Charter of the USAA and USAA Federal Savings Bank Boards of Directors Finance and Audit Committees

I. SCOPE AND PURPOSE

The Finance and Audit Committees (together, “Committee,” unless usage or context dictates otherwise) are established by the Board of Directors of United Services Automobile Association (“USAA”) and by the Board of Directors (together with the USAA Board of Directors, “Board”) of USAA Federal Savings Bank (the “Bank,” and together with USAA, the “Company”) to support the Company’s mission, strategic plan, and long-term financial security.

With respect to the Company’s Audit function, financial statements, and accounting and reporting processes, the Committee will maintain oversight of: (i) the quality and integrity of the Company’s financial statements, and accounting and reporting processes; (ii) the independent external auditor’s qualifications, independence, and performance; (iii) the USAA Chief Audit Executive, the Bank Chief Audit Executive (together with the USAA Chief Audit Executive, the “Chief Audit Executives”), the USAA Audit Services Department and the Bank Audit Services Department (together, “Audit Services”), including responsibilities, performance, independence, and stature; (iv) compliance with applicable legal and regulatory requirements, as appropriate; and (v) the adequacy and effectiveness of the Company’s internal controls over financial reporting. Solely for purposes of the Audit Rule adopted by the Texas Department of Insurance, the Committee will also be deemed to be the Audit Committee for USAA’s directly or indirectly owned affiliates that are insurers who do not have an independent board audit committee.

With respect to the financial performance and operations of the Company, the Committee will maintain oversight of the Company’s: (i) capital adequacy and planning, (ii) investment portfolios, (iii) corporate financial performance, (iv) liquidity management, (v) balance sheet including asset and liability management (“ALM”), and (vi) potential strategic and other material transactions (“Transactions”).

Notwithstanding anything otherwise contained in this Charter, responsibility for oversight of USAA’s Risk Management Framework, the Bank’s Risk Governance Framework, and any risk oversight matters inherent in capital, liquidity, investment performance or stress testing activities shall remain with the Risk Committee of the Board. The Committee will discuss pertinent activities within its scope with the Risk Committee, as appropriate, to facilitate the Committee’s consideration of the impact these activities may have on the Company’s Risk Management program.

II. RESPONSIBILITIES

The Committee shall have the following responsibilities:

A. Financial Statements

1. Review and discuss with management and the independent external auditor the annual audited USAA consolidated financial statements prepared in accordance with U.S. Generally Accepted Accounting Principles (“GAAP”), the insurance entity financial statements prepared in accordance with Statutory Accounting Principles, the annual audited Bank consolidated financial statements prepared in accordance with GAAP and the independent external auditor’s reports related to the financial statements, including reviewing with management and the independent external auditor the basis for their reports issued under 12 CFR Part 363.
2. Review quarterly USAA and Bank Consolidated GAAP financial statements and analysis and quarterly insurance entity Statutory analysis and summary financials.
3. Review and approve significant Company accounting policies and practices, and any changes thereto.
4. Review significant issues as to design or operating effectiveness of the Company’s internal controls over financial reporting and oversee any specific remedial actions taken in response to any significant deficiencies or material weaknesses.
5. Review the asset/liability valuation methods used by the Company’s management.
6. Review material changes to the Company’s tax position, tax risks and impacts of pending or proposed tax legislation.
7. Review legal and regulatory matters that may have a material impact on the financial statements, including matters regarding compliance with designated laws and regulations with respect to the Bank (as designated in 12 CFR Part 363 and the Guidelines and Interpretations thereto).
8. Review the Property & Casualty loss and Loss Adjustment Expense Reserves methodology and sufficiency.

B. Independent External Auditors

1. Review and approve the annual audit scope and plan for the Company prepared by the independent external auditors, and any changes thereto, and understand completeness, the effective use of audit resources, objectivity, and general audit approach.
2. The Committee shall be directly responsible for the appointment, compensation, retention, and oversight of the work performed by the independent external auditor to prepare or issue an audit report or perform other audit, review or attest services for the Company. The independent external auditor shall report directly to the Committee.
   
