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December 26, 2023
Robert Reilly
Chief Financial Officer
PNC Financial Services Group, Inc.
The Tower at PNC Plaza, 300 Fifth Avenue
Pittsburgh, Pennsylvania 15222-2401
Re:PNC Financial Services Group, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
File No. 001-09718
Dear Robert Reilly:
            We have reviewed your filing 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, 2022
Item 7 - Management's Discussion and Analysis of Financial Condition and results of Operations
Funding Sources, page 47
1.We note your disclosure regarding the composition and change in your deposits. In future
filings, please revise to disclose:
•quantitative and qualitative detail regarding any brokered deposits outstanding at
each period date, as well as any related trends or impacts regarding the usage of
brokered deposits; and
•if applicable, whether you have policies or internal limits regarding concentrations in
uninsured and / or brokered deposits, in total or by type of depositor, and whether you
have complied with any such internal requirements for the periods presented.
Loan Portfolio Characteristics and Analysis, page 60
2.Please revise future filings to expand the discussion of the commercial real estate
portfolio to provide further disaggregation by owner and non-owner occupied and
characteristics, such as loan-to-value ratios, where material.

 FirstName LastNameRobert  Reilly
 Comapany NamePNC Financial Services Group, Inc.
 December 26, 2023 Page 2
 FirstName LastNameRobert  Reilly
PNC Financial Services Group, Inc.
December 26, 2023
Page 2
Liquidity and Capital Management, page 70
3.We note your liquidity and capital management disclosures regarding management
oversight and monitoring of liquidity, which includes reference to certain established
limits. In future filings, please address the items below.
•Expand your discussion of liquidity policy guidelines and provide examples of
specific metrics used to manage liquidity, including whether you have been in
compliance with internal guidelines and liquidity related limits for periods covered in
each filing and, if not, planned actions to remediate non-compliance.
•Consider expanding discussion of your contingency funding plan to describe actions
that would be taken to address liquidity risk during a stress event, such as balance
sheet repositioning, capital raises, promotional efforts for deposits, increased usage of
brokered deposits, etc., as applicable.
•When there have been changes in deposit composition (such as a shift between non-
interest-bearing and interest-bearing deposit levels) or the level of reliance on
different funding sources (such as a heavier reliance on Federal Home Loan Bank
borrowings), expand your disclosures to discuss and quantify the impact these
changes have had on liquidity and funding costs.
4.Please disclose a table summarizing your total available sources of liquidity, by type of
borrowing capacity, showing total borrowing capacity less borrowings outstanding to
arrive at remaining capacity, then adding in other sources of liquidity such as cash,
securities, etc. to arrive at total available liquidity, or tell us where this information is
disclosed in the aggregate.
Market Risk Management - Interest Rate Risk, page 76
5.Please expand your disclosures, in future filings, to include a discussion of your deposit
beta and/or cumulative deposit beta to the extent that it is monitored and used by
management. In this regard, we note that you appear to include a slide addressing
cumulative deposit in your earnings call presentation slides (e.g., slide 5 of the October
13, 2023 Form 8-K). In addition, include a discussion of how the metric is used, how it
has changed from period to period and how it is calculated.
6.We note your disclosure regarding interest rate sensitivity analysis. In future filings,
please enhance your disclosure to address the items below.
•Discuss key assumptions including, as applicable, 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.
•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 actual
assumption itself due to, and for example, internal data, market conditions or
significant changes in the judgments and determinations made by management as you
refine your modeling over time.
•To the extent that your ALCO or management receives information and uses any

 FirstName LastNameRobert  Reilly
 Comapany NamePNC Financial Services Group, Inc.
 December 26, 2023 Page 3
 FirstName LastName
Robert  Reilly
PNC Financial Services Group, Inc.
December 26, 2023
Page 3
other metrics, such as economic value of equity ("EVE"), for purposes of managing
or monitoring interest rate risk, consider expanding your disclosure to include
discussion of those other metrics and how they are used by management.
•To the extent that your ALCO or management receives information with interest rate
shocks (parallel changes) greater than your disclosed 100 basis point shifts, consider
expanding your sensitivity disclosures to also include those wider ranges.
            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 Cara Lubit at 202-551-5909 or Robert Klein at 202-551-3847 if you have
questions regarding comments on the financial statements and related matters. Please contact
Susan Block at 202-551-3210 or James Lopez at 202-551-3536 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance