296442
Total capital distributed to preferred and common shareholders$328$471
Weighted average diluted common shares outstanding (in thousands)147,756150,271
Common shares outstanding, at year-end (in thousands)148,153148,664
1 Includes amounts related to the common shares acquired from our publicly announced plans and those acquired in connection with our stock compensation plan. Shares were acquired from employees to pay for their payroll taxes and stock option exercise cost upon the exercise of stock options.
Pursuant to the OCC’s “Earnings Limitation Rule,” our dividend payments are restricted to an amount equal to the sum of the total of (1) our net income for that year, and (2) retained earnings for the preceding two years, unless the OCC approves the declaration and payment of dividends in excess of such amount. As of December 31, 2017, the Company has repurchased $230January 1, 2024, we had $1.0 billion of retained net profits available for distribution.
We paid dividends on preferred stock of $32 million of itsin 2023, compared with $29 million in 2022. We paid dividends on common stock at an average price of $47.42$245 million, or $1.64 per share, under the 2017 capital plan and $180in 2023, compared with $240 million, of its common stock at an average price of $35.66or $1.58 per share, underin 2022. In February 2024, the 2016 capital plan.
DuringBoard declared a quarterly dividend of $0.41 per common share payable on February 22, 2024, to shareholders of record at the first quarterclose of 2018, the Company repurchased an additional $115 million of its common stock at an average price of $53.46 per share, leaving $120 million of repurchase capacity remaining in the 2017 capital plan (which spans the timeframe of July 2017 to June 2018).
Also in accordance with our 2016 capital plan, we redeemed all outstanding shares of our 7.9% Series F preferred stockbusiness on the redemption date of JuneFebruary 15, 2017.2024.
Basel III
In 2013, the FRB, FDIC, and OCC published final rules (the “Basel III Capital Rules”) establishing a new comprehensive capital framework for U.S. banking organizations. The rules implemented the Basel Committee’s December 2010 framework, commonly referredWe are subject to as Basel III, for strengthening international capital standards as well as certain provisions of the Dodd-Frank Act. The Basel III capital rules became effective for the Company on January 1, 2015 and were subject to phase-in periods forrequirements that include certain of their components. In November 2017, the FRB, FDIC and OCC published a final rule for non-advanced approaches banks that extends the regulatory capital

treatment applicable during 2017 under theminimum regulatory capital rules for certain items. We metratios. At December 31, 2023, we exceeded all capital adequacy requirements under the Basel III Capital Rules as of December 31, 2017.
A detailed discussion of Basel III requirements, including implications for the Company, is contained on page 10 of the “Capital Standards – Basel Framework” section under Part 1, Item 1 in this Annual Report on Form 10-K.
Capital Management Actions
Total shareholders’ equity increased by $45 million to $7.7 billion at December 31, 2017 from $7.6 billion at December 31, 2016. The increase in total shareholders’ equity is primarily due to net income of $592 million. This increase is partially offset by repurchases of our common stock under our repurchase program totaling $320 million, $144 million paid to redeem our Series F preferred stock, and common and preferred dividends of $129 million.
During the latter part of 2016 and throughout 2017, the market price of our common stock increased above the exercise price of common stock warrantscapital rules. Based on our common stock. Asinternal stress testing and other assessments of December 31, 2017capital adequacy, we have 29.3 million common stock warrants at an exercise pricebelieve we hold capital sufficiently in excess of $35.37 which expireinternal and regulatory requirements for well-capitalized banks. See the “Supervision and Regulation” section on May 22, 2020
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page 7 and 5.8 million common stock warrants at an exercise price of $36.27 per share which expire on November 14, 2018. See Note 1315 of the Notes to Consolidated Financial Statements for more information onabout Basel III capital requirements. The following schedule presents our common stock warrants. The increase in the market price of our common stock increased our diluted shares throughout 2017capital amounts, capital ratios, and for the fourth quarter of 2016, but did not effect on our diluted shares for the full 2016 year.
Between January 1, 2018 and February 20, 2018, 1.0 million shares of common stock were issued from the cashless exercise of 3.2 million common stock warrants which expire on November 14, 2018. After these common stock warrant exercises, 29.3 million and 2.6 million common stock warrants, which expire on May 22, 2020 and November 14, 2018, respectively, remain outstanding.other selected performance ratios:
Schedule 32 presents41
CAPITAL AMOUNTS AND RATIOS
(Dollar amounts in millions)December 31,
2023
December 31,
2022
December 31,
2021
Basel III risk-based capital amounts:
Common equity Tier 1 capital$6,863 $6,481 $6,068 
Tier 1 risk-based7,303 6,921 6,508 
Total risk-based8,553 8,077 7,652 
Risk-weighted assets66,934 66,111 59,604 
Basel III risk-based capital ratios:
Common equity Tier 1 capital10.3 %9.8 %10.2 %
Tier 1 risk-based10.9 %10.5 %10.9 %
Total risk-based12.8 %12.2 %12.8 %
Tier 1 leverage8.3 %7.7 %7.2 %
Other ratios:
Average equity to average assets6.0 %6.6 %9.0 %
Return on average common equity13.4 %16.0 %14.9 %
Return on average tangible common equity 1
17.3 %19.8 %17.3 %
Tangible equity ratio 1
5.4 %4.3 %7.0 %
Tangible common equity ratio 1
4.9 %3.8 %6.5 %
1 See “Non-GAAP Financial Measures” on page 77 for more information regarding these ratios.
During the diluted shares from the remaining common stock warrants at various Zions Bancorporation common stock market prices aslatter half of February 20, 2018, excluding the effect of changes in exercise cost and warrant share multiplier from the future payment of common stock dividends.
Schedule 32
IMPACT OF COMMON STOCK WARRANTS
Assumed Zions Bancorporation Common Stock Market Price Diluted Shares (000s)
$35.00
 0
40.00
 4,684
45.00
 7,825
50.00
 10,338
55.00
 12,394
60.00
 14,107
65.00
 15,557
The common dividend rate was increased to $0.16 per share during the fourth quarter of 2017. We paid $89 million in dividends on common stock during 2017, compared to $58 million during 2016. During its January 2018 meeting, the Board of Directors declared a dividend of $0.20 per common share payable on February 22, 2018 to shareholders of record on February 15, 2018.
We paid preferred stock dividends of $40 million and $50 million during 2017 and 2016, respectively. We also recorded a reductions of $2 million and $10 million to net earnings2023, federal bank regulators issued certain proposals applicable to common shareholders as a result oflarge banking organizations that would significantly revise the preferred stock redemptions during 2017capital requirements, expand long-term debt requirements, and 2016.revise requirements for resolution planning. For more information about these regulatory proposals, see “Recent Regulatory Developments” in Supervision and Regulation on page 8.

Banking organizations are required by capital regulations to maintain adequate levels of capital as measured by several regulatory capital ratios. The Company’s capital ratios as of December 31, 2017, 2016, and 2015 are shown in Schedule 33.
Schedule 33
CAPITAL AND PERFORMANCE RATIOS
 2017 2016 2015
      
Tangible common equity ratio1
9.3% 9.5% 9.6%
Tangible equity ratio1
10.2
 10.6
 11.1
Average equity to average assets12.0
 12.8
 13.0
Basel III risk-based capital ratios2:
     
Common equity tier 1 capital12.1
 12.1
 12.2
Tier 1 leverage10.5
 11.1
 11.3
Tier 1 risk-based13.2
 13.5
 14.1
Total risk-based14.8
 15.2
 16.1
Return on average common equity7.7
 6.0
 3.8
Return on average tangible common equity1
9.0
 7.1
 4.6
1
See “GAAP to Non-GAAP Reconciliations” on page 29 for more information regarding these ratios.
2
Based on the applicable phase-in periods.
Note 14 of the Notes to Consolidated Financial Statements provides additional information on risk-based capital.
At December 31, 2017, Basel III regulatory tier 1 risk-based capital and total risk-based capital was $6.8 billion and $7.6 billion, respectively, compared with $6.7 billion and $7.6 billion, respectively, at December 31, 2016.
CRITICAL ACCOUNTING POLICIES AND SIGNIFICANT ESTIMATES
Note 1 of the Notes to Consolidated Financial Statements contains a summary of the Company’sour significant accounting policies. Discussed below are certain significantCertain accounting policies that we consider critical to the Company’s financial statements. These critical accounting policies were selectedare described below because the amounts affected by themtheir related balances and estimates are significant to the financial statements. Any changes to these amounts, including changes in estimates, may also be significant to the financial statements. We believe that an understanding of these policies, along with the related estimates we are required to make in recording theour financial transactions, of the Company, is important to have a complete picture of the Company’sour financial condition. In addition,Additionally, in arriving atmaking these estimates, we are required to make complex and subjective judgments, many of which include a high degree of uncertainty. The following discussion ofWe discuss these critical accounting policies includes the significant estimates related to these policies. We have discussed each of these accounting policies and the related estimates with the Audit Committee of the Board of Directors.below.
We have included, where applicable in this document, sensitivity schedules and other examples to demonstrate the impact of the changes in estimates made for various financial transactions. The sensitivities in these schedules and examples are hypothetical and should be viewed with caution. Changes in estimates are based on variations in assumptions and are not subject to simple extrapolation, as the relationship of the change in the assumption to the change in the amount of the estimate may not be linear. In addition, the effect of a variation in one assumption is in reality likely to cause changes in other assumptions, which could potentially magnify or counteract the sensitivities.
Allowance for Credit Losses
The ACL includes the ALLL and the RULC and represents our estimate of current expected credit losses related to the loan and lease portfolio and unfunded lending commitments as of the balance sheet date. The ACL for our AFS and HTM debt securities portfolio is estimated separately from loans and is not presented separately on the
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consolidated balance sheet due to immateriality. The ACL for debt securities was less than $1 million at both December 31, 2023 and 2022.
The ACL may change significantly each period because the ACL is subject to economic forecasts that may change materially from period to period. We believe that our methodology for determining an appropriate level for the ACL adequately addresses the various components that could potentially result in credit losses. Any unfavorable differences between the actual outcome of credit-related events and our estimates could require an additional provision for credit losses.
The ACL is calculated based on quantitative models and management’s qualitative judgment based on many factors over the life of loan. The primary assumptions of the quantitative model are the economic forecast, the length of the reasonable and supportable forecast period, the length of the reversion period, prepayment rates, and the credit quality of the portfolio. The quantitative ACL estimate is based on losses under multiple economic scenarios that reflect optimistic, baseline, and stressed economic conditions. Management uses qualitative judgment to adjust scenario weights to more closely reflect management’s assessments of current conditions and reasonable and supportable forecasts.
If the ACL was evaluated on the baseline economic scenario rather than weighting multiple scenarios, the quantitatively determined amount of the ACL at December 31, 2023 would decrease by approximately $138 million. Additionally, if the probability of default risk-grade for all pass-graded loans was immediately downgraded one grade on our internal risk-grading scale, the quantitatively determined amount of the ACL at December 31, 2023 would increase by approximately $51 million. These sensitivity analyses are hypothetical and have been provided only to indicate the potential impact that changes in economic forecasts and changes in risk-grades may have on the ACL estimate. See Note 6 of the Notes to Consolidated Financial Statements for more information on the processes and methodologies used to estimate the ACL.
Fair Value Estimates
We measure or monitor many of ourcertain assets and liabilities on aat fair value basis.value. Fair value is the price that couldwould be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants. To increase consistency and comparability in fair value measurements, GAAP has establishedwe prioritize valuation inputs in accordance with a three-level hierarchy to prioritize the valuation inputs amonghierarchy: (1) observable inputs that reflect quoted prices in active markets, (2) inputs

other than quoted prices with observable market data, and (3) unobservable data such as the Company’sour own data or single dealer nonbinding pricing quotes.data.
When observable market prices are not available, fair value is estimated using modeling techniques such as discounted cash flow analysis. These modeling techniques use assumptions that market participants would consider in pricing the asset or the liability, including assumptions about the risk inherent in a particular valuation technique, the effect of a restriction on the sale or use of an asset, the life of the asset and applicable growth rate, the risk of nonperformance, and other related assumptions.liability.
The selection and weighting of the various fair value techniques may result in a fair value higher or lower than the carrying value.value of the item being valued. Considerable judgment may be involved in determining the amount that is most representative of fair value.
For assets and liabilities recordedmeasured at fair value, the Company’sour policy is to maximize the use of observable inputs, when available, and minimize the use of unobservable inputs when developingestimating fair value measurements for those items where there is an active market.value. In certain cases, when market observable inputs for model-based valuation techniques may not be readily available, the Company iswe are required to make judgments about the assumptions that we believe market participants would useconsider in estimating the fair value of the financial instrument.instruments. The models used to determineestimate fair value adjustments are regularly evaluated by management for relevance under current facts and circumstances.
Changes in market conditions may reduce the availability of quoted prices or observable data. For example, reduced liquidity in the capital markets or changes in secondary market activities could result in observable market inputs becoming unavailable. When market data is not available, the Company uses valuation techniques requiring more management judgment to estimate the appropriate fair value.
Fair value is used on a recurring basis for certain assets and liabilities in which fair value is the primary measure of accounting. Fair value is used on a nonrecurring basis to measurefor certain assets or liabilities (including HTM securities, loans held for sale, and OREO) forto determine any impairment or for disclosure purposes in accordance with current accounting guidance.purposes.
Impairment analysis also relates to long-lived assets, goodwill, and core deposit and other intangible assets. An impairment loss is recognized if the carrying amount
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AFS securities are valued using several methodologies, which depend on the nature of the security, availability of current market information, and other factors. InvestmentAFS securities in an unrealized loss position are formally reviewed on a quarterly basis for the presence of other-than-temporary impairment (“OTTI”). OTTI is considered tocredit impairment. If we have occurred if the instrument’s fair value is below its amortized cost and (1) we intendintent to sell thean identified security, or (2) it is “moremore likely than not”not we will be required to sell the security before recovery of its amortized cost basis, or (3)we first recognize an identified impairment. If we do not have the present valueintent to sell a security, and it is more likely than not that we will not be required to sell a security prior to recovery of expected cash flows is not sufficient to recover the entireits amortized cost basis. The “more likely than not” criterionbasis, then we determine whether there is a lower threshold thanany impairment attributable to credit-related factors. Credit-related impairment is recognized as an allowance. Full or partial write-offs of an AFS security are recorded in the “probable” criterion.period in which the security is deemed to be uncollectible.
While certain assets and liabilities are measured at fair value, such as our AFS securities, the majority of our assets and liabilities are not adjusted for changes in fair value. This asymmetrical accounting creates volatility in AOCI and equity.
Notes 1, 3, 5, 7, 9, and 310 of the Notes to Consolidated Financial Statements and the “Investment Securities Portfolio” on page 5046 contain further information regarding the use of fair value estimates.
Allowance for Credit Losses
The ACL includes the ALLL and the RULC. The ALLL represents management’s estimate of probable losses believed to be inherent in the loan portfolio. The determination of the appropriate level of the allowance is based on periodic evaluations of the portfolios. This process includes both quantitative and qualitative analyses, as well as a qualitative review of the results. The qualitative review requires a significant amount of judgment, and is described in more detail in Note 6 of the Notes to Consolidated Financial Statements.

The RULC provides for potential losses associated with off-balance sheet lending commitments and standby letters of credit. The reserve is estimated using the same procedures and methodologies as for the ALLL, plus assumptions regarding the probability and amount of unfunded commitments being drawn.
Although we believe that our processes for determining an appropriate level for the allowance adequately address the various components that could potentially result in credit losses, the processes and their elements include features that may be susceptible to significant change. Any unfavorable differences between the actual outcome of credit-related events and our estimates could require an additional provision for credit losses.As an example, if the probability of default risk grade for all pass-graded commercial and CRE loans was immediately downgraded one grade on our internal risk grading scale, the quantitatively determined amount of the ALLL at December 31, 2017 would increase by approximately $105 million. This sensitivity analysis is hypothetical and has been provided only to indicate the potential impact that changes in risk grades may have on the allowance estimate.
Although the qualitative process is subjective, it represents the Company’s best estimate of qualitative factors impacting the determination of the ACL. We believe that given the procedures we follow in determining the ACL, the various components used in the current estimation processes are appropriate.
Note 6 of the Notes to Consolidated Financial Statements and “Credit Risk Management” on page 56contains further information and more specific descriptions of the processes and methodologies used to estimate the ACL.
Accounting for Goodwill
Goodwill is initially recorded at fair value in the financial statements of a reporting unit at the time of its acquisition and is subsequently evaluated at least annually for impairment in accordance with current accounting guidance. impairment.
We perform this annual test as of September 30an evaluation during the fourth quarter of each year, or more oftenfrequently if events or circumstances indicate that the carrying value exceeds fair value. We may elect to perform a qualitative analysis to determine if it is more likely than not that the fair value of a reporting unit is less than its carrying value may not be recoverable. The goodwill impairment test for a given reporting unit (generally one of our banking segments) compares its fair value with its carrying value.amount. If the carrying amount exceedsis more likely than not to exceed its fair value, an additional quantitative analysis must beis performed to determine the amount if any, by whichof goodwill impairment. If the fair value is impaired.less than the carrying value, an impairment is recorded for the difference. Goodwill impairment does not impact our regulatory capital ratios or tangible common equity ratio.
To determine the fair value of a reporting unit, we use (1) a combination of up to three separate methods:market value approach that incorporates comparable publicly-traded financial service companies (primarilypublicly traded commercial banks, and bank holding companies) in the western and southwestern states (“Market Value”); where applicable, comparable acquisitions(2) an income method that consists of financial services companies in the western and southwestern states (“Transaction Value”); and thea discounted present value of management’s estimates of future cash flows.
Critical assumptions that are used as part of these calculationsmethods include:
selectionSelection of comparable publicly-tradedpublicly traded companies based on location, size, and business focus and composition;
selectionSelection of market comparable acquisition transactions, if available, based on location, size, business focus and composition, and date of the transaction;
theThe discount rate, which is based on Zions’our estimate of itsthe cost of capital, applied to future cash flows;equity capital;
theThe projections of future earnings and cash flows of the reporting unit;
theThe relative weight given to the valuations derived by the threetwo methods described;described previously; and
theThe control premium associated with reporting units.
We apply a control premium in the Market Value approach to determine the reporting units’ equity values. Control premiums represent the ability of a controlling shareholder to change how the Company is managed and can cause the fair value of a reporting unit as a whole to exceed its market capitalization. Based on a review of historical bank acquisition transactions within the Company’s geographic footprint, and a comparison of the target banks’ market values 30 days prior to the announced transaction to the deal value, we have determined that a control premium ranging from 0% to 15% for the reporting units was appropriate at the most recent test date.
Since estimates are an integral part of the impairment test computations, changes in these estimates could have a significant impact on any calculatedour reporting units’ fair value and the goodwill impairment amount.amount, if any. Estimates include economic conditions, which impact the assumptions related to interest and growth rates, loss rates, and imputed cost of equity capital. The fair value estimates for each reporting unit incorporate current economic and market conditions, including Federal Reserve

monetary policy expectations and the impact of legislative and regulatory changes. Additional factors that may significantly affect the estimates include, among others, competitive forces, customer behaviors and attrition, loan losses, changes in growth trends, cost structures and technology, changes in equity market values and merger and acquisition valuations, and changes in industry conditions.
Weakening in the economic environment, a decline in the performance of the reporting units, or other factors could cause the fair value of one or more of the reporting units to fall below carrying value, resulting in a goodwill impairment charge. Additionally, new legislative or regulatory changes not anticipated in management’s expectations may cause the fair value of one or more of the reporting units to fall below the carrying value, resulting in a goodwill impairment charge. Any impairment charge would not affect the Companys regulatory capital ratios, tangible common equity ratio, or liquidity position.
During the fourth quarter of 2017, weWe performed our annual goodwill impairment evaluation, of the entire organization, effective September 30, 2017.October 1, 2023. We concluded that none of our reporting units waswere impaired. Furthermore, the evaluation process determined that the fair values of Amegy, CB&T, and Zions Bank, and NSB exceeded their carrying values by 35%38%, 54%70%, 80%, and 78%139%, respectively. Additionally, we performed a hypothetical sensitivity analysis on the discount rate assumption to evaluate the
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
impact of an adverse change to this assumption. If the discount rate applied to future earnings werewas increased by 100bps,100 bps, the fair values of Amegy, CB&T, and Zions Bank, and NSB would exceed their carrying values by 33%32%, 52%60%, 63%, and 72%124%, respectively.
Income Taxes
We are subject to the income tax laws of the United States, its states and other jurisdictions where we conduct business. These laws are complex and subject to different interpretations by the taxpayer and the various taxing authorities. Calculation of the provision for income taxes requires significant judgments and estimates about the application of these laws and related regulations. Management attempts to make reasonable interpretations of these tax laws as we prepare the Company’s tax returns. These interpretations are subject to challenge by the tax authorities upon audit or to reinterpretation based on management’s ongoing assessment of facts and evolving case law.
On December 22, 2017, H.R. 1, known as the Tax Cuts and Jobs Act (“the Act”), was signed into law. The Act makes significant changes to the U.S. Internal Revenue Code of 1986, including a decrease in the current corporate federal income tax rate to 21% from 35%, effective January 1, 2018. In conjunction with the enactment of the Act, the SEC issued SAB 118 to address the accounting for certain income tax effects of the Act that may not be complete by the time financial statements are issued. The Company evaluated all available information and made reasonable estimates of the impact of the Act to substantially all components of its net DTA. The provisional impact of the Act on the net DTA resulted in a non-cash charge of $47 million, recorded through income tax expense. The Company anticipates that additional adjustments to net DTA and income tax expense may be made in 2018 as the Company’s initial determination of the tax basis of deferred items such as foregone interest, equity investments in flow-through entities, certain employee compensation arrangements, FDIC-supported transactions and premises and equipment are finalized. These adjustments will be recorded in the financial statements in the reporting period when such adjustments are determined; however, SAB 118 requires all impacts from the Act to be recorded prior to December 22, 2018, which is one year from the enactment date of the Act.
In 2017, the Company early adopted the guidance in ASU 2018-02, which allows reclassification from AOCI to retained earnings for the stranded tax effects related to the change in the corporate income tax rate from the Act. The early adoption of the guidance resulted in a $25 million increase to retained earnings out of AOCI as of December 31, 2017.
We had net DTAs of $93 million at December 31, 2017, compared with $250 million at December 31, 2016. The most significant portions of the deductible temporary differences relate to (1) the ALLL, (2) fair value adjustments or impairment write-downs related to securities, (3) pension and postretirement obligations, and (4) deferred compensation arrangements. No valuation allowance has been recorded as of December 31, 2017 related to DTAs except for a full valuation reserve related to certain acquired net operating losses from an immaterial nonbank

subsidiary. In assessing the need for a valuation allowance, both the positive and negative evidence about the realization of DTAs were evaluated. The ultimate realization of DTAs is based on the Company’s ability to (1) carry back net operating losses to prior tax periods, (2) utilize the reversal of taxable temporary differences to offset deductible temporary differences, (3) implement tax planning strategies that are prudent and feasible, and (4) generate future taxable income.
After considering the weight of the positive evidence compared to the negative evidence, management has concluded it is more likely than not that we will realize the existing DTAs and that an additional valuation allowance is not needed.
On a quarterly basis, management assesses the reasonableness of its effective tax rate based upon its current best estimate of net income and the applicable taxes expected for the full year. Deferred tax assets and liabilities are also reassessed on a regular basis. Reserves for contingent tax liabilities are reviewed quarterly for adequacy based upon developments in tax law and the status of examinations or audits. We have tax reserves at December 31, 2017 of approximately $5 million, net of federal and/or state benefits, primarily relating to uncertain tax positions for tax credits on technology initiatives.
Note 18 of the Notes to Consolidated Financial Statements contains additional information regarding income taxes.
RECENT ACCOUNTING PRONOUNCEMENTS AND DEVELOPMENTS
Note 2 of the Notes to Consolidated Financial Statements discusses recently issued accounting pronouncements that we are, or will be, required to adopt. Also discusseddescribed is our expectation of the impact these new accounting pronouncements will have, to the extent they are material, on our financial condition or results of operations,operations.
NON-GAAP FINANCIAL MEASURES
This Form 10-K presents non-GAAP financial measures in addition to GAAP financial measures. The adjustments to reconcile from the applicable GAAP financial measures to the non-GAAP financial measures are presented in the following schedules. We consider these adjustments to be relevant to ongoing operating results and provide a meaningful basis for period-to-period comparisons. We use these non-GAAP financial measures to assess our performance and financial position. We believe that presenting these non-GAAP financial measures allows investors to assess our performance on the same basis as that applied by our management and the financial services industry.
Non-GAAP financial measures have inherent limitations and are not necessarily comparable to similar financial measures that may be presented by other financial services companies. Although non-GAAP financial measures are frequently used by stakeholders to evaluate a company, they have limitations as an analytical tool and should not be considered in isolation or liquidity.as a substitute for analysis of results reported under GAAP.
Tangible Common Equity and Related Measures
Tangible common equity and related measures are non-GAAP measures that exclude the impact of intangible assets and their related amortization. We believe these non-GAAP measures provide useful information about our use of shareholders’ equity and provide a basis for evaluating the performance of a business more consistently, whether acquired or developed internally.
Schedule 42
RETURN ON AVERAGE TANGIBLE COMMON EQUITY (NON-GAAP)
Year Ended December 31,
(Dollar amounts in millions)202320222021
Net earnings applicable to common shareholders (GAAP)$648 $878 $1,100 
Adjustment, net of tax:
Amortization of core deposit and other intangibles
Net earnings applicable to common shareholders, net of tax(a)$653 $879 $1,101 
Average common equity (GAAP)$4,839 $5,472 $7,371 
Average goodwill and intangibles(1,062)(1,022)(1,015)
Average tangible common equity (non-GAAP)(b)$3,777 $4,450 $6,356 
Return on average tangible common equity (non-GAAP) 1
(a/b)17.3 %19.8 %17.3 %
1 Excluding the effect of AOCI from average tangible common equity would result in associated returns of 9.7%, 13.9%, and 17.8% for the periods presented, respectively.
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ITEM 7A.QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK
ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Schedule 43
TANGIBLE EQUITY RATIO, TANGIBLE COMMON EQUITY RATIO, AND TANGIBLE BOOK VALUE PER COMMON SHARE (ALL NON-GAAP MEASURES)
(Dollar amounts in millions, except per share amounts)December 31,
202320222021
Total shareholders’ equity (GAAP)$5,691$4,893$7,463
Goodwill and intangibles(1,059)(1,065)(1,015)
Tangible equity (non-GAAP)(a)4,6323,8286,448
Preferred stock(440)(440)(440)
Tangible common equity (non-GAAP)(b)$4,192$3,388$6,008
Total assets (GAAP)$87,203$89,545$93,200
Goodwill and intangibles(1,059)(1,065)(1,015)
Tangible assets (non-GAAP)(c)$86,144$88,480$92,185
Common shares outstanding (in thousands)(d)148,153148,664151,625
Tangible equity ratio (non-GAAP)(a/c)5.4 %4.3 %7.0 %
Tangible common equity ratio (non-GAAP)(b/c)4.9 %3.8 %6.5 %
Tangible book value per common share (non-GAAP)(b/d)$28.30$22.79$39.62
Efficiency Ratio and Adjusted Pre-Provision Net Revenue
The efficiency ratio is a measure of operating expense relative to revenue. We believe the efficiency ratio provides useful information regarding the cost of generating revenue. We make adjustments to exclude certain items that are not generally expected to recur frequently, as identified in the subsequent schedule, which we believe allow for more consistent comparability across periods. Adjusted noninterest expense provides a measure as to how we are managing our expenses. Adjusted pre-provision net revenue enables management and others to assess our ability to generate capital. Taxable-equivalent net interest income allows us to assess the comparability of revenue arising from both taxable and tax-exempt sources.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Schedule 44
EFFICIENCY RATIO (NON-GAAP) AND ADJUSTED PRE-PROVISION NET REVENUE (NON-GAAP)
(Dollar amounts in millions)202320222021
Noninterest expense (GAAP)(a)$2,097 $1,878 $1,741 
Adjustments:
Severance costs14 
Other real estate expense, net— — 
Amortization of core deposit and other intangibles
Restructuring costs— — 
Pension termination-related expense (income) 1
— — (5)
SBIC investment success fee accrual 2
— (1)
FDIC special assessment90 — — 
Total adjustments(b)111 
Adjusted noninterest expense (non-GAAP)(a-b)=(c)$1,986 $1,876 $1,737 
Net interest income (GAAP)(d)$2,438 $2,520 $2,208 
Fully taxable-equivalent adjustments(e)41 37 32 
Taxable-equivalent net interest income (non-GAAP)(d+e)=(f)2,479 2,557 2,240 
Noninterest income (GAAP)(g)677 632 703 
Combined income (non-GAAP)(f+g)=(h)3,156 3,189 2,943 
Adjustments:
Fair value and nonhedge derivative gain (loss)(4)16 14 
Securities gains (losses), net(15)71 
Total adjustments(i)— 85 
Adjusted taxable-equivalent revenue (non-GAAP)(h-i)=(j)$3,156 $3,188 $2,858 
Pre-provision net revenue (non-GAAP)(h)-(a)$1,059 $1,311 $1,202 
Adjusted pre-provision net revenue (non-GAAP)(j-c)1,170 1,312 1,121 
Efficiency ratio (non-GAAP) 3
(c/j)62.9 %58.8 %60.8 %
1 Represents a subsequent valuation adjustment related to the termination of our defined benefit pension plan in 2020.
2 The success fee accrual is associated with the gains and losses from our SBIC investments, which are excluded from the efficiency ratio through securities gains (losses), net.
3 Including the one-time $90 million accrual associated with the FDIC special assessment recorded in deposit insurance and regulatory expense during the fourth quarter of 2023, the efficiency ratio for 2023 would have been 65.8%.
ITEM 7A. QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK
Information required by this Item is included in “Interest Rate and Market Risk Management” in MD&A beginning on page 6863, and is hereby incorporated by reference.
ITEM 8. FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA

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ITEM 8.FINANCIAL STATEMENTS AND SUPPLEMENTARY DATA
ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
REPORT ON MANAGEMENT’S ASSESSMENT OF INTERNAL CONTROL OVER FINANCIAL REPORTING
The management of Zions Bancorporation, and subsidiaries (“the Company”)N.A is responsible for establishing and maintaining adequate internal control over financial reporting for the Company as defined by Exchange Act Rules 13a-15 and 15d-15.
Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate. Although any system of internal control can be compromised by human error or intentional circumvention of required procedures, we believe our system provides reasonable assurance that financial transactions are recorded and reported properly, providing an adequate basis for reliable financial statements.
The Company’sOur management has used the criteria established in Internal Control – Integrated Framework (2013 framework) issued by the COSOCommittee of Sponsoring Organizations of the Treadway Commission (“COSO”) to evaluate the effectiveness of the Company’sour internal control over financial reporting.
The Company’sOur management has assessed the effectiveness of the Company’sour internal control over financial reporting as of December 31, 20172023, and has concluded that such internal control over financial reporting is effective. There are no material weaknesses in the Company’sour internal control over financial reporting that have been identified by the Company’sour management.

Ernst & Young LLP, an independent registered public accounting firm, has audited theour consolidated financial statements of the Company for the year ended December 31, 20172023, and has also issued an attestation report, which is included herein, on internal control over financial reporting in accordance with the standards of the Public Company Accounting Oversight Board (“PCAOB”).

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
REPORTS OF ERNST & YOUNG LLP, INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM (PCAOB ID: 42)
REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING
To the Shareholders and the Board of Directors of Zions Bancorporation, and SubsidiariesNational Association
Opinion on Internal Control overOver Financial Reporting
We have audited Zions Bancorporation, and subsidiaries’ National Association’s (“the Bank”) internal control over financial reporting as of December 31, 2017,2023, based on criteria established in Internal Control-IntegratedControl — Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (2013 framework) (the(“the COSO criteria)criteria”). In our opinion, Zions Bancorporation and subsidiaries (the Company)the Bank maintained, in all material respects, effective internal control over financial reporting as of December 31, 2017,2023, based on the COSO criteria.
We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB)(“PCAOB”), the 20172023 consolidated financial statements of the CompanyBank and our report dated February 28, 201823, 2024, expressed an unqualified opinion thereon.
Basis for Opinion
The Company’sBank’s management is responsible for maintaining effective internal control over financial reporting and for its assessment of the effectiveness of internal control over financial reporting included in the accompanying Report on Management’s Assessment of Internal Control over Financial Reporting. Our responsibility is to express an opinion on the Company’sBank’s internal control over financial reporting based on our audit. We are a public accounting firm registered with the PCAOB and are required to be independent with respect to the CompanyBank in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.
We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all material respects.
Our audit included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness exists, testing and evaluating the design and operating effectiveness of internal control based on the assessed risk, and performing such other procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable basis for our opinion.
Definition and Limitations of Internal Control Over Financial Reporting
A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the company’s assets that could have a material effect on the financial statements.
Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.
/s/ Ernst & Young LLP
Salt Lake City, Utah
February 28, 201823, 2024

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
REPORT ON CONSOLIDATED FINANCIAL STATEMENTS
To the Shareholders and the Board of Directors of Zions Bancorporation, and Subsidiaries National Association
Opinion on the Financial Statements
We have audited the accompanying consolidated balance sheets of Zions Bancorporation, and subsidiaries (the Company)National Association (“the Bank”) as of December 31, 20172023 and 2016, and2022, the related consolidated statements of income, comprehensive income (loss), changes in shareholders'shareholders’ equity, and cash flows for each of the three years in the period ended December 31, 2017,2023, and the related notes (collectively referred to as the “consolidatedconsolidated financial statements”statements). In our opinion, the consolidated financial statements present fairly, in all material respects, the financial position of the CompanyBank at December 31, 20172023 and 2016,2022, and the results of its operations and its cash flows for each of the three years in the period ended December 31, 2017,2023, in conformity with U.S. generally accepted accounting principles.
We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB)(“PCAOB”), the Company’sBank’s internal control over financial reporting as of December 31, 2017,2023, based on criteria established in Internal Control-Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (2013 framework), and our report dated February 28, 201823, 2024 expressed an unqualified opinion thereon.
Basis for Opinion
These financial statements are the responsibility of the Company’sBank’s management. Our responsibility is to express an opinion on the Company’sBank’s financial statements based on our audits. We are a public accounting firm registered with the PCAOB and are required to be independent with respect to the CompanyBank in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.
We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.
Critical Audit Matter
The critical audit matter communicated below is a matter arising from the current period audit of the financial statements that was communicated or required to be communicated to the audit committee and that: (1) relates to accounts or disclosures that are material to the financial statements and (2) involved our especially challenging, subjective or complex judgments. The communication of the critical audit matter does not alter in any way our opinion on the consolidated financial statements, taken as a whole, and we are not, by communicating the critical audit matter below, providing a separate opinion on the critical audit matter or on the account and the disclosures to which it relates.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Allowance for loan and lease losses
Description of the Matter
The Bank’s loan and lease portfolio and the associated allowance for loan and lease losses (ALLL), were $57.8 billion and $684 million as of December 31, 2023, respectively. The provision for loan and lease losses was $148 million for the year ended December 31, 2023.

As discussed in Note 1 and 6 to the consolidated financial statements, the ALLL represented the Bank’s estimate of current expected credit losses over the contractual remaining life of the loan and lease portfolio as of the consolidated balance sheet date. Management’s ALLL estimate includes quantitative calculations based on the statistical analysis of historical loss experience dependent on weighted economic scenarios and other loan-level characteristics forecasted over a reasonable period, losses estimated using historical loss experience for periods outside the reasonable economic forecast period (collectively the quantitative portion), supplemented with qualitative adjustments that bring the ALLL to the level management deemed appropriate based on factors that are not fully considered in the quantitative analysis. The statistical analysis of historical loss experience was derived from credit loss models used to determine the quantitative portion of the ALLL. Judgment was required by management to determine the weightings of the economic scenarios and the magnitude of the impact of the qualitative adjustments to the ALLL.

Auditing management’s ALLL estimate is complex due to the judgment used to weigh the economic scenarios and the judgment involved in determining the magnitude of the impact of the various risk factors used to derive the qualitative adjustments to the ALLL.
How We Addressed the Matter in Our AuditWe obtained an understanding, evaluated the design, and tested the operating effectiveness of controls that address the risk of material misstatement in determining the weightings of the economic scenarios and in determining the impact of the qualitative adjustments to the ALLL. We tested controls over the Bank’s ALLL governance process, model development and model risk management as it relates to the credit loss models used in the ALLL process. Such testing included testing controls over model governance, controls over data input into the models, and controls over model calculation accuracy and observing key management meetings where weightings of the economic scenarios and the magnitude of qualitative adjustments are reviewed and approved.
To test the reasonableness of the weightings of the economic scenarios, our procedures consisted of obtaining an understanding of the forecasted economic scenarios used, including agreeing the economic scenarios to third party published data and economic scenarios developed from market information as well as evaluating management’s methodology. We also performed analytical procedures and sensitivity analyses on the weightings of the economic scenarios and searched for and evaluated information that corroborated or contradicted these weightings.
Regarding the completeness of qualitative adjustments identified and incorporated into measuring the ALLL, we evaluated the potential impact of imprecision in the credit loss models and emerging risks related to changes in the economic environment impacting the Bank’s loan and lease portfolio. We also evaluated and tested internal and external data used in the qualitative adjustments by agreeing significant inputs and underlying data to internal and external sources.
Further, we assessed whether the total amount of the ALLL estimate was consistent with the Bank’s historical loss information, peer bank information, credit quality statistics, subsequent events and transactions, and publicly observable indicators of macroeconomic financial conditions and whether the total ALLL amount was reflective of current expected losses in the loan and lease portfolio as of the consolidated balance sheet date.
/s/ Ernst & Young LLP
We have served as the Company’sBank’s auditor since 2000.
Salt Lake City, Utah
February 28, 201823, 2024

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

CONSOLIDATED BALANCE SHEETS
ZIONS BANCORPORATION AND SUBSIDIARIES
CONSOLIDATED BALANCE SHEETS
(In millions, shares in thousands)December 31,(In millions, shares in thousands)December 31,
2017 201620232022
ASSETS   
Cash and due from banks$548
 $737
Cash and due from banks
Cash and due from banks
Money market investments:   
Interest-bearing deposits782
 1,411
Federal funds sold and security resell agreements514
 568
Interest-bearing deposits
Interest-bearing deposits
Federal funds sold and securities purchased under agreements to resell
Investment securities:   
Held-to-maturity, at amortized cost (approximate fair value $762 and $850)770
 868
Held-to-maturity, at amortized cost (fair value $10,466 and $11,239)
Held-to-maturity, at amortized cost (fair value $10,466 and $11,239)
Held-to-maturity, at amortized cost (fair value $10,466 and $11,239)
Available-for-sale, at fair value15,161
 13,372
Trading account, at fair value148
 115
Total investment securities16,079
 14,355
Loans held for sale44
 172
Loans and leases, net of unearned income and fees44,780
 42,649
Less allowance for loan losses518
 567
Less allowance for loan and lease losses
Loans, net of allowance44,262
 42,082
Other noninterest-bearing investments1,029
 884
Premises, equipment and software, net1,094
 1,020
Goodwill1,014
 1,014
Core deposit and other intangibles2
 8
Goodwill and intangibles
Other real estate owned4
 4
Other assets916
 984
Total assets$66,288
 $63,239
LIABILITIES AND SHAREHOLDERS’ EQUITY   
Deposits:   
Deposits:
Deposits:
Noninterest-bearing demand
Noninterest-bearing demand
Noninterest-bearing demand$23,886
 $24,115
Interest-bearing:   
Savings and money market25,620
 26,364
Savings and money market
Savings and money market
Time3,115
 2,757
Total deposits
Total deposits
Total deposits52,621
 53,236
Federal funds and other short-term borrowings4,976
 827
Long-term debt383
 535
Reserve for unfunded lending commitments58
 65
Other liabilities571
 942
Total liabilities58,609
 55,605
Shareholders’ equity:   
Preferred stock, without par value, authorized 4,400 shares566
 710
Common stock, without par value; authorized 350,000 shares; issued and outstanding 197,532 and 203,085 shares4,445
 4,725
Preferred stock, without par value; authorized 4,400 shares
Preferred stock, without par value; authorized 4,400 shares
Preferred stock, without par value; authorized 4,400 shares
Common stock ($0.001 par value; authorized 350,000 shares; issued and outstanding 148,153 and 148,664 shares and additional paid-in capital)
Retained earnings2,807
 2,321
Accumulated other comprehensive income (loss)(139) (122)
Accumulated other comprehensive income
Total shareholders’ equity
Total shareholders’ equity
Total shareholders’ equity7,679
 7,634
Total liabilities and shareholders’ equity$66,288
 $63,239
See accompanying notes to consolidated financial statements.

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CONSOLIDATED STATEMENTS OF INCOME
ZIONS BANCORPORATION AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF INCOME
(In millions, except shares and per share amounts)Year Ended December 31,(In millions, except shares and per share amounts)Year Ended December 31,
2017 2016 2015202320222021
Interest income:     
Interest and fees on loans
Interest and fees on loans
Interest and fees on loans$1,847
 $1,729
 $1,686
Interest on money market investments19
 21
 23
Interest on securities326
 204
 124
Total interest income2,192
 1,954
 1,833
Interest expense:     
Interest on deposits59
 49
 49
Interest on deposits
Interest on deposits
Interest on short- and long-term borrowings68
 38
 69
Total interest expense127
 87
 118
Net interest income2,065
 1,867
 1,715
Provision for credit losses:
Provision for loan losses24
 93
 40
Net interest income after provision for loan losses2,041
 1,774
 1,675
Provision for loan losses
Provision for loan losses
Provision for unfunded lending commitments
Total provision for credit losses
Net interest income after provision for credit losses
Noninterest income:     
Service charges and fees on deposit accounts171
 171
 168
Other service charges, commissions and fees217
 208
 187
Wealth management and trust income42
 37
 31
Loan sales and servicing income25
 35
 31
Capital markets and foreign exchange30
 22
 26
Customer-related fees485
 473
 443
Dividends and other investment income40
 24
 30
Commercial account fees
Commercial account fees
Commercial account fees
Card fees
Retail and business banking fees
Loan-related fees and income
Capital markets fees
Wealth management fees
Other customer-related fees
Other customer-related fees
Other customer-related fees
Customer-related noninterest income
Fair value and nonhedge derivative income (loss)
Dividends and other income
Securities gains (losses), net14
 7
 (127)
Other5
 12
 11
Total noninterest income544
 516
 357
Noninterest expense:     
Salaries and employee benefits1,011
 983
 973
Occupancy, net129
 125
 120
Furniture, equipment and software, net130
 125
 123
Salaries and employee benefits
Salaries and employee benefits
Technology, telecom, and information processing
Occupancy and equipment, net
Professional and legal services
Marketing and business development
Deposit insurance and regulatory expense
Credit-related expense
Other real estate expense, net(1) (2) (1)
Credit-related expense29
 26
 29
Provision for unfunded lending commitments(7) (10) (6)
Professional and legal services54
 55
 50
Advertising22
 22
 25
FDIC premiums53
 40
 34
Amortization of core deposit and other intangibles6
 8
 9
Other223
 213
 225
Total noninterest expense1,649
 1,585
 1,581
Income before income taxes936
 705
 451
Income taxes344
 236
 142
Net income592
 469
 309
Preferred stock dividends(40) (48) (62)
Preferred stock redemption(2) (10) 
Preferred stock dividends
Preferred stock dividends
Net earnings applicable to common shareholders
Net earnings applicable to common shareholders
Net earnings applicable to common shareholders$550
 $411
 $247
Weighted average common shares outstanding during the year:     
Basic shares (in thousands)
Basic shares (in thousands)
Basic shares (in thousands)200,776
 203,855
 203,265
Diluted shares (in thousands)209,653
 204,269
 203,698
Net earnings per common share:     
Basic$2.71
 $2.00
 $1.20
Basic
Basic
Diluted2.60
 1.99
 1.20
See accompanying notes to consolidated financial statements.