   1. Review annually the qualifications, performance, and independence of the independent external auditor, including (i) the review of the lead audit partner, taking into account the opinions of management and Audit Services, and (ii) compliance with the required qualifications for independent external auditors set forth in 12 CFR §§ 363.3(f) and (g) and Guidelines 13 through 16 (or successor regulations).
   2. At least annually, obtain and review a report by the independent external auditor describing, to the extent permitted under applicable auditing standards, (i) the independent external auditor’s internal quality-control procedures, (ii) any material issues raised by the most recent quality-control review, or peer review, of the independent external auditor, or by any inquiry or investigation by governmental or professional authorities, including the Public Company Accounting Oversight Board, within the preceding five years, with respect to one or more audits carried out by the independent external auditor, and any steps taken to deal with any such issues, and (iii) all relationships between the independent external auditor and the Company to assess auditor independence and discuss with the independent external auditor the potential effects of any such relationships on independence.
   3. Determine whether the independent external auditor has a process in place to address the rotation of the lead audit partner and other audit partners serving the account as required under applicable regulatory auditor independence rules.
3. At least annually, review and pre-approve all proposed audit and permissible non-audit services (utilizing the bucket or category approach) to be provided by the independent external auditor, including the related fees, terms, and conditions. The Committee shall not engage the independent external auditor to perform non-audit services prohibited by applicable law or regulation. The Committee shall ensure that audit engagement letters comply with the provisions of 12 CFR § 363.5(c) (or successor regulations) before engaging the independent external auditor. The Committee delegates to its Chair the authority to pre-approve audit or permissible non-audit services not originally pre-approved via the bucket or category approach that must be commenced before the next regularly scheduled Committee meeting and to inform the Committee thereof at or before the next scheduled meeting.
4. Review and discuss with the independent external auditor matters related to the audit of the Company’s financial statements which are to be communicated to the Committee under generally accepted auditing standards, including: the auditor’s judgment about the quality of the Company’s accounting principles as applied in its financial reporting, such as the clarity of the Company’s financial disclosures and consistency of the Company’s accounting principles and underlying estimates and other significant decisions made by management in preparing the financial disclosures. The independent external auditor should review with the Committee the Company’s critical accounting policies and practices, including material permitted practices, corrected and uncorrected audit differences, and alternative accounting treatment related to material items discussed with management. The independent external auditor also should disclose to the Committee other material communications with management or regulators related to accounting or auditing matters.
5. Resolve any disagreements between management and the independent external auditor.
6. Review at least annually with senior management and the independent external auditor the adequacy and operating effectiveness of the Company’s internal controls over financial reporting.
7. Receive reports at least annually regarding the types of non-audit services (and the fees for such services) provided by the independent external auditor to the Company as applicable.
8. Meet regularly with the independent external auditor and senior management in separate executive sessions to discuss any matters that the Committee or these groups believe should be discussed privately with the Committee.
9. Periodically review the Company’s procedures for hiring of employees or former employees of the independent external auditor.

C. Audit Services Department

1. At least annually, review and approve the Audit Services Charters and mandates, including any significant changes.
2. At least annually, review and approve the risk-based audit plans and general risk assessment methodology. Periodically review audit plan completion status and ratify significant changes to the audit plans.
3. At least annually, review and approve the Audit Services’ budgets and staffing levels and skills. Review and approve any significant interim changes to Audit Services’ budgets and staffing levels made during the year.
4. Review and approve any significant aspects of Audit Services’ outsourcing arrangements with a third party and retain oversight responsibility for any aspects of the internal audit function that are outsourced to a third party.
5. Periodically review any significant aspects of Audit Services’ co-sourcing arrangements with third parties.
6. Review, at least annually, the activities, organizational structures, qualifications, and independence of Audit Services using industry standards such as the Global Internal Audit Standards as promulgated by the Institute of Internal Auditors and any applicable regulatory guidance.
7. Consider and review with the Chief Audit Executives, as appropriate:
   
