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Bank of America

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FY2018 Annual Report · Bank of America
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What would you like 
the power to do?

2018 Annual Report

CONTENTS

A letter from 
Chairman and CEO
Brian Moynihan

1–9

A message from 
Lead Independent Director
Jack Bovender

8

What would you like 
the power to do?

10–11

Financing a sustainable world: 
A message from Vice Chairman 
Anne Finucane

22–23

Improving lives 
through community 
development

24–25

Driving economic mobility 
and social progress

26–27

Transforming financial services with 
high-tech and high-touch solutions

Sharing our success —
ESG highlights

12–13

28

Q&A with Dean Athanasia, President 
of Consumer and Small Business

Being a great place to work —
2018 highlights

14–15

Delivering tailored 
wealth management 
solutions for every 
stage in life

16–18

Supporting companies as 
they grow, innovate and lead

19–21

29

We ask our teammates, too: 
A message from 
Chief Human Resources Officer 
Sheri Bronstein

30–31

Financial 
highlights

32

A letter from Chairman and CEO Brian Moynihan

Dear shareholders,

I am pleased to report to you that by adhering to Responsible Growth, the 
200,000-strong team at Bank of America produced record earnings in 2018 of 
$28.1 billion, or $2.61 per share. We did this by living our purpose, which is to 
help make our clients’ financial lives better through the power of every connection 
we can make — both for them and with them. Even as we continue to provide 
capital to our customers and clients, invest heavily in our company, and deploy 
capital to address some of the world’s toughest priorities, we were able to return 
nearly $26 billion in capital to our shareholders, including more than $5 billion in 
dividends and more than $20 billion in share repurchases. We continue to make 
progress to undo the dilution from the shares we issued due to the economic crisis 
of 2008-2009 and subsequent regulatory changes. Our capital, liquidity and capa-
city to serve clients are at record levels, and we have reduced the total number of 
fully diluted shares outstanding to below 10 billion. Over a three-year period, total 
shareholder return increased by more than 50 percent, outpacing the S&P 500  
and exceeding the average of our U.S. large cap peers by more than three times.

Our culture of careful expense management has resulted 
in a $30 billion reduction in our expense base since 2010. 
We achieved this even as we generated greater customer 
activity and revenue, addressed industrywide inflation  
and cost challenges, and invested consistently. Positive oper-
ating leverage — meaning the change in revenue outpacing 
the change in expenses — has resulted in an efficiency ratio 
of 58.5 percent for 2018, transforming Bank of America  
into one of the most efficient firms in our industry. 

Backdrop for 2019
The U.S. economy remains resilient and is growing. We are 
proud of our Bank of America Research team, which has been 
ranked as the best in the world for six of the last eight years. 
As I write this letter in late February 2019, those experts see 
the U.S. GDP growing 2.2 percent this year, and the world 
economy growing 3.4 percent. The U.S. consumer is solid: 
We observed 9 percent growth in 2018 over 2017 in our U.S. 
customer spending and money movement through Bank of 
America channels. Business and consumer confidence also 
remain solid. We see good opportunities ahead as we deepen 
our relationships, and add new ones, in each of our businesses. 

Driving Responsible Growth
Our commitment to Responsible Growth is resolute. In  
previous letters, we have discussed this framework. 
Responsible Growth has four tenets: We have to grow — no 
excuses. We have to grow by delivering more for our 
customers and clients. We have to grow by managing risk well. 
And, our growth must be sustainable. Sustainable means  
we have to share our success with our communities, we have 

53.8%

Total Shareholder Return¹

30.4%

17.4%

Rolling 3-year

  Bank of America
  U.S. Large Cap Peer Avg.
  S&P 500

1  Total shareholder return includes stock price appreciation and dividends paid. 
Peer bank average includes C, JPM, MS, GS and WFC.

to be a great place to work for our teammates, and we have 
to drive operational excellence. This creates the ability to 
reinvest the savings back into our team, our capabilities, our 
client experience, and our communities and shareholders. 

I’ll review our company’s performance in 2018 by discussing 
each of these tenets of Responsible Growth in more detail. 
By following them, we have kept credit costs at decade-lows 
and have driven positive operating leverage each consecu-
tive quarter for four years running. For the year, we were  
the world’s third most valuable financial services company 
(as measured by market capitalization) and among the world’s 
top 10 most profitable companies. Our fourth-quarter 2018 
earnings were the most among all U.S. global banks. 

BANK OF AMERICA 2018 | 1

BRIAN MOYNIHAN
Chairman and CEO

External recognition
Being one of the most profitable and efficient banks 
makes it possible for us to invest in award-winning capa-
bilities, people and products to serve our customers and 
clients well. In 2018, we received top recognition as a 
company, including being named “World’s Best Bank” by 
Euromoney, an authoritative industry publication. We 
also were recognized for our employment practices and 
commitment to being a great place to work, our customer 
service, our mobile and digital capabilities, and for other 
products and services in every major category. In February 
2019, we were ranked as one of the “100 Best Companies 
to Work For” by Fortune magazine and the global research 
and consulting firm Great Place to Work®. Bank of America 
also was recognized as the only financial services company 
on Fortune’s inaugural “Best Big Companies to Work For” 
list, which comprises seven companies with more than 
100,000 U.S.-based employees.

What would you like the power to do? 
Listening to how customers, our employees and our share-
holders answer the question “What would you like the power 
to do?” is how we learn what matters most to them. By asking, 
we start a conversation centered on our commitment to serve 
by bringing our capabilities to help clients be successful. 

We ask this question of our customers, in the communities 
we serve, and of our employees. Responsible Growth guides 
us in living our purpose to help make financial lives better, 
and to achieve strong operating results the right way. The 
three-year company strategy that our board of directors 
reviews and approves each fall is based on continuing to 
adhere to this approach.

What are we asking our clients with our straightforward 
question? It’s your financial life; it’s your decision. We will bring 
capabilities that are second to none to help you be successful. 

2 |   BANK OF AMERICA 2018

We will connect our capabilities for clients as no other finan-
cial services company can. Simply put: We are here to serve.

In 2018, we refined our company’s brand and logo to better 
reflect our work and progress over many years. Over time, 
these will continue to evolve to better visualize the way 
we run our company today. We’ll continue to serve by 
deepening our relationships, helping each individual, each 
business and each investor through the power of every 
connection we can help them make. That is our purpose, and 
it is how we want everyone — employees, the communities 
we serve, clients and investors — to see us. 

Grow. No excuses.
The first tenet of Responsible Growth is that we have to grow, 
no excuses. As you can see on page 4, each of our businesses 
grew, thereby contributing to our record earnings in 2018. 

Over the last four years, deposits have grown 4 percent 
and loans across all our business segments have grown 
6 percent on average. For 2018, deposit and loan growth 
within our business segments exceeded the net U.S. GDP 
rate. That is our core growth goal: to grow somewhat 
faster than the economy. Throughout 2018, our client base 
expanded and our market positions continued to improve in 
most of our businesses.

Rising interest rates helped us deliver earnings growth, but 
we don’t depend on them. Our growth in client deposits 
funds our loan growth across all of our businesses and 
enables us to continue to grow net interest income, even if 
further interest rate rises fail to materialize.

Our eight lines of business grew as a result of deepening 
client relationships and developing new relationships. 

Growing by focusing on the customer
We are pleased to serve more than one in three U.S. house-
holds and more than 9 million business-owner clients. Our 

Consumer Banking business held $684 billion in average 
deposits during 2018, representing year-over-year growth 
of 5 percent. Average loans in that business grew by 7 percent. 
We have grown consumer checking balances for 40 consec-
utive quarters, producing an additional $200 billion in 
core checking deposits in our consumer business alone. 
In addition, average small business loans in Consumer 
Banking have grown 13 percent over the last three years.

Through 2018, we also continued to see rapid growth in our 
digital and mobile channels due to decades of investment. 
In 2018, our customers registered nearly 6 billion consumer 
banking app logins, allowing us to maintain regular connec-
tivity with them, and provide unparalleled convenience. 
We have nearly 37 million digital banking users; nearly 
27 million are active mobile banking customers. We now 
process more deposit transactions through mobile devices 
than in our financial centers. And 25 percent of our consumer 
sales, including credit cards and auto loans, were completed 
through a digital channel in 2018. 