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CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME (LOSS)
ZIONS BANCORPORATION AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME

(In millions)Year Ended December 31,
2017 2016 2015
      
Net income$592
 $469
 $309
Other comprehensive income (loss), net of tax:     
Net unrealized holding losses on investment securities(2) (74) (23)
Reclassification of HTM securities to AFS securities
 
 11
Reclassification to earnings for realized net securities losses
 
 86
Net unrealized gains (losses) on other noninterest-bearing investments3
 2
 (3)
Net unrealized holding gains (losses) on derivative instruments(3) 5
 7
Reclassification adjustment for increase in interest income recognized in earnings on derivative instruments(2) (7) (6)
Pension and postretirement12
 7
 1
Effect of new tax rates from Tax Cuts and Jobs Act of 2017(25) 
 
Other comprehensive income (loss)(17) (67) 73
Comprehensive income$575
 $402
 $382
(In millions)Year Ended December 31,
202320222021
Net income$680 $907 $1,129 
Other comprehensive income (loss), net of tax:
Net unrealized holding gains (losses) on investment securities66 (2,762)(336)
Unrealized loss amortization associated with the securities transferred from AFS to HTM208 40 — 
Net unrealized gains (losses) on other noninterest-bearing investments(2)
Net unrealized holding gains (losses) on derivative instruments21 (330)(26)
Reclassification adjustment for decrease (increase) in interest income recognized in earnings on derivative instruments124 21 (46)
Pension and post-retirement— — 
Other comprehensive income (loss), net of tax420 (3,032)(405)
Comprehensive income (loss)$1,100 $(2,125)$724 
See accompanying notes to consolidated financial statements.

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CONSOLIDATED STATEMENTS OF CHANGES IN SHAREHOLDERS’ EQUITY
ZIONS BANCORPORATION AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF CHANGES IN SHAREHOLDERS’ EQUITY
(In millions, except shares
and per share amounts)
Preferred
stock
 Common stock Retained earnings Accumulated
other
comprehensive income (loss)
 
Total
shareholders’ equity
Shares
(in thousands)
 Amount 
(In millions, except shares
and per share amounts)
(In millions, except shares
and per share amounts)
Preferred
stock
Common stock shares
(in thousands)
Accumulated paid-in capitalRetained earningsAccumulated
other
comprehensive income (loss)
Total
shareholders’ equity
 
Balance at December 31, 2014$1,004
 203,015
 $4,724
 $1,769
 $(128) $7,369
Balance at December 31, 2020
Balance at December 31, 2020
Balance at December 31, 2020
Net income      309
   309
Other comprehensive income, net of tax        73
 73
Other comprehensive loss, net of tax
Other comprehensive loss, net of tax
Other comprehensive loss, net of tax
Bank common stock repurchased
Bank common stock repurchased
Bank common stock repurchased
Preferred stock redemption(176)   3
 (3)   (176)
Net activity under employee plans and related tax benefits  1,402
 40
     40
Dividends on preferred stock      (62)   (62)
Dividends on common stock, $0.22 per share      (45)   (45)
Dividends on common stock, $1.44 per share
Change in deferred compensation      (1)   (1)
Balance at December 31, 2015828
 204,417
 4,767
 1,967
 (55) 7,507
Balance at December 31, 2021
Net income      469
   469
Other comprehensive income (loss), net of tax        (67) (67)
Preferred stock redemption(118)   2
 (10)   (126)
Company common stock repurchased under repurchase programs

 (2,889) (90)     (90)
Other comprehensive loss, net of tax
Other comprehensive loss, net of tax
Other comprehensive loss, net of tax
Bank common stock repurchased
Net activity under employee plans and related tax benefits
Net activity under employee plans and related tax benefits
Net activity under employee plans and related tax benefits  1,557
 46
     46
Dividends on preferred stock

     (48)   (48)
Dividends on common stock, $0.28 per share      (58)   (58)
Dividends on common stock, $1.58 per share
Change in deferred compensation      1
   1
Balance at December 31, 2016710
 203,085
 4,725
 2,321
 (122) 7,634
Balance at December 31, 2022
Net income      592
   592
Cumulative effect adjustment, adoption of ASU 2022-02, Financial Instruments - Credit Losses: Troubled Debt Restructurings
Other comprehensive income, net of tax        8
 8
Preferred stock redemption(144)   2
 (2)   (144)
Company common stock repurchased under repurchase programs  (7,009) (320)     (320)
Bank common stock repurchased
Net activity under employee plans and related tax benefits
Net activity under employee plans and related tax benefits
Net activity under employee plans and related tax benefits  1,456
 38
     38
Dividends on preferred stock      (40)   (40)
Dividends on common stock, $0.44 per share      (89)   (89)
Effect of new tax rates from Tax Cuts and Jobs Act of 2017      25
 (25) 
Balance at December 31, 2017$566
 197,532
 $4,445
 $2,807
 $(139) $7,679
Dividends on common stock, $1.64 per share
Change in deferred compensation
Balance at December 31, 2023
See accompanying notes to consolidated financial statements.

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CONSOLIDATED STATEMENTS OF CASH FLOWS
ZIONS BANCORPORATION AND SUBSIDIARIES
CONSOLIDATED STATEMENTS OF CASH FLOWS
(In millions)Year Ended December 31,(In millions)Year Ended December 31,
2017 2016 2015202320222021
CASH FLOWS FROM OPERATING ACTIVITIES     
Net income$592
 $469
 $309
Net income
Net income
Adjustments to reconcile net income to net cash provided by operating activities:     
Provision for credit losses
Provision for credit losses
Provision for credit losses17
 83
 34
Depreciation and amortization179
 123
 86
Share-based compensation25
 26
 25
Securities losses (gains), net(14) (7) 127
Deferred income tax expense (benefit)154
 (8) (30)
Net decrease (increase) in trading securities(33) (67) 22
Net decrease (increase) in loans held for sale97
 1
 (6)
Change in other liabilities29
 1
 (6)
Change in other assets(89) (10) (67)
Other, net(29) (15) (30)
Net cash provided by operating activities928
 596
 464
CASH FLOWS FROM INVESTING ACTIVITIES     
Net decrease in money market investments683
 4,749
 1,837
Net decrease (increase) in money market investments
Net decrease (increase) in money market investments
Net decrease (increase) in money market investments
Proceeds from maturities and paydowns of investment securities held-to-maturity314
 94
 123
Purchases of investment securities held-to-maturity(216) (416) (61)
Proceeds from sales, maturities, and paydowns of investment securities
available-for-sale
2,412
 3,787
 1,681
Purchases of investment securities available-for-sale(4,719) (9,359) (5,513)
Net change in loans and leases(2,135) (2,102) (563)
Purchases and sales of other noninterest-bearing investments(105) (20) 31
Purchases of premises and equipment(169) (196) (157)
Proceeds from sales of other real estate owned8
 20
 25
Acquisition of Nevada branches, net of cash acquired
Other, net8
 7
 18
Net cash used in investing activities(3,919) (3,436) (2,579)
Net cash provided by (used in) investing activities
CASH FLOWS FROM FINANCING ACTIVITIES     
Net increase (decrease) in deposits(614) 2,883
 2,526
Net increase (decrease) in deposits
Net increase (decrease) in deposits
Net change in short-term funds borrowed2,149
 480
 103
Proceeds from debt over 90 days and up to one year5,100
 
 
Repayments of debt over 90 days and up to one year(3,100) 
 
Cash paid for preferred stock redemptions(144) (126) (176)
Repayments of long-term debt(153) (280) (288)
Company common stock repurchased(332) (97) (7)
Cash paid for preferred stock redemption
Cash paid for preferred stock redemption
Cash paid for preferred stock redemption
Redemption of long-term debt
Proceeds from the issuance of common stock
Proceeds from the issuance of common stock
Proceeds from the issuance of common stock25
 25
 22
Dividends paid on common and preferred stock(129) (108) (108)
Bank common stock repurchased
Other, net
 2
 (1)
Net cash provided by financing activities2,802
 2,779
 2,071
Net decrease in cash and due from banks(189) (61) (44)
Net cash provided by (used in) financing activities
Net increase in cash and due from banks
Cash and due from banks at beginning of year737
 798
 842
Cash and due from banks at end of year$548
 $737
 $798
     
Cash paid for interest$118
 $83
 $102
Cash paid for interest
Cash paid for interest
Net cash paid for income taxes246
 214
 132
Noncash activities are summarized as follows:     
Noncash activities:
Loans held for investment transferred to other real estate owned
Loans held for investment transferred to other real estate owned
Loans held for investment transferred to other real estate owned6
 15
 12
Loans held for investment reclassified to loans held for sale, net25
 50
 5
AFS securities purchased, not settled5
 395
 
Adjusted cost of HTM securities reclassified as AFS securities
 
 79
Trading securities reclassified to money market investments
Investment securities available-for-sale transferred to held-to-maturity, at amortized cost (fair value $10,691)
Deposits acquired in purchase of Nevada branches
Loans acquired in purchase of Nevada branches, net
See accompanying notes to consolidated financial statements.

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
December 31, 20172023
1.SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
1.SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
Business
Zions Bancorporation, National Association (“the Parent”Zions Bancorporation, N.A.,” “the Bank,” “we,” “our,” “us”) is a financial holding companybank headquartered in Salt Lake City, Utah, which owns and operates a commercial bank. The Parent and its subsidiaries (collectively “the Company”)Utah. We provide a fullwide range of banking products and related services in 11 westernWestern and southwesternSouthwestern states through seven separately managed and branded units as follows:affiliates: Zions Bank in Utah, Idaho, and Wyoming; California Bank & Trust (“CB&T”); Amegy Bank (“Amegy”), in Texas; National Bank of Arizona (“NBAZ”); Nevada State Bank (“NSB”); Vectra Bank Colorado (“Vectra”), in Colorado and New Mexico; and The Commerce Bank of Washington (“TCBW”) which operates under that name in Washington and under the name The Commerce Bank of Oregon (“TCBO”) in Oregon. Pursuant to a Board resolution adopted November 21, 2014, TCBO merged into TCBW effective March 31, 2015. The Parent also owns and operates certain nonbank subsidiaries that engage in financial services.
Basis of Financial Statement Presentation and Principles of Consolidation
The consolidated financial statements include theour accounts and those of the Parent and itsour majority-owned, subsidiaries (“the Company,” “we,” “our,” “us”).consolidated subsidiaries. Unconsolidated investments where we have the ability to exercise significant influence over the operating and financial policies of the respective investee are accounted for using the equity method of accounting; those that are not consolidated or accounted for using the equity method of accounting are accounted for under cost or fair value accounting. All significant intercompany accounts and transactions have been eliminated in consolidation. Assets held in an agency or fiduciary capacity are not included in the consolidated financial statements.
The consolidated financial statements have been prepared in accordance with United States (“U.S.”) generally accepted accounting principles (“GAAP”) and prevailing practices within the financial services industry. References to GAAP, including standards promulgated by the Financial Accounting Standards Board (“FASB”), are made according to sections of the Accounting Standards Codification (“ASC”). Changes to the ASC are made with Accounting Standards Updates (“ASU”) that include consensus issues of the Emerging Issues Task Force (“EITF”). In certain cases, ASUs are issued jointly with International Financial Reporting Standards.
In preparing the consolidated financial statements, we are required to make estimates and assumptions that affect the amounts reported in the financial statements and accompanying notes. Actual results could differ from those estimates. Certain prior year amounts have been reclassified
Subsequent Events
We evaluated events that occurred between December 31, 2023 and the date the accompanying financial statements were issued, and determined that there were no material events that would require adjustments to conform withour consolidated financial statements or significant disclosure in the current year presentation. These reclassifications did not affect net income or shareholders’ equity.accompanying Notes.
Variable Interest Entities
A variable interest entity (“VIE”) is consolidated when a company iswe are the primary beneficiary of the VIE. Current accounting guidance requires continuous analysis on a qualitative rather than a quantitative basis to determine the primary beneficiary of a VIE. At the commencement of our involvement, and periodically thereafter, we consider our consolidation conclusions for all entities with which we are involved. As ofAt December 31, 20172023, and 2016,2022, we had no VIEs that have been consolidated in the Company’sour financial statements.
Statement of Cash Flows
For purposes of presentation inon the consolidated statements of cash flows, “cash and cash equivalents” are defined as those amounts included in cash“Cash and due from banks inbanks” on the consolidated balance sheets.
Fair Value Estimates
We measure many of our assets and liabilities on a fair value basis. Fair value is the price that couldwould be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants. To improveincrease consistency and comparability in fair value measurements, GAAP has established a hierarchy towe prioritize the

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valuation inputs among three levels. The Company prioritizesin accordance with a three-level hierarchy. We prioritize quoted prices in active markets and minimizesminimize reliance on unobservable inputs when possible. When observable market prices are not available, fair value is estimated using modeling techniques such as discounted cash flow analysis. These modeling techniquesrequiring professional judgment to estimate the appropriate fair value. We believe we use assumptions that market
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participants would consider in pricing the asset or the liability, including assumptions about the risk inherent in a particular valuation technique, the effect of a restriction on the sale or use of an asset, the life of the asset and applicable growth rate, the risk of nonperformance, and other related assumptions.liability. Changes in market conditions may reduce the availability of quoted prices or observable data. When market data is not available, the Company uses valuation techniques requiring more management judgment to estimate the appropriate fair value. See Note 3 of the Notes to Consolidated Financial Statements for further information regarding the use of fair value estimates.
SecuritySecurities Purchased Under Agreements to Resell Agreements
SecuritySecurities purchased under agreements to resell agreements represent overnight and term agreements with the majority maturing within 30 days. These agreements are generally treated as collateralized financing transactions and are carried at amounts at which the securities were acquired plus accrued interest. Either the Company,We, or in some instances third parties on itsour behalf, take possession of the underlying securities. The fair value of such securities is monitored throughout the contract term to ensure that asset values remain sufficient to protect against counterparty default. We are permitted by contract to sell or repledge certain securities that we accept as collateral for security resell agreements.securities purchased under agreements to resell. If sold, our obligation to return the collateral is recorded as “securities sold, not yet purchased” and included as a liability in “Federal funds and other short-term borrowings.”borrowings” on the consolidated balance sheet. At December 31, 2017,2023, and 2022, we held $287$877 million and $2.3 billion of securities for which we were permitted by contract to sell or repledge. Securityrepledge, respectively. Securities purchased under agreements to resell agreements averaged $360 million$1.3 billion and $2.4 billion during 2017,2023 and 2022, and the maximum amount outstanding at any month-end during 2017those same time periods was $1.8$2.0 billion. and $2.7 billion, respectively.
Investment Securities
We classify our investment securities according to their purpose and holding period. Gains or losses on the sale of securities are recognized using the specific identification method and recorded in noninterest income.
Held-to-maturity (“HTM”) debt securities are carried at amortized cost with purchase discounts or premiums accreted or amortized into interest income over the contractual life of the security. The Company hasWe have the intent and ability to hold such securities until maturity. For HTM securities, the allowance for credit losses (“ACL”) is assessed consistent with the approach described in Note 6 for loans carried at amortized cost.
Available-for-sale (“AFS”) securities are statedmeasured at fair value and generally consist of debt securities held for investment. Unrealized gains and losses of AFS securities, after applicable taxes, are recorded as a component of other comprehensive income (“OCI”).
We review AFS securities in an unrealized loss position are formally reviewed on a quarterly our investmentbasis for the presence of credit impairment. If we have the intent to sell an identified security, or it is more likely than not we will be required to sell the security before recovery of its amortized cost basis, we write the amortized cost down to the security’s fair value at the reporting date through earnings. If we have the intent and ability to hold the securities, portfoliothey are analyzed to determine whether any impairment was attributable to credit-related factors. If a credit impairment is determined to exist, then we measure the amount of credit loss and recognize an allowance for any declines inthe credit loss. In measuring the credit loss, we generally compare the present value that are consideredof cash flows expected to be other-than-temporarycollected from the security to the amortized cost basis of the security. These cash flows are credit adjusted using, among other things, assumptions for default probability and loss severity. Certain other inputs, such as prepayment rate assumptions, are also utilized. In addition, certain internal models may be utilized. To determine the credit-related portion of impairment, (“OTTI”)we use the security-specific effective interest rate when estimating the present value of cash flows. If the present value of cash flows is less than the amortized cost basis of the security, then this amount is recorded as an allowance for credit loss, limited to the amount that the fair value is less than the amortized cost basis (i.e., the credit impairment cannot result in the security being carried at an amount lower than its fair value). The process, methodology, and factors considered to evaluate securities for OTTIimpairment are discusseddescribed further in Note 5.
Trading See also Note 3 for further information regarding the measurement of our investment securities are stated at fair value.
When a security is transferred from AFS to HTM, the difference between its amortized cost basis and fair value at the date of transfer is amortized as a yield adjustment through interest income, and consistthe fair value at the date of securities acquiredtransfer results in either a premium or discount to the amortized cost basis of the HTM securities. The amortization of unrealized losses reported in accumulated other comprehensive income (“AOCI”) will offset the effect of the amortization of the premium or discount in interest income that is created by the transfer.
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Leases
All leases with lease terms greater than twelve months are reported as a lease liability with a corresponding right-of-use (“ROU”) asset. We include ROU assets for short-term appreciation or other trading purposes. Realizedoperating leases and unrealized gainsfinance leases in “Other assets,” and losses“Premises, equipment and software, net” on the consolidated balance sheet, respectively. The corresponding liabilities for those leases are recorded in trading income, which is included in “Capital markets“Other liabilities,” and foreign exchange.”
The fair values of investment securities, as estimated under current“Long-term debt” on the consolidated balance sheet, respectively. See Note 8 for further information regarding the accounting guidance, are discussed in Note 3.for leases.
Loans and Allowance for Credit Losses
Loans are reported at their amortized cost basis, which includes the principal amount outstanding, net of unearned income. Unearned income,unamortized purchase premiums, discounts, and deferred loan fees and costs, which includes deferred fees net of deferred direct loan origination costs, isare amortized tointo interest income over the life of the loan using the interest method. Interest income is recognized on an accrual basis.
At the time of origination, we generally determine whether loans will beare held for investment or held for sale. We may subsequently change our intent to holdfor a loan or group of loans for investment and reclassify them as held for sale.accordingly. Loans held for sale are carried at the lower of aggregate cost or fair value. A valuation allowance is recorded when cost exceeds fair

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value based on reviews at the time of reclassification and periodically thereafter. GainsAssociated gains and losses are recorded in noninterest incomecalculated based on the difference between sales proceeds and carrying value.value, and are included in “Loan-related fees and income” on the consolidated statement of income.
We evaluate loans throughout their lives for signsindications of credit deterioration, which may impact the loan’sloan status, risk-grading, and potentially impact ourthe accounting for that loan. Loan status categories include past due as to contractual payments, nonaccrual, impaired,accruing or nonaccruing, and modified or restructured, (includingincluding troubled debt restructurings (“TDRs”), which were no longer identified after the adoption of Accounting Standards Update (“ASU”). 2022-02, Financial Instruments—Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures, beginning January 1, 2023 as discussed in Note 2. Our accounting policies for these loan statusesloans and our estimation of the related allowance for loan losses (“ALLL”)ACL are discusseddescribed further in Note 6.
In the ordinary course of business, we may syndicate portions of loans or transfer portions of loans under participation agreements to manage credit risk and our portfolio concentration. We evaluate the loan participations to determine if they meet the appropriate accounting guidance to qualify as sales. Certain purchased loans require separate accounting procedures that are also discusseddescribed in Note 6.
We elect the fair value option for certain commercial real estate (“CRE”) loans that are intended for sale or securitization and are hedged with derivative instruments, as described further in Note 3.
Allowance for Credit Losses
The ACL, which consists of the allowance for creditloan and lease losses (“ACL”ALLL”) includes the ALLL and the reserve for unfunded lending commitments (“RULC”), and represents our estimate of current expected credit losses inherent inrelated to the loan and lease portfolio that may be recognized from loans and unfunded lending commitments that are not recoverable. Furtheras of the balance sheet date. The ACL for debt securities is estimated separately from loans. See Note 6 for further discussion of our estimation process for the ACL is included in Note 6.ACL.
Other Noninterest-BearingNoninterest-bearing Investments
These investments include investments in private equity funds (referred to in this document as private equity investments “PEIs”(“PEIs”), venture capital securities, securities acquired for various debt and regulatory requirements, bank-owned life insurance (“BOLI”), and certain other noninterest-bearing investments. See further discussionsdiscussion in Notes 5, 15 andNote 3.
Certain PEIs and venture capital securities are accounted for under the equity method when we are able to exercise significant influence over the operating and financial policies of the investee. Equity investments in PEIs that do not give us significant influence are reported at fair value, unless there is not a readily determinable fair value. We have elected to measure PEIs without readily determinable fair values at cost less impairment (if any), plus or minus observable price changes from an identical or similar investment of the same issuer, referred to as the “measurement alternative.”
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Periodic reviews are conducted for impairment by comparing carrying values with estimates of fair value. Changes in fair value, impairment losses, and gains and losses from sales are recognizedincluded in noninterest“Securities gains (losses), net” on the consolidated statement of income. The values assigned to the securities where no market quotations exist are based upon available information and may not necessarily represent amounts that will ultimately be realized. Such estimated amounts depend on future circumstances and will not be realized until the individual securities are liquidated.
Bank-owned life insuranceBOLI is accounted for at fair value based on the cash surrender values (“CSVs”) of the general account insurance policies. A third party service provides these values.
Other PEIs and those acquired for various debt and regulatory requirements are accounted for at cost. Periodic reviews are conducted for impairment by comparing carrying values with estimates of fair value determined according to the previous discussion.
Premises, Equipment, and Software Net
Premises, equipment, and software are statedreported at cost, net of accumulated depreciation and amortization. Depreciation, computed primarily on the straight-line method, is charged to operations over the estimated useful lives of the properties, generally 25 to 40 years for buildings, 3three to 10 years for furniture and equipment, and 3three to 10 years for software, including capitalized costs related to the Company’sour technology initiatives. Leasehold improvements are amortized over the terms of the respective leases (including any extension options that are reasonably certain to be exercised) or the estimated useful lives of the improvements, whichever is shorter. Premises, equipment, and software are evaluated for impairment on a periodic basis.
Goodwill and Identifiable Intangible Assets
Goodwill is recorded at fair value at the time of its acquisition and intangible assets deemed to have indefinite lives are not amortized. We subject these assets to annual specifiedis subsequently evaluated for impairment tests as of the beginning of the fourth quarter andannually, or more frequently if changing conditions warrant. Core deposit assets and other intangibles with finite useful lives are generally amortized on an accelerated basis using an estimated useful life of up to 12 years.

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Business Combinations
Business combinations are accounted for under the acquisition method of accounting. Upon initially obtaining control, we recognize 100% of all acquired assets and all assumed liabilities, regardless of the percentage owned. The assets and liabilities are recorded at their estimated fair values, with goodwill being recorded when such fair values are less than the cost of acquisition. Certain transaction and restructuring costs are expensed as incurred. Changes to estimated fair values from a business combination are recognized as an adjustment to goodwill over the measurement period, which cannot exceed one year from the acquisition date. Results of operations of the acquired businessbusinesses are included inon our statement of income from the date of acquisition.
Other Real Estate Owned
Other real estate owned (“OREO”) consists principallyprimarily of commercial and residential real estate obtainedacquired in partial or total satisfaction of loan obligations. Amounts are recorded initially at fair value (less anyestimated selling costs) based on recent property appraisals at the time of transfer and subsequently at the lower of cost or fair value (less anyestimated selling costs).
Derivative Instruments
We use derivative instruments including interest ratesuch as swaps and floorspurchased and basis swaps,sold options as part ofan important tool in managing our overallasset and liability sensitivities to remain within our stated interest rate risk management strategy. These instruments enablethresholds. Their use allows us to manage to desired assetadjust and liability durationalign our mix of fixed- and to reduce interest rate risk exposure by matching estimated repricing periods of interest-sensitivefloating-rate assets and liabilities. liabilities to manage interest income and expense volatility, the duration of our assets and liabilities, and other metrics, such as the economic value of equity, by synthetically converting variable-rate assets to fixed-rate, or synthetically converting variable-rate assets and liabilities to fixed rate, or synthetically converting fixed-rate assets and funding instruments to floating rates.
We also execute both interest rate and short-term foreign currency derivative instruments with our commercial banking customers to facilitate their risk management strategies.objectives. These derivatives are immediately hedged by entering into offsetting derivatives with third parties such that we minimize our net risk exposure as a result of such transactions. We record all derivatives at fair value, and they are included in “Other assets” or “Other liabilities” on the consolidated balance sheetsheet.
The accounting for the change in value of a derivative depends on whether or not the transaction has been designated and qualifies for hedge accounting. Derivatives that are not designated as eitherhedges are reported and measured at fair value through earnings. See Note 7 for more information.
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Derivatives Designated in Qualifying Hedging Relationships
We apply hedge accounting to certain derivatives executed for risk management purposes, primarily interest rate risk. To qualify for hedge accounting, a derivative must be highly effective at reducing the risk associated with the exposure being hedged and the hedging relationship must be formally documented. We primarily use regression analysis to assess the effectiveness of each hedging relationship, unless the hedge qualifies for other assetsmethods of assessing effectiveness (e.g., shortcut or other liabilities.critical terms match), both at inception and on an ongoing basis. We designate derivatives as fair value and cash flow hedges for accounting purposes. See further discussion in Note 7.7 for more information regarding the accounting for derivatives designated as hedging instruments.
Commitments and Letters of Credit
In the ordinary course of business, we enter into loan commitments, to extend credit, commercial letters of credit, and standby letters of credit. Such financial instruments are recorded in the financial statements when they become payable.are funded. The credit risk associated with these commitments is evaluated in a manner similar to the ALLL. The RULC is presented separately inon the consolidated balance sheet.
Revenue Recognition
Service charges and fees on deposit accounts areRevenue from contracts with customers is recognized when control of the promised goods or services is transferred to our customers, in accordancean amount that reflects the consideration we expect to be entitled to in exchange for those goods or services. See Note 17 for further information regarding how we recognize revenue for contracts with published deposit account agreements for customer accounts or contractual agreements for commercial accounts. Other service charges, commissions and fees include interchange fees, bank services, and other fees, which are generally recognized at the time of transaction or as the services are performed.customers.
Share-BasedShare-based Compensation
Share-based compensation generally includes grants of stock options, restricted stock, restricted stock units (“RSUs”), and other awards to employees and non-employeenonemployee directors. We recognizerecord compensation expense in the statement of income based on the grant-date value of the associated share-based awards. See further discussion in Note 17.19.
Income Taxes
Deferred tax assets (“DTAs”) and deferred tax liabilities (“DTLs”) are determined based on temporary differences between financial statement asset and liability amounts and their respective tax bases,basis, and are measured using enacted tax laws and rates. The effect on deferred tax assets and liabilities of a change in tax rates on DTAs and DTLs is recognized ininto income in the period that includes the enactment date. Deferred tax assetsDTAs are recognized subject to management’s judgmentinsofar that realization ismanagement deems it more likely than not.not that they will be realized. Unrecognized tax benefits for uncertain tax positions primarily relate primarily to state tax contingencies.credits on technology initiatives. See further discussion in Note 18.20 for more information about the factors that impacted our effective tax rate, significant components of our DTAs and DTLs, including our assessment regarding valuation allowances and unrecognized tax benefits for uncertain tax positions.
Net Earnings Per Common Share
Net earnings per common share is based on net earnings applicable to common shareholders, which is net of preferred stock dividends. Basic net earnings per common share is based on the weighted average outstanding

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common shares during each year. Unvested share-based awards with rights to receive nonforfeitable dividends are considered participating securities and are included in the computation of basic earnings per share. Diluted net earnings per common share is based on the weighted average outstanding common shares during each year, including common stock equivalents. Stock options, restricted stock, RSUs, and stock warrants are converted to common stock equivalents using the more dilutive of the treasury stock method or the two-class method. Diluted net earnings per common share excludes common stock equivalents whose effect is antidilutive. See further discussion in Note 19.21.
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2.    RECENT ACCOUNTING PRONOUNCEMENTS
StandardDescriptionEffective dateDate of adoption
Effect on the financial statements
or other significant matters
Standards not yet adopted by the Company during 2017Bank as of December 31, 2023
ASU 2014-09,
Revenue from Contracts with Customers (Topic 606) and subsequent related ASUs

The core principle of the new guidance is that a company will recognize revenue when it transfers promised goods or services to customers in an amount that reflects the consideration to which the Company expects to be entitled in exchange for those goods or services. The banking industry does not expect significant changes because major sources of revenue are from financial instruments that have been excluded from the scope of the new standard, (including loans, derivatives, debt and equity securities, etc.). However, these new standards affect other fees charged by banks, such as asset management fees, credit card interchange fees, deposit account fees, etc. Adoption may be made on a full retrospective basis with practical expedients, or on a modified retrospective basis with a cumulative effect adjustment. Additionally, the new guidance significantly increases the disclosures related to revenue recognition practices.January 1, 2018Approximately 85% of our revenue, including all of our interest income and a portion of our noninterest income, is out of scope of the guidance. The contracts that are in scope of the guidance are primarily related to service charges and fees on deposit accounts, wealth management and trust income, and other service charges, commissions and fees. We have completed our review of these contracts and have not identified any material changes in the timing of revenue recognition. We adopted this guidance January 1, 2018 using the modified retrospective transition method. There was no material impact at adoption to the Company’s consolidated financial statements.
ASU 2016-01,2022-03,
Financial Instruments – Overall (Subtopic 825-10)Fair Value Measurement (Topic 820): Recognition andFair Value Measurement of Financial Assets and Financial LiabilitiesEquity Securities Subject to Contractual Sale Restrictions

The standard provides revised accounting guidance related to
This ASU clarifies that contractual restrictions prohibiting the accounting for and reportingsale of financial instruments. Somean equity security are not considered part of the main provisions include:
– Equity investmentsunit of account of the equity security, and therefore, are not considered in measuring fair value. The amendments clarify that do not resultan entity cannot recognize and measure a contractual sale restriction as a separate unit of account. The amendments in consolidationthis ASU also require additional qualitative and quantitative disclosures for equity securities subject to contractual sale restrictions.


January 1, 2024
The requirements of this ASU are consistent with our current treatment of equity securities subject to contractual sale restrictions and are not accounted for under the equity method would be measured at fair value through net income.
– Changes in instrument-specific credit risk for financial liabilities that are measured underexpected to impact the fair value option would be recognized in OCI.
– Eliminationmeasurements of the requirement to disclose the methods and significant assumptions used to estimate the fair value of financial instruments carried at amortized cost. However, it will require the use of exit price when measuring the fair value of financial instruments measured at amortized cost for disclosure purposes.
January 1, 2018We do not have a significant amount of equity securities classified as AFS. Additionally, we do not have any financial liabilities accounted for under the fair value option. Therefore, the transition adjustment upon adoption of this guidance as of January 1, 2018 was not material. We are refining our valuation models to better account for an exit price, which will not change our financial statements, but will have an impact on our disclosures.


these securities.
StandardDescriptionDate of adoption
Effect on the financial statements
or other significant matters
Standards not adopted by the Company during 2017 (continued)
ASC 2017-12, Derivatives and Hedging (Topic 815): Targeted Improvement to Accounting for Hedging Activities
The purposeoverall effect of this standard is not expected to better align a company’s financial reporting for hedging activities, with the economic objectives of those activities. The standard is effective for public business entities for fiscal years beginning after December 15, 2018, with early adoption, including adoption in an interim period, permitted. The standard requires a modified retrospective transition method that requires recognition of the cumulative effect of the change on the opening balance of each affected component of equity in the statement of financial position as of the date of adoption.January 1, 2018We early adopted this guidance as of January 1, 2018. The adoption of this guidance did not have a material impact on our consolidated financial statements at transition.statements.


ASU 2016-02,2023-02,
LeasesInvestments—Equity Method and Joint Ventures (Topic 842)323): Accounting for Investments in Tax Credit Structures Using the Proportional Amortization Method (a consensus of the Emerging Issues Task Force)
The standard requires thatThis ASU expands the optional use of the proportional amortization method (“PAM”), previously limited to investments in low-income housing tax credit (“LIHTC”) structures, to any eligible equity investments made primarily for the purpose of receiving income tax credit and other tax benefits when certain criteria are met. PAM results in the cost of the investment being amortized in proportion to the income tax credits and other income tax benefits received, with the amortization of the investment and the income tax credits being presented net on the consolidated statement of income as a lessee recognize assets and liabilitiescomponent of income tax expense (benefit).

This ASU allows for leases with lease terms of more than 12 months. For leases with a term of 12 months or less, a lessee is permitted to make an accounting policy election by class of underlying asset not to recognize lease assets and lease liabilities.apply PAM on a tax-credit-program-by-tax-credit-program basis. The recognition, measurement, and presentation of expenses and cash flows arising from a lease by a lessee primarily will depend on its classification as a finance or operating lease. However, the standard will require both types of leases to be recognized on the balance sheet. ItASU also requires disclosures to better understand the amount, timing, and uncertainty of cash flows arising from leases. These disclosures include qualitative and quantitativeincludes additional disclosure requirements providing additional information about the amounts recorded in the financial statements.equity investments accounted for using PAM.
January 1, 20192024
We do not currently have any additional equity investments that are currently evaluatingeligible for PAM under the potential impactprovisions of this guidance on the Company’s financial statements. AsASU.

The overall effect of December 31, 2017, the Company had minimum noncancelable operating lease payments of $245 million that are being evaluated. The implementation teamthis standard is working on gathering all key lease data elementsnot expected to meet the requirements of the new guidance. Additionally, we are implementing new lease software that will accommodate the new accounting requirements.
ASU 2017-08, Nonrefundable Fees and Other Costs (Subtopic 310-20). Premium Amortization on Purchased Callable Debt Securities
The amendments in this ASU shorten the amortization period for certain callable debt securities held at a premium. The standard requires the premium to be amortized to the earliest call date. The update does not change the accounting for securities held at a discount.January 1, 2019Our initial analysis suggests this guidance will not have a material impact on the Company’sour financial statements, but we will continue to monitor its impact as we move closer to implementation.statements.


ASU 2016-13,
Credit Losses2023-07, Segment Reporting (Topic 326)280): Measurement of Credit Losses on Financial InstrumentsImprovements to Reportable Segment Disclosures
This ASU expands operating segment disclosures and requires all segment disclosures to be reported in both annual and interim periods. The new standard significantly changes how entities will measure credit losses for most financial assets and certain other instrumentsrequires disclosure of the following:
Significant segment expenses that are not measured at fair value through net income. regularly provided to the chief operating decision maker (“CODM”) for reportable segments;
The standard replaces today’s “incurred loss” approach with an “expected loss” model for instruments such as loanstitle and HTM securities that are measured at amortized cost. The standard requires credit losses relating to AFS debt securities to be recorded through an ACL rather than a reductionposition of the carrying amount. It also changesCODM as well as how the accounting for purchased credit-impaired (“PCI”)debt securitiesCODM uses the reported measure(s) of profit and loans. The standard retains manyloss to assess segment performance; and
“Other segment items” by reportable segment and a description of the current disclosure requirements in current GAAP and expands certain disclosure requirements. Early adoption of the guidance is permitted as ofits composition.
Annual periods beginning January 1, 2019.2024; Interim periods beginning January 1, 20202025
We have formed an implementation team led jointly by Credit and the Corporate Controller’s group, that also includes other linesThe overall effect of business and functions within the Company. The implementation team is working on developing models that can meet the requirements of the new guidance. While this standard may potentiallyis not expected to have a material impact on the Company’sour financial statements, we are still in process of conducting our evaluation.statements.




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StandardDescriptionDate of adoption
Effect on the financial statements
or other significant matters
Standards not adopted by the Company during 2017 (continued)
ASU 2017-04,
Intangibles – Goodwill and Other2023-09, Income Taxes (Topic 350)740): Simplifying the Test for Goodwill ImpairmentImprovements to Income Tax Disclosures
This ASU expands tax disclosures to provide more information to better assess how an entity’s operations and related tax risks and tax planning and opportunities affect its tax rate and prospects for future cash flows. The enhancements in this ASU require that an entity disaggregate income taxes paid and income (or loss) from continuing operations before tax expense (or benefit), and income tax expense (or benefit) from continuing operations.

The new standard requires disclosure of specific categories in the rate reconciliation and provide additional information for reconciling items that meet a quantitative threshold.
The standard eliminates the requirement to calculate the implied fair value of goodwill (i.e. Step 2 of the current goodwill impairment test) to measure a goodwill impairment charge. Instead, entities would record an impairment charge based on the excess of a reporting unit’s carrying amount over its fair value (i.e., measure the charge based on Step 1 of the current guidance). The standard does not change the guidance on completing Step 1 of the goodwill impairment test. The standard also continues to allow entities to perform the optional qualitative goodwill impairment assessment before determining whether to proceed to Step 1. The standard is effective for the Company as of January 1, 2020. Early adoption is allowed for any goodwill impairment test performed after January 1, 2017.January 1, 20202025
We doare evaluating the disclosure requirements. The overall effect of this standard is not currently expect this guidance willexpected to have a material impact on the Company’sour financial statements since the fair values of our reporting units were not lower than their respective carrying amounts at the time of our goodwill impairment analysis for 2017.statements.


StandardDescriptionDate of adoptionEffect on the financial statements
or other significant matters
Standards adopted by the Company during 2017Bank in 2023
ASU 2016-09,2022-02,
Stock CompensationFinancial Instruments—Credit Losses (Topic 718)326): Improvements to Employee Share-Based Payment AccountingTroubled Debt Restructurings and Vintage Disclosures


This ASU eliminated the recognition and measurement guidance on troubled debt restructurings for creditors that have adopted ASC 326 (“CECL”), and eliminated certain previously required TDR disclosures while expanding disclosures about loan modifications for borrowers experiencing financial difficulty. The new standard also required public companies to present gross write-offs (on a year-to-date basis for interim-period disclosures) by year of origination in their vintage disclosures.    

The standard requires entities to recognizeJanuary 1, 2023We adopted the income tax effects of share-based awardsguidance in the income statement when the awards vest or are settled (i.e. the additional paid-in capital pools will be eliminated). The guidancenew standard on employers’ accounting for an employee’s use of shares to satisfy the employer’s statutory income tax withholding obligation and for forfeitures is changing. The standard also provides an entity the option to make an entity-wide accounting policy election to either estimate the number of awards that are expected to vest or account for forfeitures when they occur.January 1, 2017Upon2023. The adoption of this ASU, there was nostandard did not have a material impact from the cumulative effect adjustment to retained earnings. We elected to account for forfeitures when they occur and to reflect excess tax benefits in the operating section of the statement of cash flows on a prospective basis.
ASU 2018-02, Income StatementReporting Comprehensive Income (Topic 220): Reclassification of Certain Tax Effects from Accumulated Other Comprehensive Income
The standard allows a one-time movement between Accumulated Other Comprehensive Income (“AOCI”) and Retained Earnings to adjust for amounts that would otherwise be stranded in AOCI as a result of implementing changes due to the enactment of H.R. 1, known as the Tax Cuts and Jobs Act. The standard is effective for public companies for fiscal years beginning after December 15, 2018, with early adoption, including in an interim period, permitted.December 31, 2017The Company adopted this standard for the 2017 fiscal yearour financial statements with a $25 million adjusting entry between AOCI and Retained Earnings.statements.
3.FAIR VALUE
3. FAIR VALUE
Fair Value Measurement
Fair value is defined as the exchange price that would be received for an asset or paid to transfer a liability (an exit price) in the principal or most advantageous market for the asset or liability in an orderly transaction between market participants on the measurement date. To measure fair value, a hierarchy has been established that requires an entity to maximizeprioritizes the use of observable inputs and minimize the use ofover unobservable inputs. This hierarchy uses the following three levels of inputs to measure the fair value of assets and liabilities as follows:liabilities:
Level 1 Quoted prices in active markets for identical assets or liabilities in active markets that the Company haswe have the ability to access;


Level 2 Observable inputs other than Level 1, including quoted prices for similar assets or liabilities in active markets, quoted prices for identical or similar assets or liabilities in less active markets, observable inputs other than quoted prices that are used in the valuation of an asset or liability, and inputs that are derived principally from or corroborated by observable market data by correlation or other means; and
Level 3 Unobservable inputs supported by little or no market activity for financial instruments whose value is determined by pricing models, discounted cash flow methodologies or similar techniques, as well as instruments for which the determination of fair value requires significant management judgment or estimation.
The level in the fair value hierarchy within which the fair value measurement is classified is determined based on the lowest level input that is significant to the fair value measurement in its entirety. Market activity is presumed to be orderly in the absence of evidence of forced or disorderly sales, although such sales may still be indicative of fair value.sales. Applicable accounting guidance precludes the use of blockage factors or liquidity adjustments due to the quantity of securities held by an entity.
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We use fair value to measure certain assets and liabilities at fair value on a recurring basis when fair value is the primary measure for accounting. Fair value is used on a nonrecurring basis to measure certain assets, when adjusting carrying values, such as the application of lower of cost or fair value accounting includingand the recognition of impairment on assets. Fair value is also used when providing required disclosures for certain financial instruments.
Fair Value Policies and Procedures
We have various policies, processes, and controls in place to ensure that fair values are reasonably developed, reviewed, and approved for use. These include aOur Securities Valuation Committee, comprised of executive management, that reviews and approves on a quarterly basis the key components of fair value estimation,measurements, including critical valuation assumptions for Level 3 modeling. Ameasurements. Our Model Risk Management Group conducts model validations, including internal models, and sets policies and procedures for revalidation, including the timing of revalidation.
Third PartyThird-party Service Providers
We use a third partythird-party pricing service to measure fair value for approximately 92%substantially all of our AFS Level 2 AFS securities. Fair value measurements for other AFS Level 2 AFS securities generally use certain inputs corroborated by market data and include standard discounted cash flow analysis.analyses.
For Level 2 securities, the third partythird-party pricing service provides documentation on an ongoing basis that presents market corroborative data, including detaildetailed pricing information and market reference data. The documentation includes benchmark yields, reported trades, broker-dealer quotes, issuer spreads, two-sided markets, benchmark securities, bids, offers, and reference data, including information from the vendor trading platform. We review, test, and validate this information as appropriate. Absent observable trade data, we do not adjust prices from our third party sources.on a regular basis.
The following describes the hierarchy designations, valuation methodologies and key inputs to measure fair value on a recurring basis for designated financial instruments:
Available-for-Sale
U.S. Treasury, Agencies and Corporations
U.S. Treasury securities are measured under Level 1 using quoted market prices when available.are classified in Level 1. U.S. agenciesagency and corporationscorporate securities measured using observable market inputs are measured underclassified in Level 2 generally using the previously discussed third party pricing service.2.
Municipal Securities
Municipal securities are measured underusing observable market inputs and are classified in Level 2 generally using the third party pricing service or an internal model. Valuation inputs include Baa municipal curves, as well as Federal Home Loan Bank (“FHLB”) and LIBOR swap curves. Our valuation methodology for non-rated municipal securities changed at year-end of2.