   1. Significant findings identified by Audit Services, including areas of concern in internal controls, past due and repeat issues, root cause themes, and thematic historical trends and management's responses thereto, along with timeliness of remediation.
   2. Any significant difficulties encountered during Audit Services audits, including any scope limitations or interference that impacted the work or restricted access to required information.
   3. Information on i) significant current and industry internal audit practices, ii) significant industry and Company trends in risks and controls, and iii) major Company projects.
   4. Significant changes in Audit Services processes.
8. Consider and review with the Chief Audit Executives and senior management, as appropriate, Audit Services’ assessment and opinion on the effectiveness, efficiency and adequacy of front-line units, risk management, internal controls, and governance processes, including the effectiveness of management’s self-assessment and remediation of identified issues; review significant instances where first line and independent risk management are not adhering to the Bank’s Risk Governance Framework; and elicit any recommendations for the improvement of such processes.
9. Provide the Chief Audit Executives with unrestricted access to the Committee and meet regularly with each Chief Audit Executive in separate executive sessions, as appropriate, to discuss any matters that the Committee or either Chief Audit Executive believe should be discussed privately.
10. Review the qualifications of and approve the appointment and removal of the Chief Audit Executives, who shall report functionally to the Committee and administratively to the USAA Chief Executive Officer and the Bank President, respectively.
11. Review and approve Chief Audit Executives’ roles and responsibilities beyond the scope of internal auditing. Acknowledge the actual or potential impairments to independence when such roles or responsibilities are approved and engage with senior management and the Chief Audit Executives to establish appropriate safeguards.
12. Annually review and approve succession plans for the Chief Audit Executives.
13. Annually review the Audit Services strategy for alignment with the Company’s strategy and the expectations of senior management and the Board.
14. At least annually review and approve clear nonfinancial goals and performance objectives as outlined in the Audit Services Charters for the Chief Audit Executives that are consistent with the Company’s strategy, financial objectives, risk appetite and culture, and risk management practices and the Audit Services Department Charters.
15. Annually review the performance of and approve the compensation for the Chief Audit Executives.
16. Review the results and status of activities of the internal quality assurance and improvement program at least annually. Review and approve the USAA Chief Audit Executive’s plan for the performance of an external quality assessment at least once every five years. Require receipt of the assessment results directly from the assessor and review the Chief Audit Executives’ plans to address any deficiencies and opportunities for improvement, if applicable.
17. Provide functional oversight of the credit risk review function for the Bank, including annually reviewing and approving the credit risk review function’s budget and business plan and the Bank’s Credit Risk Review Policy. Provide the Credit Risk Review Executive with unrestricted access to the Committee in separate executive sessions, as appropriate, to discuss any matters that the Committee or the Credit Risk Review Executive believe should be discussed privately. The Committee shall also review periodic reporting on credit risk review results.

D. Capital Adequacy and Planning

1. Annually review and approve the USAA and Bank Capital Policies.
2. Review and assess the sufficiency of the capital adequacy management program and appropriateness for the Company’s overall size, complexity, and risk profile.
3. Jointly with the Risk Committee, approve the annual USAA Consolidated and Bank Capital Plans, which include capital targets that reflect the potential impact of legal and/or regulatory restrictions and capital transactions.
4. Review capital adequacy reporting at least quarterly, including current capital levels and risks, with consideration of planned capital contributions and distributions.
5. Oversee efforts to restore capital above the identified risk appetite by following the established USAA and/or Bank Capital Contingency Plans.
6. Jointly with the Risk Committee, annually review and approve the USAA-wide and Bank stress testing results that are included in the respective Capital Plans, and any remediation or recovery planning efforts which result from such stress testing.

E. Liquidity Management

1. Annually review and approve the USAA and Bank Liquidity Management Policies and the USAA Consolidated and Bank Contingency Funding Plans in coordination with review and approval of the USAA and Bank Liquidity Management Policies and Consolidated and Bank Contingency Funding Plans by the Risk Committee.
2. Jointly with the Risk Committee, annually review USAA-wide and Bank liquidity stress testing results for inclusion in the contingency funding plans, and any remediation or recovery planning efforts which result from such stress testing.
3. Review and assess the sufficiency of liquidity and the liquidity management program (including stress and fungibility) and appropriateness for the Company’s overall size, complexity, and risk profile.
4. Review quarterly liquidity reporting and stress test results to evaluate adequacy of liquidity for current and projected cash flow needs, and for consistency with established risk tolerances.
5. Oversee efforts to restore liquidity above the identified risk appetite by following the established Consolidated and/or Bank Contingency Funding Plan.

F. Company Balance Sheet

1. Review reports at least quarterly pertaining to the Company’s ALM or interest rate risk and capital markets activities, including related reports pertaining to risk tolerances for such activities.
2. Annually review and approve the Derivative Use Plan of USAA.