While we are seeing digital and mobile growth, we are 
investing heavily in our facilities and in the teammates who 
serve there, as well. We have retooled many of our ATMs, our 
financial centers, and our technology in the branches and call 
centers. And we have invested in skills for our teammates to 
have more opportunity in our consumer businesses. 

These efforts have led to our strongest customer scores 
in our history. Our ability to deepen customer and client rela-
tionships is driven in part by the investments we are making 
to provide the best client care in the industry. For example, 
overall, our company was certified or recognized as having 
industry-leading capabilities six times by J.D. Power in 2018.  
Specifically, J.D. Power recognized our Digital Mortgage 
Experience and Home Loan Navigator for making the home- 
buying experience simpler than ever, and identified Bank 
of America as a top performer in several areas. We are the 
first financial services company to be both mobile app- 

Recognition Highlights 
2018 and 1Q 2019

Fortune
100 Best Companies 
to Work For (2019)

Fortune
Top global bank 
on 2018 “Change the 
World” list

Working Mother 
Among the 100 Best 
Companies for 
30 consecutive years

Euromoney
• World’s Best Bank 
•  World’s Best Bank 
for Diversity and 
Inclusion

J.D. Power
“Outstanding Website 
Experience” —  Merrill 
Edge Call Centers for 
7 consecutive years

Military Times 
One of the Best 
Employers for Vets

Investing in 
Women Initiative
2019 Catalyst 
Award Winner

Greenwich Associates 
Recognized for excellence 
in digital design, digital 
product capabilities and 
security for U.S. corporate 
cash management 

Barron’s 
#1 wealth management 
firm on Top 100 Women 
Financial Advisors list 
for 13 consecutive years

J.D. Power
#1 in Retail Banking 
Advice

Kiplinger
A Best Rewards 
Credit Card 

The Banker 
2018 U.S. Bank of the 
Year, Top Transaction 
Services Bank in N.A.

Forbes 
#1 wealth management 
firm on America’s 
Top Next-Generation 
Wealth Advisors list

BANK OF AMERICA 2018   | 3

Consumer Banking
Net income  
of $12B, up  
47% over 2017

Average loans  
and leases up  
7% to $284 billion

Average deposits up 
5% to $684 billion

Global Banking

Net income  
of $8.2B, up 
18% over 2017

Average loans  
and leases increased 
2% to $354 billion

Average deposits 
increased 8% to  
$336 billion

Global Wealth & Investment Management
Net income  
of $4.1B, up 
32% over 2017

Average loans  
and leases increased  
6% to $161 billion

Pretax margin  
increased to 28%*

Global Markets

Net income  
of $4B, up  
21% over 2017

Sales and Trading 
revenue of $13.1 billion*

Return on average  
allocated capital of 11%, 
up from 9% in 2017

*Presented on a fully taxable-equivalent basis.

and online banking-certified by J.D. Power for providing 
“An Outstanding Customer Experience.” Our auto finance, 
digital, mobile and credit card banking capabilities all were 
recognized as best-in-class, as were our small business 
offerings. 

We saw similar growth in our Global Wealth and Investment 
Management business, where net new household growth 
was up four times from 2017, and overall client balances 
exceeded $2.6 trillion. We have added digital capabilities, 
more advisors and new products.

Growing within our Risk Framework 
Another core tenet of Responsible Growth is that we 
grow within our Risk Framework, and we had solid results 
in 2018. Total net charge-offs remained at decade-lows, 
while the net charge-off ratio declined 3 basis points to 
41 basis points. All key asset quality metrics are solid. We 
are committed to being in a strong position to support 
clients throughout economic cycles. We have also managed 
market risk well during the turbulent markets in 2018, and 
our market risk indicators remain low. Through operational 
excellence we have also kept operational risk in check.

Our Global Banking business continues to do a great job serving 
up to the largest multinational companies. We also are 
deepening relationships with those clients, and adding new 
clients. As a result of investments we have made in rela-
tionship bankers, we have seen a 28 percent and 32 percent 
increase in net new relationships, respectively, in Business 
Banking serving smaller companies, and Global Commercial 
Banking serving middle-market companies. This is accom-
panied by solid deposit growth in Global Banking overall, up 
9 percent at the end of 2018. Our teams earned top awards 
for providing the best client care in the industry, including 
Euromoney naming us the best bank in North America for 
small- and medium-sized enterprises. We received further 
recognition as the top Transaction Services bank in North 
America and best brand for cash management.

Our customer-centered growth extends into our institu-
tional investor segment. Through our investments in our 
Global Markets business, and increased balance sheet 
commitment to our clients, we have seen an expansion in 
our prime brokerage business. Over the last several years, 
we have invested heavily in new systems and expanded 
products and electronic trading for investor clients. This 
contributed to record revenues in our equities business and 
solid fixed income business performance. 

4 | BANK OF AMERICA 2018

Delivering sustainable Responsible Growth 
As I mentioned earlier, we ensure Responsible Growth is 
sustainable. This requires relentless progress across three 
dimensions: sharing our success with our communities; 
striving to be a great place to work for our employees; 
and driving operational excellence. We continued to make 
progress in each area in the past year. 

Sharing success with the communities we serve
There are many ways we share our success. Our teammates 
volunteered 2 million hours supporting local organiza-
tions in 2018, and we introduced enhancements to our 
employee giving and matching gift programs. For 2019, we 
are increasing total annual philanthropic giving across the 
company to $250 million from $200 million. Since 2010, 
we have extended nearly $2 billion in philanthropic giving 
across the markets we serve in the U.S. and abroad. 

Also in 2018, we provided $4.7 billion in loans, tax credit 
equity investments and real estate development solutions 
through our Community Development Banking business. We 
financed affordable housing for seniors, veterans and the 
formerly homeless, charter schools and economic develop-
ment. Through our Capital Deployment Group, we have been 
developing innovative financing approaches to address 

global challenges outlined in the United Nations Sustainable 
Development Goals, including affordable housing, clean water 
and sanitation, education, health care and renewable energy. 

In recognition of the attention we pay to addressing these 
important priorities, I’m pleased that Bank of America was 
named the top global bank on Fortune magazine’s 2018 
“Change the World” list. Fortune recognized our work mobi-
lizing and deploying capital to address global challenges 
through our core business strategy. 

We know if we continue to align our work to serve 
shareholder interests and address the priorities of our 
communities at the same time, the progress can be sustain-
able. I’ll discuss that in further detail below, and you can 
find an extended review of our work in these areas later  
in this report, including a letter from Vice Chairman  
Anne Finucane on page 22. 

Being a great place to work
Another tenet of sustainability is ensuring we remain 
a great place to work for our teammates; the record 
employee satisfaction scores in our 2018 annual employee 
survey demonstrate this commitment. Our teammates 
especially value how we provide for employee health and 
wellness. Between current U.S.-based employees and their 
families, and retirees, we are responsible for providing 
comprehensive health and wellness benefits to nearly 
400,000 people. For the ninth consecutive year, we have held 
the cost of this benefit flat for the lowest-compensated 
employees, even as we continue to improve the coverage. 
For all employees, we have managed to keep increases 
below national averages.

We also continue to make regular adjustments to starting- 
level compensation at our company. We have been a 
leader in establishing an internal minimum rate of pay for 
our U.S. hourly paid employees and have made regular 
increases over many years. Two years ago, we raised our 
minimum wage to $15 per hour, and our minimum wage 
is higher today. Our average rate for all U.S. hourly paid 
employees is significantly above this level.

Our work in this area also includes employee development 
and opportunities for growth. We foster our client-centric 
culture through strategic workforce planning, anticipating 
the future of work and creating a culture of lifelong learning. 
In 2018, nearly 40,000 of our Consumer and Small Business 
employees completed a learning curriculum, giving them 
more skills for broader success. We hired more than  
27,000 new teammates to the company last year (including  
3,500 plus from colleges and universities); we helped more 
than 17,000 employees find new roles in the bank; and  
86 percent of eligible managers voluntarily participated in 
manager development courses to improve their skills. The 
implications are global; we also moved more than 5,000 jobs 
from non-U.S. markets to the U.S. over the last four years. 

Another area of focus has been sharing the benefits of  
the 2017 U.S. tax reform. Since the passage of the Tax Cuts 
and Jobs Act in December 2017, we have extended two 
special compensation awards, impacting approximately  
90 percent (in 2017) and 95 percent (in 2018) of our team-
mates globally. These awards included cash bonuses and 
stock, totaling more than $1 billion, and were in addition to 
the compensation these teammates otherwise received. 

Please look for more details in this report, and in our proxy 
statement, about all we do to be a great place to work, 
including a letter from Chief Human Resources Officer 
Sheri Bronstein on page 30.

Driving operational excellence
We also ensure that Responsible Growth is sustainable 
though our focus on operational excellence — continuous 
improvement in our internal and external processes to make 
it easier for our employees to work with each other and to 
serve clients and customers. By pursuing operational excel-
lence, we are becoming more efficient, so we can continue 
to invest while providing you good returns. This makes all 
the other progress that I’ve discussed possible. 

Focusing on operational excellence allows us to continue 
to invest in our capabilities and in our team, even as we 
maintain expense discipline. While we face the same 

Responsible Growth has four tenets

Grow
and win  
in the market,  
no excuses

Grow
with our  
customer-focused  
strategy

Grow
within  
our Risk  
Framework

Grow
in a  
sustainable  
manner

BANK OF AMERICA 2018 | 5

inflation and cost challenges all employers do (e.g., benefit 
increases, wage increases, real estate cost increases, more 
investment), we managed through them. We achieved our 
2018 expense target of approximately $53 billion. We set 
that goal in mid-2016, when our annual expense run rate 
was $57 billion. Managing expenses well has contributed to 
four straight years of positive operative leverage and allowed 
us to grow pretax earnings at 18 percent in 2018 — all while 
investing in the company. 

I have mentioned some of the areas in which we are 
investing: adding relationship managers for our Global 
Banking clients, continuing to improve on our leading digital 
and mobile capabilities for all client segments and for our 
teammates, investing in health and wellness benefits for 
employees, our philanthropy increase, and the shared success 
bonuses we paid to 95 percent of our teammates in 2018. 

Since 2010, we have invested roughly $25 billion in new 
technology initiatives. This includes reworking effectively 
all of our major systems and adding innovative capabilities, 
while also building an internal cloud and software architec-
ture for maximum efficiency and speed to market.

Technology investments are directed at innovation across 
our company. Perhaps that is most apparent in the invest-
ments we continue to make in our industry-leading online 
consumer platform and state-of-the-art branch network. 
Erica™ is one example. Our virtual banking assistant that 
combines interactive communications and artificial intelli-
gence (AI) to learn and anticipate client needs is unique in 
the industry. Since we introduced Erica in spring 2018, more 
than 5 million customers have used the capability and the 
adoption rate is growing fast. 

Another innovation in which we’ve invested is Zelle™, our 
peer-to-peer transfer capability enabled by our mobile app. 
Bank of America, along with other large banks, developed 
Zelle and we have extended full access to the capability to 
a growing network of participating financial institutions. 
Customers of virtually any bank of any size can now send 
money to one another through the safety of their bank 
account in real time. Zelle transactions by our clients are 
growing over 100 percent a year, and we had nearly 5 million 
users at the end of 2018. And we’re just getting started. 

Another investment we’ve made is in our digital auto 
shopping experience, enabling customers to search, select 
a car, and get underwritten in real time. Customers can 
use our mobile app to search online for a car with access 
to thousands of dealers’ inventories, with over 1 million 
cars available. We have seen a seven-fold jump in financing 
applications in this area since launch in May 2017.

Our investments in digital and mobile preferences for the 
customer have resulted in higher customer satisfaction 
scores and more deposits, while allowing us to reduce our 
branch count by more than 1,300 since 2012. 

And we continue to invest in improving our customer branch 
experience. Our 4,300 current centers are places where 

6 | BANK OF AMERICA 2018

800,000 customers come each day to talk with a relation-
ship or product specialist for the financial advice, products 
and services they need.

In 2016, we announced our plans to renovate our financial 
centers and upgrade our ATMs nationwide to better serve 
our clients, expand our consumer and small business services 
into new markets, and grow our presence in existing markets. 
I provided an update last year, including our intention to 
expand our financial center presence in nine new markets to 
offer retail banking, lending, small business and investment 
services. Today, we cover more than 80 percent of the U.S. 
population with our retail branch footprint. With the sched-
uled investments, we will cover more than 90 percent.

We continued to execute this plan in 2018. We expanded 
our presence in 25 markets, including our newest — 
Denver, Minneapolis, and Indianapolis. We also entered the 
Pittsburgh market in 2018, and will be opening our first 
financial center in Salt Lake City in early 2019. In addition 
to opening 81 new financial centers last year, we completed 
renovations on 567 others. We are redesigning more than 
2,500 financial centers by 2021 to make it easier for clients 
to access our banking and investing professionals for advice 
on their life priorities and financial goals. Adding financial 
centers also helps drive local employment, as we have 
added teammates across the new centers. 

Look for a more detailed discussion of our high-tech, 
high-touch capabilities with Dean Athanasia, president of 
Consumer and Small Business, on page 15 of this report. 

While our investments may be most apparent in the 
Consumer and Small Business segment, we are investing 
and innovating to better serve all of our clients. We 
have extended our mobile consumer experience into 
our commercial banking digital platform, with capabili-
ties that enable treasurers of companies, both large and 
small, to transact with the same mobile convenience. 
This innovation benefits the clients whom we assist with 
markets-related services and activities, such as electronic 
trading, algorithms, analytical capabilities, systems and 
data management, and counterparty risk management and 

Focusing on operational 
excellence allows us to 
continue to invest in our 
capabilities and in our 
team, even as we maintain 
expense discipline.

underwriting systems. For wealth management and invest-
ment clients, we have automated investing tools, enhanced 
document scanning and client texting.

Across our company, upgraded, integrated systems allow faster 
execution for customers with our enhanced reporting, robotics 
and automation. The application of advanced technology, 
coupled with our focus on client relationship management, 
creates a competitive advantage. And our universal, enter-
prisewide platform increases our efficiency and helps us 
better serve clients and customers. All this, combined with 
our global reach, creates a tremendous capability for you. 

Remember, all this investment is driven by operational 
excellence — creating efficiency and investment in the 
future. The investments made in 2018 were extensive but 
we were able to reduce expenses through operational excel-
lence. For 2019 and 2020, we expect expenses to remain 
flat even while we are making these investments. That 
makes our growth sustainable so we won’t have to pull back 
in times of slower economic growth. 

Committed to strong governance
Please read the letter from Jack Bovender, our lead inde-
pendent director, for a description of how the board of 
directors supports and oversees our strategy. Jack and our 
directors continue their practice of systematic investor 
engagement. In 2018, we met with shareholders holding 
more than 30 percent of our shares. Jack discusses this  
in further detail in his letter on the next page. 

We were pleased to welcome back to the board last year  
Dr. Clayton S. Rose, who served as a director of our company 
from 2013 until 2015. Clayton was named president of Bowdoin 
College in Brunswick, Maine in 2015. He was able to rejoin 
our board last year and offers terrific perspective. We benefit 
from his insight on a range of issues. 

Operating at scale to address 
important societal priorities
Earlier, I referenced challenges related to affordable housing, 
clean water, education, health care, renewable energy, energy 
efficiency and other critical areas outlined in the United 

Nations Sustainable Development Goals (SDGs). The way I 
think of this is that, in effect, we asked the world through 
the efforts of the United Nations, “What would you like the 
power to do?” And the world spoke. Society would like to 
see timely progress in addressing these priorities. 

The issues are, of course, a concern to policymakers and 
elected officials at every level of government. But they 
are also a concern to our teammates, our customers and 
clients, the communities we serve, and our shareholders. 

At Bank of America, we realize there is a significant gap 
between the capital that must be applied to these global 
challenges and the amount that is currently being spent. 
Credible estimates of what is needed to address the U.N. 
SDGs is about $6 trillion per year; the current annual funding 
gap is as much as half that. 

Government alone can’t solve these challenges. The U.S. 
government, with the largest economy in the world, will spend 
more than $4 trillion this year. But almost two-thirds of those 
total expenditures are committed to non-discretionary needs: 
funding the social safety net, servicing U.S. debt and other 
commitments. The discretionary elements of the budget 
include national security, education, health care and other 
priorities. The same is true for other governments and econ-
omies around the world. The government budgets are fully 
committed, and in many cases in difficult shape, so counting 
on governments to spend more is not a likely solution. 

Charitable giving alone also cannot fill the need. Annual giving 
from individuals, foundations, and corporations is spread 
across many worthy causes and, even in the aggregate, falls 
short. The U.S. is the largest philanthropic giver in the world  
as a percentage of GDP. Total giving to charitable organiza-
tions overall in the world was around $800 billion in 2017 and  
$410 billion in the U.S., primarily from individuals. Assets by 
foundations in the world are estimated at about $1.5 trillion; 
nearly half of that is held by foundations in the U.S. at  
$890 billion. Again, even if we spent all that money in a single 
year, it would be insufficient to close the gap. 

We operate in nearly 300 cities, towns, and communities, 
consolidated into 92 distinct markets in the United States, 
and in three dozen countries around the world. We are  
part of the fabric of those communities, where our 200,000 
teammates live, work, and raise their families. 

Public companies that employ and invest at the scale that 
we and others do are well-positioned to address income 
inequality, clean energy, health care, and affordable housing 
through thought leadership, investment, innovation, mobili-
zation of capital and in other ways. Private-sector leadership 
is necessary because solutions involving capitalism are inher-
ently sustainable, and the returns will bring continued and 
increasing investment. 

But, as the great student of business and author Jim Collins 
has said, we have to embrace “the genius of the AND.” We 
have to do our part to achieve strong and timely progress on 
the sustainable development goals AND we have to deliver 

BANK OF AMERICA 2018 | 7

A message from 
Lead Independent Director
Jack Bovender

Dear fellow shareholders,

On behalf of the independent directors of the company,  
I join Brian and the management team in thanking you for 
choosing to invest in Bank of America.

Our board continues to focus on its responsibility to 

oversee the company’s execution of the strategy that 
we review and approve each fall. To do that, the board 
engages in a year-round strategic assessment and 
planning process. That includes regular discussions with 
the company’s management about the current operating 
environment, industry trends and global and  geopolitical 
developments. We also engage in regular and systematic 
dialogue with our shareholders. Throughout 2018 and 
into this year, we have provided updates to, and solicited 
input from, shareholders representing more than a third 
of our shares outstanding. Shareholder feedback informs 

our board meeting agendas and contributes to governance 
enhancements. We seek input and exchange views on matters 
ranging from executive compensation to capital deployment 
and environmental, social, and governance initiatives.

The board comprises diverse individuals representing a 
spectrum of informed viewpoints. Fifteen of the 16 directors 
are independent; 63 percent have CEO-level  experience; and 
38 percent have senior executive experience at financial 
institutions. As Brian outlines in his letter, the board in 2018 
welcomed the return of Dr. Clayton S. Rose as a director. 
Clayton’s expertise includes strategy, ethics, moral leadership 
and corporate responsibility. He and all the  directors provide 
valuable perspective as the company continues to pursue 
responsible growth.

We remain committed to providing you all the material 
and information you need to understand and appreciate both 
the opportunities and the challenges ahead as the company 
continues to execute its strategy. Please take the time to 
carefully review this annual report, as well as our proxy state-
ment, and the other materials the company makes available 
to shareholders. 

Thank you again for your investment and for your 

continued engagement. 

Sincerely,

strong returns to you, our shareholders, as we do so. This 
enables us to keep addressing these important priorities. We 
are doing this, and we are committed to doing more. 

How does Bank of America do this? 
First, we continue to align our expense base and our balance 
sheet to find every business opportunity to provide good 
returns and to make progress toward our goals. We do this 
by financing new energy sources, by financing affordable 
housing, and by financing other types of development. These 
financing opportunities provide a return for investors while 
making progress on the goals. 

Second, we bring thought leadership to the discussion. Our 
Research team has demonstrated that companies adhering to 
sound environment, social, and governance (ESG) practices 
will avoid serious issues. In fact, their research shows that 
investors could have avoided almost all of the bankruptcies 
of the last several years by avoiding companies that do not 
have good metrics on ESG. Increasingly, investors are looking 
for that kind of adherence in making investment decisions. 
This is driving more private-sector investment capital from 
institutional investors toward companies that are addressing 

8 | BANK OF AMERICA 2018

these priorities. We also see this in our wealth manage-
ment businesses, where we are meeting client demands 
to construct portfolios focused on companies that meet 
standards consistent with progress toward the sustainable 
development goals. The practice is growing. By harnessing 
private capital in this manner, the alignment we create can 
help fill the gap left by limitations in government and phil-
anthropic spending by bringing more resources, capital, and 
expense to the task. In addition, we can be a catalyst for 
others to act. Our expertise, credibility, and ability to assess 
the opportunities can help others who have the desire but 
may lack the expertise to deploy capital. 

Third, we contribute in the ways we manage our own  
activities. We are more than halfway through our 10-year, 
$125 billion Environmental Business Initiative, supporting 
clients and others who are helping create a sustainable 
energy future. We also focus on our own sustainable facilities 
management and improved energy efficiency. For instance, 
we have set a goal to be carbon neutral by the end of 2020.

We also run your company to provide great opportunities 
for teammates. We hire from a diverse range of locations and 

backgrounds, and provide opportunities for teammates to pursue their own path 
and excel. That kind of opportunity for success allows a teammate to join us, for 
instance, from a low- or moderate- income neighborhood (as did more than 
30 percent of our Consumer and Small Business external hires last year) and move 
into future openings throughout our company based on their own merit and desire. 

Fourth, our own ESG work makes a direct impact. The direct investments we 
make, the volunteer efforts of our teammates, our philanthropic works — all of 
this helps address the challenges. While our own ESG work through giving and 
volunteerism cannot solve the challenges as we have relayed, we are proud of 
what our teammates directly do to help make progress on these priorities.

Let me give some examples of the different types of activities set forth above:

Bank of America committed more than $50 billion last year in lending, investing 
and philanthropy to deploy capital toward the SDGs. In fall 2018, we created 
a special $60 million Blended Finance Catalyst Pool to encourage more compa-
nies to participate in addressing those priorities. Our blended finance initiative 
combines different sources of capital for a targeted objective, in order to accom-
modate different risk tolerances and rates of return. As this approach expands 
over time, we can create the capacity to mobilize vast amounts of capital and 
achieve the scale necessary to fundamentally address global challenges driven by 
the force of private-sector capital returns.

In one of the first commitments of our catalyst pool, we joined with two other 
financial services companies in our headquarter city of Charlotte, North Carolina, 
to extend more than $70 million to fund low-income housing developments. 
Most of that amount will be low-interest loans to private developers building 
income-restricted housing.

We believe it is not only possible, but it is the desired outcome for Bank of 
America as a public company to simultaneously serve our clients, deliver for 
our shareholders AND address these local, national, and global social priorities. 
Delivering on both aspects of the “AND” is the way to ensure that we can continue 
to channel the capital from others and from our company that is needed to fund 
societal needs. We all have to provide great returns, while delivering on the goals. 

Our teammates are called upon in every community where they live and work to 
lead efforts that promote economic and social development, and I am proud of 
how they step in to help. We welcome the continued interest of elected officials 
in these efforts and engage them across the cities, towns and communities we 
serve. Our commitment is a core element of Responsible Growth.

Thank you for being a shareholder
I hope you find it informative and enjoyable to read more about Bank of America 
in the following pages, where you’ll see more examples of how we’re helping 
to make financial lives better through every connection. You can read how we’re 
connecting with clients every day to help them achieve their goals, simply by asking: 

“What would you like the power to do?”

I am proud to work with my 200,000-plus teammates who are listening for 
your answer.

REVENUE ($B)

$85.9

$83.0

$83.7

$91.2

$87.4

2014

2015

2016

2017

2018

NET INCOME ($B)

$28.1

$17.8

$18.2

$15.9

Thank you for your support and investment in Bank of America.

$5.5

Brian Moynihan 
March 1, 2019

2014

2015

2016

2017

2018

BANK OF AMERICA 2018   | 9

We work every day to finance progress 
and spur entrepreneurship —  to help you 
build financial know-how and strengthen 
communities. Meet people who are 
making a difference and the partners 
who are championing them.

What would you like 

10   |   BANK OF AMERICA 2018

the power to do?™

BANK OF AMERICA 2018   |   11

With Bank of America, you 
have the power to manage 
your financial life here...