2015 to utilize more observable inputs, primarily municipal market yield curves, compared to our previous valuation method. The resulting values were determined to be Level 2.
Money Market Mutual Funds and Other
Money market mutual funds and other Debt Securities — Other debt securities are measured under Level 1 or Level 2. For Level 1, quoted market prices are used which may include net asset values (“NAVs”) or their equivalents. Level 2 valuations generally useusing quoted prices for similar securities.securities and are classified in Level 2.
Trading
Trading Accountsecurities are measured using observable market inputs and are classified in Level 1 and Level 2.
Securities in the trading account are generally measured under Level 2 using third party pricing service providers as described previously.
Bank-OwnedBank-owned Life Insurance
Bank-owned life insurance (“BOLI”)BOLI is measured under Level 2 according to CSVsthe CSV of the insurance policies that are provided by a third party service.policies. Nearly all policies are general account policies with CSVs based on the Company’sour claims on the assets of the insurance companies. The insurance companies’ investments include predominantly fixed incomefixed-income securities consisting of investment-grade corporate bonds and various types of mortgage instruments. Management regularly reviews its BOLI investment performance, including concentrations among insurance providers.providers and classifies BOLI balances in Level 2.
Private Equity Investments
PEIs are measured under Level 3. The majority of these investments are held in Zions’ Small Business Investment Company (“SBIC”) and are early stage venture investments. Theat fair value measurements of these investments are reviewed on a quarterlyrecurring basis by the Securities Valuation Committee. The Equity Investments Committee, consisting of executives familiar with the investments, reviews periodic financial information, including audited financial statements when available.
Certain valuation analytics may be employed thatare generally classified in Level 3 because related measurements include unobservable inputs. Key assumptions and considerations include current and projected financial performance, recent financing activities, economic and market conditions, market comparables,comparable companies, market liquidity, sales restrictions, and other factors. A significant changeThe majority of these PEIs are held in our Small Business Investment Company (“SBIC”) and are early-stage venture investments. These investments are reviewed at least quarterly by the expected performanceSecurities Valuation Committee and whenever a new round of the individual investment would resultfinancing occurs. Some of these investments may be
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measured using multiples of operating performance. The Equity Investments Committee reviews periodic financial information for these investments, including audited financial statements when available. On occasion, PEIs may become publicly traded and are measured in a change in the fair value measurement of the investment. The amount of unfunded commitments to invest is disclosed in Note 15.Level 1. Certain restrictions may apply for the redemption of these investments and certain investments are prohibited by the Volcker Rule. See discussion in Notes 5 and 15.investments.
Agriculture Loan Servicing
This asset results from our servicing ofWe service agriculture loans approved and funded by Federal Agricultural Mortgage Corporation (“FAMC”). We, and provide this servicing under an agreement with FAMC for the loans they own.it owns. The asset’sservicing assets are measured at fair value, which represents our projection of the present value of net future cash flowsflows. Because related measurements include unobservable inputs, these assets are classified in Level 3.
Loans held for sale
We have elected the fair value option for certain commercial real estate loans that are intended for sale to a third-party conduit for securitization. These loans are measured under Level 3at fair value using discounted cash flow methodologies.
Interest-Only Strips
Interest-only strips are created as a by-productobservable market prices for mortgage-backed securities with similar collateral. The value of the securitization process. Whenloans incorporates adjustments for differences between the guaranteed portionssecurities and the value of Small Business Administration (“SBA”) 7(a)the underlying loans due to credit quality, portfolio composition, and liquidity. Valuations of loans measured at fair value are pooled, interest-only strips may be createdgenerally classified in Level 2 in the pooling process. The asset’s fair value represents our projection of the present value of future cash flows measured under Level 3 using discounted cash flow methodologies.hierarchy because their pricing is largely based on observable market inputs.
Deferred Compensation Plan Assets and Obligations
Invested assets in the deferred compensation plan consist of shares of registered investment companies. These mutual funds are valued under Level 1 atusing quoted market prices, which represents the NAVnet asset value (“NAV”) of shares held by the plan at the end of the period.


As such, these assets are classified in Level 1.
Derivatives
Derivatives are measured according to their classification as either exchange-traded or over-the-counter. Exchange-traded derivatives, consist ofincluding foreign currency exchange contracts, measured underare generally classified in Level 1 because they are traded in active markets. Over-the-counter derivatives, including those for customers, consistconsisting primarily of interest rate swaps and options. These derivativesoptions, are measured undergenerally classified in Level 2 using third party services.as the related fair values are obtained from third-party services that utilize observable market inputs. Observable market inputs include yield curves, (the LIBOR swap curve and relevant overnight index swap curves), foreign exchange rates, commodity prices, option volatilities,volatility, counterparty credit risk, and other related data. CreditValuations include credit valuation adjustments are required(“CVAs”) to reflect nonperformance risk for both the Companyus and the respective counterparty. These adjustmentsour counterparties. CVAs are determined generally by applying a credit spread to the total expected exposure (net of any collateral) of the derivative.
Securities Sold, Not Yet Purchased
Securities sold, not yet purchased, are included in “Federal funds and other short-term borrowings” on the consolidated balance sheet, and are measured under Level 1 using quoted market prices.prices and are generally classified in Level 1. If market prices for identical securities are not available, quoted prices under Level 2 for similar securities are used.used with the related balances classified in Level 2.
Quantitative Disclosure by
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Fair Value Hierarchy
AssetsThe following schedule presents assets and liabilities measured at fair value by class on a recurring basis are summarized as follows:basis:
(In millions)December 31, 2023
Level 1Level 2Level 3Total
ASSETS
Available-for-sale securities:
U.S. Treasury, agencies, and corporations$492 $8,467 $— $8,959 
Municipal securities1,318 1,318 
Other debt securities23 23 
Total available-for-sale492 9,808 — 10,300 
Trading securities48 48 
Other noninterest-bearing investments:
Bank-owned life insurance553 553 
Private equity investments 1
92 95 
Other assets:
Agriculture loan servicing19 19 
Loans held for sale43 43 
Deferred compensation plan assets124 124 
Derivatives420 420 
Total assets$619 $10,872 $111 $11,602 
LIABILITIES
Securities sold, not yet purchased$65 $— $— $65 
Other liabilities:
Derivatives333 333 
Total liabilities$65 $333 $— $398 
(In millions)December 31, 2017
 Level 1 Level 2 Level 3 Total
ASSETS       
Investment securities:       
Available-for-sale:       
U.S. Treasury, agencies and corporations$25
 $13,706
 $
 $13,731
Municipal securities  1,334
 

 1,334
Other debt securities  24
 

 24
Money market mutual funds and other71
 1
   72
Total Available-for-sale96
 15,065
 
 15,161
Trading account  148
   148
Other noninterest-bearing investments:       
Bank-owned life insurance  507
   507
Private equity investments    95
 95
Other assets:       
Agriculture loan servicing and interest-only strips    18
 18
Deferred compensation plan assets102
     102
Derivatives:       
Interest rate related and other  1
   1
Interest rate swaps for customers  28
   28
Foreign currency exchange contracts9
     9
Total Assets$207
 $15,749
 $113
 $16,069
LIABILITIES       
Securities sold, not yet purchased$95
 $
 $
 $95
Other liabilities:       
Deferred compensation plan obligations102
     102
Derivatives:       
Interest rate swaps for customers  33
   33
Foreign currency exchange contracts7
     7
Total Liabilities$204
 $33
 $
 $237


(In millions)December 31, 2016
 Level 1 Level 2 Level 3 Total
ASSETS       
Investment securities:       
Available-for-sale:       
U.S. Treasury, agencies and corporations$
 $12,009
 $
 $12,009
Municipal securities  1,154
 

 1,154
Other debt securities  24
 

 24
Money market mutual funds and other184
 1
   185
Total Available-for-sale184
 13,188
 
 13,372
Trading account  115
   115
Other noninterest-bearing investments:       
Bank-owned life insurance  497
   497
Private equity investments 1
18
 

 73
 91
Other assets:      

Agriculture loan servicing and interest-only strips    20
 20
Deferred compensation plan assets91
     91
Derivatives:       
Interest rate related and other  4
   4
Interest rate swaps for customers  49
   49
Foreign currency exchange contracts11
     11
Total Assets$304
 $13,853
 $93
 $14,250
LIABILITIES       
Securities sold, not yet purchased$25
 $
 $
 $25
Other liabilities:      

Deferred compensation plan obligations91
     91
Derivatives:       
Interest rate related and other  1
   1
Interest rate swaps for customers  49
   49
Foreign currency exchange contracts9
     9
Total Liabilities$125
 $50
 $
 $175
1The level 1 PEIs amount relatesrelate to the portion of our SBIC investments that are now publicly traded.
Reconciliation
(In millions)December 31, 2022
Level 1Level 2Level 3Total
ASSETS
Available-for-sale securities:
U.S. Treasury, agencies, and corporations$393 $9,815 $— $10,208 
Municipal securities1,634 1,634 
Other debt securities73 73 
Total available-for-sale393 11,522 — 11,915 
Trading securities395 70 465 
Other noninterest-bearing investments:
Bank-owned life insurance546 546 
Private equity investments 1
81 85 
Other assets:
Agriculture loan servicing14 14 
Deferred compensation plan assets114 114 
Derivatives386 386 
Total assets$906 $12,524 $95 $13,525 
LIABILITIES
Securities sold, not yet purchased$187 $— $— $187 
Other liabilities:
Derivatives451 451 
Total liabilities$187 $451 $— $638 
1 The level 1 PEIs relate to the portion of our SBIC investments that are publicly traded.
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Roll-forward of Level 3 Fair Value Measurements
The following reconciles the beginning and ending balancesschedule presents a roll-forward of assets and liabilities that are measured at fair value by class on a recurring basis using Level 3 inputs:
 Level 3 Instruments
December 31, 2023December 31, 2022December 31, 2021
(In millions)Private
equity
investments
Ag loan servicingPrivate
equity
investments
Ag loan servicingPrivate
equity
investments
Ag loan servicing
Balance at beginning of year$81 $14 $66 $12 $80 $16 
Unrealized securities gains (losses), net(2)— — 71 — 
Other noninterest income (expense) 1
— — — (3)
Purchases14 — 16 — 17 — 
Cost of investments sold(1)— (3)— (24)— 
Redemptions and paydowns— — — — — (1)
Transfers out 2
— — (1)— (78)— 
Balance at end of year$92 $19 $81 $14 $66 $12 
 Level 3 Instruments
 December 31, 2017 December 31, 2016
(In millions)Private
equity
investments
 Ag loan svcg and int-only strips Private
equity
investments
 Ag loan svcg and int-only strips
        
Balance at beginning of year$73
 $20
 $58
 $14
Securities gains, net7
 
 6
 
Other noninterest income
 (1) 
 6
Purchases20
 
 10
 
Redemptions and paydowns(5) (1) (1) 
Balance at end of year$95
 $18
 $73
 $20
1 Represents the valuation adjustments related to the agricultural loan servicing asset.
No transfers2 Represents the transfer of assets or liabilities occurred among LevelsSBIC investments out of Level 3 and into Level 1 2 or 3 for 2017 and 2016.


because they are publicly traded.
The preceding reconciling amounts usingroll-forward of Level 3 inputs includeinstruments includes the following realized gains/gains and losses included in “Securities gains (losses), net” on the consolidated statement of income:income for the periods presented:
(In millions)
Year Ended
December 31,
2017 2016
    
Equity securities gains, net$3
 $6
(In millions)Year Ended December 31,
202320222021
Securities gains (losses), net$(1)$(2)$31 
Nonrecurring Fair Value Measurements
IncludedCertain assets and liabilities may be recorded at fair value on a nonrecurring basis, including impaired loans that have been measured based on the fair value of the underlying collateral, OREO, and equity investments without readily determinable fair values. Nonrecurring fair value adjustments generally include changes in value resulting from observable price changes for equity investments without readily determinable fair values, write-downs of individual assets, or the balance sheet amounts are the following amountsapplication of lower of cost or fair value accounting. At December 31, 2023, we had an insignificant amount of assets or liabilities that had fair value changes measured on a nonrecurring basis:basis.
(In millions)Fair value at December 31, 2017 Gains (losses) from
fair value changes Year Ended December 31, 2017
Level 1 Level 2 Level 3 Total 
ASSETS         
Private equity investments, carried at cost$
 $
 $1
 $1
 $(1)
Impaired loans
 9
 
 9
 (5)
Other real estate owned
 
 
 
 
Total$
 $9
 $1
 $10
 $(6)
(In millions)Fair value at December 31, 2016 Gains (losses) from
fair value changes Year Ended December 31, 2016
Level 1 Level 2 Level 3 Total 
ASSETS         
Private equity investments, carried at cost$
 $
 $1
 $1
 $(1)
Impaired loans
 52
 
 52
 (36)
Other real estate owned
 1
 
 1
 (2)
Total$
 $53
 $1
 $54
 $(39)
The previous fair values may not be current as of the dates indicated, but rather as of the date the fair value change occurred, such as a charge for impairment. Accordingly, carrying values may not equal current fair value.
We recognized net gains of $2 million in 2017 and $4 million in 2016 from the sale of OREO propertiesLoans that had a carrying value at the time of sale of approximately $6 million in 2017 and $13 million in 2016. Previous to their sale in these years, we recognized an insignificant amount of impairment on these properties in 2017 and 2016.
PEIs carried at costare collateral dependent were measured at fair value for impairment purposes according to the methodology previously discussed for these investments. Amountslower of PEIs carried atamortized cost were $10 million and $13 million at December 31, 2017 and 2016, respectively. Amounts of other noninterest-bearing investments carried at cost were $338 million and $211 million at December 31, 2017 and 2016, respectively, which were comprised of Federal Reserve and FHLB stock. PEIs accounted for using the equity method were $36 million at December 31, 2017 and $38 million at December 31, 2016.
Impaired (or nonperforming) loans that are collateral-dependent were measured at fair value based onor the fair value of the collateral. OREO was measured initially at fair value based on collateral appraisals at the time of transfer and subsequently at the lower of cost or fair value.
value (less any selling costs). Measurement of fair value for collateral-dependent loans and OREO was based on third partythird-party appraisals that utilize one or more valuation techniques (income, market and/or cost approaches). Any adjustments to calculated fair value were made based on recently completed and validated third partythird-party appraisals, third partythird-party appraisal services, automated valuation services, or our informed judgment. Evaluations were made to determine that the appraisal process met the relevant concepts and requirements of applicable accounting guidance.


Automated valuation services may be used primarily for residential properties when values from any of the previous methods were not available within 90 days of the balance sheet date. These services use models based on market, economic, and demographic values. The useAt December 31, 2023, we had less than $1 million of these models has only occurredcollateral-dependent loans classified in a very few instancesLevel 2, and the related property valuations have not been sufficiently significant to consider disclosure under Level 3 rather than Level 2.
Impaired loans that are not collateral-dependent were measured based on the present valuewe recognized an insignificant amount of future cash flows discounted at the expected coupon rates over the lives of the loans. Because the loans were not discounted at market interest rates, the valuations do not representlosses from fair value and have been excluded from the nonrecurring fair value balance in the preceding schedules.changes related to these loans.
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Fair Value of Certain Financial Instruments
Following is a summary ofThe following schedule presents the carrying values and estimated fair values of certain financial instruments:
 December 31, 2023December 31, 2022
(In millions)Carrying
value
Fair valueLevelCarrying
value
Fair valueLevel
Financial assets:
Held-to-maturity investment securities$10,382 $10,466 2$11,126 $11,239 2
Loans and leases (including loans held for sale), net of allowance57,148 54,832 355,086 53,093 3
Financial liabilities:
Time deposits9,996 9,964 22,309 2,269 2
Long-term debt542 494 2651 635 2
 December 31, 2017 December 31, 2016
(Dollar amounts in millions)
Carrying
value
 
Estimated
fair value
 Level 
Carrying
value
 
Estimated
fair value
 Level
Financial assets:           
Held-to-maturity investment securities$770
 $762
 2 $868
 $850
 2
Loans and leases (including loans held for sale), net of allowance44,306
 44,226
 3 42,254
 42,111
 3
Financial liabilities:           
Time deposits3,115
 3,099
 2 2,757
 2,744
 2
Other short-term borrowings3,600
 3,600
 2 500
 500
 2
Long-term debt (less fair value hedges)383
 402
 2 535
 552
 2
This summary excludes financial assets and liabilities for which carrying value approximates fair value andThe preceding schedule does not include certain financial instruments that are recorded at fair value on a recurring basis. Financial instrumentsbasis, as well as certain financial assets and liabilities for which the carrying values approximatevalue approximates fair value, includesuch as cash and due from banks,banks; money market investments,investments; demand, savings, and money market deposits,deposits; federal funds purchased and other short-term borrowings,borrowings; and security repurchase agreements. The estimated fair value of demand, savings and money market deposits is the amount payable on demand at the reporting date. Carrying value is used because the accounts have no stated maturity, and the customer has the ability to withdraw funds immediately.
HTM investment securities primarily consist of municipal securities. They were measured atimmediately, and there is generally negligible credit risk. Instruments for which carrying value approximates fair value according toare generally classified in Level 2 in the methodology previously discussed.
Loans are measured at fair value according tohierarchy because their status as nonimpaired or impaired. For nonimpaired loans, fair valuepricing is estimated by discounting future cash flows using the LIBOR yield curve adjusted by a factor which reflects the credit and interest rate risk inherent in the loan. These future cash flows are then reduced by the estimated “life-of-the-loan” aggregate credit losses in the loan portfolio. These adjustments for lifetime future credit losses are derived from the methods used to estimate the ALLL for our loan portfolio and are adjusted quarterly as necessary to reflect the most recent loss experience. Impaired loans that are collateral-dependent are already considered to be held at fair value. Impaired loans that are not collateral-dependent have future cash flows reduced by the estimated “life-of-the-loan” credit loss derived from methods used to estimate the ALLL for these loans. See Impaired Loans in Note 6 for detailslargely based on the impairment measurement method for impaired loans. Loans, other than those held for sale, are not normally purchased and sold by the Company, and there are no active trading markets for most of this portfolio.
observable market inputs. Time and foreign deposits and any other short-term borrowings, are measured at fair value by discounting future cash flows using the LIBORapplicable yield curve to the given maturity dates.
Long-term debt is measured at fair value based on actual market trades (i.e., an asset value) when available, or discounting cash flows to maturity using the LIBORapplicable yield curve adjusted for credit spreads.


For loans measured at amortized cost, fair value is estimated for disclosure purposes by discounting future cash flows using the applicable yield curve adjusted by a factor that is derived from analyzing recent loan originations and combined with a liquidity premium inherent in the loan. These future cash flows are then reduced by the estimated life-of-the-loan aggregate credit losses in the loan portfolio. The methods used to measure fair value for HTM securities was previously described.
These fair value disclosures represent our best estimates based on relevant market information and information about the financial instruments.information. Fair value estimates are based on judgments regarding current economic conditions, future expected loss experience, risk characteristics of the various instruments, and other factors. These estimates are subjective in nature, involve uncertainties and matters of significant judgment, and cannot be determined with precision. Changes in these methodologies and assumptions couldwould significantly affect the estimates.
Fair Value Option for Certain Loans Held for Sale
During the second quarter of 2023, we elected the fair value option for certain commercial real estate loans that are intended for sale to a third-party conduit for securitization and are hedged with derivative instruments. Electing the fair value option reduces the accounting volatility that would otherwise result from the asymmetry created by accounting for the loans held for sale at the lower of cost or fair value and the derivatives at fair value without the complexity of applying hedge accounting. These loans are included in “Loans held for sale” on the consolidated balance sheet, and associated gains and losses are included in “Capital markets fees” on the consolidated statement of income. At December 31, 2023, we had $43 million of loans measured at fair value ($43 million par value). During 2023, we recognized approximately $4 million of net gains from valuation adjustments of loans carried at fair value and the associated derivatives.
4.OFFSETTING ASSETS AND LIABILITIES
Gross
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4.    OFFSETTING ASSETS AND LIABILITIES
The following schedule presents gross and net information for selected financial instruments inon the balance sheet is as follows:sheet:
December 31, 2023
(In millions)Gross amounts not offset on the balance sheet
DescriptionGross amounts recognizedGross amounts offset on the balance sheetNet amounts presented on the balance sheetFinancial instrumentsCash collateral received/pledgedNet amount
Assets:
Federal funds sold and securities purchased under agreements to resell$1,170 $(233)$937 $— $— $937 
Derivatives (included in Other assets)
420 — 420 (31)(357)32 
Total assets$1,590 $(233)$1,357 $(31)$(357)$969 
Liabilities:
Federal funds and other short-term borrowings$4,612 $(233)$4,379 $— $— $4,379 
Derivatives (included in Other liabilities)
333 — 333 (31)(1)301 
Total liabilities$4,945 $(233)$4,712 $(31)$(1)$4,680 
  December 31, 2017
(In millions)       Gross amounts not offset in the balance sheet  
Description Gross amounts recognized Gross amounts offset in the balance sheet Net amounts presented in the balance sheet Financial instruments Cash collateral received/pledged Net amount
Assets:            
Federal funds sold and security resell agreements $809
 $(295) $514
 $
 $
 $514
Derivatives (included in other assets) 38
 
 38
 (21) (1) 16
Total assets $847
 $(295) $552
 $(21) $(1) $530
Liabilities:            
Federal funds and other short-term borrowings $5,271
 $(295) $4,976
 $
 $
 $4,976
Derivatives (included in other liabilities) 40
 
 40
 (21) (6) 13
Total liabilities $5,311
 $(295) $5,016
 $(21)
$(6)
$4,989
 December 31, 2016
December 31, 2022December 31, 2022
(In millions)       Gross amounts not offset in the balance sheet  
Description Gross amounts recognized Gross amounts offset in the balance sheet Net amounts presented in the balance sheet Financial instruments Cash collateral received/pledged Net amount
Description
DescriptionGross amounts recognizedGross amounts offset on the balance sheetNet amounts presented on the balance sheetFinancial instrumentsCash collateral received/pledgedNet amount
Assets:            
Federal funds sold and security resell agreements $568
 $
 $568
 $
 $
 $568
Derivatives (included in other assets) 64
 
 64
 (17) 
 47
Federal funds sold and securities purchased under agreements to resell
Federal funds sold and securities purchased under agreements to resell
Federal funds sold and securities purchased under agreements to resell
Derivatives (included in Other assets)
Total assets $632
 $
 $632
 $(17) $
 $615
Liabilities:            
Federal funds and other short-term borrowings $827
 $
 $827
 $
 $
 $827
Derivatives (included in other liabilities) 59
 
 59
 (17) (17) 25
Federal funds and other short-term borrowings
Federal funds and other short-term borrowings
Derivatives (included in Other liabilities)
Total liabilities $886
 $
 $886
 $(17) $(17) $852
Security repurchase and reverse repurchase (“resell”) agreements are offset, when applicable, inon the balance sheet according to master netting agreements. Security repurchase agreements are included within “Federal funds and other short-term borrowings.” on the consolidated balance sheet. Derivative instruments may be offset under their master netting agreements; however, for accounting purposes, we present these items on a gross basis in the Company’son our balance sheet. See Note 7 for further information regarding derivative instruments.

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5.    INVESTMENTS
5.INVESTMENTS
Investment Securities
SecuritiesInvestment securities are classified as HTM, AFS, or trading. HTM securities, which management has the intent and ability to hold until maturity, are carried at amortized cost. The amortized cost amounts represent the original cost of the investments, adjusted for related amortization or accretion of any purchase premiums or discounts, and for any impairment losses, including credit-related impairment. AFS securities are carried at fair value, and unrealizedchanges in fair value (unrealized gains and losseslosses) are reported as net increases or decreases to AOCI. Realized gains and losses on AFS securities are determined by using the cost basisAOCI, net of each individual security.related taxes. Trading securities are carriedmeasured at fair value with gains and losses recognized in current period earnings.
The carrying values of our securities do not include accrued interest receivables of $65 million and $75 million at December 31, 2023, and 2022, respectively. These receivables are included in “Other assets” on the consolidated balance sheet. The purchase premiums for callable debt securities classified as HTM or AFS are amortized into interest income at an effective yield to the earliest call date. The purchase premiums and discounts for bothall other HTM and AFS securities are amortized and accreted at a constantrecorded as interest income over the contractual life of the security using the effective yield to the contractual maturity date and no assumption is made concerning prepayments.method. As principal prepayments occur,are received on securities, a proportionate amount of the related premium or discount is recognized in income so that the effective yield on the remaining portion of the unamortized premium or discount associated with the principal reduction is recognized as interest income in the period the principal is reduced.security continues unchanged. See Note 3 discussesfor more information about the process to estimate fair value for investment securities.
 December 31, 2017
(In millions)
Amortized
cost
 
Gross
unrealized
gains
 
Gross
unrealized
losses
 
Estimated
fair value
Held-to-maturity       
Municipal securities$770
 $5
 $13
 $762
Available-for-sale       
U.S. Treasury securities25
 
 
 25
U.S. Government agencies and corporations:       
Agency securities1,830
 1
 13
 1,818
Agency guaranteed mortgage-backed securities9,798
 9
 141
 9,666
Small Business Administration loan-backed securities2,227
 10
 15
 2,222
Municipal securities1,336
 9
 11
 1,334
Other debt securities25
 
 1
 24
Total available-for-sale debt securities15,241
 29
 181
 15,089
Money market mutual funds and other72
 
 
 72
Total available-for-sale15,313
 29
 181
 15,161
Total investment securities$16,083
 $34
 $194
 $15,923
 December 31, 2016
(In millions)Amortized
cost
 Gross
unrealized
gains
 Gross
unrealized
losses
 Estimated
fair value
Held-to-maturity       
Municipal securities$868
 $5
 $23
 $850
Available-for-sale       
U.S. Treasury securities
 
 
 
U.S. Government agencies and corporations:      
Agency securities1,846
 2
 9
 1,839
Agency guaranteed mortgage-backed securities7,986
 7
 110
 7,883
Small Business Administration loan-backed securities2,298
 8
 18
 2,288
Municipal securities1,182
 1
 29
 1,154
Other debt securities25
 
 1
 24
Total available-for-sale debt securities13,337
 18
 167
 13,188
Money market mutual funds and other184
 
 
 184
Total available-for-sale13,521
 18
 167
 13,372
Total investment securities$14,389
 $23
 $190
 $14,222

TableWhen a security is transferred from AFS to HTM, the difference between its amortized cost basis and fair value at the date of Contents

Maturitiestransfer is amortized as a yield adjustment through interest income, and the fair value at the date of transfer results in either a premium or discount to the amortized cost basis of the HTM securities. The amortization of unrealized gains or losses reported in AOCI will offset the effect of the amortization of the premium or discount in interest income that is created by the transfer.
The following schedules present the amortized cost and estimated fair values of our HTM and AFS securities:
December 31, 2023
(In millions)Amortized
cost
Gross
unrealized
gains 1
Gross
unrealized
losses
Estimated
fair value
Held-to-maturity
U.S. Government agencies and corporations:
Agency securities$93 $— $$87 
Agency guaranteed mortgage-backed securities9,935 1565010,041 
Municipal securities354 — 16 338 
Total held-to-maturity10,382 156 72 10,466 
Available-for-sale
U.S. Treasury securities585 — 93 492 
U.S. Government agencies and corporations:
Agency securities663 — 33 630 
Agency guaranteed mortgage-backed securities8,530 — 1,239 7,291 
Small Business Administration loan-backed securities571 — 25 546 
Municipal securities1,385 — 67 1,318 
Other25 — 23 
Total available-for-sale11,759 — 1,459 10,300 
Total HTM and AFS investment securities$22,141 $156 $1,531 $20,766 
1 Gross unrealized gains for the respective AFS security categories were individually less than $1 million.
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December 31, 2022
(In millions)Amortized
cost
Gross unrealized gainsGross unrealized lossesEstimated
fair value
Held-to-maturity
U.S. Government agencies and corporations:
Agency securities$100 $— $$93 
Agency guaranteed mortgage-backed securities10,621 165 14 10,772 
Municipal securities405 — 31 374 
Total held-to-maturity11,126 165 52 11,239 
Available-for-sale
U.S. Treasury securities557 — 164 393 
U.S. Government agencies and corporations:
Agency securities782 — 46 736 
Agency guaranteed mortgage-backed securities 1
9,652 — 1,285 8,367 
Small Business Administration loan-backed securities740 29 712 
Municipal securities1,732 99 1,634 
Other 1
75 — 73 
Total available-for-sale13,538 1,625 11,915 
Total HTM and AFS investment securities$24,664 $167 $1,677 $23,154 
1 Gross unrealized gains for these security categories were less than $1 million.
During the fourth quarter of 2022, we transferred approximately $10.7 billion fair value ($13.1 billion amortized cost) of investment debtmortgage-backed AFS securities are shown subsequently asto HTM. The transfer of these securities resulted in a discount to the amortized cost basis of the HTM securities equivalent to the $2.4 billion ($1.8 billion after tax) of unrealized losses in AOCI attributable to these securities. The amortization of the unrealized losses will offset the effect of the accretion of the discount created by the transfer. At December 31, 2017 by expected timing of principal payments. Actual principal payments may differ from contractual or expected principal payments because borrowers may have2023, the right to call or prepay obligations with or without call or prepayment penalties.unamortized discount on the HTM securities totaled approximately $2.1 billion ($1.5 billion after tax).
 Held-to-maturity Available-for-sale
(In millions)
Amortized
cost
 
Estimated
fair value
 
Amortized
cost
 
Estimated
fair value
        
Due in one year or less$180
 $90
 $2,499
 $2,054
Due after one year through five years372
 336
 5,727
 5,575
Due after five years through ten years159
 230
 4,331
 4,485
Due after ten years59
 106
 2,684
 2,975
Total$770
 $762
 $15,241
 $15,089
Maturities
The following is a summaryschedule presents the amortized cost and weighted average yields of debt securities by contractual maturity of principal payments at December 31, 2023. This schedule does not reflect the duration of the amountportfolio, which would incorporate amortization, expected prepayments, interest rate resets, and fair value hedges; the effects of which result in measured durations shorter than contractual maturities.
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December 31, 2023
Total debt securitiesDue in one year or lessDue after one year through five yearsDue after five years through ten yearsDue after ten years
(Dollar amounts in millions)Amortized costAverage yieldAmortized costAverage yieldAmortized costAverage yieldAmortized costAverage yieldAmortized costAverage yield
Held-to-maturity
U.S. Government agencies and corporations:
Agency securities$93 3.55 %$— — %$— — %$— — %$93 3.55 %
Agency guaranteed mortgage-backed securities9,935 1.85 — — — — 45 1.94 9,890 1.85 
Municipal securities 1
354 3.15 26 2.70 127 3.00 166 3.36 35 3.08 
Total held-to-maturity securities10,382 1.91 26 2.70 127 3.00 211 3.06 10,018 1.87 
Available-for-sale
U.S. Treasury securities585 3.26 184 5.24 — — — — 401 2.35 
U.S. Government agencies and corporations:
Agency securities663 2.63 116 0.93 154 3.16 207 2.73 186 3.15 
Agency guaranteed mortgage-backed securities8,530 2.01 1.40 174 1.63 1,459 2.11 6,894 2.00 
Small Business Administration loan-backed securities571 5.54 5.33 22 6.33 141 4.40 407 5.89 
Municipal securities 1
1,385 2.18 138 2.54 432 2.63 717 1.84 98 2.22 
Other debt securities25 8.77 — — — — 10 9.50 15 8.28 
Total available-for-sale securities11,759 2.32 442 3.24 782 2.61 2,534 2.24 8,001 2.26 
Total HTM and AFS investment securities$22,141 2.13 %$468 3.21 %$909 2.67 %$2,745 2.30 %$18,019 2.04 %
1 The yields on tax-exempt securities are calculated on a tax-equivalent basis.
The following schedule presents gross unrealized losses for debtAFS securities and the estimated fair value by length of time the securities have been in an unrealized loss position:
December 31, 2023
Less than 12 months12 months or moreTotal
(In millions)Gross
unrealized
losses
Estimated
fair
value
Gross
unrealized
losses
Estimated
fair
value
Gross
unrealized
losses
Estimated
fair
value
Available-for-sale
U.S. Treasury securities$— $— $93 $308 $93 $308 
U.S. Government agencies and corporations:
Agency securities— 33 605 33 610 
Agency guaranteed mortgage-backed securities71 312 1,168 6,902 1,239 7,214 
Small Business Administration loan-backed securities— 25 484 25 488 
Municipal securities229 65 1,061 67 1,290 
Other— — 13 13 
Total available-for-sale investment securities$73 $550 $1,386 $9,373 $1,459 $9,923 
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
December 31, 2017
Less than 12 months 12 months or more Total
December 31, 2022December 31, 2022
Less than 12 monthsLess than 12 months12 months or moreTotal
(In millions)
Gross
unrealized
losses
 
Estimated
fair value
 
Gross
unrealized
losses
 
Estimated
fair value
 
Gross
unrealized
losses
 
Estimated
fair value
(In millions)Gross
unrealized
losses
Estimated
fair
value
Gross
unrealized
losses
Estimated
fair
value
Gross
unrealized
losses
Estimated
fair
value
Held-to-maturity           
Municipal securities$3
 $263
 $10
 $292
 $13
 $555
Available-for-sale           
U.S. Treasury securities
U.S. Treasury securities
U.S. Treasury securities
U.S. Government agencies and corporations:           
Agency securities
Agency securities
Agency securities6
 808
 7
 808
 13
 1,616
Agency guaranteed mortgage-backed securities29
 3,609
 112
 4,721
 141
 8,330
Small Business Administration loan-backed securities3
 408
 12
 649
 15
 1,057
Municipal securities6
 554
 5
 230
 11
 784
Other
 
 1
 14
 1
 14
Total available-for-sale44
 5,379
 137
 6,422
 181
 11,801
Total$47
 $5,642
 $147
 $6,714
 $194
 $12,356
Total available-for-sale investment securities
Total available-for-sale investment securities
Total available-for-sale investment securities
 December 31, 2016
 Less than 12 months 12 months or more Total
(In millions)
Gross
unrealized
losses
 
Estimated
fair
value
 
Gross
unrealized
losses
 
Estimated
fair
value
 
Gross
unrealized
losses
 
Estimated
fair
value
Held-to-maturity           
Municipal securities$15
 $467
 $8
 $61
 $23
 $528
Available-for-sale           
U.S. Government agencies and corporations:           
Agency securities9
 950
 
 127
 9
 1,077
Agency guaranteed mortgage-backed securities102
 6,649
 7
 326
 109
 6,975
Small Business Administration loan-backed securities3
 527
 16
 841
 19
 1,368
Municipal securities28
 992
 
 9
 28
 1,001
Other
 
 2
 14
 2
 14
Total available-for-sale142
 9,118
 25
 1,317
 167
 10,435
Total$157
 $9,585
 $33
 $1,378
 $190
 $10,963
At December 31, 20172023, and 2016, respectively, 6672022, approximately 2,998 and 642 HTM and 2,262 and 2,3983,562 AFS investment securities were in an unrealized loss position.position, respectively.

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Other-Than-Temporary Impairment
Ongoing Policy
WeOn a quarterly basis, we review our investment securities on a quarterly basisportfolio for the presence of OTTI. We assess whether OTTI is presentimpairment on an individual security basis. For AFS securities, when the fair value of a debt security is less than its amortized cost basis at the balance sheet date, (the majoritywe assess for the presence of credit impairment. When determining if the fair value of an investment is less than the amortized cost basis, we have elected to exclude accrued interest from the amortized cost basis of the investment portfolio are debt securities). Under these circumstances, OTTI is considered to have occurred if (1)investment. If we have formed a documentedthe intent to sell an identified securitiessecurity, or initiated such sales; (2)if it is “moremore likely than not”not we will be required to sell the security before recovery of its amortized cost basis; or (3)basis, we write the present value of expected cash flows is not sufficient to recover the entire amortized cost basis.
Noncredit-related OTTI in securities we intenddown to sell is recognized in earnings as is any credit-related OTTI in securities, regardless of our intent. Noncredit-related OTTI on AFS securities not expected to be sold is recognized in OCI. The amount of noncredit-related OTTI in a security is quantified as the difference in a security’s amortized cost after adjustment for credit impairment, and its lower fair value. Presentation of OTTI is made in the statement of income on a gross basis with an offset for the amount of OTTI recognized in OCI.
Our OTTI evaluation process takes into consideration current market conditions; fair value in relationship to cost; extent and nature of change in fair value; severity and duration ofat the impairment; recent events specific to the issuer or industry; our assessment of the creditworthiness of the issuer, including external credit ratings, changes, recent downgrades, and trends; the cash flow priority position of the instrument that we hold in the case of structured securities; volatility of earnings and trends; current analysts’ evaluations; all available information relevant to the collectability of debt securities; and other key measures. In addition, for AFS securities with fair values below amortized cost, we must determine if we intend to sell the securities or if it is more likely than not that we will be required to sell the securities before recovery of their amortized cost basis. For HTM securities, we must determinereporting date through earnings.
If we have the intent and ability to hold the securities, we determine whether there is any impairment attributable to maturity.credit-related factors. We consider anyanalyze certain factors, primarily internal and external credit ratings, to determine if the decline in fair value below the amortized cost basis has resulted from a credit loss or other relevant factors before concluding our evaluationfactors. If a credit impairment is determined to exist, then we measure the amount of credit loss and recognize an allowance for the existencecredit loss. In measuring the credit loss, we generally compare the present value of OTTI in our securities portfolio.
Other-Than-Temporary Impairment Conclusions
The Company did not recognize any OTTI on its investment securities portfolio during 2017. Unrealized losses relatecash flows expected to changes in interest rates subsequentbe collected from the security to purchase and are not attributable to credit. At December 31, 2017, we did not have an intent to sell identified securities with unrealized losses or initiate such sales, and we believe it is not more likely than not we would be required to sell such securities before recovery of theirthe amortized cost basis.
To determinebasis of the credit component of OTTI for all security types, we utilize projected cash flows.security. These cash flows are credit adjusted using, among other things, assumptions for default probability and loss severity. Certain other unobservable inputs, such as prepayment rate assumptions, are also utilized. In addition, certain internal models may be utilized. See Note 3 for further discussion. To determine the credit-related portion of OTTI in accordance with applicable accounting guidance,impairment, we use the security specificsecurity-specific effective interest rate when estimating the present value of cash flows. If the present value of cash flows is less than the amortized cost basis of the security, then this amount is recorded as an allowance for credit loss, limited to the amount that the fair value is less than the amortized cost basis (i.e., the credit impairment cannot result in the security being carried at an amount lower than its fair value). The assumptions used to estimate the expected cash flows depend on the particular asset class, structure, and credit rating of the security. Declines in fair value that are not recorded in the allowance are recorded in other comprehensive income, net of applicable taxes.
AFS Impairment
We did not recognize any impairment on our AFS investment securities portfolio during 2023 or 2022. Unrealized losses primarily relate to changes in interest rates subsequent to purchase and are not attributable to credit; as such, absent any future sales, we would expect to receive the full principal value at maturity. At December 31, 2023, we had not initiated any sales of AFS securities, nor did we have an intent to sell any identified securities with unrealized losses. We do not believe it is more likely than not that we would be required to sell such securities before recovery of their amortized cost basis.
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The following summarizes gains and losses, including OTTI, that were recognized in the statement of income:
 2017 2016 2015
(In millions)
Gross
gains
 
Gross
losses
 
Gross
gains
 
Gross
losses
 
Gross
gains
 
Gross
losses
Investment securities:           
Available-for-sale$
 $
 $
 $
 $9
 $148
Other noninterest-bearing investments22
 8
 21
 14
 25
 13
Total investments22
 8
 21
 14
 34
 161
Net gains (losses)  $14
   $7
   $(127)
Statement of income information:           
Equity securities gains, net  $14



$7
   $12
Fixed income securities gains (losses), net  




   (139)
Net gains (losses)  $14
   $7
   $(127)


ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

HTM Impairment
InterestFor HTM securities, the ACL is assessed consistent with the approach described in Note 6 for loans and leases measured at amortized cost. At December 31, 2023, the ACL on HTM securities was less than $1 million, all HTM securities were risk-graded as “Pass” in terms of credit quality, and none were considered past due.
Securities Gains and Losses Recognized in Income
The following schedule presents securities gains and losses recognized in income:
202320222021
(In millions)Gross
gains
Gross
losses
Gross
gains
Gross
losses
Gross
gains
Gross
losses
Available-for-sale72 72 — — — — 
Trading13 11 — — — — 
Other noninterest-bearing investments$27 $25 $11 $26 $119 $48 
Total112 108 11 26 119 48 
Net gains (losses) 1
$$(15)$71 
1 Net gains (losses) are included in “Securities gains (losses), net on the consolidated statement of income.
The following schedule presents interest income by security type is as follows:type:
(In millions)202320222021
TaxableNontaxableTotalTaxableNontaxableTotalTaxableNontaxableTotal
Investment securities:
Held-to-maturity$236 $$239 $42 $$46 $10 $$15 
Available-for-sale291 31 322 411 40 451 256 29 285 
Trading— — 15 15 — 11 11 
Total securities$527 $36 $563 $453 $59 $512 $266 $45 $311 
106
(In millions)2017 2016 2015
Taxable Nontaxable Total Taxable Nontaxable Total Taxable Nontaxable Total
Investment securities:                
Held-to-maturity$10
 $13
 $23
 $10
 $13
 $23
 $13
 $11
 $24
Available-for-sale277
 24
 301
 166
 12
 178
 95
 3
 98
Trading2
 
 2
 3
 
 3
 2
 
 2
Total$289
 $37
 $326
 $179
 $25
 $204
 $110
 $14
 $124


Investment securities with a carrying value of approximately $2.1 billion and $1.4 billion at December 31, 2017 and 2016, respectively, were pledged to secure public and trust deposits, advances, and for other purposes as required by law. Securities are also pledged as collateral for security repurchase agreements.
Private Equity Investments
Effect of Volcker Rule
The Company’s PEIs are subject to the provisions of the Dodd-Frank Act. The Volcker Rule of the Dodd-Frank Act prohibits banks and bank holding companies from holding PEIs, except for SBIC funds and certain other permitted exclusions, beyond a required deadline. The Federal Reserve Board announced in December 2016 that it would allow banks to apply for an additional five-year extension beyond the July 21, 2017 deadline to comply with the Dodd-Frank Act requirement for these investments. The Company applied for and was granted an extension for its eligible PEIs. All positions in the remaining portfolio of PEIs are subject to the extended deadline or other applicable exclusions.
Of the recorded PEIs of $141 million at December 31, 2017, approximately $3 million remain prohibited by the Volcker Rule. At December 31, 2017, we have $31 million of unfunded commitments for PEIs, of which approximately $4 million relate to prohibited PEIs. We currently do not believe that this divestiture requirement will ultimately have a material impact on our financial statements. See other discussions related to PEI in Note 3.

ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

6.    LOANS, LEASES, AND ALLOWANCE FOR CREDIT LOSSES
6.LOANS AND ALLOWANCE FOR CREDIT LOSSES
Loans, Leases, and Loans Held for Sale
Loans and leases are summarized as follows according to major portfolio segment and specific loan class:
December 31,
(In millions)20232022
Loans held for sale$53 $
Commercial:
Commercial and industrial 1
$16,684 $16,377 
Leasing383 386 
Owner-occupied9,219 9,371 
Municipal4,302 4,361 
Total commercial30,588 30,495 
Commercial real estate:
Construction and land development2,669 2,513 
Term10,702 10,226 
Total commercial real estate13,371 12,739 
Consumer:
Home equity credit line3,356 3,377 
1-4 family residential8,415 7,286 
Construction and other consumer real estate1,442 1,161 
Bankcard and other revolving plans474 471 
Other133 124 
Total consumer13,820 12,419 
Total loans and leases$57,779 $55,653 
 December 31,
(In millions)2017 2016
    
Loans held for sale$44
 $172
Commercial:   
Commercial and industrial$14,003
 $13,452
Leasing364
 423
Owner-occupied7,288
 6,962
Municipal1,271
 778
Total commercial22,926
 21,615
Commercial real estate:   
Construction and land development2,021
 2,019
Term9,103
 9,322
Total commercial real estate11,124
 11,341
Consumer:   
Home equity credit line2,777
 2,645
1-4 family residential6,662
 5,891
Construction and other consumer real estate597
 486
Bankcard and other revolving plans509
 481
Other185
 190
Total consumer10,730
 9,693
Total loans$44,780
 $42,649
1Commercial and industrial loan balances include Paycheck Protection Program (“PPP”) loans of $77 million and $197 million for the respective periods presented.
Loan balancesLoans and leases are measured and presented at their amortized cost basis, which includes net of unearned incomeunamortized purchase premiums, discounts, and deferred loan fees which amounted to $65and costs totaling $37 million at December 31, 2017and $77$49 million at December 31, 2016.
Owner-occupied2023, and commercial real estate loans include unamortized premiums of approximately $16 million at December 31, 20172022, respectively. Amortized cost basis does not include accrued interest receivables of $299 million and $20$247 million at December 31, 2016.2023, and December 31, 2022, respectively. These receivables are included in “Other assets” on the consolidated balance sheet.
Municipal loans generally include loans to municipalitiesstate and local governments (“municipalities”) with the debt service being repaid from general funds or pledged revenues of the municipal entity, or to private commercial entities or 501(c)(3) not-for-profit entities utilizing a pass-through municipal entity to achieve favorable tax treatment.
Land acquisition and development loans included in the construction and land development loan classportfolio were $220 million at December 31, 2017, and $290$219 million at December 31, 2016.2023 and $262 million at December 31, 2022.
Loans with a carrying value of approximately $25.6 billion at December 31, 2017 and $24.0$36.3 billion at December 31, 20162023, and $27.6 billion at December 31, 2022, have been pledged at the Federal Reserve and the FHLBFederal Home Loan Bank (“FHLB”) of Des Moines as collateral for current and potential borrowings.
We soldAt the time of origination, we determine the classification of loans totaling $0.9 billion in 2017, $1.4 billion in 2016, and $1.4 billion in 2015, that were classified as loanseither held for investment or held for sale. The sold loans were derecognized from the balance sheet. Loans classified as loans held for sale are measured individually at fair value or the lower of cost or fair value and primarily consist of (1) CRE loans that are sold into securitization entities, and (2) conforming residential mortgages and the guaranteed portion of SBA loans. The loansthat are mainlygenerally sold to U.S. government agenciesagencies.
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The following schedule presents loans added to, or participated to third parties. At times,sold from, the held for sale category during the periods presented:
Twelve Months Ended
December 31,
(In millions)202320222021
Loans added to held for sale$678 $659 $1,700 
Loans sold from held for sale632 716 1,683 
Occasionally, we have continuing involvement in the transferredsold loans in the form of servicing rights or a guarantee from the respective issuer. Amounts added to loans held for sale during these same periods were $0.8 billion, $1.4 billion, and $1.4 billion, respectively.


guarantees. The principal balance of sold loans for which we retainhave retained servicing was approximately $2.2$0.4 billion at December 31, 2017,2023, and $2.0$3.5 billion at December 31, 2016, and $2.02022. During the third quarter of 2023, we sold the servicing rights related to $3.0 billion at December 31, 2015.of mortgage loans. Income from loans sold, excluding servicing, was $13$16 million in 2017, $182023, $14 million in 2016,2022, and $18$34 million in 2015.2021.
Allowance for Credit Losses
The ACL, which consists of the ALLL and the RULC.
Allowance for Loan and Lease Losses
The ALLLRULC, represents our estimate of probable and estimablecurrent expected credit losses inherent inrelated to the loan and lease portfolio and unfunded lending commitments as of the balance sheet date. The ACL for AFS and HTM debt securities is estimated separately from loans. For HTM securities, the ACL is assessed consistent with the approach for loans carried at amortized cost. See Note 5 for further discussion on our assessment of expected credit losses on AFS securities and disclosures related to AFS and HTM securities.
The ACL reflects our best estimate of credit losses and is calculated using the loan’s amortized cost basis (principal balance, net of unamortized premiums, discounts, and deferred fees and costs). We do not estimate the ACL for accrued interest receivables because we reverse or write-off uncollectible accrued interest receivable balances in a timely manner, generally within one month.
The methodologies we use to estimate the ACL depend upon the type of loan, the age and contractual term of the loan, expected payments (both contractual and estimated prepayments), credit quality indicators, economic forecasts, and the evaluation method (whether individually or collectively evaluated). Loan extensions or renewals are not considered in the ACL unless they are included in the original or modified loan contract and are not unconditionally cancellable.
Losses are charged to the ALLLACL when recognized. Generally, commercial and commercial real estate (“CRE”)CRE loans are charged off or charged down when they are determined to be uncollectible in whole or in part, or when 180 days past due, unless the loan is well securedwell-secured and in process of collection. Consumer loans are either charged off or charged down to net realizable value no later than the month in which they become 180 days past due. Closed-end consumer loans that are not secured by residential real estate are either charged off or charged down to net realizable value no later than the month in which they become 120 days past due.
We establish the amount of the ALLLACL by analyzing the portfolio at least quarterly, and we adjust the provision for loan losses soand unfunded lending commitments to ensure the ALLLACL is at an appropriate level at the balance sheet date. The ACL is determined based on our review of loans that have similar risk characteristics, which are evaluated on a collective basis, as well as loans that do not have similar risk characteristics, which are evaluated on an individual basis.
We determine our ALLL as the best estimate within a range of estimated losses. The methodologies we use to estimate the ALLL depend upon the impairment status and loan portfolio. The methodology for impaired loans is discussed subsequently. For commercial and CRE loans with commitments greater than $1 million, we assign internal risk grades using a comprehensive loan grading system based on financial and statistical models, individual credit analysis, and loan officer experience and judgment. The credit quality indicators discusseddescribed subsequently are based on this grading system. Estimated credit losses for these commercial and CRE loans are derived from a statistical analysis of our historical default and loss given default (“LGD”) experience over the period of January 2008 through the most recent full quarter.
Foron all loan segments, including consumer and small commercial and CRE loans with commitments less than or equal to $1 million we primarily use roll rate models to forecast probable inherent losses. Roll rate models measure the rate at which these loans migratethat are evaluated on a collective basis, are derived from one delinquency category to the next worse delinquency category, and eventually to loss. We estimate roll rates for these loans using recent delinquencystatistical analyses of our historical default and loss experience by segmentingsince January 2008.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
We estimate current expected credit losses for each loan, which includes considerations of historical credit loss experience, current conditions, and reasonable and supportable forecasts about the future. We use the following two types of credit loss estimation models:
Econometric loss models, which rely on statistical analyses of our historical loss experience dependent upon economic factors and other loan-level characteristics. Statistically relevant economic factors vary depending upon the type of loan, portfolios into separate poolsbut include variables such as unemployment, real estate price indices, energy prices, gross domestic product (“GDP”), etc. The models use multiple economic scenarios that reflect optimistic, baseline, and stressed economic conditions. The results derived using these economic scenarios are weighted to produce the credit loss estimate. Management may adjust the weights to reflect management’s assessment of current conditions and reasonable and supportable forecasts.
Loss models that are based on commonour long-term average historical credit loss experience since 2008, which rely on statistical analyses of our historical loss experience dependent upon loan-level characteristics.
Credit loss estimates for the first 12 months of a loan’s remaining life are derived using econometric loss models. Over a subsequent 12-month reversion period, we blend the estimated credit losses from the two models on a straight-line basis. For the remaining life of the loan, the estimated credit losses are derived from the long-term average historical credit loss models.
For loans that do not share risk characteristics and separately calculating historical delinquency and loss experiencewith other loans, we estimate lifetime expected credit losses on an individual basis. These include nonaccrual loans with a balance greater than $1 million. When a loan is individually evaluated for each pool. These roll rates are then appliedexpected credit losses, we estimate a specific reserve for the loan based on either the projected present value of the loan’s future cash flows discounted at the loan’s effective interest rate, the observable market price of the loan, or the fair value of the loan’s underlying collateral.
When we base the specific reserve on the fair value of the loan’s underlying collateral, we generally charge-off the portion of the balance that is greater than fair value. For these loans, subsequent to current delinquency levelsthe charge-off, if the fair value of the loan’s underlying collateral increases according to estimate probable inherent losses.an updated appraisal, we establish a negative reserve up to the lesser of the amount of the charge-off or the updated fair value.
The current status andmethodologies described previously generally rely on historical changes inloss information to help determine our quantitative portion of the ACL. However, we also consider other qualitative and environmental factors related to current conditions and reasonable and supportable forecasts that may not beindicate current expected credit losses may differ from the historical information reflected in our quantitative models. Thus, after applying historical loss experience, as described above, we review the
quantitatively derived level quantitative portion of ALLLACL for each segment using qualitative criteria and use those criteria to determine
our qualitative estimate.segment. We trackmonitor various risk factors that influence our judgment regarding the level of the
ALLL ACL across the portfolio segments. These factors primarily include:
Changes in lending policiesActual and procedures, includingexpected changes in underwriting standards and collection, charge-off, and recovery practices;
Changes in international, national, regional, and local economic and business conditions;conditions and developments;
Changes in the nature and volume of the portfolio and in the terms of loans;
Changes in the experience, ability, and depth of lending management and other relevant staff;
Changes in theThe volume and severity of past due loans, the volume of nonaccrual loans, and the volume and severity of adversely classified or graded loans;
ChangesLending policies and procedures, including changes in underwriting standards and practices for collection, charge-off, and recovery;
The experience, ability, and depth of lending management and other relevant staff;
The nature and volume of the portfolio;
The quality of the loancredit review system;function;
Changes in the value of underlying collateral for collateral-dependent loans;
The existence, growth, and effect of any concentration of credit, and changes in the level of such concentrations;credit;

The effect of other external factors such as competition andregulatory, legal, and regulatory requirements;technological environments; fiscal and monetary actions; competition; and events such as natural disasters and pandemics.
The magnitude of the impact of these factors on our qualitative assessment of the ALLLACL changes from quarter to quarter according to changes made by management in its assessment of these factors, the extent these factors are
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already reflected in historicquantitative loss rates,estimates, and the extent changes in these factors diverge from one to another. We also consider the uncertainty and imprecision inherent in the estimation process when evaluating the ALLL.ACL.
ReserveOff-balance Sheet Credit Exposures
As previously mentioned, we estimate current expected credit losses for Unfunded Lending Commitments
We also estimate a reserve for potential losses associated with off-balance sheet loan commitments, including standby letters of credit. We determine the RULC usingcredit that are not unconditionally cancellable. This estimate uses the same procedures and methodologies that we usedescribed previously for loans and is calculated by taking the ALLL. Thedifference between the estimated current expected credit loss factors used in the RULC are the same as the loss factors used in the ALLL, and the qualitative adjustments used in the RULC are the same as the qualitative adjustments used in the ALLL. We adjust the Company’s unfunded lending commitments that are not unconditionally cancelable to an outstanding amount equivalent using credit conversion factors, and we apply the loss factors to the outstanding equivalents.funded balance, if greater than zero.
Changes in the Allowance for Credit Losses Assumptions
During the first quarter of 2016, due to the consolidation of our separate banking charters, we enhanced our methodology to estimate the ACL on a company-wide basis. As described previously, for large commercial and CRE loans, we began estimating historic loss factors by separately calculating historic default and LGD rates, instead of directly calculating loss rates for groupings of probability of default and LGD grades using a loss migration approach. For small commercial and CRE loans, we began using roll rate models to estimate probable inherent losses. For consumer loans, we began pooling loans by current loan-to-value, where applicable. The impact of these changes was largely neutral to the total ACL at implementation.
Changes in the allowance for credit lossesACL are summarized as follows:
December 31, 2023
(In millions)
 
CommercialCommercial
real estate
ConsumerTotal
Allowance for loan and lease losses
Balance at December 31, 2022$300 $156 $119 $575 
Adjustment for change in accounting standard— (4)(3)
Balance at beginning of year$300 $152 $120 $572 
Provision for loan losses27 92 29 148 
Gross loan and lease charge-offs45 14 62 
Recoveries20 — 26 
Net loan and lease charge-offs (recoveries)25 36 
Balance at end of year$302 $241 $141 $684 
Reserve for unfunded lending commitments
Balance at beginning of year$16 $33 $12 $61 
Provision for unfunded lending commitments(16)(3)(16)
Balance at end of year$19 $17 $$45 
Total allowance for credit losses
Allowance for loan and lease losses$302 $241 $141 $684 
Reserve for unfunded lending commitments19 17 45 
Total allowance for credit losses$321 $258 $150 $729 
December 31, 2017
December 31, 2022
December 31, 2022
December 31, 2022
(In millions)
Commercial 
Commercial
real estate
 Consumer Total(In millions)CommercialCommercial
real estate
ConsumerTotal
Allowance for loan losses       
Allowance for loan and lease losses
Balance at beginning of year$420
 $116
 $31
 $567
Additions:       
Balance at beginning of year
Balance at beginning of year
Provision for loan losses23
 (18) 19
 24
Deductions:       
Gross loan and lease charge-offs(118) (9) (17) (144)
Recoveries46
 14
 11
 71
Net loan and lease (charge-offs) recoveries(72) 5
 (6) (73)
Net loan and lease charge-offs (recoveries)
Balance at end of year$371
 $103
 $44
 $518
Reserve for unfunded lending commitments       
Balance at beginning of year$54
 $11
 $
 $65
Provision credited to earnings(6) (1) 
 (7)
Balance at beginning of year
Balance at beginning of year
Provision for unfunded lending commitments
Balance at end of year$48
 $10
 $
 $58
Total allowance for credit losses       
Allowance for loan losses$371
 $103
 $44
 $518
Allowance for loan and lease losses
Allowance for loan and lease losses
Allowance for loan and lease losses
Reserve for unfunded lending commitments48
 10
 
 58
Total allowance for credit losses$419
 $113
 $44
 $576

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 December 31, 2016
(In millions)Commercial 
Commercial
real estate
 Consumer Total
Allowance for loan losses       
Balance at beginning of year$454
 $114
 $38
 $606
Additions:       
Provision for loan losses93
 
 
 93
Deductions:       
Gross loan and lease charge-offs(170) (12) (16) (198)
Recoveries43
 14
 9
 66
Net loan and lease charge-offs(127) 2
 (7) (132)
Balance at end of year$420
 $116
 $31
 $567
Reserve for unfunded lending commitments       
Balance at beginning of year$58
 $16
 $1
 $75
Provision credited to earnings(4) (5) (1) (10)
Balance at end of year$54
 $11
 $
 $65
Total allowance for credit losses       
Allowance for loan losses$420

$116

$31

$567
Reserve for unfunded lending commitments54

11



65
Total allowance for credit losses$474
 $127
 $31
 $632
The ALLL and outstanding loan balances according to the Company’s impairment method are summarized as follows:
 December 31, 2017
(In millions)Commercial 
Commercial
real estate
 Consumer Total
Allowance for loan losses       
Individually evaluated for impairment$26
 $1
 $4
 $31
Collectively evaluated for impairment345
 102
 40
 487
Purchased loans with evidence of credit deterioration
 
 
 
Total$371
 $103
 $44
 $518
Outstanding loan balances       
Individually evaluated for impairment$314
 $69
 $76
 $459
Collectively evaluated for impairment22,598
 11,048
 10,648
 44,294
Purchased loans with evidence of credit deterioration14
 7
 6
 27
Total$22,926
 $11,124
 $10,730
 $44,780



 December 31, 2016
(In millions)Commercial 
Commercial
real estate
 Consumer Total
Allowance for loan losses       
Individually evaluated for impairment$56
 $3
 $6
 $65
Collectively evaluated for impairment364
 113
 25
 502
Purchased loans with evidence of credit deterioration
 
 
 
Total$420
 $116
 $31
 $567
Outstanding loan balances       
Individually evaluated for impairment$466
 $78
 $75
 $619
Collectively evaluated for impairment21,111
 11,231
 9,611
 41,953
Purchased loans with evidence of credit deterioration38
 32
 7
 77
Total$21,615
 $11,341
 $9,693
 $42,649
Nonaccrual and Past Due Loans
Loans are generally placed on nonaccrual status when payment in full of principal and interest is not expected, or the loan is 90 days or more past due as to principal or interest, unless the loan is both well securedwell-secured and in the process of collection. Factors we consider in determining whether a loan is placed on nonaccrual include delinquency status, collateral-value,collateral value, borrower or guarantor financial statement information, bankruptcy status, and other information which would indicate that the full and timely collection of interest and principal is uncertain.
A nonaccrual loan may be returned to accrual status when (1) all delinquent interest and principal become current in accordance with the terms of the loan agreement; (2) the loan, if secured, is well secured;well-secured; (3) the borrower has paid according to the contractual terms for a minimum of six months; and (4) an analysis of the borrower indicates a reasonable assurance of the borrowers ability and willingness to maintain payments. PaymentsThe amortized cost basis of loans on nonaccrual status is summarized as follows:
December 31, 2023
Amortized cost basisTotal amortized cost basis
(In millions)with no allowancewith allowanceRelated allowance
Commercial:
Commercial and industrial$11 $71 $82 $30 
Leasing— 
Owner-occupied12 20 
Total commercial23 81 104 32 
Commercial real estate:
Construction and land development22 — 22 — 
Term37 39 
Total commercial real estate59 61 
Consumer:
Home equity credit line16 17 
1-4 family residential32 40 
Total consumer loans48 57 10 
Total$91 $131 $222 $43 
December 31, 2022
Amortized cost basisTotal amortized cost basis
(In millions)with no allowancewith allowanceRelated allowance
Commercial:
Commercial and industrial$$55 $63 $27 
Owner-occupied13 11 24 
Total commercial21 66 87 28 
Commercial real estate:
Term— 14 14 
Total commercial real estate— 14 14 
Consumer:
Home equity credit line10 11 
1-4 family residential28 37 
Total consumer loans10 38 48 
Total$31 $118 $149 $35 
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For accruing loans, interest is accrued and interest payments are recognized into interest income according to the contractual loan agreement. For nonaccruing loans, the accrual of interest is discontinued, any uncollected or accrued interest is reversed from interest income in a timely manner (generally within one month), and any payments received on nonaccrualthese loans are not recognized into interest income, but are applied as a reduction to the principal outstanding. When the collectibility of the amortized cost basis for a nonaccrual loan is no longer in doubt, then interest payments may be recognized in interest income on a cash basis. For 2023 and 2022, there was no interest income recognized on a cash basis during the period the loans were on nonaccrual.
The amount of accrued interest receivables reversed from interest income during the periods presented is summarized by loan portfolio segment as follows:
Twelve Months Ended
December 31,
(In millions)202320222021
Commercial$10 $12 $15 
Commercial real estate
Consumer— — 
Total$15 $13 $17 
Past Due Loans
Closed-end loans with payments scheduled monthly are reported as past due when the borrower is in arrears for two or more monthly payments. Similarly, open-end creditcredits, such as charge-card plansbankcard and other revolving credit plans, are reported as past due when the minimum payment has not been made for two or more billing cycles. Other multi-payment obligations (i.e., quarterly, semiannual,semi-annual, etc.), single payment, and demand notes, are reported as past due when either principal or interest is due and unpaid for a period of 30 days or more.
Past-due loans (accruing and nonaccruing) are summarized as follows:
December 31, 2023
(In millions)Current30-89 days
past due
90+ days
past due
Total
past due
Total
loans
Accruing
loans
90+ days
past due
Nonaccrual
loans
that are
current1
Commercial:
Commercial and industrial$16,631 $38 $15 $53 $16,684 $$65 
Leasing381 — 383 — — 
Owner-occupied9,206 11 13 9,219 18 
Municipal4,301 — 4,302 — — 
Total commercial30,519 52 17 69 30,588 83 
Commercial real estate:
Construction and land development2,645 22 24 2,669 — — 
Term10,661 14 27 41 10,702 — 
Total commercial real estate13,306 16 49 65 13,371 — 
Consumer:
Home equity credit line3,334 17 22 3,356 — 
1-4 family residential8,375 17 23 40 8,415 — 13 
Construction and other consumer real estate1,442 — — — 1,442 — 
Bankcard and other revolving plans468 474 — 
Other132 — 133 — — 
Total consumer loans13,751 40 29 69 13,820 22 
Total$57,576 $108 $95 $203 $57,779 $$108 

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December 31, 2022
(In millions)Current30-89 days
past due
90+ days
past due
Total
past due
Total
loans
Accruing
loans
90+ days
past due
Nonaccrual
loans
that are
current1
Commercial:
Commercial and industrial$16,331 $24 $22 $46 $16,377 $$45 
Leasing386 — — — 386 — — 
Owner-occupied9,344 20 27 9,371 15 
Municipal4,361 — — — 4,361 — — 
Total commercial30,422 44 29 73 30,495 60 
Commercial real estate:
Construction and land development2,511 — 2,513 — — 
Term10,179 37 10 47 10,226 — 
Total commercial real estate12,690 39 10 49 12,739 — 
Consumer:
Home equity credit line3,369 3,377 — 
1-4 family residential7,258 19 28 7,286 — 16 
Construction and other consumer real estate1,161 — — — 1,161 — — 
Bankcard and other revolving plans467 471 — 
Other124 — — — 124 — — 
Total consumer loans12,379 17 23 40 12,419 22 
Total$55,491 $100 $62 $162 $55,653 $$86 
Nonaccrual loans are summarized as follows:
 December 31,
(In millions)2017 2016
    
Loans held for sale$12
 $40
Commercial:   
Commercial and industrial$195
 $354
Leasing8
 14
Owner-occupied90
 74
Municipal1
 1
Total commercial294
 443
Commercial real estate:   
Construction and land development4
 7
Term36
 29
Total commercial real estate40
 36
Consumer:   
Home equity credit line13
 11
1-4 family residential55
 36
Construction and other consumer real estate
 2
Bankcard and other revolving plans
 1
Other
 
Total consumer loans68
 50
Total$402
 $529
Past due loans (accruing and nonaccruing) are summarized as follows:
 December 31, 2017
(In millions)Current 
30-89 days
past due
 
90+ days
past due
 
Total
past due
 
Total
loans
 
Accruing
loans
90+ days
past due
 
Nonaccrual
loans
that are
current1
              
Loans held for sale$44
 $
 $
 $
 $44
 $
 $12
Commercial:             
Commercial and industrial$13,887
 $60
 $56
 $116
 $14,003
 $13
 $146
Leasing363
 1
 
 1
 364
 
 8
Owner-occupied7,219
 29
 40
 69
 7,288
 4
 49
Municipal1,271
 
 
 
 1,271
 
 1
Total commercial22,740
 90
 96
 186
 22,926
 17
 204
Commercial real estate:             
Construction and land development2,014
 3
 4
 7
 2,021
 
 
Term9,079
 13
 11
 24
 9,103
 2
 25
Total commercial real estate11,093
 16
 15
 31
 11,124
 2
 25
Consumer:             
Home equity credit line2,763
 9
 5
 14
 2,777
 
 5
1-4 family residential6,621
 16
 25
 41
 6,662
 1
 27
Construction and other consumer real estate590
 6
 1
 7
 597
 1
 
Bankcard and other revolving plans506
 2
 1
 3
 509
 1
 
Other184
 1
 
 1
 185
 
 
Total consumer loans10,664
 34
 32
 66
 10,730
 3
 32
Total$44,497
 $140
 $143
 $283
 $44,780
 $22
 $261


 December 31, 2016
(In millions)Current 
30-89 days
past due
 
90+ days
past due
 
Total
past due
 
Total
loans
 
Accruing
loans
90+ days
past due
 
Nonaccrual
loans
that are
current1
              
Loans held for sale$172
 $
 $
 $
 $172
 $
 $40
Commercial:             
Commercial and industrial$13,306
 $72
 $74
 $146
 $13,452
 $10
 $287
Leasing423
 
 
 
 423
 
 14
Owner-occupied6,894
 40
 28
 68
 6,962
 8
 43
Municipal778
 
 
 
 778
 
 1
Total commercial21,401
 112
 102
 214
 21,615
 18
 345
Commercial real estate:             
Construction and land development2,010
 7
 2
 9
 2,019
 1
 1
Term9,291
 9
 22
 31
 9,322
 12
 18
Total commercial real estate11,301
 16
 24
 40
 11,341
 13
 19
Consumer:             
Home equity credit line2,635
 4
 6
 10
 2,645
 1
 5
1-4 family residential5,857
 12
 22
 34
 5,891
 
 11
Construction and other consumer real estate479
 3
 4
 7
 486
 3
 
Bankcard and other revolving plans478
 2
 1
 3
 481
 1
 1
Other189
 1
 
 1
 190
 
 
Total consumer loans9,638
 22
 33
 55
 9,693
 5
 17
Total$42,340
 $150
 $159
 $309
 $42,649
 $36
 $381
1
Represents nonaccrual loans that are not past due more than 30 days; however, full payment of principal and interest is still not expected.
Credit Quality Indicators
In addition to the nonaccrual and past due and nonaccrual criteria, we also analyze loans using loan risk gradingrisk-grading systems, which vary based on the size and type of credit risk exposure. The internal risk gradesrisk-grades assigned to loans follow our definitions of Pass, Special Mention, Substandard, and Doubtful, which are consistent with published definitions of regulatory risk classifications.
Definitions of Pass, Special Mention, Substandard, and Doubtful are summarized as follows:
Pass A Pass asset is higher qualityhigher-quality and does not fit any of the other categories described below. The likelihood of loss is considered low.
Special Mention A Special Mention asset has potential weaknesses that deserve management’s close attention. If left uncorrected, these potential weaknesses may result in deterioration of the repayment prospects for the asset or in the Bank’sour credit position at some future date.
Substandard A Substandard asset is inadequately protected by the current sound worth and paying capacity of the obligor or of the collateral pledged, if any. Assets so classified have well-defined weaknesses and are characterized by the distinct possibility that the Bankwe may sustain some loss if deficiencies are not corrected.
Doubtful A Doubtful asset has all the weaknesses inherent in a Substandard asset with the added characteristics that the weaknesses make collection or liquidation in full highly questionable and improbable.
We generally assign internal risk grades toThere were no loans classified as Doubtful at both December 31, 2023, and December 31, 2022.
For commercial and CRE loans with commitments greater than $1 million, based on financial and statistical models, individual credit analysis, and loan officer experience and judgment. For these larger loans, we assign one of multiple grades within the Pass classification or one of the following four grades: Special Mention, Substandard, Doubtful, and Loss. Loss indicates that the outstanding balance has been


charged off.risk classifications described previously. We confirmassess our internal risk gradesrisk-grades quarterly, or as soon as we identify information that affects the credit risk of the loan.
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For consumer loans and certain smallfor commercial and CRE loans with commitments less than or equal to $1 million, we generally assign internal risk gradesrisk-grades similar to those described previously based on automated rules that depend on refreshed credit scores, payment performance, and other risk indicators. These are generally assigned either a Pass, Special Mention, or Substandard grade, and are reviewed as we identify information that might warrant a grade change.
Outstanding loan balances (accruingThe following schedule presents the amortized cost basis of loans and nonaccruing)leases categorized by theseyear of origination and by credit quality classifications are summarized as follows:monitored by management, as well as year-to-date gross charge-offs:
114

 December 31, 2017
(In millions)Pass 
Special
mention
 
Sub-
standard
 Doubtful 
Total
loans
 
Total
allowance
            
Commercial:           
Commercial and industrial$13,001
 $395
 $606
 $1
 $14,003
  
Leasing342
 6
 16
 
 364
  
Owner-occupied6,920
 93
 275
 
 7,288
  
Municipal1,257
 13
 1
 
 1,271
  
Total commercial21,520
 507
 898
 1
 22,926
 $371
Commercial real estate:           
Construction and land development2,002
 15
 4
 
 2,021
  
Term8,816
 138
 149
 
 9,103
  
Total commercial real estate10,818
 153
 153
 
 11,124
 103
Consumer:           
Home equity credit line2,759
 
 18
 
 2,777
  
1-4 family residential6,602
 
 60
 
 6,662
  
Construction and other consumer real estate596
 
 1
 
 597
  
Bankcard and other revolving plans507
 
 2
 
 509
  
Other185
 
 
 
 185
  
Total consumer loans10,649
 
 81
 
 10,730
 44
Total$42,987
 $660
 $1,132
 $1
 $44,780
 $518


ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

December 31, 2023
Term LoansRevolving loans amortized cost basisRevolving loans converted to term loans amortized cost basis
Amortized cost basis by year of origination
(In millions)20232022202120202019PriorTotal
Commercial:
Commercial and industrial
Pass$2,654 $2,420 $1,204 $639 $494 $598 $7,973 $151 $16,133 
Special Mention98 34 20 37 103 — 302 
Accruing Substandard11 18 19 99 167 
Nonaccrual36 11 21 82 
Total commercial and industrial2,678 2,572 1,246 645 544 644 8,196 159 16,684 
Gross charge-offs10 — — 24 45 
Leasing
Pass104 125 47 29 45 18 — — 368 
Special Mention— — — — 13 
Accruing Substandard— — — — — — — — — 
Nonaccrual— — — — — — — 
Total leasing106 136 48 30 45 18 — — 383 
Gross charge-offs— — — — — — — — — 
Owner-occupied
Pass1,080 1,945 2,020 1,002 721 1,907 212 52 8,939 
Special Mention17 17 15 — — 61 
Accruing Substandard10 31 29 21 16 90 — 199 
Nonaccrual— — — 20 
Total owner-occupied1,092 1,982 2,067 1,035 757 2,020 214 52 9,219 
Gross charge-offs— — — — — — — — — 
Municipal
Pass601 1,080 1,069 623 382 512 — 4,270 
Special Mention— — — — — — 13 
Accruing Substandard— — — 19 
Nonaccrual— — — — — — — — — 
Total municipal616 1,080 1,075 626 383 519 — 4,302 
Gross charge-offs— — — — — — — — — 
Total commercial4,492 5,770 4,436 2,336 1,729 3,201 8,410 214 30,588 
Total commercial gross charge-offs10 — — 24 45 
Commercial real estate:
Construction and land development
Pass553 938 355 56 518 127 2,558 
Special Mention— — 29 30 — — — — 59 
Accruing Substandard23 — — — — — 30 
Nonaccrual— — — — 21 — — 22 
Total construction and land development576 940 384 91 28 519 127 2,669 
Gross charge-offs— — — — — — — 
Term
Pass1,861 2,385 1,833 1,449 804 1,438 238 110 10,118 
Special Mention55 108 65 78 44 — — 356 
Accruing Substandard79 18 12 16 24 — 35 189 
Nonaccrual— 26 — — 10 — — 39 
Total term1,995 2,537 1,910 1,543 856 1,478 238 145 10,702 
Gross charge-offs— — — — — — — 
Total commercial real estate2,571 3,477 2,294 1,634 884 1,482 757 272 13,371 
Total commercial real estate gross charge-offs— — — — — — 
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 December 31, 2016
(In millions)Pass 
Special
mention
 
Sub-
standard
 Doubtful 
Total
loans
 
Total
allowance
            
Commercial:           
Commercial and industrial$12,185
 $266
 $998
 $3
 $13,452
  
Leasing387
 5
 30
 1
 423
  
Owner-occupied6,560
 96
 306
 
 6,962
  
Municipal765
 7
 6
 
 778
  
Total commercial19,897
 374
 1,340
 4
 21,615
 $420
Commercial real estate:           
Construction and land development1,942
 52
 25
 
 2,019
  
Term9,096
 82
 144
 
 9,322
  
Total commercial real estate11,038
 134
 169
 
 11,341
 116
Consumer:           
Home equity credit line2,629
 
 16
 
 2,645
  
1-4 family residential5,851
 
 40
 
 5,891
  
Construction and other consumer real estate482
 
 4
 
 486
  
Bankcard and other revolving plans478
 
 3
 
 481
  
Other189
 
 1
 
 190
  
Total consumer loans9,629
 
 64
 
 9,693
 31
Total$40,564
 $508
 $1,573
 $4
 $42,649
 $567
December 31, 2023
Term LoansRevolving loans amortized cost basisRevolving loans converted to term loans amortized cost basis
Amortized cost basis by year of origination
(In millions)20232022202120202019PriorTotal
Consumer:
Home equity credit line
Pass— — — — — — 3,237 97 3,334 
Special Mention— — — — — — — — — 
Accruing Substandard— — — — — — 
Nonaccrual— — — — — — 15 17 
Total home equity credit line— — — — — — 3,256 100 3,356 
Gross charge-offs— — — — — — — 
1-4 family residential
Pass814 2,264 1,823 988 594 1,891 — — 8,374 
Special Mention— — — — — — — — — 
Accruing Substandard— — — — — — — 
Nonaccrual— 27 — — 40 
Total 1-4 family residential814 2,267 1,826 991 598 1,919 — — 8,415 
Gross charge-offs— — — — — — — 
Construction and other consumer real estate
Pass212 1,002 200 15 — — 1,442 
Special Mention— — — — — — — — — 
Accruing Substandard— — — — — — — — — 
Nonaccrual— — — — — — — — — 
Total construction and other consumer real estate212 1,002 200 15 — — 1,442 
Gross charge-offs— — — — — — — — — 
Bankcard and other revolving plans
Pass— — — — — — 471 472 
Special Mention— — — — — — — — — 
Accruing Substandard— — — — — — — 
Nonaccrual— — — — — — — — — 
Total bankcard and other revolving plans— — — — — — 473 474 
Gross charge-offs— — — — — — — 
Other consumer
Pass66 37 18 — — 133 
Special Mention— — — — — — — — — 
Accruing Substandard— — — — — — — — — 
Nonaccrual— — — — — — — — — 
Total other consumer66 37 18 — — 133 
Gross charge-offs— — — — — — — — — 
Total consumer1,092 3,306 2,044 1,012 609 1,927 3,729 101 13,820 
Total consumer gross charge-offs— — — — — 12 — 14 
Total loans$8,155 $12,553 $8,774 $4,982 $3,222 $6,610 $12,896 $587 $57,779 
Total gross charge-offs$$12 $$— $$$36 $$62 
Impaired Loans
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December 31, 2022
Term LoansRevolving loans amortized cost basisRevolving loans converted to term loans amortized cost basis
Amortized cost basis by year of origination
(In millions)20222021202020192018PriorTotal
Commercial:
Commercial and industrial
Pass$3,363 $1,874 $979 $876 $293 $264 $8,054 $182 $15,885 
Special Mention10 52 50 — 118 
Accruing Substandard26 17 78 30 67 84 311 
Nonaccrual— 11 32 63 
Total commercial and industrial3,390 1,891 1,011 1,017 325 335 8,220 188 16,377 
Leasing
Pass160 71 47 66 18 19 — — 381 
Special Mention— — — — — — — — — 
Accruing Substandard— — — — — — — 
Nonaccrual— — — — — — — — — 
Total leasing160 71 47 66 18 24 — — 386 
Owner-occupied
Pass2,157 2,285 1,143 874 654 1,679 187 74 9,053 
Special Mention15 16 — 49 
Accruing Substandard16 33 48 20 55 64 — 245 
Nonaccrual10 — 24 
Total owner-occupied2,175 2,334 1,198 906 717 1,769 198 74 9,371 
Municipal
Pass1,230 1,220 816 441 168 437 — 4,320 
Special Mention32 — — — — — — 38 
Accruing Substandard— — — — — — — 
Nonaccrual— — — — — — — — — 
Total municipal1,262 1,226 816 441 168 440 — 4,361 
Total commercial6,987 5,522 3,072 2,430 1,228 2,568 8,426 262 30,495 
Commercial real estate:
Construction and land development
Pass548 671 455 81 617 96 2,472 
Special Mention— — — — — — 
Accruing Substandard17 — — 22 — — — — 39 
Nonaccrual— — — — — — — — — 
Total construction and land development566 672 455 103 617 96 2,513 
Term
Pass2,861 2,107 1,686 1,012 666 1,229 276 112 9,949 
Special Mention39 21 11 — — — 76 
Accruing Substandard42 34 21 53 35 — — 187 
Nonaccrual— — — — — 14 
Total term2,942 2,130 1,731 1,037 724 1,274 276 112 10,226 
Total commercial real estate3,508 2,802 2,186 1,140 726 1,276 893 208 12,739 
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December 31, 2022
Term LoansRevolving loans amortized cost basisRevolving loans converted to term loans amortized cost basis
Amortized cost basis by year of origination
(In millions)20222021202020192018PriorTotal
Consumer:
Home equity credit line
Pass— — — — — — 3,265 98 3,363 
Special Mention— — — — — — — — — 
Accruing Substandard— — — — — — — 
Nonaccrual— — — — — — 11 
Total home equity credit line— — — — — — 3,276 101 3,377 
1-4 family residential
Pass1,913 1,503 1,024 638 381 1,788 — — 7,247 
Special Mention— — — — — — — — — 
Accruing Substandard— — — — — — — 
Nonaccrual— 26 — — 37 
Total 1-4 family residential1,913 1,505 1,026 642 384 1,816 — — 7,286 
Construction and other consumer real estate
Pass583 485 64 19 — — 1,161 
Special Mention— — — — — — — — — 
Accruing Substandard— — — — — — — — — 
Nonaccrual— — — — — — — — — 
Total construction and other consumer real estate583 485 64 19 — — 1,161 
Bankcard and other revolving plans
Pass— — — — — — 468 470 
Special Mention— — — — — — — — — 
Accruing Substandard— — — — — — — 
Nonaccrual— — — — — — — — — 
Total bankcard and other revolving plans— — — — — — 469 471 
Other consumer
Pass68 30 12 — — 124 
Special Mention— — — — — — — — — 
Accruing Substandard— — — — — — — — — 
Nonaccrual— — — — — — — — — 
Total other consumer68 30 12 — — 124 
Total consumer2,564 2,020 1,102 669 393 1,823 3,745 103 12,419 
Total loans$13,059 $10,344 $6,360 $4,239 $2,347 $5,667 $13,064 $573 $55,653 
Loan Modifications
On January 1, 2023, we adopted ASU 2022-02, Financial Instruments—Credit Losses (Topic 326): Troubled Debt Restructurings and events, it is probable thatVintage Disclosures, which eliminated the recognition and measurement of TDRs and their related disclosures. As a result, we will be unable to collect all amounts due in accordance with the contractual terms of the loan agreement, including scheduled interest payments. For our non-purchased credit-impaired loans, if a nonaccrual loan has a balance greater than $1 million, or if a loan is a TDR, including TDRs that subsequently default, or if the loan is no longer reported as a TDR, we individually evaluate the loanseparately measure an allowance for impairment and estimate a specific reservecredit losses for the loan for all portfolio segments under applicable accounting guidance. Smaller nonaccrual loans are pooled for ALLLTDRs, relying instead on our credit loss estimation purposes. PCI loans are included in impaired loans and are accounted for under separate accounting guidance. See subsequent discussion under Purchased Loans.
When a loan is impaired, we estimate a specific reserve for the loan based on the projected present valuemodels. The adoption of the loan’s future cash flows discounted at the loan’s effective interest rate, the observable market price of the loan, or the fair value of the loan’s underlying collateral. The process of estimating future cash flows also incorporates the same determining factors discussed previously under nonaccrual loans. When we base the impairment amount on the fair value of the loan’s underlying collateral, we generally charge-off the portion of the balance that is impaired, such that these loans dothis guidance did not have a specific reserve in the ALLL. Payments receivedmaterial impact on impaired loans that are accruing are recognized in interest income, according to the contractual loan agreement. Payments received on impaired loans that are on nonaccrual are not recognized in interest income, but are applied as a reduction to the principal outstanding. The amount of interest income recognized on a cash basis during the time the loans were impaired within the years ended December 31, 2017 and 2016 was not significant.our financial statements.