G. Investment Portfolio Oversight

1. Review periodic reports pertaining to investment portfolio objectives, overall investment strategies, and portfolio performance against approved benchmarks and established risk tolerances.
2. Annually review and approve the P&C and Bank Investment Policies and Strategic Asset Allocation (minimum and maximum).
3. Review reports pertaining to the Bank’s adherence to external regulatory and contractual requirements, including the Qualified Thrift Lender test.

H. Corporate Financial Performance

1. Review management reports pertaining to the Company’s financial performance including its consolidated balance sheet and income statement and evaluate corporate performance.
2. Review Rating Agency results and remediation plans as necessary.
3. Review and make recommendations pertaining to Subscriber’s Account (“SA”) allocations, P&C policyholder dividends, SA distributions (including December discretionary, terminations, and Senior Bonus distributions) and Bank dividends.
4. As needed, review significant budget variances, and all significant strategic Company project expenditures for alignment with the Company’s strategic priorities and for effective implementation.

I. Monitoring and Internal Reporting

1. Receive and discuss reports from management concerning the status of significant financial examinations by regulatory authorities.
2. Receive and discuss reports from management concerning significant operating and control issues identified in independent external audit or Audit Services reports, management letters, significant regulatory authorities' examination reports and investigations, and the status of significant special investigations, if any.
3. Approve and oversee procedures for receipt, retention, and treatment of complaints received by the Company regarding accounting, internal accounting controls, or auditing matters and for confidential, anonymous submission by employees of concerns regarding questionable accounting, internal accounting controls, or auditing matters and periodically review and approve any updates, as needed, to the Notification Procedure For Complaints Alleging Senior Management Misconduct and the Guidelines for Conducting Board Directed Internal Investigations.
4. Receive reports promptly from the Board Chairman, Committee Chair, Chief Executive Officer, and/or Chief Legal Officer concerning material complaints of deficiencies regarding accounting, internal controls or auditing matters, including the status and results of any investigation and the disciplinary or other corrective action taken in response. If “other than material” complaints of accounting, internal controls, or auditing matters have been made, written reports summarizing the status or resolution of such complaints will be received by the Committee in connection with each regularly scheduled meeting until such complaint is reported resolved.
5. Receive reports promptly from the Chief Ethics Officer, Chief Compliance and Operational Risk Officer, Chief Risk Officer, and Chief Legal Officer, as appropriate, concerning complaints of criminal misconduct or potential criminal misconduct.
6. Regularly receive reports from the Chief Ethics Officer and the Chief Compliance and Operational Risk Officer concerning USAA’s ethics program, including information on case management, indicative trends and any related investigations.

J. Transactions

1. Review and provide oversight on proposals or indications of interest for Transactions proposed by management to be sent to a third party and make a recommendation to the Board as to whether the final terms and associated materials of such proposals should be approved by the Board (except in instances where a different Board committee is overseeing a proposed Transaction).
2. Maintain post-closing oversight of Transactions, as needed.

K. Fiduciary Audit Committee

1. As necessary, serve as the fiduciary audit committee for the Bank and oversee the audit of the Bank’s fiduciary activities to the extent required under 12 CFR § 150.470.

L. Committee Performance

1. Annually review and assess the Committee's performance and provide the results to the Board.
2. Annually review the Committee charter and recommend any necessary changes for approval by the Board.
3. As necessary, recommend, execute, and oversee investigations into any matters under the Committee's purview.

M. Other

1. Periodically review the adequacy of the staffing level and talent, skills, and allocation of resources supporting the Company’s finance functions.
2. The Committee shall perform such other duties as may be delegated to it from time to time by the Board.
3. The Committee may delegate its authority to subcommittees, which shall report regularly to the Committee.

III. DURATION

The Committee shall continue in existence until dissolved by the Board.

IV. COMMITTEE CHAIR

The Chair of the Committee and if the Committee so decides, the Vice Chair of the Committee shall be elected by the Board at least annually or as necessary with due consideration given to nominee(s) recommended by the Nominating and Governance Committee. In the event of the death, disability or other incapacity that prevents the Committee Chair from properly performing their duties, the duties of the Committee Chair shall pass to the Committee Vice Chair or in the absence of a Vice Chair, a Committee member designated by the Committee, until a new Committee Chair is elected as provided for herein.

