United States securities and exchange commission logo
April 17, 2024
Michael B. Maguire
Chief Financial Officer
Truist Financial Corporation
214 North Tryon Street
Charlotte, NC 28202
Re: Truist Financial
Corporation
Form 10-K for the
Fiscal Year Ended December 31, 2023
File No. 001-10853
Dear Michael B. Maguire:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Lending Activities, page 57
1. We note your disclosure
that your loan portfolio is diverse in terms of loan type, industry
and geographic
concentrations. We further note the tabular disclosure on page 58 detailing
the composition of your
gross loan portfolio, which includes commercial and industrial
loans. Given the
significance of commercial and industrial loans in your total loan
portfolio, please
revise your disclosures, in future filings, to further disaggregate the
composition of your
commercial and industrial loan portfolio by separately presenting by
geographic and industry
concentrations which may be material to an investor s
understanding of these
portfolio types. We note Item 303 of Regulation S-K.
Item 7A. Quantitative and Qualitative Disclosures About Market Risk
Interest Rate Market Risk, page 70
2. We note your disclosure
discussing various key assumptions associated with your interest
sensitivity simulation
analysis. For example, we note that key assumptions, such as
Michael B. Maguire
Truist Financial Corporation
April 17, 2024
Page 2
prepayments and deposit pricing (betas), largely move in line with
those it has
experienced in prior rate cycles. You further state that estimated
changes to net interest
income in your analysis assumes no change in deposit balances or mix
relative to the
baseline scenario. In order to provide more usefulness to the
disclosures, please revise in
future filings to more fully discuss how you monitor and perform
sensitivity tests of
deposit and other key assumptions used in interest rate risk,
including, but not limited to
future balance sheet composition; loan and deposit pricing;
assumptions related to the
magnitude of asset prepayments; earlier than anticipated deposit
withdrawals; and impacts
from derivatives, to the extent applicable. In addition, please
provide a discussion of how
any assumptions have changed from period to period, including any
changes to the data
source used or significant changes in the assumption itself, and the
impact on your
modeling and results as presented in your interest sensitivity
simulation analysis, etc.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact Jee Yeon Ahn at 202-551-3673 or John P. Nolan at
202-551-3492 with
any questions.
FirstName LastNameMichael B. Maguire Sincerely,
Comapany NameTruist Financial Corporation
Division of
Corporation Finance
April 17, 2024 Page 2 Office of Finance
FirstName LastName