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Information on impaired loans individually evaluated is summarized as follows, including the average recorded investment and interest income recognizedASU 2022-02 requires enhanced disclosures for the years ended December 31, 2017 and 2016:
 December 31, 2017 Year Ended
December 31, 2017
(In millions)

Unpaid
principal
balance
 Recorded investment 
Total
recorded
investment
 
Related
allowance
 
Average
recorded
investment
 Interest
income
recognized
with no
allowance
 
with
allowance
  
Commercial:             
Commercial and industrial$293
 $80
 $142
 $222
 $24
 $289
 $6
Owner-occupied120
 79
 23
 102
 2
 97
 6
Municipal1
 1
 
 1
 
 1
 
Total commercial414
 160
 165
 325
 26
 387
 12
Commercial real estate:             
Construction and land development8
 4
 2
 6
 
 8
 
Term56
 36
 12
 48
 
 49
 12
Total commercial real estate64
 40
 14
 54
 
 57
 12
Consumer:             
Home equity credit line25
 13
 9
 22
 
 21
 1
1-4 family residential67
 28
 29
 57
 4
 52
 1
Construction and other consumer real estate2
 1
 1
 2
 
 2
 
Other1
 1
 
 1
 
 1
 1
Total consumer loans95
 43
 39
 82
 4
 76
 3
Total$573
 $243
 $218
 $461
 $30
 $520
 $27
 December 31, 2016 Year Ended
December 31, 2016
(In millions)

Unpaid
principal
balance
 Recorded investment 
Total
recorded
investment
 
Related
allowance
 
Average
recorded
investment
 Interest
income
recognized
with no
allowance
 
with
allowance
 
Commercial:             
Commercial and industrial$470
 $82
 $311
 $393
 $52
 $333
 $5
Owner-occupied115
 71
 30
 101
 3
 99
 9
Municipal1
 1
 
 1
 
 1
 
Total commercial586
 154
 341
 495
 55
 433
 14
Commercial real estate:             
Construction and land development22
 7
 6
 13
 
 11
 2
Term92
 53
 17
 70
 2
 76
 13
Total commercial real estate114
 60
 23
 83
 2
 87
 15
Consumer:             
Home equity credit line24
 16
 7
 23
 
 22
 1
1-4 family residential59
 27
 28
 55
 6
 57
 2
Construction and other consumer real estate3
 1
 2
 3
 
 2
 
Other2
 1
 
 1
 
 2
 
Total consumer loans88
 45
 37
 82
 6
 83
 3
Total$788
 $259
 $401
 $660
 $63
 $603
 $32
Modified and Restructured Loans
loan modifications to borrowers experiencing financial difficulty. Loans may be modified in the normal course of business for competitive reasons or to strengthen the Company’sour collateral position. Loan modifications and restructurings may also occur when the borrower experiences financial difficulty and needs temporary or permanent relief from the original contractual terms of the loan. LoansFor loans that have been


modified to accommodatewith a borrower who is experiencing financial difficulties,difficulty, we use the same credit loss estimation methods that we use for the rest of the loan portfolio. These methods incorporate the post-modification loan terms, as well as defaults and for which the Company has granted a concession that it would not otherwise consider,charge-offs associated with historical modified loans. All nonaccruing loans more than $1 million are considered troubled debt restructurings (“TDRs”).evaluated individually, regardless of modification.
We consider many factors in determining whether to agree to a loan modification involving concessions, and we seek a solution that will both minimize potential loss to the Companyus and attempt to help the borrower. We evaluate borrowers’ current and forecasted future cash flows, their ability and willingness to make current contractual or proposed modified payments, the value of the underlying collateral (if applicable), the possibility of obtaining additional security or guarantees, and the potential costs related to a repossession or foreclosure and the subsequent sale of the collateral.
A modified loan on nonaccrual will generally remain on nonaccrual until the borrower has proven the ability to perform under the modified structure for a minimum of six months, and there is evidence that such payments can and are likely to continue as agreed. Performance prior to the modification, or significant events that coincide with the modification, are included in assessing whether the borrower can meet the new terms and may result in the loan being returned to accrual at the time of modification or after a shorter performance period. If the borrower’s ability to meet the revised payment schedule is uncertain, the loan remains on nonaccrual. There were less than $1 million of loans to borrowers experiencing financial difficulty that had a payment default during the twelve months ended December 31, 2023, which were still in default at period end, and were within 12 months or less of being modified.
The amortized cost of loans to borrowers experiencing financial difficulty that were modified during the period, by loan class and modification type, is summarized in the following schedule:
Twelve Months Ended December 31, 2023
Amortized cost associated with
the following modification types:
(Dollar amounts in millions)Interest
rate reduction
Maturity
or term
extension
Principal
forgiveness
Payment
deferral
Multiple modification types 1
Total 2
Percentage of total loans 3
Commercial:
Commercial and industrial$— $46 $— $$— $47 0.3 %
Owner-occupied— — 14 0.2 
Municipal— — — — 0.2 
Total commercial63 — — 69 0.2 
Commercial real estate:
Construction and land development— 27 — — — 27 1.0 
Term— 165 — — — 165 1.5 
Total commercial real estate— 192 — — — 192 1.4 
Consumer:
1-4 family residential— — — — 
Bankcard and other revolving plans— — — — 0.2 
Total consumer loans— — — 
Total$$256 $$$$264 0.5 %
1 Includes modifications that resulted from a combination of interest rate reduction, maturity or term extension, principal forgiveness, and payment deferral modifications.
2 Unfunded lending commitments related to loans modified to borrowers experiencing financial difficulty totaled $22 million at December 31, 2023.
3 Amounts less than 0.05% are rounded to zero.
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The financial impact of loan modifications to borrowers experiencing financial difficulty during the twelve months ended December 31, 2023, is summarized in the following schedule:
Twelve Months Ended
December 31, 2023
Weighted-average interest rate reduction (in percentage points)Weighted-average term extension
(in months)
Commercial:
Commercial and industrial— %13
Owner-occupied 1
4.4 18
Municipal— 12
Total commercial4.4 14
Commercial real estate:
Construction and land development— 8
Term— 18
Total commercial real estate— 16
Consumer: 1
1-4 family residential— 103
Bankcard and other revolving plans— 50
Total consumer loans— 82
Total weighted average financial impact4.4 %16
1 Primarily relates to a small number of loans within each respective loan class.
Loan modifications to borrowers experiencing financial difficulty during the twelve months ended December 31, 2023, resulted in less than $1 million of principal forgiveness for the total loan portfolio for the period.
The following schedule presents the aging of loans to borrowers experiencing financial difficulty that were modified on or after January 1, 2023 (the date we adopted ASU 2022-02) through December 31, 2023, presented by portfolio segment and loan class.
December 31, 2023
(In millions)Current30-89 days
past due
90+ days
past due
Total
past due
Total
amortized cost of loans
Commercial:
Commercial and industrial$44 $$— $$47 
Owner-occupied13 — 14 
Municipal— — — 
Total commercial65 — 69 
Commercial real estate:
Construction and land development27 — — — 27 
Term156 — 165 
Total commercial real estate183 — 192 
Consumer:
1-4 family residential— — — 
Bankcard and other revolving plans— — — 
Total consumer loans— — — 
Total$251 $13 $— $13 $264 
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Troubled Debt Restructuring Disclosures Prior to Our Adoption of ASU 2022-02
Loans may be modified in the normal course of business for competitive reasons or to strengthen our collateral position. Loan modifications and restructurings may also occur when the borrower experiences financial difficulty and needs temporary or permanent relief from the original contractual terms of the loan. Loans that have been modified to accommodate a borrower who is experiencing financial difficulties, and for which we have granted a concession that we would not otherwise consider, are reported as TDRs.
Consistent with modifications to troubled borrowers discussed in the previous section, we consider many factors in determining whether to agree to a loan modification involving concessions, and we seek a solution that will both minimize potential loss to us and attempt to help the borrower.
TDRs are classified as either accrual or nonaccrual loans. A loan on nonaccrual and restructured as a TDR will remain on nonaccrual status until the borrower has proven the ability to perform under the modified structure for a minimum of six months, and there is evidence that such payments can and are likely to continue as agreed. Performance prior to the restructuring, or significant events that coincide with the restructuring, are included in assessing whether the borrower can meet the new terms and may result in the loan being returned to accrual at the time of restructuring or after a shorter performance period. If the borrower’s ability to meet the revised payment schedule is uncertain, the loan remains classified as a nonaccrual loan. A TDR loan that specifies an interest rate that, at the time of the restructuring, is greater than or equal to the rate the Bank iswe are willing to accept for a new loan with comparable risk may not be reported as a TDR or an impaired loan in the calendar years subsequent to the restructuring if it is in compliance with its modified terms.
Loan modifications provided to borrowers experiencing financial difficulties exclusively related to the COVID-19 pandemic, in which we provided certain short-term modifications or payment deferrals, were not classified as TDRs. The TDRs disclosed subsequently do not include these loan modifications. Other loan modifications above and beyond these short-term modifications or payment deferrals were assessed for TDR classification.

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Selected informationInformation on TDRs, at year-end that includes the recorded investmentincluding their amortized cost on an accruing and nonaccruing basis by loan class, and by modification type, is summarized in the following schedules:
December 31, 2022
Amortized cost basis resulting from the following modification types: 
(In millions)Interest
rate below
market
Maturity
or term
extension
Principal
forgiveness
Payment
deferral
Other1
Multiple
modification
types2
Total
Accruing
Commercial:
Commercial and industrial$$12 $— $— $$28 $50 
Owner-occupied— — 13 12 28 
Total commercial13 — 22 40 78 
Commercial real estate:
Construction and land development— — — — — 
Term27 — 27 28 84 
Total commercial real estate27 — 27 28 92 
Consumer:
Home equity credit line— — — 
1-4 family residential— 15 21 
Total consumer loans— 16 27 
Total accruing$$42 $$29 $51 $65 $197 
Nonaccruing
Commercial:
Commercial and industrial$— $— $— $$$$15 
Owner-occupied— — — — 
Total commercial— — 23 
Commercial real estate:
Term— 10 — — — — 10 
Total commercial real estate— 10 — — — — 10 
Consumer:
Home equity credit line— — — — — 
1-4 family residential— — — 
Total consumer loans— — 
Total nonaccruing11 10 38 
Total$$53 $$32 $61 $74 $235 
 December 31, 2017
 Recorded investment resulting from the following modification types:  
(In millions)

Interest
rate below
market
 
Maturity
or term
extension
 
Principal
forgiveness
 
Payment
deferral
 
Other1
 
Multiple
modification
types2
 Total
Accruing             
Commercial:             
Commercial and industrial$
 $2
 $
 $
 $12
 $33
 $47
Owner-occupied1
 1
 
 
 7
 14
 23
Total commercial1
 3
 
 
 19
 47
 70
Commercial real estate:             
Construction and land development
 
 
 
 
 2
 2
Term6
 
 
 1
 
 7
 14
Total commercial real estate6
 
 
 1
 
 9
 16
Consumer:             
Home equity credit line
 2
 9
 
 1
 3
 15
1-4 family residential1
 
 6
 1
 2
 26
 36
Construction and other consumer real estate
 1
 
 
 
 1
 2
Total consumer loans1
 3
 15
 1
 3
 30
 53
Total accruing8
 6
 15
 2
 22
 86
 139
Nonaccruing             
Commercial:             
Commercial and industrial
 3
 5
 2
 28
 24
 62
Owner-occupied1
 2
 
 1
 1
 5
 10
Municipal
 1
 
 
 
 
 1
Total commercial1
 6
 5
 3
 29
 29
 73
Commercial real estate:             
Construction and land development
 
 
 
 
 
 
Term2
 
 
 
 
 3
 5
Total commercial real estate2
 
 
 
 
 3
 5
Consumer:             
Home equity credit line
 
 1
 
 
 
 1
1-4 family residential
 
 2
 
 1
 5
 8
Construction and other consumer real estate
 
 
 
 
 
 
Total consumer loans
 
 3
 
 1
 5
 9
Total nonaccruing3
 6
 8
 3
 30
 37
 87
Total$11
 $12
 $23
 $5
 $52
 $123
 $226
1
Includes TDRs that resulted from other modification types including, but not limited to, a legal judgment awarded on different terms, a bankruptcy plan confirmed on different terms, a settlement that includes the delivery of collateral in exchange for debt reduction, etc.
2
Includes TDRs that resulted from a combination of any of the previous modification types.

1 Includes TDRs that resulted from other modification types including, but not limited to, a legal judgment awarded on different terms, a bankruptcy plan confirmed on different terms, a settlement that includes the delivery of collateral in exchange for debt reduction, etc.
any of the previous modification types.

 December 31, 2016
 Recorded investment resulting from the following modification types:  
(In millions)

Interest
rate below
market
 
Maturity
or term
extension
 
Principal
forgiveness
 
Payment
deferral
 
Other1
 
Multiple
modification
types2
 Total
Accruing             
Commercial:             
Commercial and industrial$
 $19
 $
 $
 $
 $28
 $47
Owner-occupied3
 
 1
 
 8
 10
 22
Total commercial3
 19
 1
 
 8
 38
 69
Commercial real estate:             
Construction and land development
 4
 
 
 
 4
 8
Term4
 
 
 1
 2
 10
 17
Total commercial real estate4
 4
 
 1
 2
 14
 25
Consumer:             
Home equity credit line
 1
 10
 
 
 3
 14
1-4 family residential3
 1
 6
 
 2
 30
 42
Construction and other consumer real estate
 
 
 
 
 1
 1
Total consumer loans3
 2
 16
 
 2
 34
 57
Total accruing10
 25
 17
 1
 12
 86
 151
Nonaccruing             
Commercial:             
Commercial and industrial1
 
 
 1
 33
 25
 60
Owner-occupied
 1
 
 3
 1
 12
 17
Municipal
 1
 
 
 
 
 1
Total commercial1
 2
 
 4
 34
 37
 78
Commercial real estate:             
Construction and land development
 
 
 
 2
 
 2
Term2
 1
 
 
 2
 3
 8
Total commercial real estate2
 1
 
 
 4
 3
 10
Consumer:             
Home equity credit line
 
 1
 
 
 1
 2
1-4 family residential
 
 2
 
 1
 5
 8
Construction and other consumer real estate
 
 
 2
 
 
 2
Total consumer loans
 
 3
 2
 1
 6
 12
Total nonaccruing3
 3
 3
 6
 39
 46
 100
Total$13
 $28
 $20
 $7
 $51
 $132
 $251
1
Includes TDRs that resulted from other modification types including, but not limited to, a legal judgment awarded on different terms, a bankruptcy plan confirmed on different terms, a settlement that includes the delivery of collateral in exchange for debt reduction, etc.
2
Includes TDRs that resulted from a combination of any of the previous modification types.
Unfunded lending commitments on TDRs amounted to approximately $22 million at December 31, 2017 and $14totaled $7 million at December 31, 2016.2022.
The total recorded investmentamortized cost of all TDRs in which interest rates were modified below market was $120$63 million at December 31, 2017 and $128 million at December 31, 2016, respectively.2022. These loans are included in the previous schedule in the columns for interest rate below market and multiple modification types.


The net financial impact on interest income due to interest rate modifications below market for accruing TDRs is summarized infor the following schedule:year ended December 31, 2022 was not significant.
(In millions)2017 2016
Consumer:   
1-4 family residential$(1) $(1)
Total consumer loans(1) (1)
Total decrease to interest income 1
$(1) $(1)
1
Calculated based on the difference between the modified rate and the premodified rate applied to the recorded investment.
On an ongoing basis, we monitor the performance of all TDRs according to their restructured terms. Subsequent payment default is defined in terms of delinquency, when principal or interest payments are past due 90 days or more for commercial loans, or 60 days or more for consumer loans.
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The recorded investmentamortized cost of accruing and nonaccruing TDRs that had a payment default during the period listed below (and areyear ended December 31, 2022, and were still in default at year-end)period end, and arewere within 12 months or less of being modified as TDRs was approximately $10 million.
Collateral-dependent Loans
When a loan is individually evaluated for expected credit losses, we estimate a specific reserve for the loan based on the projected present value of the loan’s future cash flows discounted at the loan’s effective interest rate, the observable market price of the loan, or the fair value of the loan’s underlying collateral.
Select information on loans for which the repayment is expected to be provided substantially through the operation or sale of the underlying collateral and the borrower is experiencing financial difficulties, including the type of collateral and the extent to which the collateral secures the loans, is summarized as follows:
December 31, 2023
(In millions)Amortized CostMajor Types of Collateral
Weighted Average LTV1
Commercial:
Owner-occupied$Hospital17%
Commercial real estate:
Construction and land development22 Office Building92%
Term28 Office Building87%
Total$57 
December 31, 2022December 31, 2022
(In millions)(In millions)Amortized CostMajor Types of Collateral
Weighted Average LTV1
Commercial:
(In millions)December 31, 2017 December 31, 2016
Accruing Nonaccruing Total Accruing Nonaccruing Total
Commercial:           
Commercial and industrial$1
 $3
 $4
 $
 $
 $
Owner-occupied
 1
 1
 
 1
 1
Total commercial1
 4
 5
 
 1
 1
Owner-occupied
Owner-occupied$Land, Warehouse29%
Commercial real estate:
Commercial real estate:
Commercial real estate:
Term
Term
TermMulti-family55%
Consumer:           
Construction and other consumer real estate
 
 
 
 2
 2
Total consumer loans
 
 
 
 2
 2
Consumer:
Consumer:
Home equity credit line
Home equity credit line
Home equity credit lineSingle family residential13%
1-4 family residential1-4 family residentialSingle family residential41%
Total$1
 $4
 $5
 $
 $3
 $3
Total
Total
Note: Total loans modified as TDRs during1 The fair value is based on the 12 months previous to December 31, 2017 and 2016 were $94 million and $73 million, respectively.most recent appraisal or other collateral evaluation.
Foreclosed Residential Real Estate
At December 31, 20172023, and December 31, 2016, the amount of2022, we did not have any foreclosed residential real estate property held by the Company was less than $1 million and $2 million, and the recorded investment inproperty. The amortized cost basis of consumer mortgage loans collateralized by residential real estate property that are in the process of foreclosure was approximately$11 million and $10 million for both periods, respectively.the same respective periods.
Concentrations of Credit Risk
Credit risk7.    DERIVATIVE INSTRUMENTS AND HEDGING ACTIVITIES
Objectives for Using Derivatives
Our primary objective for using derivatives is the possibility of loss from the failure of a borrower, guarantor, or another obligor to fully perform under the terms of a credit-related contract. Creditmanage risks, (whether on- or off-balance sheet) may occur when individual borrowers, groups of borrowers, or counterparties have similar economic characteristics, including industries, geographies, collateral types, sponsors, etc., and are similarly affected by changesprimarily interest rate risk. We use derivatives to manage volatility in economic or other conditions. Credit risk also includes the loss that would be recognized subsequent to the reporting date if counterparties failed to perform as contracted. See Note 7 for a discussion of counterparty risk associated with the Company’s derivative transactions.
We perform an ongoing analysis of our loan portfolio to evaluate whether there is any significant exposure to any concentrations of credit risk. Based on this analysis, we believe that the loan portfolio is generally well diversified; however, there are certain significant concentrations in CRE and oil and gas-related lending. Further, we cannot guarantee that we have fully understood or mitigated all risk concentrations or correlated risks. We have adopted and adhere to concentration limits on various types of CRE lending, particularly construction and land development lending, leveraged and enterprise value lending, municipal lending, and oil and gas-related lending. All of these limits are continually monitored and revised as necessary.


Purchased Loans
Background and Accounting
We purchase loans in the ordinary course of business and account for them and the related interest income, based on their performing status at the time of acquisition. PCI loans have evidence of credit deterioration at the time of acquisitioninterest expense, earnings, and it is probable that not all contractual payments will be collected. Interest income for PCI loans is accounted for on an expected cash flow basis. Upon acquisition, in accordance with applicable accounting guidance, the acquired loans were recorded at their fair value without a corresponding ALLL. Certain acquired loans with similar characteristics such as risk exposure, type, size, etc., are grouped and accounted for in loan pools.
During 2009, CB&T and NSB acquired failed bank assets from the FDIC as receiver and entered into loss sharing
agreements (“LSAs”) with the FDIC for the acquired loans and foreclosed assets. Accordingcapital by adjusting our interest rate sensitivity to the agreements, the FDIC assumes 80% of credit losses of non-single family residential loans up to a threshold specified for each acquisition, and 95% above that threshold for five years. The agreements expire after ten years, or in 2019, for single family residential loans. Subsequent to December 31, 2017, we entered into agreements with the FDIC to early-terminate the LSAs, mainly because carrying values of the acquired loans have significantly declined, and the loans have performed better than originally expected. Future losses on these loans are expected to be insignificant.
Outstanding Balances and Accretable Yield
The outstanding balances of all required payments and the related carrying amounts for PCI loans are as follows:
 December 31,
(In millions) 
2017 2016
    
Commercial$25
 $49
Commercial real estate9
 51
Consumer7
 9
Outstanding balance$41
 $109
Carrying amount$27
 $77
Less ALLL
 1
Carrying amount, net$27
 $76
At the time of acquisition of PCI loans, we determine the loan’s contractually required payments in excess of all cash flows expected to be collected as an amount that should not be accreted (nonaccretable difference). With respect to the cash flows expected to be collected, the portion representing the excess of the loan’s expected cash flows over our initial investment (accretable yield) is accreted into interest income on a level yield basis over the remaining expected life of the loan or pool of loans. The effects of estimated prepayments are considered in estimating the expected cash flows.
Certain PCI loans are not accounted for as previously described because the estimation of cash flows to be collected involves a high degree of uncertainty. Under these circumstances, the accounting guidance provides that interest income is recognized on a cash basis similar to the cost recovery methodology for nonaccrual loans. The net carrying amounts in the preceding schedule also include the amounts for these loans. There were no loans of this type at December 31, 2017 and December 31, 2016.


Changes in the accretable yield for PCI loans were as follows: 
(In millions)2017 2016
    
Balance at beginning of year$33
 $40
Accretion(20) (24)
Reclassification from nonaccretable difference
 11
Disposals and other1
 6
Balance at end of year$14
 $33
Note: Amounts have been adjusted based on refinements to the original estimates of the accretable yield.
The primary drivers of reclassification to accretable yield from nonaccretable difference and increases in disposals and other resulted primarily from (1) changes in estimated cash flows, (2) unexpected payments on nonaccrual loans, and (3) recoveries on zero balance loans pools. See subsequent discussion under changes in cash flow estimates.
Allowance for Loan and Lease Losses Determination
For all acquired loans, the ALLL is only established for credit deterioration subsequent to the date of acquisition and represents our estimate of the inherent losses in excess of the book value of acquired loans. The ALLL for acquired loans is included in the overall ALLL in the balance sheet.
During 2017, 2016 and 2015, we adjusted the ALLL for acquired loans by recording a provision for loan losses of less than $1 million in each period. The provision is net of the ALLL reversals resulting from changes in cash flow estimates, which are discussed subsequently.
Changes in the provision for loan losses and related ALLL are driven in large part by the same factors that affect the changes in reclassification from nonaccretable difference to accretable yield, as discussed under changes in cash flow estimates.
Changes in Cash Flow Estimates
Over the life of the loan or loan pool, we continue to estimate cash flows expected to be collected. We evaluate quarterly at the balance sheet date whether the estimated present values of these loans using the effective interest rates have decreased below their carrying values. If so, we record a provision for loan losses.
For increases in carrying values that resulted from better than expected cash flows, we use such increases first to reverse any existing ALLL. During 2017, 2016, and 2015, total reversals to the ALLL, includingminimize the impact of increases in estimated cash flows, were less than $1 million in 2017, $2 million in 2016, and $4 million in 2015. When there is no current ALLL, we increase the amount of accretable yield on a prospective basis over the remaining life of the loan and recognize this increasefluctuations in interest income.
The impact of increased cash flow estimates recognized in the statement of income for acquired loans with no ALLL was approximately $18 million in 2017, $19 million in 2016, and $32 million in 2015, of additional interest income.
7.DERIVATIVE INSTRUMENTS AND HEDGING ACTIVITIES
Objectives
Our objectives in using derivativesrates. Derivatives are used to add stability tostabilize forecasted interest income or expense,from variable-rate assets and to modify the coupon or the duration of specificfixed-rate financial assets or liabilities as we consider advisable,advisable. We also assist customers with their risk management needs through the use of derivatives.
Derivatives Related to Interest Rate Risk Management — When we use derivatives as hedges, either for economic or accounting purposes, it is done only to manage exposure to interest rate movements or other identified risks, and/or to directly offset derivatives sold to our customers.risks. We apply hedge accounting to certain derivatives executed for risk management purposes as described in more detail subsequently.purposes. However, we do not apply hedge accounting to all of the derivatives involved in our risk management activities. Derivatives not designated as accounting hedges are not speculative and are used
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to economically manage our exposure to interest rate movements, and other identified risks, butincluding offsetting customer-facing derivatives. These derivatives either do not require the use of hedge accounting for their economic impact to be appropriately reflected in our financial statements or they do not meet the strict hedge accounting requirements.

Derivatives Related to Customers — We provide certain borrowers access to over-the-counter interest rate derivatives, which we generally offset with interest rate derivatives executed with dealers or central clearing houses. Other interest rate derivatives that we provide to customers, or use for our own purposes, include mortgage rate locks and forward sale loan commitments. We also provide commercial customers with short-term foreign currency spot trades or forward contracts with maturities that are typically 90 days or less. These trades are also largely offset by foreign currency trades with closely matching terms executed with other dealer counterparties or central clearing houses.
Accounting for Derivatives
We record all derivatives at fair value, and they are included in “Other assets” or “Other liabilities” on the consolidated balance sheet, atregardless of the accounting designation of each derivative. We enter into International Swaps and Derivatives Association, Inc. (“ISDA”) master netting agreements, or similar agreements, with substantially all derivative counterparties. Where legally enforceable, these master netting agreements give us, in the event of default or the triggering of other specified contingent events by the counterparty, the right to use cash or liquidate securities held as collateral and to offset receivables and payables with the same counterparty. For purposes of the consolidated balance sheet, we report all derivatives on a gross fair value.value basis (i.e., we do not offset derivative assets and liabilities and cash collateral held with the same counterparty where we have a legally enforceable master netting agreement). Note 3 discusses the process to estimate fair value for derivatives. The accounting for changes in the fair value of derivatives depends on the intended use of the derivative and the resulting accounting designation. Derivatives used to hedge the exposure to changes in the fair value of an asset, liability,assets, liabilities, or firm commitmentcommitments attributable to a particular risk, such as interest rate risk,rates or other eligible risks, are considered fair value hedges. Derivatives used to hedge the exposure to variability in expected future cash flows, or other types of forecasted transactions, are considered cash flow hedges. Changes in the fair value of derivatives that are not part of designated fair value or cash flow hedging relationships are recorded in current period earnings.
ForFair Value Hedges — We generally use interest rate swaps designated as fair value hedges to hedge changes in the fair value of fixed-rate assets and liabilities for specific risks (e.g., interest rate risk resulting from changes in a benchmark interest rate). We use both pay-fixed, receive-floating and received-fixed, pay-floating interest rate swaps to effectively convert certain fixed-rate assets and liabilities to floating rates. In qualifying fair value hedges, changes in value of the derivative hedging instrument are recognized in current period earnings in the same line item affected by the hedged item. Similarly, the periodic changes in value of the hedged item, for the risk being hedged, are recognized in current period earnings, thereby offsetting all, or a significant majority, of the change in the value of the derivative hedging instrument. Interest accruals on both the derivative hedging instrument and the hedged item are recorded in the same line item, effectively converting the designated fixed-rate assets or liabilities to a floating rate. Generally, the designated risk being hedged in all of our fair value hedges is the change in fair value of the secured overnight financing rate (“SOFR”) (or alternative rate) benchmark swap rate component of the contractual coupon cash flows of the fixed-rate assets or liabilities. The swaps are structured to match the critical terms of the hedged items, maximizing the economic (and accounting) effectiveness of the hedging relationships and resulting in the expectation that the swaps will be highly effective as a hedging instrument. All interest rate swaps designated as fair value hedges were highly effective and met all other requirements to remain designated and part of qualifying hedge accounting relationships as of the balance sheet date.
Fair Value Hedges of Liabilities — During the second quarter of 2023, we terminated our remaining receive-fixed interest rate swap with a notional amount of $500 million that had been designated in a qualifying fair value hedge relationship of fixed-rate debt. The receive-fixed interest rate swap effectively converted the interest on our fixed-rate debt to floating until it was terminated. Prior to termination, changes in the fair value of derivatives designated as fair value hedges of debt were offset by changes in the fair value of the derivative are recognizedhedged debt instruments as shown in earnings togetherthe schedules on the following pages. The unamortized hedge basis adjustments resulting from the terminated hedging relationship will be amortized over the remaining life of the fixed-rate debt, which matures in 2029.
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Fair Value Hedges of Assets — During the third quarter of 2023, we entered into new hedges of a defined portfolio of fixed-rate commercial loans using pay-fixed, receive-floating swaps with an aggregate notional amount of $1.0 billion that were designated as fair value hedges under the portfolio layer method described in ASU 2022-01, Derivatives and Hedging (Topic 815): Fair Value Hedging—Portfolio Layer Method. We had an additional $2.5 billion in aggregate notional amount of pay-fixed swaps designated under the portfolio layer method as fair value hedges of a defined portfolio of fixed-rate AFS securities.
At December 31, 2023, we also had pay-fixed, receive-floating interest rate swaps with an aggregate notional amount of $1.1 billion designated as fair value hedges of specifically identified AFS securities. Fair value hedges of fixed-rate assets effectively convert certain fixed interest income to a floating rate on the hedged portion of the assets. Changes in fair value of derivatives designated as fair value hedges of fixed-rate financial assets were largely offset by changes in the value of the hedged assets, as presented in the schedules on the following pages.
Cash Flow Hedges — For derivatives designated and qualifying as cash flow hedges, as long as the hedging relationship continues to qualify for hedge accounting, the entire change in the fair value of the related hedged item. The net amount, if any, representing hedge ineffectiveness,hedging instrument is reflected in earnings. In previous years, we used fair value hedges to manage interest rate exposure to certain long-term debt. These hedges have been terminated and their remaining balances were completely amortized into earnings during 2015.
For derivatives designated as cash flow hedges, the effective portion of changes in the fair value of the derivative are recorded in OCI and recognized in earnings whenas the hedged transaction affects earnings. The ineffective portion of changes in the fair value ofIneffectiveness is not measured or separately disclosed. Gains or losses on derivatives designated as cash flow hedges isare recognized directly in earnings.the same financial statement line item as the hedged transactions. We may use interest rate swaps, as partoptions, or a combination of options in our cash flow hedging strategy to hedgeeliminate or reduce the variable cash flows associated with designatedvariability of interest receipts on floating-rate commercial loans. Theseloans and interest payments on floating rate debt due to changes in any separately identifiable and reliably measurable contractual interest rate swap agreementsindex.
At December 31, 2023, we had receive-fixed interest rate swaps with an aggregate notional amount of $1.5 billion designated as cash flow hedges involve the receipt of fixed-rate amounts in exchange for variable-rate payments over the life of the agreements without exchangevariability of interest receipts on floating-rate commercial loans. During 2023, we terminated receive-fixed swaps with an aggregate notional amount of $5.0 billion. At December 31, 2023, we had $201 million of net losses deferred in AOCI related to terminated cash flow hedges. Amounts deferred in AOCI from terminated cash flow hedges will be amortized into interest income on a straight-line basis through the original maturity dates of the underlyinghedges as long as the hedged forecasted transactions continue to be expected to occur. Amounts deferred in AOCI related to terminated cash flow hedges will be fully reclassified to interest income by the fourth quarter of 2027. Additionally, at December 31, 2023, we had one pay-fixed interest rate swap with a notional amount.
During 2016 we closed our branch in Grand Cayman, Grand Cayman Islands B.W.I. and no longer have foreign operations. No derivatives wereamount of $500 million designated as hedgesa cash flow hedge of investmentsthe variability in foreign operations during 2017.the interest payments on certain FHLB advances.
Hedge Effectiveness — We assess the effectiveness of each hedging relationship by comparing the changes in fair value or cash flows on the derivative hedging instrument with the changes in fair value or cash flows on the designated hedged item or transaction. For derivatives not designated astransactions for the risk being hedged. If a hedging relationship ceases to qualify for hedge accounting, hedges,the relationship is discontinued and future changes in the fair value of the derivative instrument are recognized in current period earnings. TheFor a discontinued or terminated fair value hedging relationship, all remaining balancesbasis adjustments to the carrying amount of any derivative instruments terminated prior to maturity, including amounts in AOCI for cash flow hedges,the hedged item are accreted or amortized to interest income or expense over the period to their previously stated maturity dates. Amountsremaining life of the hedged item consistent with the amortization of other discounts or premiums. Previous balances deferred in AOCI from discontinued or terminated cash flow hedges are reclassified to interest income or expense as interest is earned on related variable-rate loans and as amounts for terminated hedges are accretedthe hedged transactions affect earnings or amortized to earnings.over the originally specified term of the hedging relationship.
Collateral and Credit Risk
Exposure to creditCredit risk arises from the possibility of nonperformance by counterparties. No significant losses on derivative instruments have occurred during 2023 as a result of counterparty nonperformance. Financial institutions which are well-capitalized and well-established are the counterparties for those derivatives entered into for asset-liability management and to offset derivatives sold toWe reduce our customers. The Company reduces its counterparty exposure for derivative contracts by centrally clearing all eligible derivatives.derivatives and by executing dealer-facing derivative transactions with well-capitalized financial institutions.
For those derivatives that are not centrally cleared, the counterparties are typically financial institutions or customers of the Company.our customers. For those that are financial institutions, as noted above, we manage our credit exposure through the use of a Credit Support Annex (“CSA”) to International Swaps and Derivative Associationan ISDA master agreements.agreement with each counterparty. Eligible collateral types are documented by the CSA and controlled under the Company’sour general credit policies. Collateral balances are typically
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monitored on a daily basis. A valuation haircut policy reflects the fact that collateral may fall in value between the date the collateral is called and the date of liquidation or enforcement. In practice,At December 31, 2023, all of the Company’sour collateral held as credit risk mitigation under a CSA iswas cash.
We offer interest rate swaps to our customers to assist them in managing their exposure to changing interest rates. Upon issuance, all of these customer swaps are immediately offset through closely matching derivative contracts such that the Company minimizes itsto minimize our interest rate risk exposure resulting from such transactions. MostFee income from customer swaps is included in “Capital markets fees” on the consolidated statement of these customers do not have the capability for centralized clearing. Therefore, weincome.
We manage the credit risk associated with customer nonperformance through loanadditional underwriting whichthat includes amodeling the credit risk exposure formula for the swap, the sameshared collateral and guarantee protection applicable


to the loan and credit approvals, limits, and monitoring procedures. Fee income from customer swaps isWe measure counterparty credit risk through the calculation of a CVA that captures the value of both the nonperformance risk that we have to our customers and that they have to us. Periodic changes in the net CVA are recorded in current period earnings and included in other service charges, commissions“Fair value and fees. No significant lossesnonhedge derivative income or loss” on derivative instruments have occurred as a resultthe consolidated statement of counterparty nonperformance. Nevertheless, the related credit risk is considered and measured when and where appropriate. See Notes 6 and 15 for further discussion of our underwriting, collateral requirements, and other procedures used to address credit risk.income.
Our derivative contracts require us to pledge collateral for derivatives that are in a net liability position at a given balance sheet date.position. Certain of these derivative contracts contain credit-risk-related contingent features that include the requirement to maintain a minimum debt credit rating. We may be required to pledge additional collateral if a credit-risk-related feature were triggered, such as a downgrade of our credit rating. However, in past situations, not all counterparties have demanded that additional collateral be pledged when provided for under their contracts.by the contractual terms. At December 31, 2017,2023, the fair value of our derivative liabilities was $40$333 million, for which we were required to pledge cash collateral of approximately $38$2 million in the normal course of business. If our credit rating were downgraded one notch by either Standard &and Poor’s (“S&P”) or Moody’s at December 31, 2017, the2023, there would likely be no additional amount of collateral we could be required to pledge is approximately $1 million. As a result of the Dodd-Frank Act, all newly eligible derivatives entered into are cleared through a central clearinghouse.be pledged. Derivatives that are centrally cleared do not have credit-risk-related features that require additional collateral if our credit rating were downgraded.
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Derivative Amounts
Selected information with respect toThe following schedule presents derivative notional amounts and recorded gross fair values at December 31, 20172023 and 2016, and the related gain (loss) of derivative instruments for the years then ended is summarized as follows:2022:
December 31, 2023December 31, 2022
Notional
amount
Fair valueNotional
amount
Fair value
(In millions)Other
assets
Other
liabilities
Other
assets
Other
liabilities
Derivatives designated as hedging instruments:
Cash flow hedges of floating-rate assets:
Receive-fixed interest rate swaps1,450 — — 7,633 — 
Cash flow hedges of floating rate liabilities:
Pay-fixed interest rate swaps500 — — — — — 
Fair value hedges:
Debt hedges: Receive-fixed interest rate swaps— — — 500 — — 
Asset hedges: Pay-fixed interest rate swaps 1
4,571 78 — 1,228 84 — 
Total derivatives designated as hedging instruments6,521 78 — 9,361 84 
Derivatives not designated as hedging instruments:
Customer interest rate derivatives 2
14,375 337 330 13,670 296 443 
Other interest rate derivatives1,001 — 862 — — 
Foreign exchange derivatives216 605 
Purchased credit derivatives35 — — — — 
Total derivatives not designated as hedging instruments15,627 342 333 15,137 302 450 
Total derivatives$22,148 $420 $333 $24,498 $386 $451 
 December 31, 2017 December 31, 2016
 
Notional
amount
 Fair value 
Notional
amount
 Fair value
(In millions)
Other
assets
 
Other
liabilities
 
Other
assets
 
Other
liabilities
Derivatives designated as hedging instruments           
Cash flow hedges:           
Interest rate swaps$1,138
 $
 $
 $1,388
 $2
 $1
Derivatives not designated as hedging instruments           
Interest rate swaps223
 1
 
 235
 2
 
Interest rate swaps for customers 1
4,550
 28
 33
 4,162
 49
 49
Foreign exchange913
 9
 7
 424
 11
 9
Total derivatives not designated as hedging instruments5,686
 38
 40
 4,821
 62
 58
Total derivatives$6,824
 $38
 $40
 $6,209
 $64
 $59
1 The notional amount includes forward starting swaps that are not yet effective.
1 Notional amounts2 Customer interest rate derivatives include both the customer swapscustomer-facing derivatives and the offsetting, derivative contracts.


 Year Ended December 31, 2017 Year Ended December 31, 2016
 Amount of derivative gain (loss) recognized/reclassified
(In millions)

OCI 
Reclassified
from AOCI
to interest
income
 
Noninterest
income
(expense)
 
Offset to
interest
expense
 OCI 
Reclassified
from AOCI
to interest
income
 
Noninterest
income
(expense)
 
Offset to
interest
expense
Derivatives designated as hedging instruments               
Cash flow hedges: 1
               
Interest rate swaps$(8) $4
     $8
 $11
    
Derivatives not designated as hedging instruments               
Interest rate swaps    $(1)       $1
  
Interest rate swaps for customers    11
       14
  
Foreign exchange    17
       11
  
Total derivatives$(8) $4
 $27
 $
 $8
 $11
 $26
 $
Note: These schedules are not intended to present at any given time$9 million and $13 million, reducing the Company’s long/short position with respect to its derivative contracts.
1
Amounts recognized in OCI and reclassified from AOCI represent the effective portion of the derivative gain (loss). For the 12 months following December 31, 2017, we estimate that $1 million will be reclassified from AOCI into interest income.
The fair value of derivative assets was reduced by a net credit valuation adjustment of $2 millionamount at December 31, 20172023, and 2016, respectively. The fair value of derivative liabilities was reduced by a net debit valuation adjustment of $1 million at December 31, 2017 and 2016,2022, respectively. These adjustments are required to reflect both our own nonperformance risk and that of the respective counterparty’s nonperformance risk.counterparty.
The following schedules present the amount of gains (losses) from derivative instruments designated as cash flow and fair value hedges that were deferred in OCI or recognized in earnings for years ended December 31, 2023 and 2022:
Year Ended December 31, 2023
(In millions)Effective portion of derivative gain/(loss) deferred in AOCIAmount of gain/(loss) reclassified from AOCI into incomeNet interest income or expense on fair value hedgesHedge ineffectiveness / AOCI reclass due to missed forecast
Cash flow hedges of floating-rate assets: 1
Purchased interest rate floors$— $— $— $— 
Interest rate swaps31 (170)— — 
Cash flow hedges of floating-rate liabilities:
Pay-fixed interest rate swaps— — 
Fair value hedges of liabilities:
Receive-fixed interest rate swaps— — (5)— 
Basis amortization on terminated hedges 2, 3
— — (4)— 
Fair value hedges of assets:
Pay-fixed interest rate swaps— — 57 — 
Basis amortization on terminated hedges 2, 3
— — — 
Total derivatives designated as hedging instruments$35 $(165)$49 $— 
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Year Ended December 31, 2022
(In millions)Effective portion of derivative gain/(loss) deferred in AOCIAmount of gain/(loss) reclassified from AOCI into incomeNet interest income or expense on fair value hedgesHedge ineffectiveness / AOCI reclass due to missed forecast
Cash flow hedges of floating-rate assets: 1
Purchased interest rate floors$— $$— $— 
Interest rate swaps(437)(29)— — 
Fair value hedges of liabilities:
Receive-fixed interest rate swaps— — (1)— 
Basis amortization on terminated hedges 2, 3
— — — 
Fair value hedges of assets:
Pay-fixed interest rate swaps— — (1)
Basis amortization on terminated hedges 2, 3
— — — — 
Total derivatives designated as hedging instruments$(437)$(27)$$(1)
1 For the 12 months following December 31, 2023, we estimate that $118 million of net losses from active and terminated cash flow hedges will be reclassified from AOCI into interest income/expense, compared with an estimate of $205 million at December 31, 2022.
2 Adjustment to interest income or expense resulting from the amortization of the basis adjustment from previously terminated hedging relationships.
3 The cumulative unamortized basis adjustment from previously terminated or redesignated fair value hedges at December 31, 2023 was $46 million and $3 million of terminated fair value debt and asset hedges, respectively, compared with zero and $10 million at December 31, 2022.
The following schedule presents the amount of gains (losses) recognized from derivatives not designated as accounting hedges:
Other Noninterest
Income/(Expense)
(In millions)20232022
Derivatives not designated as hedging instruments:
Customer interest rate derivatives$17 $43 
Other interest rate derivatives— 
Foreign exchange derivatives29 29 
Purchased credit derivatives(1)— 
Total derivatives not designated as hedging instruments$49 $72 
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The following schedule presents derivatives used in fair value hedge accounting relationships, as well as pre-tax gains/(losses) recorded on such derivatives and the related hedged items for the periods presented:
Gain/(loss) recorded in income
Twelve Months Ended
December 31, 2023
Twelve Months Ended
December 31, 2022
(In millions)
Derivatives 2
Hedged itemsTotal income statement impact
Derivatives 2
Hedged itemsTotal income statement impact
Debt: Receive-fixed interest rate swaps 1,2
$14 $(14)$— $(79)$79 $— 
Assets: Pay-fixed interest rate swaps 1,2
(22)22 — 224 (225)(1)
1 Consists of hedges of benchmark interest rate risk of fixed-rate long-term debt and fixed-rate AFS securities. Gains and losses were recorded in interest expense or income consistent with the hedged items.
2 The income/expense for derivatives does not reflect interest income/expense from periodic accruals and payments to be consistent with the presentation of the gains/(losses) on the hedged items. Periodic interest income/expense for fair value hedges is shown in a separate schedule above.
The following schedule provides information regarding basis adjustments for hedged items:
Par value of hedged assets/(liabilities)Carrying amount of the hedged assets/(liabilities)Cumulative amount of fair value hedging adjustment included in the carrying amount of the hedged assets/(liabilities)
(In millions)202320222023202220232022
Long-term fixed-rate debt 1,2
$— $(500)$— $(435)$— $65 
Fixed-rate AFS securities 1,3
12,389 1,228 12,209 962 (180)(266)
1 Carrying amounts exclude (1) issuance and purchase discounts or premiums, (2) unamortized issuance and acquisition costs, and (3) amounts related to terminated fair value hedges.
2 We terminated the remaining fair value hedge of debt during the second quarter of 2023. The remaining hedge basis adjustments will be amortized over the life of the associated debt.
3 These amounts include the amortized cost basis of defined portfolios of AFS securities and commercial loans used to designate hedging relationships in which the hedged item is the stated amount of assets in the defined portfolio anticipated to be outstanding for the designated hedged period. At December 31, 2023, the amortized cost basis of the defined portfolios used in these hedging relationships was $11.3 billion; the cumulative basis adjustment associated with these hedging relationships was $16 million, and the notional amounts of the designated hedging instruments were $3.5 billion.
8. LEASES
We have operating and finance leases for branches, corporate offices, and data centers. At December 31, 2023, we had 407 branches, of which 278 are owned and 129 are leased. We lease our headquarters in Salt Lake City, Utah. The remaining maturities of our lease commitments range from the year 2024 to 2062, and some lease arrangements include options to extend or terminate the leases.
All leases with lease terms greater than twelve months are reported as a lease liability with a corresponding ROU asset. We include ROU assets for operating leases and finance leases in “Other assets” and “Premises, equipment and software, net” on the consolidated balance sheet, respectively. The corresponding liabilities for those leases are included in “Other liabilities” and “Long-term debt.”
ROU assets and related lease liabilities reflect the present value of the future minimum lease payments over the lease term at commencement date. Because most of our leases do not provide an implicit rate, we use our secured incremental borrowing rate that is commensurate with the lease term when calculating the present value of future payments. The ROU asset also reflects any lease prepayments, initial direct costs, amortization, and certain nonlease components, such as maintenance, utilities, or tax payments. Our lease terms incorporate options to extend or terminate the lease when it is reasonably certain that we will exercise these options.
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The following schedule presents ROU assets and lease liabilities with associated weighted average remaining life and discount rate:
December 31,
(Dollar amounts in millions)20232022
Operating leases
ROU assets, net of amortization$172$173
Lease liabilities198198
Finance leases
ROU assets, net of amortization34
Lease liabilities44
Weighted average remaining lease term (years)
  Operating leases8.78.4
  Finance leases16.517.4
Weighted average discount rate
  Operating leases3.4 %2.9 %
  Finance leases3.1 %3.1 %
The following schedule presents additional information related to lease expense:
Year Ended December 31,
(In millions)202320222021
Lease expense:
Operating lease expense$43 $46 $47 
Other expenses associated with operating leases 1
60 51 50 
Total lease expense$103 $97 $97 
Related cash disbursements for operating leases$49 $50 $50 
1 Other expenses primarily include property taxes and building and property maintenance.
The following schedule presents the total contractual undiscounted lease payments for operating lease liabilities by expected due date for each of the next five years:
(In millions)Total undiscounted lease payments
2024$43 
202536 
202631 
202722 
202817 
Thereafter85 
Total lease payments$234 
Less imputed interest36 
Total$198 
We enter into certain lease agreements where we are the lessor of real estate. Real estate leases are made from bank-owned and subleased property to generate cash flow from the property, including from leasing vacant suites in which we occupy portions of the building. Operating lease income totaled $14 million during both 2023 and 2022, and $13 million during 2021.
We originated equipment leases, considered to be sales-type leases or direct-financing leases, totaling $383 million and $386 million at December 31, 2023 and 2022, respectively. We recorded income of $16 million, $12 million, and $11 million on these leases during 2023, 2022, and 2021, respectively.
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9.    PREMISES, EQUIPMENT, AND SOFTWARE
Net premises, equipment, and software are summarized as follows:
(In millions)December 31,
20232022
Land$269 $264 
Buildings959 943 
Furniture and equipment336 346 
Leasehold improvements137 151 
Software749 730 
Total premises, equipment, and software 1
2,450 2,434 
Less accumulated depreciation and amortization1,050 1,026 
Net book value$1,400 $1,408 
1 The totals for 2023 and 2022 include $40 million and $298 million, respectively, of costs that have been capitalized, but are not yet depreciating because the respective assets have not been placed in service.
10.    GOODWILL AND OTHER INTANGIBLE ASSETS
(In millions)December 31,
2017 2016
Land$234
 $229
Buildings720
 683
Furniture and equipment451
 458
Leasehold improvements135
 140
Software401
 355
Total1,941
 1,865
Less accumulated depreciation and amortization847
 845
Net book value$1,094
 $1,020

9.GOODWILL AND OTHER INTANGIBLE ASSETS
Core depositGoodwill is recorded at fair value at the time of its acquisition and other intangible assetsis subsequently evaluated for impairment annually as of October 1, or more frequently if events or circumstances indicate that impairment may exist. Based on the annual impairment evaluation conducted in 2023 and related accumulated amortization are as follows at December 31:
 Gross carrying amount Accumulated amortization Net carrying amount
(In millions)2017 2016 2017 2016 2017 2016
            
Core deposit intangibles$167
 $167
 $(165) $(159) $2
 $8
Customer relationships and other intangibles28
 28
 (28) (28) 
 
Total$195
 $195
 $(193) $(187) $2
 $8
2022, there was no goodwill impairment in any of our business segments.
The amount of amortization expense of core deposit and other intangible assets is separately reflected in the statement of income. Estimated amortization expense for core deposit and other intangible assets is $2 million in 2018, less than $1 million in 2019, and nothing thereafter.