V. COMMITTEE MEMBERSHIP

The Committee shall consist of at least three members, including the Chair. All members shall satisfy the requirements of 12 CFR Part 30, Appendix D, Section III.D.1-3 and qualify as “independent” under Rule 303A.02 of the New York Stock Exchange (or any successor rules). The membership of the Committee shall be through appointment by the Board on consideration of nominee(s) recommended by the Nominating and Governance Committee. The Board shall have the authority to fill any vacancies and to remove any Committee member for any reason.

Each member shall have demonstrated financial literacy through the ability to read and understand financial statements, financial management concepts, and audit principles, and at least two members of the Bank Committee shall have banking or related financial management expertise as required by section 36(g)(1)(C)(i) of the Federal Deposit Insurance Act. A person will be considered to have such required expertise if the person has significant executive, professional, educational, or regulatory experience in financial, auditing, accounting, or banking matters as determined by the Board. Significant experience as an officer or member of the board of directors or audit committee of a financial services company would satisfy these criteria. A person who has the attributes of an “audit committee financial expert” as set forth in the Securities and Exchange Commission rules would also satisfy these criteria. Each Committee member will execute a “Certification Regarding Qualifications” to identify Committee members that possess the required qualifications.

No Bank Committee member shall be a “large customer” of the Bank, as defined in 12 CFR § 363.5(b) and Guideline 33 of Appendix A to Part 363.Each member must disclose annually whether he or she serves on three or more audit committees of other companies. If a member certifies that this is so, the remaining members of the Committee will determine whether it believes that simultaneous service by such member would impair the member’s ability to fulfill his or her responsibilities as a member of the Committee.

No less than annually, the Board shall assess Committee members’ independence and determine if they meet applicable requirements.

VI. OUTSIDE CONSULTANTS

The Committee shall have the sole authority, without further approval by the Board, to select, retain, and terminate such outside consultants, including legal counsel, as it determines appropriate to assist it in the performance of its functions, to conduct investigations in accordance with the law, or to advise or inform the Committee. The Committee shall be able to approve, without further approval by the Board, any compensation payable by the Company to such consultant, including the fees, terms, and other conditions for the performance of such services.

The Committee may consult with internal or outside counsel, if, in the opinion of the Committee, any matter under consideration by the Committee has the potential for any conflict between the interests of USAA and those of the Bank in order to ensure that appropriate procedures are established for addressing any such potential conflict.

VII. MEETINGS

The Committee shall meet at such times and shall conduct such business as required to fulfill its responsibilities under this Charter, with at least four regular meetings per year. Agendas and materials will be provided to Committee members in advance of any regular meetings. Special meetings may be held as called by the Committee Chair in consultation with the Chairman.

A majority of the members of the Committee shall constitute a quorum and the affirmative vote of a majority of the members of the Committee participating in any meeting of the Committee is necessary for the approval of any Committee business. The Committee may also act by unanimous written consent. Meetings by telephonic or video conference call are authorized, and actions taken during such meetings shall have the same force and effect as actions taken at an in-person meeting.

The Committee may hold separate sessions as the USAA Committee or the Bank Committee if necessary to address issues relevant to one entity but not the other, or to consider transactions between the two entities or other matters where USAA and the Bank may have different interests.

Meetings are to be attended only by members of the Committee, the appointed recorder, designated management, and guests approved by the Committee Chair.

The Committee or any member of the Committee has the authority to contact the independent external auditor, the USAA Chief Financial Officer, the Bank Senior Financial Officer or either of the Chief Audit Executives directly. The independent external auditor, the USAA Chief Financial Officer, the Bank Senior Financial Officer, or either of the Chief Audit Executives have the right to contact the Committee Chair or any member of the Committee if warranted.

VIII. MINUTES AND REPORTS

The Corporate Secretary, in collaboration with the Committee Chair, shall designate a person to record the proceedings of the Committee's meetings. The records of the Committee meetings shall be confidential and retained in accordance with USAA's records retention schedule.

The Committee Chair may authorize the creation and distribution of reports or position papers as appropriate. The Committee shall make regular reports to the Board regarding its deliberations and actions and to make recommendations to the Board.

IX. EFFECTIVE DATE

This charter was approved by the Board on August 20, 2026, to be effective August 31, 2026, and shall govern the operation of the Committee thereafter.