Exceptional client service is  
high-tech  and high-touch.
Technology is transforming financial services and 
changing the way clients and banks interact. Yet, 
when it comes to making major financial plans, our 
clients also want to be able to work directly with 
our team of experts who can provide the advice 
and counsel they need. It’s the combination of both 
of these that makes our offering really powerful. 
We’re building relationships based on how clients’ 
needs evolve throughout their financial lives, 
combining digital access for everyday banking —  
at any time, from anywhere —  with expert advice 
for life’s big financial decisions. 

12 | BANK OF AMERICA 2018

...and here.

BANK OF AMERICA 2018 | 13

Q&A with Dean Athanasia,  
President of Consumer and  
Small Business

14   |   BANK OF AMERICA 2018

Q:  WHAT DO TODAY’S CONSUMERS LOOK FOR IN A BANK, 

AND WHAT IS BANK OF AMERICA’S STRATEGY FOR EXCEEDING 
THOSE EXPECTATIONS?

A: Clients want a bank that is committed to helping improve their  financial 

lives, so they have the power to do the things that matter most to them, like 
open their first banking account, make payments with ease, buy a home, invest, 
grow a business and leave a legacy. We’re working  continuously —  on both high-
tech and high-touch solutions —  to earn our clients’ trust and to give them 
more reasons to bank with us. Whether it’s investing in digital banking and new 
solutions, redesigning our  financial centers, or offering learning and development 
programs to help our teammates expand their skills — these actions help us 
provide better service, while growing  responsibly and sustainably with our clients.

More importantly, client care is how we build and expand rewarding relationships 
with our clients and help them at every stage of their financial lives. We put clients’ 
needs at the heart of every decision we make to ensure they have the best products 
and solutions, serving all of their financial needs, delivered with a consistently great 
experience that recognizes and rewards them for their relationship with us.

Q:  WHICH CURRENT INNOVATIONS BEST DEMONSTRATE 

BANK OF AMERICA’S LEADERSHIP IN DIGITAL BANKING?

A: We continue to invest and innovate because clients expect us to be at the 

forefront of the technological advances that are transforming banking — and their 
financial lives. We have created a best-in-class, innovative digital experience that 
gives clients the power to manage their banking and investing activities from their 
mobile phone, including checking an account balance, applying for a mortgage, 
paying a friend, or even shopping for a car. 

Our digital leadership is reflected in our award-winning mobile app, the first to 

receive J.D. Power’s certification for “An Outstanding Mobile Banking Customer 
Experience.” Erica, our artificial intelligence (AI)-driven virtual financial assistant, 
is helping more clients stay on top of their banking every day. Zelle, the person-
to-person payment platform, had nearly 5 million users at the end of 2018. Small 
Business clients can now manage more of their banking through mobile devices. 
Our Digital Mortgage Experience™ now offers clients the ability to request a 
preapproval. And, we’re continuing to expand our digital resources so clients can 
bank and invest however, wherever and whenever they choose.

Q:  WILL THE FUTURE OF BANKING LEAN MORE TOWARD 

DIGITAL OR BRICK-AND-MORTAR CAPABILITIES?

A: Clients want to be able to accomplish their everyday banking conveniently 

through their mobile devices, and connect with client representatives in our 
financial centers when they have more complex needs. The power of our integrated 
high-tech and high-touch approach means they have the best of both worlds; 
for example, clients can make an appointment to speak with a specialist on their 
mobile device, and Erica can even help them set it up! When clients come to 
our financial centers for help, knowledgeable professionals provide advice in a 
private setting. We’re on track to redesign more than 2,500 financial centers by 
2021 to make them welcoming destinations where clients can have personal, 
in-depth conversations with our professionals about their financial goals, including 
retirement, purchasing a home, investing or saving for their children’s education.
Our financial centers will always be a welcoming and professional setting 
for clients who need to speak with us about their financial priorities and goals. 
And with 9.5 million Hispanic and Latino consumer clients, we’re investing in 
talent, upgraded financial centers and community outreach, beginning with 300 
centers in Los Angeles, New York, Miami, Chicago, Dallas and San Francisco. 
We’re expanding into local markets across the U.S. where we see opportunities 
to better serve existing clients, grow our business responsibly and help local 
communities thrive.

BANK OF AMERICA 2018   |   15

Delivering tailored wealth management  
solutions for every stage in life
Our unmatched wealth management businesses serve clients of every age, at every stage of their financial lives, across the 
wealth continuum. Our top-ranked advisors provide objective, conflict-free advice and clear, actionable financial plans based  
upon our clients’ goals and aspirations. We offer rewards when clients deepen their relationship with us, and access to seamless 
integration with the rest of our global firm to help meet every banking need, whether business, commercial, corporate and 
investment, or retail.

“I like to show my clients, many of whom 
are new to investing, how easy the process 
can be when they focus on their life priori-
ties to help define their investing goals. I’m 
proud of what we offer investors through 
our online investing platform. Clients can 
put their own ideas into action or get finan-
cial guidance —  either through our digital 
capabilities or with the help of an advisor —  
and access investing insights supported by 
our award-winning research and tools.”

“What our clients are looking for is a 
partner who helps them navigate their 
financial and family plans. They value 
working with someone they trust who can 
advise them on all aspects of their financial 
affairs —  investments, banking, credit, 
philanthropy and planning for the next 
generation. The combination of Merrill Lynch 
investments and Bank of America banking 
allows us to provide clients the solutions to 
realize their goals throughout their lifetime.”

“One of the advantages we provide to 
our clients is our team-based approach 
and high level of client service. Our teams 
spend a lot of time up-front with clients 
to understand their needs and goals. 
When combined with access to all of 
Bank of America’s capabilities, our teams 
are able to provide solutions to address 
the opportunities and challenges our 
clients face.”

M i a   Z i r i n g
Financial Solutions Advisor, Merrill Edge

D e b b i e   J o r g e n s e n
Managing Director, Wealth Management  
Advisor, Merrill Lynch Wealth Management

J a n e t   R y a n
Managing Director, Private Client  
Advisor, U.S. Trust, Bank of America  
Private Wealth Management

When Fidelia retired from her successful career as 
a retail executive, she turned to Bank of America 
for help planning her financial future. With goals 
that included caring for her mother, continuing 
her education and launching a second career, she 
consolidated her accounts to Merrill Edge and rolled 
over her pension and 401 (k). She also set up a new 
Merrill Guided Investing account to help her retire-
ment savings stay on track with a  professionally 
managed portfolio. “I’m able to direct my own 
investing, but I always have an advisor to turn to,” 
she said. According to Fidelia, putting her Bank 
of America and Merrill Edge accounts together and 
having advisors who understand her goals make 
her feel more in control of her future. “I feel 
like Bank of America is invested in 
my success. They know where I want 
to go and how to help me get there.”

I would like the power  
to have a second act
FIDELIA

16   |   BANK OF AMERICA 2018

I would like the power 
to be my own boss
LISA

When faced with any of life’s sizable decisions, 
one of Lisa Young’s initial calls inevitably is 
to her Merrill Lynch financial advisor, Sammie 
Kothari Peng. “I literally asked her for advice 
about how I should most strategically allocate 
my very first paycheck,” Lisa said with 
a chuckle.

That forethought and attention to detail 
explain how Lisa enjoyed a successful corpo-
rate career before making the complicated 
transition to start her own business. “Within 
just a few years, my life underwent a series 
of significant changes: marriage, children, 
buying a home, starting my own business, 
needing to save for retirement and colleges,” 
said Lisa, who, like her parents, is a longtime 
Merrill Lynch client.

business, she clearly understood my financial 
risks and helped me plan for them. She even 
connected me with one of her clients who 
was in the same industry, which led to my 
first contract.”

Lisa added, “I want to be a role model for my 
kids —  especially my daughter —  to show her 
that you can work hard and be successful 
and also do it on your terms. To achieve that 
success, we all need people we can trust, 
who have the most reliable and sound advice. 
Sammie knows and understands 
us so well —  our family’s needs, 
our dreams and our approach 
to finances. She is always there 
when significant decisions need 
to be made.”