Changes infollowing schedule presents the carrying amount of goodwill for operatingour business segments with goodwill, are as follows:well as the balance of our core deposits and other intangible assets, net of related accumulated amortization:
December 31,
(In millions)20232022
Goodwill:
Amegy$615 $615 
CB&T379 379 
Zions Bank20 20 
Nevada State Bank13 13 
Total goodwill$1,027 $1,027 
Core deposits and other intangibles, net of accumulated amortization32 38 
Total goodwill and intangibles$1,059 $1,065 
11.    DEPOSITS
The following schedule presents the composition of our deposits:
December 31,
(Dollar amounts in millions)20232022
Noninterest-bearing demand$26,244 $35,777 
Interest-bearing:
Savings and money market38,721 33,566 
Time9,996 2,309 
Total deposits$74,961 $71,652 
131

(In millions)Zions Bank CB&T Amegy Consolidated Company
        
Balance at December 31, 2015$20
 $379
 $615
 $1,014
Impairment losses
 
 
 
Balance at December 31, 201620
 379
 615
 1,014
Impairment losses
 
 
 
Balance at December 31, 2017$20
 $379
 $615
 $1,014

A company-wide annual impairment test is conducted asTable of October 1 of each year and updated on a more frequent basis when events or circumstances indicate that impairment could have taken place. Results of the testing for 2017 and 2016 concluded that no impairment was present in any of the operating segments.Contents
ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
10.DEPOSITS
At December 31, 2017,2023, the scheduled maturitiesaggregate amount of all time deposits by maturity were as follows:
(In millions) 
2018$2,584
2019256
2020132
202185
202257
Thereafter1
Total$3,115
(In millions)Amount
2024$9,798 
2025117 
202638 
202722 
202820 
Thereafter
Total$9,996 
The contractualscheduled maturities of time deposits with a denomination of $100,000 and overthat exceed $250,000 were as follows:
(In millions)December 31, 2023
Three months or less$576 
After three months through six months1,033 
After six months through twelve months745 
After twelve months57 
Total$2,411 
(In millions)December 31, 2017
  
Three months or less$1,023
After three months through six months485
After six months through twelve months508
After twelve months312
Total$2,328
Time deposits in denominations that meet or exceed the current FDIC insurance limit of $250,000 were $1.9 billion and $1.4 billion at December 31, 2017 and 2016, respectively. Time deposits under $250,000 were $1.2 billion and $1.4 billion at December 31, 2017 and 2016, respectively. Deposit overdrafts reclassified as loan balances were $14$11 million and $11$21 million at December 31, 20172023 and 2016,2022, respectively.

12.    SHORT-TERM BORROWINGS

11.SHORT-TERM BORROWINGS
SelectedThe following schedule presents selected information for FHLB advances and other short-term borrowings isborrowings:
(Dollar amounts in millions)20232022
Federal Home Loan Bank advances
Average amount outstanding$4,208 $1,257 
Average rate5.73 %3.67 %
Highest month-end balance$11,525 $7,100 
Year-end balance1,525 7,100 
Average rate on outstanding advances at year-end5.59 %4.43 %
Other short-term borrowings, year-end balances
Federal funds purchased$597 $232 
Security repurchase agreements1,814 2,898 
Securities sold, not yet purchased65 187 
Swap margin collateral received 1
378 — 
Total federal funds and other short-term borrowings$4,379 $10,417 
1 At December 31, 2022, swap margin collateral received totaled $368 million and was included in “Other liabilities” on the consolidated balance sheet. Beginning in 2023, these balances were included in “Federal funds and other short-term borrowings” on the consolidated balance sheet.
We pledge loans and investment securities as follows:
(Dollar amounts in millions)2017 2016 2015
Federal Home Loan Bank advances     
Average amount outstanding$2,657
 $37
 $
Average rate1.13% 0.59% %
Highest month-end balance3,750
 750
 
Year-end balance3,600
 500
 
Average rate on outstandings at year-end1.44% 0.75% %
Other short-term borrowings, year-end balances     
Federal funds purchased927
 106
 111
Security repurchase agreements354
 196
 206
Securities sold, not yet purchased95
 25
 30
Total Federal Home Loan Bank advances and other short-term borrowings$4,976
 $827
 $347
ZB, N.A.collateral for current and potential borrowings. We may borrow from the FHLB under their lines of credit that are secured underby blanket pledge arrangements. ZB, N.A. maintained unencumberedWe maintain collateral with carrying amounts adjusted for the types of collateral pledged, equal to at least 100% of the outstanding advances. At December 31, 2017, the amount available for FHLB advances was approximately $8.9 billion. ZB, N.A.We may also borrow from the Federal Reserve Board (“FRB”) based on the amount of collateral pledged.
A large portion of these pledged assets are unencumbered, but are pledged to a Federal Reserve Bank.provide immediate access to contingency sources of funds. At December 31, 2017, the amount available for additional Federal Reserve borrowings2023, our remaining FHLB and FRB collateralized borrowing capacity was approximately $5.8 billion.$15.0 billion and $9.8 billion, respectively, compared with $9.4 billion and $4.0 billion at December 31, 2022.
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Federal funds purchased and security repurchase agreements generally mature in less than 30 days. Our participation in security repurchase agreements is on an overnight or term basis (e.g., 30 or 60 days). ZB, N.A. executesWe execute overnight repurchase agreements with sweep accounts in conjunction with a master repurchase agreement. When this occurs, securities under the Bank’sour control are pledged and interest is paid on the collected balance of the customers’ accounts. For the non-sweepnonsweep overnight and term repurchase agreements, securities are transferred to the applicable counterparty. The counterparty, inIn certain instances, the counterparty is contractually entitled to sell or repledge securities accepted as collateral. Of the total security repurchase agreements at December 31, 2017, $31 million 2023, nearly all were overnight and $323 million were term.term accounts.
12.LONG-TERM DEBT
13.LONG-TERM DEBT
Long-term debt is summarized as follows:
December 31,
(In millions)20232022
Subordinated notes$538 $519 
Senior notes— 128 
Finance lease obligations
Total$542 $651 
 December 31,
(In millions)2017 2016
    
Subordinated notes$247
 $246
Senior notes135
 288
Capital lease obligations1
 1
Total$383
 $535
The preceding carrying values representpresented above include the par value of the debt, adjusted for any unamortized premium or discount, or unamortized debt issuance costs.costs, and fair value hedge basis adjustments. The decrease in long-term debt from the prior year was primarily due to the maturity of $128 million, 4.50% senior notes during the second quarter of 2023.

the $500 million subordinated notes due in October 2029. The remaining unamortized hedge basis adjustment from the terminated hedging relationship is amortized into earnings through the contractual maturity date of the hedged notes. See Note 7 for more information on derivatives designated as qualifying hedges.
Subordinated Notes
SubordinatedThe following schedule presents our subordinated notes were issued by the Parent and consist of the followingoutstanding at December 31, 2017:2023:
(Dollar amounts in millions)Subordinated notes
Coupon rateBalancePar amountMaturity
6.95%$88 $88 September 2028
3.25%450 500 October 2029
Total$538 $588 
(Dollar amounts in millions) Subordinated notes  
Coupon rate Balance Par amount Maturity
       
5.65% $160
 $162
 Nov 2023
6.95% 87
 88
 Sep 2028
Total $247
 $250
  
TheseThe 6.95% subordinated notes are unsecured, andwith interest is payable semiannually on the 5.65% notes and quarterly on the 6.95% notes. Interest payments on the 5.65% notes commenced May 15, 2014 toquarterly; the earliest possible redemption date of November 15, 2018, after which they are payable quarterly at an annual floating rate equal to 3mL+4.19%. For the 6.95%for these notes interest payments commenced December 15, 2013 to the earliest possible redemption date ofwas September 15, 2023, after which the interest rate changeschanged to an annual floating rate equal to 3mL+3.89%3-month Term SOFR + 4.15%. The 3.25% subordinated notes are unsecured, interest is payable semi-annually, and the earliest redemption date is July 29, 2029.
Senior Notes
Senior notes were issued by the Parent and consist of the following at December 31, 2017:
(Dollar amounts in millions) Senior notes  
Coupon rate Balance Par amount Maturity
       
4.50% $135
 $136
 June 2023
TheseThe senior notes are unsecured, andwith interest is payable semiannually. The notessemi-annually. They were issued under a shelf registration filed with the SECSecurities and were sold via the Company’s online auction process and direct sales. The notes are not redeemable prior to maturity.
Debt Maturities and Redemptions
During 2017, $153 million of our senior notes matured. During 2016, we elected to exercise our right to redeem junior subordinated debentures related to trust preferred securities. The following amounts of long-term debt matured or were redeemed during 2016:Exchange Commission (“SEC”).
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(Dollar amounts in millions)  
Note type Par amount
Trust preferred:  
3mL+2.85% (3.38%) $51
3mL+1.90% (2.22%) 36
3mL+1.78% (2.29%) 62
3mL+3.15% (3.75%) 8
3mL+2.89% (3.42%) 8
Total trust preferred 165
Senior notes:  
3.60% 11
4.00% 89
Total senior notes 100
Total $265

Debt Extinguishment Costs
During 2017, we had no debt extinguishment costs, compared with less than $1 million in 2016 and $3 million in 2015.


ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Maturities of Long-term Debt
Maturities ofThe following schedule presents our long-term debt are as followsby maturity for each of the years succeeding December 31, 2017:next five years:
(In millions)
Par amount 1
2024$— 
2025— 
2026— 
2027— 
202888 
Thereafter500 
Total$588 
1 Does not include basis adjustments related to terminated or active fair value hedges.
14.    SHAREHOLDERS’ EQUITY
(In millions)Consolidated Parent only
    
2018$
 $
20191
 
2020
 
2021
 
2022
 
Thereafter382
 382
Total$383
 $382
The consolidated Zions Bancorporation long-term debt maturities include $1 million of capital lease obligations in addition to the subordinated and senior debt issued by the Parent.
13.SHAREHOLDERS’ EQUITY
Preferred Stock
PreferredWe have 4.4 million authorized shares of preferred stock is without par value and haswith a liquidation preference of $1,000$1,000 per share, or $25 per depositary share. Except for Series I and J, all preferred shares were issued in the form of depositary shares, with each depositary share representing a 1/40th ownership interest in a share of the preferred stock. All preferred shares are registered with the SEC. In addition, Series A and G preferred shares are listed and traded on the National Association of Securities Dealers Automated Quotations (“NASDAQ”) Global Select Market.
In general, preferredPreferred shareholders maygenerally receive asset distributions before common shareholders; however, preferred shareholders have only limited voting rights generally with respect to certain provisions of the preferred stock, the issuance of senior preferred stock, and the election of directors.rights. Preferred stock dividends reduce earnings applicable to common shareholders and are paid on the 15th day of the months indicated in the following schedule. Dividends are approvedsubject to approval by the Board of Directors andBoard.
The preferred shares are subject to regulatory non-objection to a stress test and capital plan submitted to the Federal Reserve pursuant to the annual Horizontal Capital Review, also referred to as Comprehensive Capital Analysis and Review (“HCR/CCAR”) process. Redemption of the preferred stock isredeemable at the Company’sour option after the expiration of any applicable redemption restrictions. The redemption amount is computed at the per share liquidation preference plus any declared but unpaid dividends. Redemptions are subject to certain regulatory provisions including the previously noted capital plan non-objection for a submitted capital plan in a given year.satisfying well-capitalized minimum requirements.
The following schedule summarizes key aspects of our preferred stock:
(Dollar amounts in millions)Carrying value at
December 31,
Shares at
December 31, 2023
Dividends payableEarliest
redemption date
20232022AuthorizedOutstandingRate
Series A$67 $67 140,000 66,139 
> of 4.0% or
3M Term SOFR + 0.78%
Qtrly Mar, Jun, Sep, DecDec 15, 2011
Series G138 138 200,000 138,390 
annual floating rate =
3M Term SOFR + 4.50%
Qtrly Mar, Jun, Sep, DecMar 15, 2023
Series I99 99 300,893 98,555 
annual floating rate =
3M Term SOFR + 4.06%
Qtrly Mar, Jun, Sep, DecJun 15, 2023
Series J136 136 195,152 136,368 
annual floating rate =
3M Term SOFR + 4.70%
Qtrly Mar, Jun, Sep, DecSep 15, 2023
Total$440 $440 

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Preferred stock is summarized as follows:

     Shares at
December 31, 2017
          
(Dollar amounts in millions)Carrying value at
December 31,
 Authorized Outstanding   Dividends payable 
Earliest
redemption date
 Rate following earliest redemption date Dividends payable after rate change
2017 2016 (thousands) (thousands) Rate    
               (when applicable)
Series A$67
 $67
 140,000
 66,139
 > of 4.0% or 3mL+0.52% Qtrly Mar,Jun,Sep,Dec Dec 15, 2011 
 
Series F
 144
 
 
 7.9% Qtrly Mar,Jun,Sep,Dec Jun 15, 2017    
Series G138
 138
 200,000
 138,391
 6.3% Qtrly Mar,Jun,Sep,Dec Mar 15, 2023 annual float-ing rate = 3mL+4.24% 
Series H126
 126
 126,221
 126,221
 5.75% Qtrly Mar,Jun,Sep,Dec Jun 15, 2019 
 
Series I99
 99
 300,893
 98,555
 5.8% Semi-annually Jun,Dec Jun 15, 2023 annual float-ing rate = 3mL+3.8% Qtrly Mar,Jun,Sep,Dec
Series J136
 136
 195,152
 136,368
 7.2% Semi-annually Mar,Sep Sep 15, 2023 annual float-ing rate = 3mL+4.44% Qtrly Mar,Jun,Sep,Dec
Total$566
 $710
              
Preferred Stock Redemptions
During 2017, we redeemed all outstanding shares of our 7.9% Series F preferred stock for a cash payment of approximately $144 million. The total reduction to net earnings applicable to common shareholders associated with the preferred stock redemption was $2 million due to the accelerated recognition of preferred stock issuance costs.
During 2016, we launched a cash tender offer to purchase up to $120 million par amount of certain outstanding preferred stock. Our preferred stock decreased by $118 million as a result of the tender offer, including the purchase of $26 million of our Series I preferred stock, $59 million of our Series J preferred stock, and $33 million of our Series G preferred stock for an aggregate cash payment of $126 million. The total reduction to net earnings applicable to common shareholders associated with the preferred stock redemption was $10 million. The size and terms of the redemptions in 2017 and 2016 were determined in accordance with the Company’s 2016 and 2015 capital plans. These preferred stock redemptions benefit the Company by decreasing the amount of preferred dividends paid.
Common Stock
The Company’sOur common stock is traded on the NASDAQ Global Select Market. As ofAt December 31, 2017, there were 1982023, we had 148.2 million shares of no$0.001 par common stock outstanding.
The Company continued itsbalance of common stock repurchase programand additional paid-in-capital was $1.7 billion at December 31, 2023, and decreased $23 million, or 1%, from the prior year, primarily as a result of common stock repurchases during 2017 andthe first quarter of 2023.
During the first quarter of 2023, we repurchased 70.9 million shares of common shares outstanding with a fair value of $320for $50 million at an average price of $45.66$52.82 per share. As the macroeconomic environment remained uncertain, we suspended our share repurchase program and did not repurchase common shares during the second, third, or fourth quarters of 2023. During the first quarter of 2018, the Company2022, we repurchased an additional 23.6 million common shares of common stock outstanding with a fair value of $115for $200 million at an average price of $53.46$56.13 per share, leaving $120share.
In February 2024, the Board approved a plan to repurchase up to $35 million of repurchase capacity remaining in the 2017 capital plan (which spans the timeframe of July 2017 to June 2018).
During 2016 the Company repurchased 3 million shares of common shares outstanding with a fair value of $90during the fiscal year 2024. In February 2024, we repurchased 0.9 million common shares outstanding for $35 million at an average price of $31.15 per share.


Common Stock Warrants
As of December 31, 2017, 29.3 million common stock warrants with an exercise price of $35.37 were outstanding. These warrants expire on May 22, 2020. In addition, as of December 31, 2017, 5.8 million common stock warrants with an exercise price of $36.27 per share were outstanding. These warrants expire on November 14, 2018 and were associated with the preferred stock issued under the Troubled Asset Relief Program which was redeemed in 2012.
Between January 1, 2018 and February 20, 2018, 1.0 million shares of common stock were issued from the cashless exercise of 3.2 million common stock warrants which expire on November 14, 2018. After these common stock warrant exercises, 29.3 million and 2.6 million common stock warrants, which expire on May 22, 2020 and November 14, 2018, respectively, remain outstanding.$39.32.
Accumulated Other Comprehensive Income
During 2017, $25 millionThe AOCI loss was reclassified from AOCI to retained earnings$2.7 billion at December 31, 2023, and primarily reflects declines in the fair value of fixed-rate available-for-sale securities as a result of changes in interest rates.
During the decreased corporatefourth quarter of 2022, we transferred approximately $10.7 billion fair value ($13.1 billion amortized cost) of mortgage-backed AFS securities to the HTM category to reflect our intent for these securities. The amortized cost basis of these securities does not include $2.4 billion of unrealized losses in AOCI that is amortized over the life of the securities. The amortization of the unrealized losses reported in AOCI will offset the effect of the accretion of the discount in interest income tax rate fromthat is created by adjusting the Tax Cuts and Jobs Actamortized cost basis to the securities’ fair value on the date of 2017.the transfer. At December 31, 2023, the unamortized discount on the HTM securities totaled approximately $2.1 billion ($1.5 billion after tax).
The following schedule presents the changes in AOCI:
(In millions)
Net unrealized gains (losses) on investment securitiesNet unrealized gains (losses) on derivatives and otherPension and post-retirementTotal
2023
Balance at December 31, 2022$(2,800)$(311)$(1)$(3,112)
Other comprehensive income before reclassifications, net of tax66 22 — 88 
Amounts reclassified from AOCI, net of tax208 124 — 332 
Other comprehensive income274 146 — 420 
Balance at December 31, 2023$(2,526)$(165)$(1)$(2,692)
Income tax expense included in other comprehensive income$90 $47 $— $137 
2022
Balance at December 31, 2021$(78)$— $(2)$(80)
Other comprehensive loss before reclassifications, net of tax(2,762)(332)(3,093)
Amounts reclassified from AOCI, net of tax40 21 — 61 
Other comprehensive income (loss)(2,722)(311)(3,032)
Balance at December 31, 2022$(2,800)$(311)$(1)$(3,112)
Income tax benefit included in other comprehensive loss$(888)$(101)$— $(989)
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Changes in AOCI by component are as follows:
(In millions)

Net unrealized gains (losses) on investment securities Net unrealized gains (losses) on derivatives and other Pension and post-retirement Total
2017       
Balance at December 31, 2016$(92) $1
 $(31) $(122)
Other comprehensive income (loss) before reclassifications, net of tax(2) (1) 9
 6
Amounts reclassified from AOCI, net of tax
 (2) 4
 2
Effect of new tax rates from Tax Cuts and Jobs Act of 2017(20) (1) (4) (25)
Other comprehensive income (loss)(22) (4) 9
 (17)
Balance at December 31, 2017$(114) $(3) $(22) $(139)
Income tax expense (benefit) included in other comprehensive income (loss)$19
 $(1) $11
 $29
2016       
Balance at December 31, 2015$(18) $1
 $(38) $(55)
Other comprehensive income (loss) before reclassifications, net of tax(74) 7
 2
 (65)
Amounts reclassified from AOCI, net of tax
 (7) 5
 (2)
Other comprehensive income (loss)(74) 
 7
 (67)
Balance at December 31, 2016$(92) $1
 $(31) $(122)
Income tax expense (benefit) included in other comprehensive income (loss)$(45) $
 $5
 $(40)


ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

(In millions)
Amounts reclassified from AOCI 1
Affected line item
 on statement of income
AOCI components202320222021
Net unrealized gains (losses) on investment securities$(276)$(53)$— Securities gains (losses), net
Less: Income tax expense (benefit)(68)(13)— 
$(208)$(40)$— 
Net unrealized gains (losses) on derivative instruments$(165)$(27)$61 Interest and fees on loans; Interest on short- and long-term borrowings
Less: Income tax expense (benefit)(41)(6)15 
$(124)$(21)$46 
1 Positive reclassification amounts indicate increases to earnings on the statement of income.
    Statement of Income (SI) Balance Sheet (BS)  
(In millions) 
Amounts reclassified from AOCI 1
   
Details about AOCI components 2017 2016 2015  Affected line item
           
Net realized gains (losses) on investment securities $
 $
 $(139) SI Securities losses, net
Income tax expense (benefit) 
 
 (53)    
  $
 $
 $(86)    
Net unrealized gains on derivative instruments $4
 $11
 $9
 SI Interest and fees on loans
Income tax expense 2
 4
 3
    
  $2
 $7
 $6
    
Amortization of net actuarial loss $(7) $(8) $(6) SI Salaries and employee benefits
Income tax benefit (3) (3) (2)    
  $(4) $(5) $(4)    
1
Negative reclassification amounts indicate decreases to earnings in the statement of income and increases to balance sheet assets. The opposite applies to positive reclassification amounts.
Deferred Compensation
Deferred compensation consists of invested assets, including the Company’sour common stock, which are held in rabbi trusts for certain employees and directors. At both The fair value of our common stock was approximately $19 million and $14 million at December 31, 20172023 and 2016, the cost of the common stock included in retained earnings was approximately $14 million.2022, respectively. We consolidate the fair valuerabbi trust invested assets along with the total obligationsand liabilities and include them in other assets“Other assets” and other liabilities, respectively, in“Other liabilities” on the consolidated balance sheet.sheet, respectively. At December 31, 20172023 and 2016, total invested2022, associated trust assets weretotaled approximately $102$124 million and $91 million and total obligations were approximately $116$114 million, and $105trust liabilities totaled approximately $143 million, and $128 million, respectively.
14.REGULATORY MATTERS
15.    REGULATORY MATTERS
We are subject to various regulatory capital requirements administered by federal banking agencies. Failure to meet minimum capital requirements can initiate certain mandatory and possibly additional discretionary actions by regulators that, if undertaken, could have a direct material effect on our financial statements. Under capital adequacy guidelines and the regulatory framework for prompt corrective action, we must meet specific capital guidelines that involve quantitative measures of our assets, liabilities, and certain off-balance sheet items as calculated under regulatory accounting practices. Required capital levels are also subject to judgmental review by regulators.
In 2013, the Federal Reserve Board (“FRB”), FDIC,At December 31, 2023 and OCC published final rules (the “Basel III Capital Rules”) establishing a new comprehensive capital framework for U.S. banking organizations. The rules implemented the Basel Committee’s December 2010 framework, commonly referred to as Basel III, for strengthening international capital standards as well as certain provisions of the Dodd-Frank Act. The Basel III capital rules became effective for the Company on January 1, 2015 and were subject to phase-in periods for certain of their components. In November 2017, the FRB, FDIC and OCC published a final rule for non-advanced approaches banks that extends the regulatory capital treatment applicable during 2017 under the regulatory capital rules for certain items. We met2022, we exceeded all capital adequacy requirements under the Basel III Capital Rules as of December 31, 2017.
Under prior Basel I capital standards, the effects of AOCI items included in capital were excluded for purposes of determining regulatory capital and capital ratios. As a “non-advanced approaches banking organization,” we made a one-time permanent election as of January 1, 2015 to continue to exclude these items, as allowed under the Basel III Capital Rules.rules.
Quantitative measures established by regulation to ensure capital adequacy require us to maintain minimum amounts and ratios of Total andcommon equity Tier 1 (“CET1”) to risk-weighted assets, Tier 1 capital (as defined in the regulations) to risk-weighted assets (as defined), Total capital, and of Tier 1 capital (as defined) to average assets (as defined)(Tier 1 leverage ratio). “Well-capitalized” levels are also published as a


guideline to evaluate capital positions. As ofAt December 31, 2017,2023 and 2022, all of our capital ratios of the Company and its subsidiary bank exceeded the “well-capitalized” levels under the regulatory framework for prompt corrective action.
Dividends declared by our subsidiary bank in any calendar yearus may not without the approval of the appropriate federal regulators, exceed specified criteria. Thecriteria unless otherwise approved by our regulators. When determining dividends, that ZB, N.A. can pay are restricted bywe consider current and historical earning levels, retained earnings, and risk-based and other regulatory capital requirements and limitations.
Appropriate capital levels and distributions of capital to shareholders for the Company and other SIFI are also subject to annual “stress tests” performed as a part of the Federal Reserve’s HCR/CCAR process.
TheOur internal stress tests seek to comprehensively measure all risks to which the institution iswe are exposed, including credit, liquidity, market, operating and other risks, the losses that could result from those risk exposures under adverse scenarios, and the institution’sour resulting capital levels. These stress tests have both a qualitative and a quantitative component. The qualitative component evaluates the robustness of the Company’sour risk identification processes, stress risk modeling, policies, capital planning, governance processes, and other components of a Capital Adequacy Process.capital adequacy process. The quantitative process subjects the Company’sour balance sheet and other risk characteristics to stress testing and independent determination by the Federal Reserve using itsour own models. Most capital actions, including for example, payment
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Table of dividends and repurchasing stock, are subject to non-objection by the Federal Reserve to a capital plan based on both the qualitative and quantitative assessments of the plan.Contents
Because the Company’s subsidiary bank has assets greater than $10 billion also it is subject to annual stress testing and capital planning processes examined by the OCC, known as the Dodd-Frank Act Stress Test (“DFAST”).ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
The actualfollowing schedule presents our capital amounts and ratios and the minimum requirements to be well-capitalized under Basel III at December 31, 20172023 and 2016 for the Company and its subsidiary bank under Basel III are as follows:2022:
(Dollar amounts in millions)December 31, 2023Minimum requirement to be “well-capitalized”
AmountRatioAmountRatio
Basel III Regulatory Capital Amounts and Ratios
Common equity Tier 1 capital (to risk-weighted assets)$6,863 10.3 %$4,351 6.5 %
Tier 1 capital (to risk-weighted assets)7,303 10.9 5,355 8.0 
Total capital (to risk-weighted assets)8,553 12.8 6,693 10.0 
Tier 1 leverage ratio7,303 8.3 4,379 5.0 
December 31, 2022Minimum requirement to be “well-capitalized”
(Dollar amounts in millions)AmountRatioAmountRatio
Basel III Regulatory Capital Amounts and Ratios
Common equity Tier 1 capital (to risk-weighted assets)$6,481 9.8 %$4,297 6.5 %
Tier 1 capital (to risk-weighted assets)6,921 10.5 5,289 8.0 
Total capital (to risk-weighted assets)8,077 12.2 6,611 10.0 
Tier 1 leverage ratio6,921 7.7 4,472 5.0 
(Dollar amounts in millions)December 31, 2017 To be well-capitalized
Amount Ratio Amount Ratio
Transitional Basis Basel III Regulatory Capital Rules       
Total capital (to risk-weighted assets)       
The Company$7,628
 14.8% $5,146
 10.0%
ZB, National Association7,306
 14.2
 5,130
 10.0
Tier 1 capital (to risk-weighted assets)       
The Company6,805
 13.2
 4,116
 8.0
ZB, National Association6,730
 13.1
 4,104
 8.0
Common equity tier 1 capital (to risk-weighted assets)       
The Company6,239
 12.1
 3,345
 6.5
ZB, National Association5,899
 11.5
 3,334
 6.5
Tier 1 capital (to average assets)       
The Company6,805
 10.5
 na
 
 na 1

ZB, National Association6,730
 10.4
 3,227
 5.0


 December 31, 2016 To be well-capitalized
(Dollar amounts in millions)Amount Ratio Amount Ratio
Transitional Basis Basel III Regulatory Capital Rules       
Total capital (to risk-weighted assets)       
The Company$7,609
 15.2% $4,994
 10.0%
ZB, National Association7,278
 14.6
 4,983
 10.0
Tier 1 capital (to risk-weighted assets)       
The Company6,738
 13.5
 3,995
 8.0
ZB, National Association6,655
 13.4
 3,986
 8.0
Common equity tier 1 capital (to risk-weighted assets)       
The Company6,028
 12.1
 3,246
 6.5
ZB, National Association5,824
 11.7
 3,239
 6.5
Tier 1 capital (to average assets)       
The Company6,738
 11.1
 na
 
 na 1

ZB, National Association6,655
 11.0
 3,027
 5.0
1
There is no Tier 1 leverage ratio component in the definition of a well-capitalized bank holding company.
Zions is also subject to “capital conservation buffer” regulatory requirements. When fully phased-in, theThe Basel III capital rules will also require the Company and its subsidiary bankus to maintain certain minimum capital ratios, as well as a 2.5% “capital conservation buffer”buffer,” which is designed to absorb losses during periods of economic stress, composed entirely of Common Equity Tier 1 (“CET1”), on topCET1, and in excess of the minimum risk-weighted assetrisk-based capital ratios. The following schedule presents the minimum capital ratios effectively resulting in minimumand capital conservation buffer requirements, compared with our capital ratios of (i) CET1 to risk-weighted assets of at least 7.0%, (ii) Tier 1 capital to risk-weighted assets of at least 8.5%, and (iii) Total capital to risk-weighted assets of at least 10.5%. BankingDecember 31, 2023:
December 31, 2023
Minimum capital requirementCapital conservation bufferMinimum capital ratio requirement with capital conservation bufferCurrent capital
ratio
CET1 to risk-weighted assets4.5 %2.5 %7.0 %10.3 %
Tier 1 capital (i.e., CET1 plus additional Tier 1 capital) to risk-weighted assets6.0 2.5 8.5 10.9 
Total capital (i.e., Tier 1 capital plus Tier 2 capital) to risk-weighted assets8.0 2.5 10.5 12.8 
Tier 1 capital to average consolidated assets (known as the “Tier 1 leverage ratio”)4.0 N/A4.0 8.3 
Financial institutions with a ratio of CET1 to risk-weighted assets above the minimum but below the capital conservation buffer willmay face constraints on dividends, equity repurchases, and compensation based on the amount of the shortfall. The implementation of the capital conservation buffer began on January 1, 2016 at the 0.625% level and progressively increases over time, as determined by regulation. Zions’Our internal triggers and limits under actual conditions and baseline projections are more restrictive than the capital conservation buffer requirements.
15.COMMITMENTS, GUARANTEES, CONTINGENT LIABILITIES, AND RELATED PARTIES
16.    COMMITMENTS, GUARANTEES, CONTINGENT LIABILITIES, AND RELATED PARTIES
Commitments and Guarantees
We use certain financial instruments, including derivative instruments, in the normal course of business to meet the financing needs of our customers, to reduce our own exposure to fluctuations in interest rates, and to make a market in U.S. Government,government, agency, corporate, and municipal securities. These financial instruments involve, to varying degrees, elements of credit, liquidity, and interest rate risk in excess of the amounts recognized inpresented on the consolidated balance sheet. Derivative instruments are discussed inSee Notes 3 and 7 and 3.for more information on derivative instruments.
Contractual
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
The following schedule presents the contractual amounts of therelated to off-balance sheet financial instruments used to meet the financing needs of our customers are as follows:customers:
December 31,
(In millions)20232022
Unfunded lending commitments 1
$28,940 $29,628 
Standby letters of credit:
Financial548 667 
Performance206 184 
Commercial letters of credit22 11 
Mortgage-backed security purchase agreements 2
66 23 
Total unfunded commitments$29,782 $30,513 
 December 31,
(In millions)2017 2016
    
Net unfunded commitments to extend credit 1
$19,583
 $18,274
Standby letters of credit:   
Financial721
 771
Performance196
 196
Commercial letters of credit31
 60
Total unfunded lending commitments$20,531
 $19,301
1
Net of participations.

1 Net of participations.
2 Represents agreements with Farmer Mac to purchase securities backed by certain agricultural mortgage loans.

Commitments to extend creditLoan commitments are agreements to lend to a customer as long as there is no violation of any condition established in the contract.subject to specified conditions. Commitments generally have fixed expiration dates or other termination clauses and may require the payment of a fee. The amount of collateral obtained, if deemed necessary by us upon extension of credit, is based on our initial credit evaluation of the counterparty. Types of collateral vary, but may include accounts receivable, inventory, property, plant and equipment, and income-producing properties.
While establishingmaking loan commitments to extend credit creates credit risk, a significant portion of such commitments is expected to expire without being drawn upon. As of At December 31, 2017, $6.22023, we had $8.0 billion of commitments scheduled to expire in 2018.2024. We use the same credit policies and procedures in making loan commitments to extend credit and conditional obligations as we do for on-balance sheet instruments. These policies and procedures include credit approvals, limits, and ongoing monitoring.
We issue standby and commercial letters of credit as conditional commitments generally to guarantee the performance of a customer to a third party. The guarantees are primarily issued to support public and private borrowing arrangements, including commercial paper, bond financing, and similar transactions. Standby letters of credit include remaining commitments of $610$754 million expiring in 2018 and $307 million expiring thereafter through 2027.2024. The credit risk involved in issuing letters of credit is essentiallyequivalent to the same as thatrisk involved in extending loan facilitiescredit to customers. We generally hold marketable securities and cash equivalents as collateral when necessary. At December 31, 2017, the Company recorded $5 million as a liability for these guarantees, which consisted of $1 million attributable to the RULC and $4 million of deferred commitment fees.collateral.
Certain mortgage loans sold have limited recourse provisions for periods ranging from three months to one year. The amount of losses resulting from the exercise of these provisions has not been significant.
At December 31, 2017, we had unfunded commitments for PEIs of $31 million. These obligations have no stated maturity. PEIs related to these commitments prohibited by the Volcker Rule were $4 million. See the related discussion about these investments in Note 5.
The contractual or notional amount of financial instruments indicates a level of activity associated with a particular financial instrument class and is not a reflection of the actual level of risk. As of December 31, 2017 and 2016, the regulatory risk-weighted values assigned to all off-balance sheet financial instruments and derivative instruments described herein were $6.8 billion and $6.5 billion, respectively.
At December 31, 2017, we were required to maintain cash balances of $366 million with the Federal Reserve Banks to meet minimum balance requirements in accordance with FRB regulations.
Leases
We have commitments for leasing premises and equipment under the terms of noncancelable capital and operating leases expiring from 2018 and 2052. Premises leased under capital leases at December 31, 2017, were $1 million, and were essentially amortized with accumulated amortization totaling approximately $1 million. Amortization applicable to premises leased under capital leases is included in depreciation expense.
Future aggregate minimum rental payments under existing noncancelable operating leases at December 31, 2017, are as follows:
(in millions) 
2018$40
201939
202036
202129
202225
Thereafter76
Total$245


Future aggregate minimum rental payments have been reduced by noncancelable subleases as follows: $2 million in 2018, $2 million in 2019, and $1 million in 2020. Aggregate rental expense on operating leases amounted to $61 million in 2017, $65 million in 2016, and $63 million in 2015.
Legal Matters
We are subject toinvolved in various legal proceedings or governmental inquiries, which may include litigation in court and arbitral proceedings, as well as proceedings, investigations, examinations, and other actions brought or considered by governmental and self-regulatory agencies. Litigation may relate to lending, deposit and other customer relationships, vendor and contractual issues, employee matters, intellectual property matters, personal injuries and torts, regulatory and legal compliance, and other matters. While most matters relate to individual claims, we are also subject to putative class action claims and similar broader claims. Proceedings, investigations, examinations, and other actions brought or considered by governmental and self-regulatory agencies may relate to our banking, investment advisory, trust, securities, and other products and services; our customers’ involvement in money laundering, fraud, securities violations and other illicit activities or our policies and practices relating to such customer activities; and our compliance with the broad range of banking, securities and other laws and regulations applicable to us. At any given time, we may be in the process of responding to subpoenas, requests for documents, data and testimony relating to such matters and engaging in discussions to resolve the matters.
As
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
At December 31, 2017,2023, we were subject to the following material litigation and governmental inquiries:litigation:
aTwo civil suit, Shou-En Wang v. CB&T, brought against us in the Superior Court for Los Angeles County, Central District in April 2016. The case relates to our depositor relationships with customers who were promoters of an investment program that allegedly misappropriated investors’ funds. This case is in an early phase, with initial motion practice having been completed and discovery being underway.
a civil suit, McFarland as Trustee for International Manufacturing Group v. CB&T, et. al., brought against us in the United States Bankruptcy Court for the Eastern District of California in May 2016. The Trustee seeks to recover loan payments previously repaid to us by our customer, International Manufacturing Group (“IMG”), alleging that IMG, along with its principal, obtained loans and made loan repayments in furtherance of an alleged Ponzi scheme. This case is in an early phase with initial motion practice having been completed and discovery being underway.
a civil suit, JTS Communities, Inc. et. al v. CB&T, Jun Enkoji and Dawn Satow, brought against us in the Superior Court for Sacramento County, California in June 2017. In this case four investors in IMG seek to hold us liable for losses arising from their investments in that company, alleging that we conspired with and knowingly assisted IMG and its principal in furtherance of an alleged Ponzi Scheme. This case is in an early phase with motion practice having been completed but discovery not having been commenced.
a civil class action lawsuit, Evans v. CB&T, brought against us in the United States District Court for the Eastern District of California in May 2017. This case was filed on behalf of a class of up to 50 investors in IMG and seeks to hold us liable for losses of class members arising from their investments in IMG, alleging that we conspired with and knowingly assisted IMG and its principal in furtherance of an alleged Ponzi Scheme. In the fourth quarter of 2017, the District Court dismissed all claims against the Company. On January 17, 2018, the plaintiff filed an appeal with the Court of Appeals for the Ninth Circuit.
a Private Attorney General Act (“PAGA”) claim under California law, Lawson v. CB&T, brought against us in the Superior Court for the County of San Diego, California, in February 2016. In this case, the plaintiff alleges, on behalf of herself and other current or former employees of the Company who worked in California on a non-exempt basis, violations by the Company of California wage and hour laws. The case is in the early stages of motion practice, to date mainly involving questions of venue and scope of employees covered by the PAGA claims.
a civil case, cases, Lifescan Inc. and Johnson & Johnson Health Care Services v. Jeffrey C. Smith, etet. 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 fourth quarterUnited States District Court for the District of 2017.New Jersey in March 2019. In this case,these cases, certain manufacturers and distributors of medical products seek to hold us liable for allegedly fraudulent practices of a borrower of the Company whichBank who filed for bankruptcy protection in 2017.
The cases are in discovery phases. Trial for the two cases has been scheduled for November 2024, but may be rescheduled to a later date.

