Political Contributions & Engagement

Statement of Political Activity

PNC’s business is subject to extensive laws and regulations at the federal, state, and local levels; and changes to such laws can significantly affect PNC and our employees, shareholders, communities and customers. We believe that active engagement in the political and public policy process to advance and protect our interests is an important part of responsible corporate citizenship.

Lobbying and Trade Associations

We disclose publicly all U.S. federal lobbying costs – those paid directly as well as through trade associations – and the issues to which our lobbying efforts relate, on a quarterly basis, pursuant to reports required by the Lobbying Disclosure Act. These disclosures can be viewed at https://lobbyingdisclosure.house.gov. We also disclose state and local lobbying costs where required by applicable law.

Other Contributions

On a limited basis, PNC may consider requests from organizations seeking support for ballot referendum committees and certain limited Section 527 political organizations, such as the Republican and Democratic Governors Associations. Note that referendum committees do not influence candidate elections but rather the passage of laws. The practice for support of ballot or levy issues is especially prevalent in Ohio and Michigan in our footprint. The renewal of a local school district operating levy, a levy benefitting a local park, or a levy benefitting a regional transit system are examples of these issues. PNC reviews these requests with input from Government Affairs, senior management, including our regional presidents, and our Corporate Ethics Office to determine if PNC should support the issue and whether it is legally permitted under applicable law. If we determine that a request is something that we will support and a corporate contribution to the issue is permissible under applicable law, PNC will make the contribution and comply with any law that requires PNC to disclose it. Please note that these contributions are required to be disclosed by the organization that receives them. Annually, PNC will also voluntarily disclose the use of company funds in support of ballot or levy issues or organizations formed under Section 527 of the Internal Revenue Code. For 2021, PNC used corporate funds in support of such organizations, as listed below.  Additionally, PNC may occasionally make contributions to groups organized under Section 501(c)(4) of the Internal Revenue Code.

2022 Other Contributions

Compliance and Oversight

All corporate political activities conducted by or on behalf of PNC are managed by our Government Affairs department, which reports to the General Counsel of PNC. Requests for contributions are evaluated and approved by Steering Committees composed of PNC officers. Prior to approval by a Steering Committee, contributions are also reviewed by the Corporate Ethics Office for compliance with applicable laws.

The Audit Committee of the Board of Directors reviews on an annual basis this Statement of Political Activity, major lobbying priorities, expenditures made in support of ballot or levy issues and other organizations formed under Section 527 of the Internal Revenue Code and the activities of and total dues paid to our principal national trade associations if they exceed $25,000. The non-management members of our Board of Directors reviews the contributions of our political action committees.