“These life events raised questions that 
required proactive solutions: ‘What are my 
long-term and short-term needs? What type 
of budgets should I establish, and which 
accounts and investments will that involve? 
How much should I put away for a house, and 
for our children’s education?’ Sammie not only 
answered our questions —  she anticipated 
those that my husband and I didn’t even know 
to ask. And when it came to launching my own 

“Lisa and I never lose focus on the big picture,” 
Sammie said. “That can involve a conversation 
about the equity and fixed-income markets, 
529 plans, 401(k)s, or even the ability to say 
no to a particular work contract if it does not 
align with her ultimate work-life balance goals. 
I am so proud of all that she has accomplished, 
and will always be available to her as she 
continues her journey. She knows I’m just a 
phone call away.”

BANK OF AMERICA 2018   | 17

We would like the power 
to create a legacy 
RAFAT AND ZOREEN

“If I have a financial issue, or almost any 
issue, the first person I would call is my 
Merrill Lynch advisor,” said Rafat Ansari. 
That level of trust was established in the 
first meeting Rafat and his wife, Zoreen, 
had with Merrill Lynch financial advisor 
Matt Kahn, who hit on a series of questions 
that proved invaluable. Their daughter, who 
has autism, was about to gain access to a 
trust in her name that had been established 
by a previous firm. But the trust didn’t 
incorporate her need for certain services 
she would have lost if she had gained 
access. “We had no idea she was close to 
losing what mattered most, benefits that 
you cannot buy,” said Zoreen.

To ensure her medical and financial needs 
could both be met, Matt brought in exper-
tise from another Merrill Lynch team with 
unique experience serving families with 
special needs. After much hard work and 
collaboration on a new trust, they retained 
her benefits and strengthened her  financial 
future. “Since that day, Merrill Lynch has 
been an integral part of her care plan, 
and in all aspects of our family’s financial 
planning,” said Zoreen.

With their daughter’s stability secured, 
the Ansaris began to focus more on their 
legacy. “We want to give something back 
to humanity,” said Rafat. The family, which 
is passionate about philanthropy, brought 
the idea of making a significant gift to the 
University of Notre Dame to their advisory 
team with a common question: What can 
we afford to give? Financial Advisor Jennifer 

Haggerty prepared multiple options and 
carefully explained how different gift 
levels may affect their financial future over 
time, as well as options for structuring the 
gift. “We had to think, how is it going to 
affect us? There were a lot of parts,” said 
Rafat. Over the course of several months, 
Matt and Jennifer worked closely with 
the Ansaris and their children, their CPA 
and the university to make their vision 
a reality, creating the Rafat and Zoreen 
Ansari Institute for Global Engagement with 
Religion, which was established to foster a 
better understanding of religion by studying 
the similarities and roles of religions and 
their impact on the public sphere around 
the world.

“This institute is a legacy for us,” Rafat said. 
“Merrill Lynch was quite helpful 
through the entire process. 
Our relationship with them has 
been great, and it’s on multiple 
levels, including investments, 
estate planning, lending, and 
advice. It’s a complete service 
line for us. Whatever we need, it’s just 
one call away from being taken care of. Our 
team is easily accessible at any time, and I 
feel very comfortable knowing that,” said 
Rafat. The couple agrees that working with 
Merrill Lynch has helped them meet their 
most important life goals. Zoreen added, 
“We’ve gained in our financial strength. 
We’ve established estate planning for our 
children and the program at Notre Dame. 
We feel taken care of, as a whole.”

18 |   BANK OF AMERICA 2018

Supporting companies as  
they grow, innovate and lead 

Clients down the street and around the world look to our teams to 
help power their growth. Small business owners get the support 
they need to open their first business accounts, including access 
to solutions for cash management, paying suppliers and meeting 
liquidity requirements. Larger companies may need currency risk 
management, sophisticated treasury solutions, and ongoing capital 
and liquidity financing. Companies and institutional investors alike 
rely on our talented teams and leading research for ideas and 
opportunities to grow and innovate.

$8.6 billion
in new credit extended to 
small business owners in 2018

One of the
top small  
business lenders
with approximately 
$35 billion total outstanding 
small business loan balances1

A top  
SBA lender
with more than $275 million 
in combined SBA 504 and 7(a) 
loan volume in 20182

$1.5 billion+
in loans and investments to 
community development 
financial institutions

A leading  
commercial  
lender
with nearly $500 billion in 
commercial loans and leases 
at the end of 2018

Relationships with  
79 percent of the 2018
Global  
Fortune 500
and 94 percent of the 2018  
U.S. Fortune 1,000 

Leading dealer in  
FX cash, derivatives, 
electronic trading and 
payment services in
151 currencies 

#1
global green bond  
underwriter 3

Rated #1  
global research 
firm 6 of last  
8 years
by Institutional Investor  
magazine (ranked second  
in 2017 and 2018)

650+  
analysts  
covering
3,000+ companies,  
1,100+ corporate bond 
issuers across  
54 economies and  
25 industries

1 Source: FDIC, as of Q3 2018.
2 Based on 2018 gross loan approval as provided by the SBA for fiscal year ending 9/30/2018.
3 Source: Environmental Finance.

BANK OF AMERICA 2018   |   19

Skookum would like the 
power to change the world

Skookum Contract Services operates with a mission to 
change the world through its diverse workforce of more 
than 1,100 employees, including over 400 U.S. veterans. 
The Bremerton, Washington-based nonprofit began over 
30 years ago with just a dozen employees; today, it has 
grown its presence to 11 states and Washington, D.C. by 
providing world-class logistics, aerospace manufacturing, 
and facilities management services to government and 
commercial customers.

“We’re here to change the world,” said Skookum President 
and CEO Jeff Dolven. “Each of us brings abilities to work 
that can drive performance and create value. Think about 
the engagement you get in the workforce when you help 
people realize their dreams.” That Bank of America has 
been with Skookum through each stage of its continuing 
evolution is no accident.

“Years ago, we were smaller and focused on our finan-
cial health and our balance sheet, but we had a very 
clear agenda to expand the scope of our impact,” Jeff 
said. “We wanted to be associated with a bank that 
had a brand that was clearly recognized as a symbol of 
strength. To us, there was no question that was Bank 
of America. So we made it a goal to become a client of 
the bank. Every step we took financially was to achieve 
that goal. And we did it.”

For more than 15 years, Bank of America has provided 
financial and strategic guidance to Skookum —  providing 
liquidity for new client contracts, financing their head-
quarters purchase, and even introducing a series of 
wealth management seminars to Skookum employees.

“Skookum is a best-in-class organization that lives its 
exceptional mission every day,” said Jeremy Bolles, 
Bank of America’s senior relationship manager. “While 
they are focused on helping job seekers overcome 
barriers and find long-term success in the workplace, 
we are working to help the company operate efficiently, 
act on growth opportunities, and continue to plan for 
the long term. We’re proud to support their efforts, 
whether that’s providing a new line of credit, custom-
izing payroll solutions, joining the board for strategic 
planning sessions, or even flipping burgers at the 
company picnic.”

“Jeremy and the team at Bank of America 
have taken the time to know us so well, to 
become so embedded in our planning and 
our strategies, that they’re always out in 
front of us,” Jeff said. “Whenever we are ready to 
take a step, every aspect of every financial instrument 
already is in place. We have never had to slow down, not 
once. How many banks can you say that about? Our goal 
is to make a lasting impact on communities around the 
world. And we take tremendous comfort in knowing that 
no matter where we go, Bank of America will have been 
there first.”

Photos above (left to right): Skookum employee Maurice Correia 
pursues his passion for fishing. Skookum employee and U.S. veteran 
Bonnie White puts her skills as a mechanic to work.

20 | BANK OF AMERICA 2018

IPG would like the power 
to lead an industry 

Intertape Polymer Group Inc. (IPG), a 
manufacturer of a variety of tapes, 
films, protective packaging and woven 
products, had ambitious aspirations. 
Already the second-largest tape manu-
facturer in North America, the Montreal, 
Quebec- and Sarasota, Florida-based 
company several years ago was driving 
to become a global leader through multi-
national acquisitions, investments in 
manufacturing capacity, and additions to 
its product bundle. What IPG needed was 
the power to grow on an international 
scale —  and a financial partner to help.

“Bank of America has been a key 
relationship for us,” said IPG Chief 
Financial Officer Jeffrey Crystal. 
“They put their heart and soul into 
creating solutions that work.”

During the course of a relationship of 
10-plus years, Bank of America delivered 

a world of financial solutions to IPG. 
At the outset, when IPG faced challenges 
from an unsuccessful takeover attempt 
and economic recession in 2007, Bank 
of America provided an asset-based loan 
facility. Once IPG was on strong footing 
and ready to progress to a different 
capital structure, Bank of America 
provided a revolving credit facility and 
term loan. Over time, IPG has expanded 
through joint ventures and acquisitions —  
including operations in India —  while 
bolstering its world-class manufacturing 
capacity. Bank of America supported 
those initiatives, leading a $250 million 
high-yield bond financing with a flexible 
leverage covenant, providing IPG the 
capacity for future growth while removing 
risk from its balance sheet. On a daily 
basis, services such as foreign exchange 
and interest rate hedging enable the 
global business to manage its finances 
effectively.

A local Bank of America relation-
ship management team, led by Greg 
Banach and based near IPG’s Sarasota 
head quarters, ensures an attentive, 
personalized approach to service while 
providing connections to resources around 
the world. “We’ve earned our strong 
relationship with IPG by understanding 
where they want to go, and bringing 
ideas and solutions to help them get 
there,” Greg said. As IPG’s business has 
evolved, teams from Global Commercial 
Banking, Investment Banking and other 
Bank of America units have worked 
together to deliver tailor-made solutions 
to advance the company’s strategic plans.

“Bank of America stuck with us through 
a tough time early on, and consistently 
comes to the plate with unique ideas,” 
Jeffrey said. “They’re a great partner, 
whether in North America or around 
the world.”

Caviar & Caviar USA 
would like the power to 
grow with confidence 

Entrepreneur Michael Jalileyan describes 
Bank of America in much the same 
manner as top chefs, five-star hospitality 
groups and specialty retail outlets react 
after tasting the high-end caviar and 
smoked salmon supplied by his business: 
“It’s almost too good to be true.”

A Bank of America customer since he 
was a teenager, Michael never hesitated 
when weighing the banking needs 

associated with launching, nurturing 
and growing Caviar & Caviar USA into 
the top domestic supplier of caviar and 
specialty seafood. “We don’t even 
look at other banks,” Michael 
said. “We would never need to. 
There are no surprises. We’re 
simply constantly impressed.” 
Small business banker Marc Ramer leads 
a team that supports Michael, including 
a recent, nearly two-year search for a 
larger facility to house the flourishing 
business. Marc’s extensive due diligence 
enabled Michael’s company to identify 
and avoid a potentially six-figure repair 

issue at one site. “Michael is the client 
every banker wishes to have,” Marc said. 
“Knowledgeable, engaged, enthusiastic —  
I am always curious to see which trend-
setting innovation he plans to pursue, 
and how our entire range of products can 
assist him.”

“Bank of America has tremendous 
size and scale,” Michael said. “But the 
attention always feels specialized 
and personal. Marc deftly handles the 
financial aspects, leaving me free to 
concentrate on running and growing my 
business. And that’s a lot off my plate.”

BANK OF AMERICA 2018   | 21

Financing 
a sustainable 
world

A message from
Vice Chairman 
Anne Finucane

We are bringing together private banks, 
institutional and individual investors, 
development banks, and nonprofits to 
ensure more capital can be applied 
to a single issue or opportunity.

Every day, our teams are creating new 
solutions, forging new partnerships, and 
providing guidance and support to fuel 
progress. In 2019, we will continue to 
use our focus on responsible growth 
and ESG leadership to help define how 
we operate as a force for good in the 
global economy.

In 2018,
we mobilized, 
conservatively, 
more than 
$50 billion that 
impacted a 
key subset of 
the SDGs.

Over the last several years, we have discussed with you 
how our focus on environmental, social and governance 
(ESG) principles is an essential part of how we deliver 
responsible growth. Our ESG leadership defines how we 
deploy our capital and resources, informs our business 
practices, and helps determine how and when we use 
our voice in support of our values. It also enables us 
to pursue growing business opportunities and manage 
risk associated with addressing the world’s biggest 
environmental and social issues.

Over the next several pages, you will see highlights of our 2018 work in 
all of these areas. One particular area of focus has been solidifying a 
more formal approach to how we deploy our own capital and engage our 
partners on this topic to create greater impact around the world.

Today, the world is facing monumental challenges, and it is clear that 
potential solutions are woefully under-resourced. There is a significant 
gap between the capital that must be applied to global  challenges and 
the amount that is being deployed today. This gap cannot be filled by 
public-sector and philanthropic capital alone; it requires private-sector 
engagement.

One important aspect of our ESG focus is how we can help mobilize 
players across the entire financial system to increase the flow of capital 
to address the major global challenges that are articulated by the United 
Nations Sustainable Development Goals (SDGs), such as affordable 
housing, sustainable energy, clean water and sanitation, education and 
health care. We refer to our efforts as Capital Deployment —  an enterprise-
wide initiative designed to unlock the necessary financing and investment 
to address these issues.

Continued financial innovation is also required to make a greater impact 
and spur additional private capital toward the SDGs. A key opportunity 
for us to stimulate additional private capital to finance sustainable 
development in emerging and developing markets is through an approach 
known as blended finance —  the combination of various sources of capital 
to accommodate different risk tolerances and return requirements. 

22 |   BANK OF AMERICA 2018

water and sanitation. This $50 million 
fund will impact 4.6 million people in 
India, Indonesia, Cambodia and the 
Philippines.

We also provided a $250,000 grant 
to GivePower Foundation to install 
solar-powered desalination systems, 
bringing safe water to communities in 
developing areas. Since 2015, we have 
delivered $1.75 million in grants to 
the GivePower Foundation, which has 
supported solar technology in over 1,800 
schools and 22 community microgrids.

Case study:
Transforming communities  
by empowering women
Solar power is transforming villages 
across India. In 2018, we partnered with 
four non-governmental organizations 
(NGOs) in India to set up 49 solar micro-
grids —  electrifying 1,420 homes and 
38 public institutions, including health 
care centers and schools. Powering 
the villages also empowered women in 
the community. With the solar panels 
installed, women could collect water 
in 20 minutes, rather than the typical 
three hours, which gave them more time 
to pursue education and employment 
opportunities.

Driving innovation
We work closely with many organi-
zations to help find solutions and 
drive innovation in sustainability. In 
2018, Bank of America was named 
a founding member of the Stanford 
Strategic Energy Alliance, which 
has produced a Sustainable Finance 
Initiative and will facilitate research 
and education between companies and 
faculty members.

We will continue to pursue capital 
deployment efforts that mobilize players 
across the entire financial system to 
increase the flow of capital to address 
major global challenges.

Photo: Our $500,000 grant to GRID Alternatives 
supports the organization’s SolarCorps Fellowship 
Program, which provides solar installation 
training while expanding access to solar power 
in underserved communities.

BANK OF AMERICA 2018 | 23

Meeting global challenges  
with committed capital

Our Capital Deployment efforts aim 
to unlock vital financing to address 
our target SDGs. Highlights of our 
work include:

Environmental business  
commitment
Bank of America is leveraging resources 
to support clean and renewable energy 
around the globe. In 2018, we deployed 
$21.5 billion in capital to support low- 
carbon, sustainable business activities 
through lending, investing, capital raising 
and developing financial solutions for 
clients. Over the past six years, we have 
delivered nearly $105 billion toward our 
environmental business commitment to 
deploy $125 billion by 2025. For example, 
in partnership with Vivint Solar, Inc., we 
developed a standalone financing vehicle 
that allowed the company to completely 
recycle its working capital in a rooftop 
installation. This work is reshaping how 
the residential solar industry develops 
and finances rooftop solar and supports 
95MWs of residential solar for the 
company, providing more attractive 
clean energy solutions for thousands of 
customers nationwide.

Blended Finance Catalyst Pool
In November 2018, we launched the 
Blended Finance Catalyst Pool, a new 
financing initiative to provide $60 million 
in capital and mobilize additional private 

capital to help address the SDGs. This 
new pool of Bank of America funding 
supports deals that would ordinarily fall 
outside of our Risk Framework, but by 
which, through our participation, we can 
drive significant leverage and impact.