Clark County, Nevada in February 2021 with respect to foreign transaction fees. This case is in the discovery phase and trial has been scheduled for October 2024. The parties are currently engaged in settlement discussions.
At least quarterly, we review outstanding and new legal matters, utilizing then available information. In accordance with applicable accounting guidance, if we determine that a loss from a matter is probable and the amount of the loss can be reasonably estimated, we establish an accrual for the loss. In the absence of such a determination, no accrual is made. Once established, accruals are adjusted to reflect developments relating to the matters.
In our review, we also assess whether we can determine the range of reasonably possible losses for significant matters in which we are unable to determine that the likelihood of a loss is remote. Because of the difficulty of predicting the outcome of legal matters, discussed subsequently, we are able to meaningfully estimate such a range only for a limited number of matters. Based on information available as ofat December 31, 2017,2023, we estimated that the aggregate range of reasonably possible losses for those matters to be from $0 millionzeroto roughly $20approximately $10 million in excess of amounts accrued. The matters underlying the estimated range will change from time to time, and actual results may vary significantly from this estimate. Those matters for which a meaningful estimate is not possible are not included within this estimated range and, therefore, this estimated range does not represent our maximum loss exposure.
Based on our current knowledge, we believe that our current estimated liability for litigation and other legal actions and claims, reflected in our accruals and determined in accordance with applicable accounting guidance, is adequate and that liabilities in excess of the amounts currently accrued, if any, arising from litigation and other legal actions and claims for which an estimate as previously described is possible, will not have a material impact on our financial condition, results of operations, or cash flows. However, in light of the significant uncertainties involved in these matters, and the very large or indeterminate damages sought in some of these matters, an adverse outcome in one or more of these matters could be material to our financial condition, results of operations, or cash flows for any given reporting period.
Any estimate or determination relating to the future resolution of litigation, arbitration, governmental or self-regulatory examinations, investigations or actions 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 well articulated, reviewed, analyzed, and vetted through discovery, preparation for trial or hearings, substantive and productive mediation or settlement discussions, or other actions. It is also particularly true with respect to class action and similar claims involving multiple defendants, matters with complex procedural requirements or substantive issues or novel legal theories, and examinations, investigations and other actions conducted or brought by governmental and self-regulatory agencies, in which the normal adjudicative process is not applicable. Accordingly, we are usually are 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. Accordingly, our judgments and estimates relating to claims will change from time to time in light of developments, and actual outcomes will differ from our estimates. These differences may be material.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Related Party Transactions
We have no material related party transactions requiring disclosure. In the ordinary course of business, the Company and its subsidiary bankwe extend credit to related parties, including executive officers, directors, principal shareholders, and their associates and related interests. These related party loans are made in compliance with applicable banking regulations.
17.    REVENUE RECOGNITION
We derive our revenue primarily from interest and fees on loans and interest income on securities, which combined represented approximately 81% of our total revenue (interest income plus noninterest income) in 2023. Noninterest income and revenue from contracts with customers is recognized when control of the promised goods or services is transferred to our customers, in an amount that reflects the consideration we expect to be entitled to in exchange for those goods or services. We recognize the incremental cost of obtaining a contract as an expense, when incurred, if the amortization period of the asset that we would have recognized is one year or less. For performance obligations satisfied over time, if we have a right to consideration from a customer in an amount that corresponds directly with the value to the customer of our performance completed to date, we will generally recognize revenue in the amount to which we have a right to invoice. We do not generally disclose information about our remaining performance obligations for those performance obligations that have an original expected duration of one year or less, or where we recognize revenue in the amount to which we have a right to invoice.
The following is a description of revenue from contracts with customers:
Commercial Account Fees
Commercial account fee income is comprised of account analysis fees, merchant fees, and payroll services income. Revenue is recognized as the services are rendered or upon completion of services.
Card Fees
Card fee income includes interchange fees from credit and debit cards, net fees earned from processing card transactions for merchants, and automated teller machine (“ATM”) services. Card fee income is recognized as earned. Reward program costs are recorded when the rewards are earned by the customer and as a reduction to interchange income.
Retail and Business Banking Fees
Retail and business banking fees typically consist of fees charged for providing customers with deposit services. These fees are primarily comprised of insufficient funds fees, noncustomer ATM charges, and other various fees on deposit accounts. Service charges on deposit accounts include fees earned in lieu of compensating balances, and fees earned for performing cash management services and other deposit account services. Service charges on deposit accounts are recognized over the period in which the related service is provided. Treasury management fees are billed monthly based on services rendered for the month.
Capital Markets Fees
Capital markets fees primarily consist of municipal advisory services, customer swap fees, loan syndication fees, and foreign exchange services provided to customers. Revenue is recognized as the services are rendered or upon completion of services.
Wealth Management Fees
Wealth management fees are primarily comprised of wealth management commissions, as well as other portfolio and advisory services. Revenue is recognized as the services are rendered or upon completion of services. Financial planning, fiduciary, and estate services typically have performance obligations that are greater than 12 months, although the amount of future performance obligations are not significant.
Other Customer-related Fees
Other customer-related fees generally consist of miscellaneous income sources, including fees associated with compliance and other support services to pharmacies and healthcare providers; corporate trust fees; other advisory
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16.RETIREMENT PLANS
ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
and referral fees; and fees associated with claims and inventory management services for certain customers. Revenue is recognized as the services are rendered or upon completion of services.
Disaggregation of Revenue
The following schedule presents total net revenue by operating business segment:
Zions BankCB&TAmegy
(In millions)202320222021202320222021202320222021
Commercial account fees$55 $53 $46 $32 $28 $25 $56 $46 $40 
Card fees52 55 58 21 20 17 31 33 29 
Retail and business banking fees19 22 22 11 12 12 14 16 15 
Capital markets fees— — — — — — — — — 
Wealth management fees23 22 21 17 15 13 
Other customer-related fees
Total noninterest income from contracts with customers (ASC 606)157 160 154 75 70 63 125 117 103 
Other noninterest income (non-ASC 606 customer-related)24 19 21 35 34 34 37 40 36 
Total customer-related noninterest income181 179 175 110 104 97 162 157 139 
Other noncustomer-related noninterest income11 10 22 
Total noninterest income192 184 185 116 108 102 184 158 141 
Net interest income696 741 633 598 595 536 453 513 462 
Total net revenue$888 $925 $818 $714 $703 $638 $637 $671 $603 
NBAZNSBVectra
(In millions)202320222021202320222021202320222021
Commercial account fees$10 $$$12 $11 $$$$
Card fees15 15 11 16 15 12 
Retail and business banking fees10 10 10 
Capital markets fees— — — — — — — — — 
Wealth management fees
Other customer-related fees
Total noninterest income from contracts with customers (ASC 606)37 38 31 44 42 36 25 25 21 
Other noninterest income (non-ASC 606 customer-related)13 14 12 
Total customer-related noninterest income39 46 44 45 48 50 28 31 33 
Other noncustomer-related noninterest income— — — — — — 
Total noninterest income40 48 46 45 48 50 28 31 33 
Net interest income260 241 204 191 183 146 150 153 136 
Total net revenue$300 $289 $250 $236 $231 $196 $178 $184 $169 
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
TCBWOtherConsolidated Bank
(In millions)202320222021202320222021202320222021
Commercial account fees$$$$— $$$174 $159 $137 
Card fees— — 146 149 135 
Retail and business banking fees— — — — — 66 73 73 
Capital markets fees— — — 
Wealth management fees— — (1)(2)53 51 46 
Other customer-related fees31 31 30 60 59 52 
Total noninterest income from contracts with customers (ASC 606)34 38 37 503 495 449 
Other noninterest income (non-ASC 606 customer-related)14 (6)117 119 126 
Total customer-related noninterest income48 42 31 620 614 575 
Other noncustomer-related noninterest income— — — 17 109 57 18 128 
Total noninterest income65 48 140 677 632 703 
Net interest income60 63 53 30 31 38 2,438 2,520 2,208 
Total net revenue$67 $70 $59 $95 $79 $178 $3,115 $3,152 $2,911 
Revenue from contracts with customers did not generate significant contract assets and liabilities. Contract receivables are included in “Other assets” on the consolidated balance sheet. Payment terms vary by services offered, and the timing between completion of performance obligations and payment is generally not significant.
18.    RETIREMENT PLANS
Defined Benefit Plans
Pension – This qualified noncontributory defined benefit plan is frozen to new participation. No service-related benefits have been accrued since July 1, 2013. All participants in the Plan are currently 100% vested in their benefits. Plan assets consist principally of corporate equity securities, mutual fund investments, real estate, and fixed income investments. Plan benefits are paid as a lump-sum cash value or an annuity at retirement age. Contributions to the plan are based on actuarial recommendation and pension regulations. Although there was no


minimum regulatory contribution required in 2017 and 2016, we elected to contribute$4 million to the pension plan in 2016. Currently, it is expected that no minimum regulatory contributions will be required in 2018.
Supplemental Retirement Plans These unfunded, nonqualified plans are for certain current and former employees. Each year, Companyour contributions to these plans are made in amounts sufficient to meet benefit payments to plan participants. Our liability for these plans totaled approximately $9 million and $10 million at December 31, 2023, and 2022, respectively.
Postretirement Medical/LifePost-retirement Plan This unfunded health care and life insurance plan provides postretirement medicalpost-retirement benefits to certain former full-time employees who meet minimum age and service requirements. The plan also provides specified life insurance benefits to certain employees. The plan is contributory with retiree contributions adjusted annually, and contains other cost-sharing features such as deductibles and coinsurance. Plan coverage is provided by self-funding or health maintenance organization options. Our contribution towardstoward the retiree medical premium has been permanently frozen at an amount that does not increase in any future year. Retirees pay the difference between the full premium rates and our capped contribution.
Because our contribution rate is capped, there is no effect on the postretirement plan from assumed increases or decreases in health care cost trends. Each year, Companyour contributions to the plan are made in amounts sufficient to meet the portion of the premiums that are the Company’sour responsibility.
The following presents the change in benefit obligation, change in fair value of plan assets, and funded status, of the plans and amounts recognized in the balance sheet as of the measurement date of December 31:
 Pension Supplemental
Retirement
 Postretirement
(In millions)2017 2016 2017 2016 2017 2016
Change in benefit obligation:           
Benefit obligation at beginning of year$165
 $173
 $10
 $10
 $1
 $1
Interest cost6
 7
 1
 1
 
 
Actuarial loss (gain)2
 (2) 
 
 
 
Benefits paid(19) (13) (1) (1) 
 
Benefit obligation at end of year154
 165
 10
 10
 1
 1
Change in fair value of plan assets:           
Fair value of plan assets at beginning of year161
 157
 
 
 
 
Actual return on plan assets26
 13
 
 
 
 
Employer contributions
 4
 1
 1
 
 
Benefits paid(19) (13) (1) (1) 
 
Fair value of plan assets at end of year168
 161
 
 
 
 
Funded status$14
 $(4) $(10) $(10) $(1) $(1)
Amounts recognized in balance sheet:           
Asset (liability) for pension/postretirement benefits$14
 $(4) $(10) $(10) $(1) $(1)
Accumulated other comprehensive income (loss)(28) (48) (2) (2) 
 
Accumulated other comprehensive income (loss) consists of:           
Net loss$(28) $(48) $(2) $(2) $
 $
The pension asset and the liability for supplement retirement/postretirement benefits are included in other assets and other liabilities, respectively, in the balance sheet. The accumulated benefit obligation is the same as the benefit obligation shown in the preceding schedule. During the third quarter of 2017, the Company revised its pension plan to offer certain participants a temporary opportunity to make an election to receive an immediate distribution from the pension plan. The window was available between August 1, 2017 and November 24, 2017. The impact of these distributions is included in “benefits paid” in the preceding schedule and in “settlement loss” shown in the net period benefit cost (credit) schedule.


The amounts in AOCI (loss) at December 31, 2017 expected to be recognized as an expense component of net periodic benefit cost in 2018 for the plans are estimated as follows:
(In millions)Pension Supplemental
Retirement
 Postretirement
      
Net loss$(2) $
 $
The following presents the components of net periodic benefit cost (credit) for the plans:
 Pension Supplemental
Retirement
 Postretirement
(In millions)2017 2016 2015 2017 2016 2015 2017 2016 2015
                  
Interest cost$6
 $7
 $7
 $1
 $1
 $1
 $
 $
 $
Expected return on plan assets(11) (11) (12) 
 
 
 
 
 
Amortization of net actuarial loss4
 6
 6
 
 
 
 
 
 
Settlement loss3
 2
 
 
 
 
 
 
 
Net periodic benefit cost$2
 $4
 $1
 $1
 $1
 $1
 $
 $
 $
Weighted average assumptions based on the pension plan are the same where applicable for each of the plans and are as follows:
 2017 2016 2015
Used to determine benefit obligation at year-end:     
Discount rate3.50% 4.10% 4.20%
Used to determine net periodic benefit cost for the years ended December 31:     
Discount rate4.10
 4.20
 3.95
Expected long-term return on plan assets7.25
 7.50
 7.50
The discount rate reflects the yields available on long-term, high-quality fixed income debt instruments with cash flows similar to the obligations of the pension plan, and is reset annually on the measurement date. The expected long-term rate of return on plan assets is based on a review of the target asset allocation of the plan. This rate is intended to approximate the long-term rate of return that we anticipate receiving on the plan’s investments, considering the mix of the assets that the plan holds as investments, the expected return on these underlying investments, the diversification of these investments, and the rebalancing strategies employed. An expected long-term rate of return is assumed for each asset class and an underlying inflation rate assumption is determined.
Benefit payments to the plans’ participants are estimated as follows for the years succeeding December 31, 2017:
(In millions)Pension Supplemental
Retirement
 Postretirement
      
2018$10
 $2
 $
201910
 1
 
202010
 1
 
202110
 1
 
20229
 1
 
Years 2023 - 202745
 3
 
We are also obligated under other supplemental retirement plans for certain current and former employees. Our liability for these plansthis plan was $6 million at both December 31, 2017 and 2016, respectively.
For the pension plan, the investment strategy is predicated on its investment objectives and the risk and return expectations of asset classes appropriate for the plan. Investment objectives have been established by considering the plan’s liquidity needs and time horizon and the fiduciary standards under the Employee Retirement Income Security Act of 1974. The asset allocation strategy is developed to meet the plan’s long-term needs in a manner


designed to control volatility and to reflect risk tolerance. Target investment allocation percentages as of December 31, 2017 are 65% in equity, 30% in fixed income and cash, and 5% in real estate assets.
The following presents the fair values of pension plan investments according to the fair value hierarchy described in Note 3, and the weighted average allocations:
(In millions)December 31, 2017 December 31, 2016
Level 1 Level 2 Level 3 Total Level 1 Level 2 Level 3 Total
                
Company common stock$12
     $12
 $10
     $10
Mutual funds:               
Debt7
     7
 6
     6
Guaranteed deposit account    $9
 9
     $11
 11
In addition to the investments listed in the previous schedule, as of December 31, 2017, pension plan investments valued using NAV as the practical expedient for fair value consist of $97 million in equity investments, $31 million in debt investments, and $8 million in real estate investments, which are in pooled separate accounts, as well as $4 million in limited partnerships. As of December 31, 2016, pension plan investments valued using NAV as the practical expedient for fair value consist of $92 million in equity investments, $29 million in debt instruments, and $8 million in real estate investments, which are in pooled separate accounts, as well as $5 million in limited partnerships.
No transfers of assets occurred among Levels 1, 2 or 3 during 2017 or 2016.
The following describes the pension plan investments and the valuation methodologies used to measure their fair value:
Company common stock – Shares of the Company’s common stock are valued at the last reported sales price on the last business day of the plan year in the active market where individual securities are traded.
Mutual funds – These funds are valued at quoted market prices which represent the NAVs of shares held by the plan at year-end.
Insurance company pooled separate accounts – These funds are invested in by moreless than one investor. They are offered through separate accounts of the trustee’s insurance company and managed by internal and professional advisors. Participation units in these accounts are valued at the NAV as the practical expedient for fair value as determined by the insurance company.
Guaranteed deposit account – This account is a group annuity product issued by the trustee’s insurance company with guaranteed crediting rates established at the beginning of each calendar year. The account balance is stated at fair value as estimated by the trustee. The account is credited with deposits made, plus earnings at guaranteed crediting rates, less withdrawals and administrative expenses. The underlying investments generally include investment-grade public and privately traded debt securities, mortgage loans and, to a lesser extent, real estate and other equity investments. Market value adjustments are applied at the time of redemption if certain withdrawal limits are exceeded.


Additional fair value quantitative information for the guaranteed deposit account is as follows:
Principal valuation techniquesSignificant unobservable inputs
Range (weighted average)
of significant input values
For the underlying investments – reported fair values when available for market traded investments; when not applicable, discounted cash flows under an income approach using U.S. Treasury rates and spreads based on cash flow timing and quality of assets.Earnings at guaranteed crediting rateGross guaranteed crediting rate must be greater than or equal to contractual minimum crediting rate
Composite market value factorAt December 31,
20170.992941 - 1.037825 (actual = 1.023838)
20160.979009 - 1.036866 (actual = 1.021418)
The Company’s Benefits Committee evaluates the methodology and factors used, including review of the contract, economic conditions, industry and market developments, and overall credit ratings of the underlying investments.
Limited partnerships – These partnerships invest in limited partnerships, limited liability companies, or similar investment vehicles that consist of PEIs in a wide variety of investment types, including venture and growth capital, real estate, energy and natural resources, and other private investments. The plan’s investments are valued by the limited partnerships at NAV as the practical expedient for fair value. The estimation process takes into account the plan’s proportional interests credited with realized and unrealized earnings from the underlying investments and charged for operating expenses and distributions. Investments are increased by capital calls and are part of an overall capital commitment by the plan of up to approximately $9$1 million at December 31, 2017.2023 and 2022.
The following presents additional information as of December 31, 2017liability for supplemental retirement and 2016 forpost-retirement benefits is included in “Other liabilities” on the pooled separate accounts and limited partnerships whose fair values under Levels 2 and 3 are based on NAV per share:
Investment 
Unfunded commitments
(in millions, approximately)
 Redemption
  Frequency Notice period
       
Pooled separate accounts na Daily 
< $1 million, 1 day
>= $1 million, 3 days
      
Limited partnerships $1
 Investments in these limited partnerships are illiquid and voluntary withdrawal is prohibited.
    
The following reconciles the beginning and ending balances of assets measured at fair value on a recurring basis using Level 3 inputs:
 Level 3 Instruments
 Year Ended December 31,
 2017 2016
(In millions)Guaranteed deposit account
    
Balance at beginning of year$11
 $9
Purchases17
 15
Sales(19) (13)
Balance at end of year$9
 $11
Shares of Company common stock were 233,849 at both December 31, 2017 and 2016. Dividends received by the plan were not significant in 2017 and 2016.consolidated balance sheet.
Defined Contribution Plan
The Company offersWe offer a 401(k) and employee stock ownership plan under which employees select from several investment alternatives. Employees can contribute up to 80% of their earnings subject to the annual maximum


allowed contribution. The Company matchesWe match 100% of the first 3% of employee contributions and 50% of the next 2%3% of employee contributions. Matching contributions to participants which were shares of the Company’s common stock purchased totaled $35 million, $33 million, and $32 million in the open market, amounted to $26 million in 2017, 2016,2023, 2022, and 2015.2021, respectively.
The 401(k) plan also has a noncontributory profit sharingprofit-sharing feature whichthat is discretionary and may range from 0% to 4%3.5% of eligible compensation based upon our performance according to a formula approved annually by the Company’s return on average common equity for the year.Board. The profit sharingprofit-sharing expense was computed at a contribution rate of 1.75%$16 million, $19 million, and $24 million in 2017, 1% in 2016,2023, 2022, and 1% in 2015.2021, respectively. The profit sharing expense was $11 million in 2017, and $6 million in both 2016 and2015. The profit sharingprofit-sharing contribution to participants consisted of shares of the Company’sour common stock purchased in the open market.
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17.SHARE-BASED COMPENSATION
ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
19.    SHARE-BASED COMPENSATION
We have a share-based compensation incentive plan whichthat allows us to grant stock options, restricted stock, RSUs, and other awards to employees and non-employeenonemployee directors. Total shares authorized under the plan were 9,000,000 at December 31, 2017,2023 were 4,300,000, of which 5,009,2482,747,546 were available for future grants.
All share-based payments to employees, including grants of employee stock options, are recognized in the statement of incomerecorded as compensation expense based on their grant date values.values with consideration of service and performance vesting requirements. The value of an equity award is estimated on the grant date using a fair value-basedvalue model without regard to service or performance vesting conditions, but does consider post-vesting restrictions.
We classify all share-based awards as equity instruments. Compensation expense is included in salaries“Salaries and employee benefits inbenefits” on the consolidated statement of income, withand the corresponding increaseequity effect is included in common stock.shareholders equity. We account for forfeitures of share-based compensation awards as they occur. Substantially all share-based awards of stock options, restricted stock, and RSUs have graded vesting that is recognized on a straight-line basis over the vesting period.
CompensationThe following schedule presents compensation expense and the related tax benefit for all share-based awards were as follows:awards:
(In millions)202320222021
Compensation expense$33 $30 $28 
Reduction of income tax expense11 11 
(In millions)2017 2016 2015
      
Compensation expense$25
 $26
 $25
Reduction of income tax expense19
 9
 8
During 2017, as a result of our adoption of ASU 2016-09, the tax effects recognized from the exercise of stock options and the vesting of restricted stock and RSUs was recorded as a $9 million reduction of income tax expense. Also, upon the adoption of ASU 2016-09, we elected to account for forfeitures of share-based compensation awards as they occur, rather than estimating forfeitures as was previously done. There was no material impact from the cumulative effect adjustment to retained earnings from this change.
Prior to our adoption of ASU 2016-09, the tax effects recognized from the exercise of stock options and the vesting of restricted stock and RSUs increased common stock by approximately $2 million in 2016 and decreased common stock by approximately $1 million in 2015. These amounts are included in the net activity under employee plans and related tax benefits in the statement of changes in shareholders’ equity.
During 2017, we reduced share-based compensation expense by $1 million as a result of using a valuation model to estimate a liquidity discount on RSUs with post-vesting restrictions.
As ofAt December 31, 2017,2023, compensation expense not yet recognized for nonvested share-based awards was approximately $26$34 million, which is expected to be recognized over a weighted average period of 2.32.4 years.


Stock Options
Stock options granted to employees generally vest at the rate of one third each year and expire seven years after the date of grant. For all stock options granted in 2017, 2016,2023, 2022, and 2015,2021, we used the Black-Scholes option pricing model to estimate the grant date value of stock options in determining compensation expense. The following schedule summarizes the weighted average value at grant date and the significant assumptions used in applying the Black-Scholes model for options granted:
2023202320222021
2017 2016 2015
Weighted average value for options granted$10.69
 $5.24
 $6.17
Weighted average value for options granted
Weighted average value for options granted
Weighted average assumptions used:     
Expected dividend yield
Expected dividend yield
Expected dividend yield1.8% 1.3% 1.3%3.0 %2.3 %2.5 %
Expected volatility30.0% 30.0% 25.0%Expected volatility27.0 %27.0 %25.0 %
Risk-free interest rate1.81% 1.21% 1.57%Risk-free interest rate4.00 %1.98 %0.47 %
Expected life (in years)5.0
 5.0
 5.0
Expected life (in years)4.55.0
The assumptions for expected dividend yield, expected volatility, and expected life reflect management’s judgment and include consideration of historical experience. Expected volatility is based in part on historical volatility. The risk-free interest rate is based on the U.S. Treasury yield curve in effect at the time of grant for periods corresponding with the expected life of the option.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
The following schedule summarizes our stock option activity for the three years ended December 31, 2017:2023:
Number of sharesWeighted average exercise price
Balance at December 31, 20201,683,657 $38.26 
Granted345,636 48.65 
Exercised(686,894)31.08 
Expired(7,910)42.16 
Forfeited(6,345)48.04 
Balance at December 31, 20211,328,144 44.60 
Granted201,932 73.02 
Exercised(256,004)36.79 
Expired(8,912)37.58 
Forfeited(2,794)57.75 
Balance at December 31, 20221,262,366 50.75 
Granted291,005 52.90 
Exercised(95,207)29.67 
Expired(27,948)35.41 
Forfeited(9,838)57.07 
Balance at December 31, 20231,420,378 52.83 
Outstanding stock options exercisable as of:
December 31, 2023891,884 $50.36 
December 31, 2022729,411 46.02 
December 31, 2021693,883 41.54 
 Number of shares Weighted average exercise price
    
Balance at December 31, 20145,630,502
 $31.60
Granted740,300
 29.01
Exercised(1,165,287) 25.11
Expired(1,322,067) 48.44
Forfeited(79,353) 28.09
Balance at December 31, 20153,804,095
 27.30
Granted789,651
 21.25
Exercised(1,055,532) 23.75
Expired(56,297) 61.60
Forfeited(44,007) 27.66
Balance at December 31, 20163,437,910
 26.44
Granted195,882
 44.18
Exercised(941,761) 26.03
Expired(58,257) 66.20
Forfeited(73,203) 25.63
Balance at December 31, 20172,560,571
 27.06
Outstanding stock options exercisable as of:   
December 31, 20171,648,367
 $26.55
December 31, 20161,892,136
 27.60
December 31, 20152,187,259
 26.35
We issue new authorized common shares for the exercise of stock options. The total intrinsic value of stock options exercised was approximately $17$2 million in 2017, $102023, $7 million in 2016,2022, and $7$16 million in 2015.2021. Cash received from the exercise of stock options was $23$2 million in 2017, $242023, $8 million in 2016,2022, and $23$20 million in 2015.2021.

AdditionalThe following schedule presents additional selected information on stock options at December 31, 2017 follows:2023:
Outstanding stock optionsExercisable stock options
 Exercise price range Number of sharesWeighted average exercise priceWeighted average remaining contractual life (years) Number of sharesWeighted average exercise price
$4.15 to $19.995,223 $6.41 105,223 $6.41 
$25.00 to $29.99452 29.12 3.8452 29.12 
$40.00 to $44.9973,077 44.18 0.273,077 44.18 
$45.00 to $49.99558,629 47.34 3.6446,660 47.01 
$50.00 to $59.99587,155 52.78 3.8301,194 52.67 
$60.00 to $73.22195,842 73.19 5.065,278 73.19 
1,420,378 52.83 13.7891,884 50.36 
  Outstanding stock options Exercisable stock options
 Exercise price range  Number of shares Weighted average exercise price Weighted average remaining contractual life (years)  Number of shares Weighted average exercise price
             
$ 0.32 to $19.99 198,402
 $17.39
  1.4
1 
 198,402
 $17.39
$20.00 to $24.99 744,058
 21.50
  4.3  276,953
 22.33
$25.00 to $29.99 1,346,781
 28.35
  3.5  1,094,021
 28.30
$30.00 to $39.99 32,191
 30.10
  3.4  32,191
 30.10
$40.00 to $44.99 192,339
 44.17
  6.1  
 
$45.00 to $47.10 46,800
 47.10
  0.3  46,800
 47.10
  2,560,571
 27.06
  3.7
1 
 1,648,367
 26.55
1 The weighted average remaining contractual life excludes 5,223 stock options without a fixed expiration date that were assumed with the Amegy acquisition. They expire between the date of termination and one year from the date of termination, depending upon certain circumstances.
1
The weighted average remaining contractual life excludes 21,252 stock options without a fixed expiration date that were assumed with the Amegy acquisition. They expire between the date of termination and one year from the date of termination, depending upon certain circumstances.
The aggregate intrinsic value of outstanding stock options at December 31, 20172023 and 20162022 was $61less than $1 million and $59$4 million,, respectively, while the aggregate intrinsic value of exercisable options was $40less than $1 million and $31$3 million at the same respective dates. For exercisable options, the weighted average remaining contractual life was 2.92.7 years and 3.02.8 years at December 31, 20172023 and 2016,2022, respectively, excluding the stock options previously noted without a fixed expiration date. At December 31, 2017, 912,2042023, 528,192 stock options with a weighted average exercise price of $27.99,$57.01, and a weighted average remaining life of 5.15.4 years, andwere expected to vest according to their respective schedules with an aggregate intrinsic value of $21 million, were expected to vest.$0.
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Restricted Stock and Restricted Stock Units
Restricted stock is common stock with certain restrictions that relate to trading and the possibility of forfeiture. Generally, restricted stock vests over four years. Holders of restricted stock have full voting rights and receive dividend equivalents during the vesting period. In addition, holders of restricted stock can make an election to be subject to income tax on the grant date rather than the vesting date.
RSUs represent rights to one share of common stock for each unit and generally vest over four years. Holders of RSUs receive dividend equivalents during the vesting period, but do not have voting rights.
Compensation expense is determined based on the number of restricted shares or RSUs granted and the market price of our common stock at the issue date.
During 2017, 2016,2023, 2022, and 2015,2021, we granted 20,711, 32,310,39,771, 16,722, and 31,08016,938 RSUs, respectively, to non-employeenonemployee directors. The RSUs vested immediately upon grant.

The following schedule summarizes our restricted stock activity for the three years ended December 31, 2017:2023:
Number of sharesNumber of sharesWeighted average fair value
Number of shares Weighted average issue price
   
Nonvested restricted shares at December 31, 2014161,220
 $21.82
Nonvested restricted shares at December 31, 2020
Nonvested restricted shares at December 31, 2020
Nonvested restricted shares at December 31, 2020
Issued22,441
 29.02
Vested(123,161) 22.32
Forfeited(1,130) 23.54
Nonvested restricted shares at December 31, 201559,370
 23.49
Nonvested restricted shares at December 31, 2021
Nonvested restricted shares at December 31, 2021
Nonvested restricted shares at December 31, 2021
Issued36,594
 24.43
Vested(32,709) 20.80
Nonvested restricted shares at December 31, 201663,255
 25.43
Nonvested restricted shares at December 31, 2022
Nonvested restricted shares at December 31, 2022
Nonvested restricted shares at December 31, 2022
Issued314
 44.55
Vested(24,591) 24.90
Nonvested restricted shares at December 31, 201738,978
 25.91
Nonvested restricted shares at December 31, 2023
Nonvested restricted shares at December 31, 2023
Nonvested restricted shares at December 31, 2023
The following schedule summarizes our RSU activity for the three years ended December 31, 2017:2023:
Number of restricted stock unitsWeighted average fair value
Restricted stock units at December 31, 20201,242,321 $46.31 
Granted578,056 47.02 
Vested(505,690)46.51 
Forfeited(40,604)47.97 
Restricted stock units at December 31, 20211,274,083 46.49 
Granted433,674 68.07 
Vested(504,358)47.83 
Forfeited(34,306)56.58 
Restricted stock units at December 31, 20221,169,093 53.62 
Granted727,019 48.85 
Vested(522,163)48.71 
Forfeited(44,004)56.19 
Restricted stock units at December 31, 20231,329,945 52.88 
 Number of restricted stock units Weighted average grant price
    
Restricted stock units at December 31, 20141,769,420
 $25.64
Granted790,929
 29.06
Vested(673,385) 24.78
Forfeited(88,421) 27.17
Restricted stock units at December 31, 20151,798,543
 27.39
Granted1,033,167
 21.69
Vested(724,713) 25.88
Forfeited(59,839) 26.28
Restricted stock units at December 31, 20162,047,158
 25.08
Granted587,396
 41.78
Vested(803,492) 26.19
Forfeited(121,249) 28.12
Restricted stock units at December 31, 20171,709,813
 30.08
The total value at grant date of restricted stock and RSUs vested during the year was $22$27 million in 2017 and $192023, $25 million in both 20162022, and 2015.$24 million in 2021. At December 31, 2017, 38,9782023, 35,771 shares of restricted stock and 1,181,384881,923 RSUs were expected to vest according to their respective schedules with an aggregate intrinsic value of $2 million and $60$39 million, respectively.
18.INCOME TAXES
Income tax expense is summarized as follows:
145
(In millions)2017 2016 2015
Federal:     
Current$166
 $217
 $158
Deferred146
 (4) (32)
Total Federal312
 213
 126
State:     
Current24
 27
 14
Deferred8
 (4) 2
Total State32
 23
 16
Total$344
 $236
 $142



ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

20.    INCOME TAXES
IncomeThe following schedule presents the major components of our income tax expense:
(In millions)202320222021
Federal:
Current$168 $236 $230 
Deferred— (38)27 
Total Federal168 198 257 
State:
Current47 52 55 
Deferred(9)(5)
Total State38 47 60 
Total income tax expense$206 $245 $317 
The following schedule presents a reconciliation of income tax expense computed at the statutory federal income tax rate of 35% reconciles to21% and the actual income tax expense as follows:expense:
(In millions)202320222021
Income tax expense at statutory federal rate$186 $242 $304 
State income taxes including credits, net31 38 48 
Other nondeductible expenses29 13 
Nontaxable income(41)(40)(36)
Share-based compensation(1)(4)(3)
Other(4)(4)
Total income tax expense$206 $245 $317 
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
(In millions)2017 2016 2015
      
Income tax expense at statutory federal rate$327
 $247
 $158
State income taxes including credits, net21
 15
 10
Other nondeductible expenses3
 3
 3
Nontaxable income(33) (25) (20)
Share-based compensation(8) 
 
Tax credits and other taxes1
 (2) (3)
Tax Cuts and Jobs Act of 201747
 
 
Other(14) (2) (6)
Total$344
 $236
 $142
The net DTA or DTL is included in either “Other assets” or “Other liabilities” on the consolidated balance sheet. The following schedule presents the tax effects of temporary differences that give rise to significant portions of DTAs and DTLs:
(In millions)December 31,
20232022
Gross deferred tax assets:
Book loan loss deduction in excess of tax$181 $157 
Deferred compensation81 83 
Security investments and derivative fair value adjustments879 1,011 
Lease liabilities50 49 
Capitalized costs37 82 
Other48 29 
Total deferred tax assets before valuation allowance1,276 1,411 
Valuation allowance— — 
Total deferred tax assets1,276 1,411 
Gross deferred tax liabilities:
Premises and equipment, due to differences in depreciation(101)(99)
Federal Home Loan Bank stock dividends(3)(2)
Leasing operations(49)(49)
Prepaid expenses(5)(5)
Prepaid pension reserves— (3)
Mortgage servicing(5)(12)
Deferred loan costs(34)(34)
ROU assets(43)(44)
Qualified opportunity fund deferred gains(27)(26)
Equity investments(10)(9)
Total deferred tax liabilities(277)(283)
Net deferred tax assets (liabilities)$999 $1,128 
We have certain fixed-rate AFS securities whose fair value has declined due to increases in benchmark interest rates, resulting in unrealized losses in the AFS portfolio and a corresponding DTA. The sale of these securities could result in significant realized losses, which would require future earnings to utilize the deferred tax assets. We have the ability and intent to hold these securities to recovery.
We evaluate DTAs on a regular basis to determine whether a valuation allowance is required. In conducting this evaluation, we consider all available evidence, both positive and negative, based on the more-likely-than-not criteria that such assets (“DTA”) and deferred tax liabilities are presented below:
(In millions)December 31,
2017 2016
Gross deferred tax assets:   
Book loan loss deduction in excess of tax$143
 $241
Pension and postretirement8
 19
Deferred compensation48
 87
Security investments and derivative fair value adjustments40
 57
Net operating losses, capital losses and tax credits2
 5
FDIC-supported transactions2
 5
Other34
 46
 277
 460
Valuation allowance(2) (4)
Total deferred tax assets275
 456
Gross deferred tax liabilities:   
Core deposits and purchase accounting
 (1)
Premises and equipment, due to differences in depreciation(51) (8)
Federal Home Loan Bank stock dividends(3) (4)
Leasing operations(52) (75)
Prepaid expenses(5) (7)
Prepaid pension reserves(11) (17)
Mortgage servicing(7) (10)
Subordinated debt modification(9) (31)
Deferred loan fees(23) (25)
Equity investments(21) (28)
Total deferred tax liabilities(182) (206)
Net deferred tax assets$93
 $250
On December 22, 2017, H.R. 1, known as the Tax Cuts and Jobs Act (“the Act”), was signed into law. The Act makes significant changeswill be realized. This evaluation includes, but is not limited to, the U.S. Internal Revenue Codefollowing:
Future reversals of 1986, includingexisting DTLs — These DTLs have a decrease inreversal pattern generally consistent with DTAs, and are used to realize the current corporate federal incomeDTAs.
Tax planning strategies — We have considered prudent and feasible tax rateplanning strategies that we would implement to 21% from 35%, effective January 1, 2018. In conjunction withpreserve the enactmentvalue of the Act,DTAs, if necessary.
Future projected taxable income — We expect future taxable income will offset the SEC issued Staff Accounting Bulletin No. 118 (“SAB 118”) to address the accounting for certain income tax effectsreversal of the Actremaining net DTAs.
Based on this evaluation, we concluded that maya valuation allowance was not be complete by the time financial statements are issued. The Company evaluated all available information and made reasonable estimates of the impact of the Act to substantially all components of its net DTA. The provisional impact of the Act on the net DTA resulted in a non-cash charge of $47 million recorded through income tax expense. The Company anticipates that additional adjustments to net DTA and income tax


expense may be made in 2018 as the Company’s initial determination of the tax basis of deferred items such as foregone interest, equity investments in flow-through entities, certain employee compensation arrangements, FDIC-supported transactions and premises and equipment are finalized. These adjustments will be recorded in the financial statements in the reporting period when such adjustments are determined; however, SAB 118 requires all impacts from the Act to be recorded prior to December 22, 2018, which is one year from the enactment date of the Act.
In 2017, the Company early adopted the guidance in ASU 2018-02, which allows reclassification from AOCI to retained earnings for the stranded tax effects related to the change in the corporate income tax rate from the Act. The early adoption of the guidance resulted in a $25 million increase to retained earnings out of AOCI as of December 31, 2017.
The amount of net DTAs is included with other assets in the balance sheet. The $2 million and $4 million valuation allowancesrequired at December 31, 20172023 and 2016, respectively, were for certain acquired net operating loss carryforwards included in our acquisition of the remaining interests in a less significant subsidiary. December 31, 2022.
At December 31, 2017, excluding the $2 million,2023, the tax effect of remaining net operating loss and tax credit carryforwards was less than $1 million, expiring through 2030.2039.
We evaluate the DTAs on a regular basis to determine whether an additional valuation allowance is required. In conducting this evaluation, we have considered all available evidence, both positive and negative, based on the more likely than not criteria that such assets will be realized. This evaluation includes, but is not limited to: (1) available carryback potential to prior tax years; (2) potential future reversals
147

We have a liability for unrecognized tax benefits relating to uncertain tax positions for tax credits on technology initiatives. A reconciliation of the beginning and ending amountThe following schedule presents a roll-forward of gross unrecognized tax benefits is as follows:benefits:
(In millions)202320222021
Balance at beginning of year$13 $14 $11 
Tax positions related to current year:
Additions
Tax positions related to prior years:
Additions10 — 
Reductions— (1)— 
Settlements with taxing authorities(3)— — 
Lapses in statutes of limitations(7)(2)— 
Balance at end of year$15 $13 $14 
(In millions)2017 2016 2015
      
Balance at beginning of year$4
 $5
 $3
Tax positions related to current year:     
Additions1
 1
 1
Reductions
 
 
Tax positions related to prior years:     
Additions1
 1
 1
Reductions
 
 
Settlements with taxing authorities
 
 
Lapses in statutes of limitations
 (3) 
Balance at end of year$6
 $4
 $5
At December 31, 20172023 and 2016,2022, the liability for unrecognized tax benefits included approximately $5$13 million and $3$12 million respectively (net of the federal tax benefit on state issues)taxes) that, if recognized, would affect the effective tax rate. The amount of gross unrecognized tax benefits related to tax credits on technology initiatives that may increase or decrease during the 12 months subsequent to December 31, 2017,2023 is dependent on the timing and outcome of various ongoing federal and state examinations. For tax years not currently under examination, the gross unrecognized tax benefits on technology initiatives may decrease by approximately $8 million.
Interest and penalties related to unrecognized tax benefits are included in income“Income tax expense inexpense” on the statement of income. At December 31, 20172023 and 2016,2022, accrued interest and penalties recognizedincluded in “Other liabilities” on the consolidated balance sheet, net of any federal and/orand state tax benefits, were less thantotaled approximately $2 million and $1 million.million, respectively.

The Company and its subsidiariesWe file income tax returns in U.S. federal and various state jurisdictions. The Company isjurisdictions, and we are no longer subject to income tax examinations for years prior to 2013 for federal returns and 2012 for certain state returns.
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19.NET EARNINGS PER COMMON SHARE
BasicZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
21.    NET EARNINGS PER COMMON SHARE
The following schedule summarizes the basic and diluted net earnings per common share based on the weighted average outstanding shares are summarized as follows:shares:
(In millions, except shares and per share amounts)202320222021
Basic:
Net income$680 $907 $1,129 
Less common and preferred dividends277 269 261 
Less impact from redemption of preferred stock— — 
Undistributed earnings403 638 865 
Less undistributed earnings applicable to nonvested shares
Undistributed earnings applicable to common shares399 633 858 
Distributed earnings applicable to common shares243 237 230 
Total earnings applicable to common shares$642 $870 $1,088 
Weighted average common shares outstanding (in thousands)147,748 150,064 159,913 
Net earnings per common share$4.35 $5.80 $6.80 
Diluted:
Total earnings applicable to common shares$642 $870 $1,088 
Weighted average common shares outstanding (in thousands)147,748 150,064 159,913 
Dilutive effect of stock options (in thousands)207 321 
Weighted average diluted common shares outstanding (in thousands)147,756 150,271 160,234 
Net earnings per common share$4.35 $5.79 $6.79 
The following schedule presents the weighted average stock awards that were anti-dilutive and not included in the calculation of diluted earnings per share:
(In thousands)202320222021
Restricted stock and restricted stock units$1,383 $1,265 $1,374 
Stock options1,409 178 74 

22.    OPERATING SEGMENT INFORMATION
(In millions, except per share amounts)2017 2016 2015
Basic:     
Net income$592
 $469
 $309
Less common and preferred dividends131
 115
 108
Undistributed earnings461
 354
 201
Less undistributed earnings applicable to nonvested shares4
 4
 2
Undistributed earnings applicable to common shares457
 350
 199
Distributed earnings applicable to common shares88
 57
 45
Total earnings applicable to common shares$545
 $407
 $244
Weighted average common shares outstanding (in thousands)200,776
 203,855
 203,265
Net earnings per common share$2.71
 $2.00
 $1.20
Diluted:     
Total earnings applicable to common shares$545
 $407
 $244
Weighted average common shares outstanding (in thousands)200,776
 203,855
 203,265
Additional weighted average dilutive shares (in thousands)8,877
 414
 433
Weighted average diluted common shares outstanding (in thousands)209,653
 204,269
 203,698
Net earnings per common share$2.60
 $1.99
 $1.20
For 2017 and 2016, preferred dividends were increased by $2 million and $10 million, respectively, from costs related to the full redemption of the Company’s Series F preferred stock in 2017 and partial redemption of the Company’s Series I, J, and G preferred stock in 2016. See further discussion in Note 13.
20.OPERATING SEGMENT INFORMATION
We manage our operations and prepare management reports and other information with a primary focus on geographicalgeographic area. Our bankingWe conduct our operations areprimarily through seven separately managed under theiraffiliate banks, each with its own individual brand names,local branding and management team, including Zions Bank, Amegy Bank, California Bank & Trust, National Bank of Arizona, Nevada State Bank, Vectra Bank Colorado, and The Commerce Bank of Washington. These affiliate banks comprise our primary business segments. Performance assessment and resource allocation are based upon this geographicalgeographic structure. Our affiliate banks are supported by an enterprise operating segment (referred to as the “Other” segment) that provides governance and risk management, allocates capital, establishes strategic objectives, and includes centralized technology, back-office functions, and certain lines of business not operated through our affiliate banks.
We allocate the cost of centrally provided services to the business segments based upon estimated or actual usage of those services. We also allocate capital based on the risk-weighted assets held at each business segment. We use an internal funds transfer pricing (“FTP”) allocation systemprocess to report results of operations for business segments. This process continuesis subject to be refined.change and refinement over time. Total average loans and deposits presented for the bankingbusiness segments do not include insignificant intercompany amounts between bankingbusiness segments butand may also include deposits with the Other“Other” segment. Prior period amounts have been reclassified to reflect these changes.
As of At December 31, 2017, our banking business is conducted through 7 locally managed and branded segments in distinct geographical areas. Performance assessment and resource allocation are based upon this geographical structure.2023, Zions Bank operates 97operated 95 branches in Utah, 2325 branches in Idaho, and 1one branch in Wyoming. CB&T operates 92operated 75 branches in California. Amegy operates 73operated 75 branches in Texas. NBAZ operates 58operated 56 branches in Arizona. NSB operates 50operated 43 branches in Nevada. Vectra operates 36operated 33 branches in Colorado and 1one branch in New Mexico. TCBW operates 1 branchoperated two branches in Washington and 1one branch in Oregon.
The operating segment identified as “Other” includes the Parent, certain nonbank financial service subsidiaries, centralized back-office functions, and eliminations of transactions between segments. The major components of net interest income at the Bank’s back-office include the revenue associated with the investments securities portfolio

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

In July 2022, NSB completed the purchase of three Northern Nevada City National Bank branches and their associated deposit, credit card, and loan accounts. We acquired approximately $430 million in deposits and $95 million in commercial and consumer loans at the offsettime of the FTP costs and benefits provided to the business segments. Throughout 2016 consolidation efforts continued, which resulted in transitioning full-time equivalents from thepurchase.
Transactions between business segments to the Company’s back-office units. Due to the continuing nature and timingare primarily conducted at fair value, resulting in profits that are eliminated for reporting consolidated results of this change, the Company’s back-office units retained more direct expenses in 2016 than in prior years. In the first quarter of 2017 we made changes to the FTP process and internal allocation of central expenses to better reflect the performance of business segments. Prior period amounts have been revised to reflect the impact of these changes had they been instituted in 2016.
operations. The following schedule does not present total assets or income tax expense for each operating segment, but instead presents average loans, average deposits, and income before income taxes because we use these are the metrics that management uses when evaluating performance and making decisions pertaining to the operatingbusiness segments. The Parent’s net interest income includes interest expense on other borrowed funds. The Parent’s financial statements in Note 22 provide more information about the Parent’s activities. The condensed statement of income identifies the components of income and expense which affect the operating amounts presented in the Other“Other” segment.
The accounting policies of the individual operating segments are the same as those of the Company. Transactions between operating segments are primarily conducted at fair value, resulting in profits that are eliminated for reporting consolidated results of operations.


The following is a summary ofschedule presents selected operating segment information:
(In millions)Zions BankCB&TAmegy
202320222021202320222021202320222021
SELECTED INCOME STATEMENT DATA
Net interest income$696 $741 $633 $598 $595 $536 $453 $513 $462 
Provision for credit losses20 43 (26)44 49 (78)15 (96)
Net interest income after provision for credit losses676 698 659 554 546 614 438 508 558 
Noninterest income192 184 185 116 108 102 184 158 141 
Noninterest expense557 495 464 388 340 311 404 355 337 
Income (loss) before income taxes$311 $387 $380 $282 $314 $405 $218 $311 $362 
SELECTED AVERAGE BALANCE SHEET DATA
Total average loans$14,298 $13,277 $13,198 $14,128 $13,129 $12,892 $12,851 $12,110 $12,189 
Total average deposits20,233 24,317 23,588 14,253 16,160 15,796 13,569 15,735 15,496 
(In millions)NBAZNSBVectra
202320222021202320222021202320222021
SELECTED INCOME STATEMENT DATA
Net interest income$260 $241 $204 $191 $183 $146 $150 $153 $136 
Provision for credit losses11 (27)42 (35)(12)
Net interest income after provision for credit losses256 230 231 149 179 181 143 144 148 
Noninterest income40 48 46 45 48 50 28 31 33 
Noninterest expense189 167 151 171 151 142 137 120 114 
Income (loss) before income taxes$107 $111 $126 $23 $76 $89 $34 $55 $67 
SELECTED AVERAGE BALANCE SHEET DATA
Total average loans$5,318 $4,911 $4,849 $3,392 $2,987 $3,015 $4,004 $3,632 $3,414 
Total average deposits7,008 8,035 7,288 6,964 7,436 6,691 3,482 4,109 4,386 
(In millions)TCBWOtherConsolidated Bank
202320222021202320222021202320222021
SELECTED INCOME STATEMENT DATA
Net interest income$60 $63 $53 $30 $31 $38 $2,438 $2,520 $2,208 
Provision for credit losses(3)(2)— 132 122 (276)
Net interest income after provision for credit losses58 62 56 32 31 37 2,306 2,398 2,484 
Noninterest income65 48 140 677 632 703 
Noninterest expense27 24 21 224 226 201 2,097 1,878 1,741 
Income (loss) before income taxes$38 $45 $41 $(127)$(147)$(24)$886 $1,152 $1,446 
SELECTED AVERAGE BALANCE SHEET DATA
Total average loans$1,705 $1,630 $1,569 $1,044 $922 $857 $56,740 $52,598 $51,983 
Total average deposits1,196 1,571 1,537 6,161 1,166 1,475 72,866 78,529 76,257 
150
(In millions)Zions Bank Amegy CB&T
2017 2016 2015 2017 2016 2015 2017 2016 2015
SELECTED INCOME STATEMENT DATA            
Net interest income$650
 $624
 $544
 $483
 $460
 $387
 $476
 $434
 $377
Provision for loan losses19
 (22) (28) 25
 163
 91
 (5) (9) (4)
Net interest income after provision for loan losses631
 646
 572
 458
 297
 296
 481
 443
 381
Noninterest income151
 149
 133
 118
 123
 121
 75
 67
 63
Noninterest expense436
 424
 430
 336
 326
 373
 299
 290
 294
Income before income taxes$346
 $371
 $275
 $240
 $94
 $44
 $257
 $220
 $150
SELECTED AVERAGE BALANCE SHEET DATA            
Total average loans$12,481
 $12,538
 $12,118
 $11,021
 $10,595
 $10,148
 $9,539
 $9,211
 $8,556
Total average deposits15,986
 15,991
 15,688
 11,096
 11,130
 11,495
 11,030
 10,827
 10,063
(In millions)NBAZ NSB Vectra
2017 2016 2015 2017 2016 2015 2017 2016 2015
SELECTED INCOME STATEMENT DATA            
Net interest income$206
 $190
 $152
 $134
 $122
 $94
 $126
 $120
 $101
Provision for loan losses(8) (3) 8
 (11) (28) (28) 1
 (8) 5
Net interest income after provision for loan losses214
 193
 144
 145
 150
 122
 125
 128
 96
Noninterest income40
 40
 36
 40
 39
 36
 25
 23
 21
Noninterest expense148
 144
 133
 139
 137
 131
 101
 97
 98
Income before income taxes$106
 $89
 $47
 $46
 $52
 $27
 $49
 $54
 $19
SELECTED AVERAGE BALANCE SHEET DATA            
Total average loans$4,267
 $4,086
 $3,811
 $2,357
 $2,284
 $2,344
 $2,644
 $2,469
 $2,400
Total average deposits4,762
 4,576
 4,311
 4,254
 4,137
 3,891
 2,756
 2,720
 2,792
(In millions)TCBW Other Consolidated Company
2017 2016 2015 2017 2016 2015 2017 2016 2015
SELECTED INCOME STATEMENT DATA            
Net interest income$46
 $38
 $28
 $(56) $(121) $32
 $2,065
 $1,867
 $1,715
Provision for loan losses2
 
 (3) 1
 
 (1) 24
 93
 40
Net interest income after provision for loan losses44
 38
 31
 (57) (121) 33
 2,041
 1,774
 1,675
Noninterest income5
 5
 4
 90
 70
 (57) 544
 516
 357
Noninterest expense20
 19
 17
 170
 148
 105
 1,649
 1,585
 1,581
Income (loss) before income taxes$29
 $24
 $18
 $(137) $(199) $(129) $936
 $705
 $451
SELECTED AVERAGE BALANCE SHEET DATA            
Total average loans$926
 $791
 $707
 $266
 $88
 $87
 $43,501
 $42,062
 $40,171
Total average deposits1,107
 1,007
 879
 1,209
 207
 (481) 52,200
 50,595
 48,638




ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES

23.    QUARTERLY FINANCIAL INFORMATION (UNAUDITED)
21.QUARTERLY FINANCIAL INFORMATION (UNAUDITED)
FinancialThe following schedule presents quarterly financial information by quarter for 20172023 and 2016 is as follows:2022:
(In millions, except per share amounts)Fourth QuarterThird QuarterSecond QuarterFirst Quarter
2023
Total interest income$1,040 $1,010 $977 $920 
Net interest income583 585 591 679 
Provision for credit losses— 41 46 45 
Noninterest income148 180 189 160 
Noninterest expense581 496 508 512 
Income before income taxes150 228 226 282 
Net income126 175 175 204 
Preferred stock dividends10 
Net earnings applicable to common shareholders116 168 166 198 
Net earnings per common share:
Basic0.78 1.13 1.11 1.33 
Diluted0.78 1.13 1.11 1.33 
2022
Total interest income$835 $707 $608 $555 
Net interest income720 663 593 544 
Provision for credit losses43 71 41 (33)
Noninterest income153 165 172 142 
Noninterest expense471 479 464 464 
Income before income taxes359 278 260 255 
Net income284 217 203 203 
Preferred stock dividends
Net earnings applicable to common shareholders277 211 195 195 
Net earnings per common share:
Basic1.84 1.40 1.29 1.27 
Diluted1.84 1.40 1.29 1.27 
ITEM 9.    CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND FINANCIAL DISCLOSURE
(In millions, except per share amounts)Quarters  
First Second Third Fourth Year
2017         
Gross interest income$515
 $558
 $557
 $562
 $2,192
Net interest income489
 528
 522
 526
 2,065
Provision for loan losses23
 7
 5
 (11) 24
Noninterest income132
 132
 140
 140
 544
Noninterest expense414
 405
 413
 417
 1,649
Income before income taxes184
 248
 244
 260
 936
Net income139
 168
 161
 124
 592
Preferred stock dividends(10) (12) (8) (10) (40)
Preferred stock redemption
 (2) 
 
 (2)
Net earnings applicable to common shareholders129
 154
 153
 114
 550
Net earnings per common share:         
Basic0.63
 0.76
 0.75
 0.57
 2.71
Diluted0.61
 0.73
 0.72
 0.54
 2.60
2016         
Gross interest income$475
 $487
 $491
 $501
 $1,954
Net interest income453
 465
 469
 480
 1,867
Provision for loan losses42
 35
 19
 (3) 93
Noninterest income117
 126
 145
 128
 516
Noninterest expense396
 382
 403
 404
 1,585
Income before income taxes132
 174
 192
 207
 705
Net income91
 114
 127
 137
 469
Preferred stock dividends(12) (14) (10) (12) (48)
Preferred stock redemption
 (10) 
 
 (10)
Net earnings applicable to common shareholders79
 90
 117
 125
 411
Net earnings per common share:         
Basic0.38
 0.44
 0.57
 0.61
 2.00
Diluted0.38
 0.44
 0.57
 0.60
 1.99
Certain prior year amounts have been reclassified to conform with the current year presentation. These reclassifications did not affect net income. See related discussion in Note 1. Individual quarter information may be different than previously reported due to rounding.


22.PARENT COMPANY FINANCIAL INFORMATION
CONDENSED BALANCE SHEETS
(In millions)December 31,
2017 2016
ASSETS   
Cash and due from banks$
 $2
Interest-bearing deposits332
 529
Investment securities:   
Available-for-sale, at fair value30
 40
Other noninterest-bearing investments36
 29
Investments in subsidiaries:   
Commercial bank7,620
 7,570
Other subsidiaries41
 6
Other assets32
 81
Total assets$8,091
 $8,257
LIABILITIES AND SHAREHOLDERS’ EQUITY   
Other liabilities$30
 $89
Long-term debt:   
Due to others382
 534
Total liabilities412
 623
Shareholders’ equity:   
Preferred stock566
 710
Common stock4,445
 4,725
Retained earnings2,807
 2,321
Accumulated other comprehensive income (loss)(139) (122)
Total shareholders’ equity7,679
 7,634
Total liabilities and shareholders’ equity$8,091
 $8,257


CONDENSED STATEMENTS OF INCOME
(In millions)Year Ended December 31,
2017 2016 2015
Interest income:     
Commercial bank$
 $1
 $1
Other loans and securities1
 2
 3
Total interest income1
 3
 4
Interest expense:     
Affiliated trusts
 3
 4
Other borrowed funds25
 34
 64
Total interest expense25
 37
 68
Net interest loss(24) (34) (64)
Other income:     
Dividends from consolidated subsidiaries:     
Commercial bank587
 263
 234
Securities gains, net
 
 37
Other income7
 4
 13
Total other income594
 267
 284
Expenses:     
Salaries and employee benefits24
 23
 25
Other operating expenses8
 (14) 10
Total expenses32
 9
 35
Income before income taxes and undistributed income of consolidated subsidiaries538
 224
 185
Income tax benefit(42) (19) (27)
Income before equity in undistributed income of consolidated subsidiaries580
 243
 212
Equity in undistributed income (loss) of consolidated subsidiaries:     
Commercial bank12
 230
 108
Other subsidiaries
 (4) (11)
Net income592
 469
 309
Preferred stock dividends(40) (48) (62)
Preferred stock redemption(2) (10) 
Net earnings applicable to common shareholders$550
 $411
 $247


CONDENSED STATEMENTS OF CASH FLOWS
(In millions)Year Ended December 31,
2017 2016 2015
CASH FLOWS FROM OPERATING ACTIVITIES     
Net income$592
 $469
 $309
Adjustments to reconcile net income to net cash provided by operating activities:     
Equity in undistributed income of consolidated subsidiaries(12) (226) (97)
Other, net(56) (31) 78
Net cash provided by operating activities524
 212
 290
CASH FLOWS FROM INVESTING ACTIVITIES     
Net decrease in money market investments196
 347
 132
Collection of advances to subsidiaries
 
 56
Advances to subsidiaries
 
 (41)
Proceeds from sales and maturities of investment securities20
 4
 125
Purchases of investment securities
 
 (47)
Decrease of investment in subsidiaries
 
 15
Other, net2
 7
 4
Net cash provided by investing activities218
 358
 244
CASH FLOWS FROM FINANCING ACTIVITIES     
Repayments of long-term debt(164) (280) (271)
Proceeds from issuance of common stock25
 25
 22
Cash paid for preferred stock redemptions(144) (126) (176)
Company common stock repurchased(332) (97) (7)
Dividends paid on preferred stock(40) (50) (63)
Dividends paid on common stock(89) (58) (45)
Net cash used in financing activities(744) (586) (540)
Net decrease in cash and due from banks(2) (16) (6)
Cash and due from banks at beginning of year2
 18
 24
Cash and due from banks at end of year$
 $2
 $18
The Parent paid interest of $26 million in 2017, $35 million in 2016, and $51 million in 2015.


ITEM 9.CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND FINANCIAL DISCLOSURE
None.
ITEM 9A.CONTROLS AND PROCEDURES
The Company’sITEM 9A. CONTROLS AND PROCEDURES
Our management, with the participation of the Company’sour Chief Executive Officer and Chief Financial Officer, has evaluated the effectiveness of the Company’sour disclosure controls and procedures as of December 31, 2017.2023. Based on that evaluation, the Company’sour Chief Executive Officer and Chief Financial Officer concluded that the Company’sour disclosure controls and procedures were effective as of December 31, 2017.2023. There were no changes in the Company’sour internal control over financial reporting during the fourth quarter of 20172023 that have materially affected, or are reasonably likely to materially affect, the Company’sour internal control over financial reporting. See “Report on Management’s Assessment of Internal Control over Financial Reporting” included in Item 8 on page 8480 for management’s report on the adequacy of internal control over financial reporting. Also see “Report on Internal Control over Financial Reporting” issued by Ernst & Young LLP included in Item 8 on page 86.81.
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ITEM 9B.OTHER INFORMATION
ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
ITEM 9B. OTHER INFORMATION
We have adopted insider trading policies and procedures governing the purchase, sale, and other dispositions of securities by directors, officers, and non-executive employees that are reasonably designed to promote compliance with insider trading laws, rules, and regulations, and any applicable listing standards.
None of our directors or officers have adopted, modified, or terminated a Rule 10b5-1(c) trading arrangement during the year ended December 31, 2023. Our directors and officers participate in certain of our benefits plans, such as our Omnibus Incentive Plan and Payshelter 401(k) and Employee Stock Ownership Plan, and may from time to time make elections to have shares withheld to cover withholding taxes or pay the exercise price of options granted thereunder. These elections may be designed to satisfy the affirmative defense conditions of Rule 10b5-1 under the Exchange Act or may constitute non-Rule 10b5-1 trading arrangements as defined in Item 408(c) of Regulation S-K.
ITEM 9C. DISCLOSURE REGARDING FOREIGN JURISDICTIONS THAT PREVENT INSPECTIONS
None.
PART III
ITEM 10.DIRECTORS, EXECUTIVE OFFICERS AND CORPORATE GOVERNANCE
ITEM 10. DIRECTORS, EXECUTIVE OFFICERS, AND CORPORATE GOVERNANCE
Incorporated by reference from the Companysour Proxy Statement to be subsequently filed.
ITEM 11.EXECUTIVE COMPENSATION
ITEM 11. EXECUTIVE COMPENSATION
Incorporated by reference from the Companysour Proxy Statement to be subsequently filed.
ITEM 12.SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT AND RELATED STOCKHOLDER MATTERS
EQUITY COMPENSATION PLAN INFORMATION
ITEM 12. SECURITY OWNERSHIP OF CERTAIN BENEFICIAL OWNERS AND MANAGEMENT AND RELATED STOCKHOLDER MATTERS
Equity Compensation Plan Information
The following schedule provides information as of December 31, 20172023 with respect to the shares of the Company’sour common stock that may be issued under existing equity compensation plans.plans:
(a)(b)(c)
Plan category 1
Number of securities to be issued upon exercise of outstanding options, warrants, and rightsWeighted average exercise price of outstanding options, warrants, and rightsNumber of securities remaining available for future issuance under equity compensation plans (excluding securities reflected in column (a))
Equity compensation plan approved by security holders:
Zions Bancorporation, N.A. 2022 Omnibus Incentive Plan1,415,155 $53.00 2,747,546 
  (a) (b) (c)
Plan category 1
 Number of securities to be issued upon exercise of outstanding options, warrants and rights Weighted average exercise price of outstanding options, warrants and rights Number of securities remaining available for future issuance under equity compensation plans (excluding securities reflected in column (a))
             
Equity compensation plan approved by security holders:            
             
Zions Bancorporation 2015 Omnibus Incentive Plan  1,363,432
   $27.43
   5,009,248
 
1 Column (a) excludes 35,771 shares of unvested restricted stock, and 1,329,945 RSUs (each unit representing the right to one share of common stock). The schedule also excludes 5,223 shares of common stock issuable upon the exercise of stock options, with a weighted average exercise price of $6.41, granted under plans assumed in mergers that are outstanding.
1
Column (a) excludes 38,978 shares of unvested restricted stock, 1,709,813 RSUs (each unit representing the right to one share of common stock), and 1,175,887 shares of common stock issuable upon the exercise of stock options, with a weighted average exercise price of $27.03, granted under the prior plan. The schedule also excludes 21,252 shares of common stock issuable upon the exercise of stock options, with a weighted average exercise price of $5.02, granted under plans assumed in mergers that are outstanding.
Other information required by Item 12 is incorporated by reference from the Company’sour Proxy Statement to be subsequently filed.

ITEM 13. CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS, AND DIRECTOR INDEPENDENCE

ITEM 13.CERTAIN RELATIONSHIPS AND RELATED TRANSACTIONS, AND DIRECTOR INDEPENDENCE
Incorporated by reference from the Companysour Proxy Statement to be subsequently filed.
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ITEM 14.PRINCIPAL ACCOUNTING FEES AND SERVICES
ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
ITEM 14. PRINCIPAL ACCOUNTANT FEES AND SERVICES
Incorporated by reference from the Companysour Proxy Statement to be subsequently filed.
PART IV
ITEM 15.EXHIBITS, FINANCIAL STATEMENT SCHEDULES
(a)(1)    Financial statements – The following consolidated financial statements of Zions Bancorporation and subsidiaries are filed as part of this Form 10-K under Item 8, Financial Statements and Supplementary Data:
ITEM 15. EXHIBITS AND FINANCIAL STATEMENT SCHEDULES
a.(1) Financial statements — The following consolidated financial statements of Zions Bancorporation, N.A. are filed as part of this Form 10-K under Item 8, Financial Statements and Supplementary Data:
Consolidated balance sheets December 31, 20172023 and 20162022
Consolidated statements of income Years ended December 31, 2017, 20162023, 2022, and 20152021
Consolidated statements of comprehensive income Years ended December 31, 2017, 20162023, 2022, and 20152021
Consolidated statements of changes in shareholders equity Years ended December 31, 2017, 20162023, 2022, and 20152021
Consolidated statements of cash flows Years ended December 31, 2017, 20162023, 2022, and 20152021
Notes to consolidated financial statements December 31, 20172023
(2) Financial statement schedules All financial statement schedules for which provision is made in the applicable accounting regulations of the Securities and Exchange CommissionSEC are not required under the related instructions, the required information is contained elsewhere in the Form 10-K, or the schedules are inapplicable and have therefore been omitted.
(3) List of Exhibits:
Exhibit NumberDescription
Exhibit NumberDescription
Second Amended and Restated Articles of IncorporationAssociation of Zions Bancorporation, dated July 8, 2014,National Association, incorporated by reference to Exhibit 3.1 of Form 8-K/A8-K filed on July 18, 2014.October 2, 2018.*
Second Amended and Restated Bylaws of Zions Bancorporation, dated February 27, 2015,National Association, incorporated by reference to Exhibit 3.2 of Form 8-K filed on April 4, 2019.*
Description of Securities of Zions Bancorporation, National Association, as of December 31, 2023 (filed herewith).
Zions Bancorporation 2021-2023 Value Sharing Plan, incorporated by reference to Exhibit 10.2 of Form 10-Q for the quarter ended March 31, 2015.June 30, 2022.*
Senior Debt Indenture dated September 10, 2002 between Zions Bancorporation and The Bank of New York Mellon Trust Company, N.A. as successor to J.P. Morgan Trust Company, N.A., as trustee, with respect to senior debt securities of Zions Bancorporation (filed herewith).
Subordinated Debt Indenture dated September 10, 2002 between Zions Bancorporation and The Bank of New York Mellon Trust Company, N.A. as successor to J.P. Morgan Trust Company, N.A., as trustee, with respect to subordinated debt securities of Zions Bancorporation (filed herewith).
Junior Subordinated Indenture dated August 21, 2002 between Zions Bancorporation and The Bank of New York Mellon Trust Company, N.A. as successor to J.P. Morgan Trust Company, N.A., as trustee, with respect to junior subordinated debentures of Zions Bancorporation (filed herewith).


Exhibit NumberDescription
Warrant to purchase up to 5,789,909 shares of Common Stock, issued on November 14, 2008, incorporated by reference to Exhibit 4.4 of Form 10-K for the year ended December 31, 2013.*
Warrant Agreement, between Zions Bancorporation and Zions First National Bank (now known as ZB, N.A.), and Warrant Certificate, incorporated by reference to Exhibit 4.5 of
Form 10-K for the year ended December 31, 2016.
*
Zions Bancorporation 2015-20172023-2025 Value Sharing Plan, incorporated by reference to Exhibit 10.1 of Form 10-Q for the quarter ended March 31, 2015.2023.*
Zions Bancorporation 2016-20182021-2023 Value Sharing Plan with conditional incentives, incorporated by reference to Exhibit 10.1 of Form 10-Q for the quarter ended September 30, 2016.*
Zions Bancorporation 2017-2019 Value Sharing Plan, incorporated by reference to Exhibit 10.2 of Form 10-Q for the quarter ended June 30, 2017.2022.*
Zions Bancorporation 2022-2024 Value Sharing Plan, incorporated by reference to Exhibit 10.4 of Form 10-Q for the quarter ended June 30, 2022.*
Zions Bancorporation 2017 Management Incentive Compensation Plan, incorporated by reference to Appendix I of the Company’sour Proxy Statement dated April 14, 2016.*
153


ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Exhibit NumberDescription
Zions Bancorporation Third Restated and Revised Deferred Compensation Plan, incorporated by reference to Exhibit 10.110.5 of Form 10-Q10-K for the quarteryear ended September 30, 2013.December 31, 2018.*
Zions Bancorporation Fourth Restated Deferred Compensation Plan for Directors, incorporated by reference to Exhibit 10.210.6 of Form 10-Q10-K for the quarteryear ended September 30, 2013.December 31, 2018.*
Amendment to the Zions Bancorporation Fourth Restated Deferred Compensation Plan for Directors, incorporated by reference to Exhibit 10.8 of Form 10-K for the year ended December 31, 2015.*
Amegy Bancorporation, Inc. Fifth Amended and Restated Amegy Bancorporation, Inc. Non-Employee Directors Deferred Fee Plan (Frozen upon merger with Zions Bancorporation in 2005), incorporated by reference to Exhibit 10.310.8 of Form 10-Q10-K for the quarteryear ended September 30, 2013.December 31, 2018.*
Zions Bancorporation First Restated Excess BenefitExecutive Management Pension Plan, incorporated by reference to Exhibit 10.8 of Form 10-K for the year ended December 31, 2014.2020.*
Zions Bancorporation First Restated Excess Benefit Plan, incorporated by reference to Exhibit 10.9 of Form 10-K for the year ended December 31, 2020.*
Amegy Bancorporation 2004 (formerly Southwest Bancorporation of Texas, Inc.) Omnibus Incentive Plan, incorporated by reference to Exhibit 10.38 of Form 10-K for the year ended December 31, 2015.*
Trust Agreement establishing the Zions Bancorporation Deferred Compensation Plan Trust by and between Zions Bancorporation and Cigna Bank & Trust Company, FSB effective October 1, 2002, incorporated by reference to Exhibit 10.910.12 of Form 10-K for the year ended December 31, 2012.2018.*
Amendment to the Trust Agreement Establishing the Zions Bancorporation Deferred Compensation Plans Trust, effective September 1, 2006, incorporated by reference to Exhibit 10.13 of Form 10-K for the year ended December 31, 2018.*
Amendment to the Trust Agreement establishing the Zions Bancorporation Deferred Compensation Plan Trust by and between Zions Bancorporation and Cigna Bank & Trust Company, FSB substituting Prudential Bank & Trust, FSB as the trustee, incorporated by reference to Exhibit 10.12 of Form 10-K for the year ended December 31, 2016.*
Amendment to Trust Agreement Establishing the Zions Bancorporation Deferred Compensation Plans Trust, effective September 1, 2006, incorporated by reference to Exhibit 10.11 of Form 10-K for the year ended December 31, 2012.*
Fifth Amendment to Trust Agreement between Fidelity Management Trust Company and Zions Bancorporation for the Deferred Compensation Plans, incorporated by reference to Exhibit 10.5 of Form 10-Q for the quarter September 30, 2013.*


Exhibit NumberDescription
Sixth Amendment to Trust Agreement between Fidelity Management Trust Company and Zions Bancorporation for the Deferred Compensation Plans, dated August 17, 2015, incorporated by reference to Exhibit 10.1 of Form 10-Q for the quarter September 30, 2015.*
Zions Bancorporation Deferred Compensation Plans Master Trust between Zions Bancorporation and Fidelity Management Trust Company, effective September 1, 2006, incorporated by reference to Exhibit 10.1210.15 of Form 10-K for the year ended December 31, 2012.2018.*
Revised schedule C to Zions Bancorporation Deferred Compensation Plans Master Trust between Zions Bancorporation and Fidelity Management Trust Company, effective September 13, 2006, incorporated by reference to Exhibit 10.1310.16 of Form 10-K for the year ended December 31, 2012.2018.*
Third Amendment to the Zions Bancorporation Deferred Compensation Plans Master Trust agreementAgreement between Zions Bancorporation and Fidelity Management Trust Company and Zions Bancorporation for the Deferred Compensation Plans, dated June 13, 2012, (filed herewith).
Zions Bancorporation Restated Pension Plan effective January 1, 2002, including amendments adopted through December 31, 2010, incorporated by reference to Exhibit 10.1910.17 of Form 10-K for the year ended December 31, 2016.2017.*
Fifth Amendment to the Trust Agreement between Fidelity Management Trust Company and Zions Bancorporation for the Deferred Compensation Plans, incorporated by reference to Exhibit 10.18 of Form 10-K for the year ended December 31, 2018.*
154


ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Exhibit NumberDescription
Sixth Amendment to the Trust Agreement between Fidelity Management Trust Company and Zions Bancorporation for the Deferred Compensation Plans, dated August 17, 2015, incorporated by reference to Exhibit 10.18 of Form 10-K for the year ended December 31, 2020.First amendment*
Seventh Amendment to the Trust Agreement between Fidelity Management Trust Company and Zions Bancorporation for the Deferred Compensation Plans, effective September 30, 2018, incorporated by reference to Exhibit 10.2 of Form 10-Q for the quarter ended September 30, 2018.*
Ninth Amendment to the Trust Agreement between Fidelity Management Trust Company and Zions Bancorporation for the Deferred Compensation Plans, effective April 1, 2022, incorporated by reference to Exhibit 10.1 of Form 10-Q for the quarter ended September 30, 2022.*
Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan, Restated and Amended effective January 1, 2007, incorporated by reference to Exhibit 10.3 of Form 10-Q for the quarter ended June 30, 2018.*
Second Amendment to the Zions Bancorporation PensionPayshelter 401(k) and Employee Stock Ownership Plan, dated December 31, 2018, effective January 1, 2019, incorporated by reference to Exhibit 10.27 of Form 10-K for the year ended December 31, 2018.*
Third Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan, dated June 28, 2013,27, 2019, effective September 30, 2018, incorporated by reference to Exhibit 10.1 of Form 10-Q for the quarter ended June 30, 2013.2019.*
Second amendmentFourth Amendment to the Zions Bancorporation PensionPayshelter 401(k) and Employee Stock Ownership Plan, dated July 17, 2017,September 11, 2020, effective January 1, 2020, incorporated by reference to Exhibit 10.1 of Form 10-Q for the quarter ended September 30, 2020.*
Fifth Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan, dated September 11, 2020, effective January 1, 2020, incorporated by reference to Exhibit 10.2 of Form 10-Q for the quarter ended September 30, 2020.*
Sixth Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan, dated September 11, 2020, effective October 1, 2020, incorporated by reference to Exhibit 10.3 of Form 10-Q for the quarter ended JuneSeptember 30, 2017.2020.*
Zions Bancorporation Executive Management Pension Plan, incorporated by reference to Exhibit 10.18 of Form 10-K for the year ended December 31, 2014.*
Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan, Restated and Amended effective January 1, 2002, including amendments adopted through December 31, 2010, incorporated by reference to Exhibit 10.22 of Form 10-K for the year ended December 31, 2016.*
First amendmentSeventh Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan, dated November 14, 2012,December 23, 2020, effective January 1, 2021, incorporated by reference to Exhibit 10.1810.32 of Form 10-K for the year ended December 31, 2012.2020.*
Second amendmentEighth Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan, dated August 19, 2016,December 20, 2022, effective January 1, 2023, incorporated by reference to Exhibit 10.110.30 of
Form 10-Q10-K for the quarteryear ended June 30, 2017.
December 31, 2022.
*
Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, dated July 3, 2006, incorporated by reference to Exhibit 10.1910.28 of Form 10-K for the year ended December 31, 2012.2018.*
First Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, dated April 5, 2010, incorporated by reference to Exhibit 10.25 of Form 10-K for the year ended December 31, 2015.*

155


ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Exhibit NumberDescription
Exhibit NumberDescription
Second Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, dated April 5, 2010, incorporated by reference to Exhibit 10.26 of Form 10-K for the year ended December 31, 2015.*
Third Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, dated April 30, 2010, incorporated by reference to Exhibit 10.27 of

Form 10-K for the year ended December 31, 2015.
*
Fourth Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, dated October 1, 2014, incorporated by reference to Exhibit 10.2510.37 of
Form 10-K for the year ended December 31, 2014.
2020.
*
Fifth Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, dated October 1, 2014, incorporated by reference to Exhibit 10.2610.38 of
Form 10-K for the year ended December 31, 2014.
2020.
*
Sixth Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, dated August 17, 2015, incorporated by reference to Exhibit 10.210.39 of
Form 10-Q10-K for the quarteryear ended September 30, 2015.
December 31, 2020.
*
Seventh Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, dated April 27, 2016, incorporated by reference to Exhibit 10.31 of

Form 10-K for the year ended December 31, 2016.
*
Eighth Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, effective September 30, 2018, incorporated by reference to Exhibit 10.3 of Form 10-Q for the quarter ended September 30, 2018.*
Ninth Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, effective October 27, 2020, incorporated by reference to Exhibit 10.1 of Form 10-Q for the quarter ended June 30, 2021.*
Tenth Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, effective October 1, 2019, incorporated by reference to Exhibit 10.5 of Form 10-Q for the quarter ended June 30, 2022.*
Eleventh Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, effective November 1, 2020, incorporated by reference to Exhibit 10.6 of Form 10-Q for the quarter ended June 30, 2022.*
Twelfth Amendment to the Zions Bancorporation Payshelter 401(k) and Employee Stock Ownership Plan Trust Agreement between Zions Bancorporation and Fidelity Management Trust Company, effective April 1, 2022, incorporated by reference to Exhibit 10.7 of Form 10-Q for the quarter ended June 30, 2022.*
Zions Bancorporation 2015 Omnibus Incentive Plan, incorporated by reference to Exhibit 4.110.42 of Form S-8 filed on July 1, 2015.10-K for the year ended December 31, 2020.*
156


ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Exhibit NumberDescription
Form of Standard Restricted Stock Award Agreement, Zions Bancorporation 2015 Omnibus Incentive Plan, incorporated by reference to Exhibit 4.3 of Form S-8 filed on July 1, 2015.*
Form of Standard Restricted Stock Unit Award Agreement, Zions Bancorporation 2015 Omnibus Incentive Plan, incorporated by reference to Exhibit 4.4 of Form S-8 filed on July 1, 2015.*
Form of Standard Stock Option Award Agreement, Zions Bancorporation 2015 Omnibus Incentive Plan, incorporated by reference to Exhibit 4.6 of Form S-8 filed on July 1, 2015.*
Form of Standard Directors Stock Award Agreement, Zions Bancorporation 2015 Omnibus Incentive Plan, incorporated by reference to Exhibit 4.7 of Form S-8 filed on July 1, 2015.*
Form of Restricted Stock Award Agreement subject to holding requirement, Zions Bancorporation 2015 Omnibus Incentive Plan, incorporated by reference to Exhibit 4.210.43 of Form S-8 filed on July 1, 2015.10-K for the year ended December 31, 2020.*
Form of Standard Restricted Stock Award Agreement, Zions Bancorporation 2015 Omnibus Incentive Plan, incorporated by reference to Exhibit 10.44 of Form 10-K for the year ended December 31, 2020.*
Form of Standard Restricted Stock Unit Award Agreement, Zions Bancorporation 2015 Omnibus Incentive Plan, incorporated by reference to Exhibit 10.45 of Form 10-K for the year ended December 31, 2020.*
Form of Restricted Stock Unit Agreement subject to holding requirement, Zions Bancorporation 2015 Omnibus Incentive Plan, incorporated by reference to Exhibit 4.5 of Form S-8 filed on July 1, 2015.*
Amegy Bancorporation 2004 (formerly Southwest Bancorporation of Texas, Inc.) Omnibus Incentive Plan, incorporated by reference to Exhibit 10.3810.46 of Form 10-K for the year ended December 31, 2015.2020.*


Form of Standard Stock Option Award Agreement, Zions Bancorporation 2015 Omnibus Incentive Plan, incorporated by reference to Exhibit 10.47 of Form 10-K for the year ended December 31, 2020.*
Form of Standard Directors Stock Award Agreement, Zions Bancorporation 2015 Omnibus Incentive Plan, incorporated by reference to Exhibit Number10.48 of Form 10-K for the year ended December 31, 2020.Description*
Zions Bancorporation 2022 Omnibus Incentive Plan, incorporated by reference to Appendix I of Schedule 14A, dated March 17, 2022.*
Form of Standard Restricted Stock Award Agreement, Zions Bancorporation 2022 Omnibus Incentive Plan, incorporated by reference to Exhibit 10.8 of Form 10-Q for the quarter ended June 30, 2022.*
Form of Restricted Stock Award Agreement subject to holding requirement, Zions Bancorporation 2022 Omnibus Incentive Plan, incorporated by reference to Exhibit 10.9 of Form 10-Q for the quarter ended June 30, 2022.*
Form of Standard Restricted Stock Unit Award Agreement, Zions Bancorporation 2022 Omnibus Incentive Plan, incorporated by reference to Exhibit 10.10 of Form 10-Q for the quarter ended June 30, 2022.*
Form of Restricted Stock Unit Award Agreement subject to holding requirement, Zions Bancorporation 2022 Omnibus Incentive Plan, incorporated by reference to Exhibit 10.11 of Form 10-Q for the quarter ended June 30, 2022.*
Form of Standard Stock Option Award Agreement, Zions Bancorporation 2022 Omnibus Incentive Plan, incorporated by reference to Exhibit 10.12 of Form 10-Q for the quarter ended June 30, 2022).*
Form of Standard Directors Stock Award Agreement, Zions Bancorporation 2022 Omnibus Incentive Plan, incorporated by reference to Exhibit 10.13 of Form 10-Q for the quarter ended June 30, 2022.*
Form of Change in Control Agreement between the CompanyBank and Certain Executive Officers, incorporated by reference to Exhibit 10.3710.49 of Form 10-K for the year ended December 31, 2012.2020.*
Addendum to Change in Control Agreement, incorporated by reference to Exhibit 10.38 of Form 10-K for the year ended December 31, 2014.*
Form of Change in Control Agreement between the CompanyBank and Dallas E. Haun, dated May 23, 2008, incorporated by reference to Exhibit 10.3910.50 of Form 10-K for the year ended December 31, 2014.2020.*
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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES
Exhibit NumberDescription
Ratios of Earnings to Fixed Charges and Earnings to Fixed Charges and Preferred Dividends (filed herewith).
List of Subsidiaries of Zions Bancorporation, National Association (filed herewith).
Consent of Independent Registered Public Accounting Firm (filed herewith).
Certification by Chief Executive Officer required by Rules 13a-15(f) and 15d-15(f) under the Securities Exchange Act of 1934 (filed herewith).
Certification by Chief Financial Officer required by Rules 13a-15(f) and 15d-15(f) under the Securities Exchange Act of 1934 (filed herewith).
Certification by Chief Executive Officer and Chief Financial Officer required by Sections 13(a) or 15(d), as applicable, of the Securities Exchange Act of 1934 (15 U.S.C. 78m) and 18 U.S.C. Section 1350 (furnished herewith).
101Recoupment policy of Zions Bancorporation, National Association (filed herewith).Interactive data files pursuant
101Pursuant to RuleRules 405 and 406 of Regulation S-T:S-T, the following information is formatted in inline XBRL: (i) the Consolidated Balance Sheets as of December 31, 20172023 and December 31, 2016,2022, (ii) the Consolidated Statements of Income for the years ended December 31, 2017,2023, December 31, 2016,2022, and December 31, 2015,2021, (iii) the Consolidated Statements of Comprehensive Income for the years ended December 31, 2017,2023, December 31, 2016,2022, and December 31, 2015,2021, (iv) the Consolidated Statements of Changes in Shareholders’ Equity for the years ended December 31, 2017,2023, December 31, 2016,2022, and December 31, 2015,2021, (v) the Consolidated Statements of Cash Flows for the years ended December 31, 2017,2023, December 31, 2016,2022, and December 31, 20152021, and (vi) the Notes to Consolidated Financial Statements (filed herewith).
104The cover page from this Form 10-K, formatted as Inline XBRL.

* Incorporated by reference

CertainPursuant to Item 601(b)(4)(iii)(A) of Regulation S-K, copies of certain instruments defining the rights of holders of long-term debt securities of the Registrant and its subsidiaries are omitted pursuant to Item 601(b)(4)(iii) of Regulation S-K. The Registrant hereby undertakesnot filed. We agree to furnish a copy thereof to the SEC and the OCC upon request, copies of any such instruments.request.
ITEM 16. FORM 10-K SUMMARY
Not applicable.

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ZIONS BANCORPORATION, NATIONAL ASSOCIATION AND SUBSIDIARIES



SIGNATURES

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

February 28, 201823, 2024    ZIONS BANCORPORATION,

NATIONAL ASSOCIATION
By
By/s/ Harris H. Simmons
HARRIS H. SIMMONS, Chairman

and Chief Executive Officer


Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following persons on behalf of the Registrant and in the capacities and on the date indicated.

February 23, 2024
February 28, 2018


/s/ Harris H. Simmons/s/ Paul E. Burdiss
HARRIS H. SIMMONS, Director, Chairman

and Chief Executive Officer

(Principal Executive Officer)
PAUL E. BURDISS, Executive Vice President

and Chief Financial Officer

(Principal Financial Officer)

/s/ R. Ryan Richards/s/ Maria Contreras-Sweet
/s/ Alexander J. Hume/s/ Jerry C. Atkin
ALEXANDER J. HUME,R. RYAN RICHARDS, Controller

(Principal Accounting Officer)
JERRY C. ATKIN,MARIA CONTRERAS-SWEET, Director

/s/ Gary L. Crittenden/s/ Suren K. Gupta
GARY L. CRITTENDEN, DirectorSUREN K. GUPTA, Director

/s/ J. David HeaneyClaire A. Huang/s/ Vivian S. Lee
J. DAVID HEANEY,CLAIRE A. HUANG, DirectorVIVIAN S. LEE, Director

/s/ Scott J. McLean
/s/ Edward F. Murphy/s/ Roger B. Porter
SCOTT J. MCLEAN, DirectorEDWARD F. MURPHY, DirectorROGER B. PORTER, Director


/s/ Stephen D. Quinn/s/ Aaron B. Skonnard
STEPHEN D. QUINN, DirectorAARON B. SKONNARD, Director
/s/ Barbara A. Yastine
STEPHEN D. QUINN, DirectorBARBARA A. YASTINE, Director





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