In January 2019, we announced the first 
two projects that will benefit from this 
capital. We are investing $2.5 million in 
the $50 million LISC Charlotte Housing 
Investment Fund, which will support the 
construction of affordable housing in 
our headquarter city. Our investment is 
expected to help house more than 1,500 
families. We also made a $5 million 
commitment to invest in the soon-to-be 
launched responAbility Access to Clean 
Power Fund, which aims to finance the 
expansion of off-grid, affordable solar 
power for residential and small busi-
nesses in sub-Saharan Africa and India. 
Our investment is expected to help 
provide clean energy to 6 million people 
and 6,000 small businesses in energy 
impoverished areas.

Addressing clean water 
and sanitation
In 2018, we closed on our $5 million 
loan to WaterEquity’s WaterCredit 
Investment Fund 3, which immediately 
deployed the capital to microfinance 
institutions on the ground to provide 
loans that connect households to clean 

Improving 
lives through 
community 
development

As a leader in community development, Bank of America is delivering financing solutions 
that build and preserve affordable housing, create jobs through economic development, 
and support environmentally sustainable business activity. This includes a commitment 
from our Community Development Banking, which deployed $4.7 billion in loans, tax credit 
equity investments and other real estate development solutions in 2018.

Community Development Banking remains focused on providing safe housing options, 
with an added emphasis on employment opportunities. Much of this effort is driven by 
creating affordable housing for families, seniors, students, veterans, the formerly homeless, 
those with special needs and other at-risk groups. In 2018, Community Development 
Banking financed more than 16,000 housing units —  of which, over 15,000 were affordable.

Revitalizing the  
Jordan Downs  
housing project

Jordan Downs, a 1950s-era public housing 
development in the Watts neighborhood of 
Los Angeles, is being transformed through 
a public-private partnership involving Bank 
of America Merrill Lynch, the city of Los 
Angeles, the Los Angeles Housing Authority, 
nonprofit developer BRIDGE Housing, and 
for-profit developer Michaels Organization 
Development Company.

The multiyear redevelopment project encom-
passes construction of 1,400 new affordable 
housing units with new retail, a community 
center and parks. For the initial phase of 
the project, Bank of America Merrill Lynch 

provided $56.7 million in construction loans 
and $50.4 million in low-income housing tax 
credit (LIHTC) equity to construct 250 new 
affordable housing units.

Improving resident services and creating 
jobs are also part of the life-changing impact 
of Jordan Downs. The project created 65 
new jobs, of which 46 were filled by Jordan 
Downs residents, participants in YouthBuild® 
and other community members. As the 
project continues, there will be additional 
opportunities for residents to apply for jobs 
to help rebuild their community —  and build 
successful lives.

24 | BANK OF AMERICA 2018

“We are committed to helping 
underserved neighborhoods become 
thriving communities. Community 
Development Banking uses a wide 
variety of financing solutions to 
help provide affordable housing, 
improve education and create jobs, 
thereby improving the quality of 
life for residents and creating more 
sustainable neighborhoods.”

Jim DeMare
Co-Head of Global FICC Trading and Head of 
the Commercial Real Estate Bank (CREB) 

1,400

Redevelopment of Jordan Downs  
will include 1,400 new affordable 
housing units

Photo: Raul Anaya, market president for 
Greater Los Angeles, is joined by Mayor Eric 
Garcetti and other city officials, developers, 
activists, and residents at the groundbreaking 
ceremony for the new Jordan Downs housing 
development. (Photo by Ted7 Photography, 
courtesy of BRIDGE Housing).

A deep connection to  
the communities we serve

At Bank of America, we are making 
financial lives better through a 
tailored, community-centered 
approach that matches our  products 
and services, jobs, and capital 
to meet the unique needs of our 
clients in low- and moderate- 
income (LMI) communities.

From managing daily finances 

to establishing good credit, we 
help people build their financial 
foundations through safe and 
transparent products, such as 
our Bank of America Advantage 
SafeBalance Banking™, an account 
that prevents overdraft fees. In the 
past two years, more than 400,000 
Advantage SafeBalance Banking 
accounts have been opened, under-
scoring how we are connecting 
people to tailored products that 
best serve their needs.

Our community financial 
centers also provide convenient 
access to our team of professionals 
trained to serve our clients’ needs. 
In addition to being well-versed 
in banking resources, employees 
in community  financial centers 
receive training on Better Money 
Habits® to share financial know-
how with clients about topics such 
as rebuilding credit, savings and 
budgeting, and more.

To build pathways to economic 

mobility, we invest in and hire 
directly from the communities 
we serve by partnering with local 
nonprofit organizations to foster 

a diverse pipeline of talent and 
connect individuals to meaningful 
career opportunities. In June 2018, 
we committed to hiring 10,000 indi-
viduals from LMI neighborhoods 
over five years through our Pathways 
career development program.
We are also equipping our 
employees with career develop-
ment tools and resources through 
the Academy at Bank of America, 
including on- boarding, mentoring 
and career advice, and long-term 
development training. Nearly 
40,000 Consumer and Small 
Business employees participated 
in the training in 2018, with one- 
quarter moving their careers forward.
Rounding out our approach to 
enable economic mobility in LMI 
communities, loans and philan-
thropic investments help to finance 
the institutions, individuals and 
programs that help make neighbor-
hoods stronger. For example, we 
invest in community development 
 financial institutions (CDFIs) to 
extend credit to those unable to 
qualify for traditional loans, and we 
now have a $1.5 billion portfolio of 
loans and investments to 255 CDFIs 
across the United States, Puerto 
Rico and the District of Columbia.

Photo Above: At the Boyle Heights 
Community financial center in Los Angeles, 
and all around the U.S., we are connecting 
communities to the resources they need 
to succeed.

“We understand the unique challenges clients in LMI neighborhoods 
face managing their day-to-day finances, improving credit and 
building long-term financial wellness. Delivering tailored resources 
to these clients is an important part of our strategy because when 
these communities are made stronger, we all benefit.”

Dean Athanasia
President of Consumer and Small Business

BANK OF AMERICA 2018 | 25

Driving economic mobility 
and social progress

To help individuals and families achieve a more secure financial life, we 
have invested $2 billion of philanthropic capital over the past 10 years to 
advance economic mobility through the funding of workforce development 
and education, community development and basic needs. For example, in 
early 2019, the Women of Ireland Fund established the first endowment 
in Ireland to support charities and social enterprises seeking to enhance 
women’s economic mobility. The €1 million, three-year fund will be matched 
by the Irish government to create a €2 million fund for women’s workforce 
development programs.

Additionally, we are creating thriving communities through resources, 
capital deployment, and the power of our employee volunteers. This 
includes our free Better Money Habits financial education platform, now 
fully available in Spanish and English. Recent analysis indicated 1 in 4 users 
of Better Money Habits content and tools grew their savings by 20 percent 
or more.

Arts matter

We believe in the power of the arts to help 
economies thrive, educate and enrich societies, 
and create greater cultural understanding. 
That is why we are a leader in helping the arts 
flourish across the globe, supporting more than 
2,000 nonprofit  cultural institutions each year.

With unique programs such as Museums 
on Us®, Art in our Communities®, and the 
Bank of America Art Conservation Project, 
we are  creating access for our customers 
and employees, helping art museums create 
revenue-generating opportunities, and 
conserving  cultural treasures from around 
the world.

>2,000 

nonprofit cultural institutions  
supported annually

Investing in young people

In 2019, as part of our broader commitment to 
preparing young adults for workforce success, 
we expanded our long-standing partnership with 
City Year to help students succeed in school and 
prepare young leaders for fulfilling careers in the 
United States, United Kingdom and South Africa. 
The collaboration represents the first time a cor-
porate sponsor is investing in teams in all three 
countries where City Year operates.

Celebrating 15 years of Neighborhood Builders 
and creating stronger communities

In response to nonprofits’ need to 
access capital for strategic growth, 
we’ve developed Capital Connections, 
which leverages our robust partnerships 
with CDFIs to connect Neighborhood 
Builders to low-interest loans. Recently, 
Habitat for Humanity® of Durham in 
Durham, N.C., a 2017 Neighborhood 
Builder awardee, secured $1.5 million in 
capital to expand its housing program. 
The organization typically builds, sells 
and finances 25 homes and repairs 50 
homes annually, mostly in low-income 
areas of the city.

To mark the 15th year of our 
Neighborhood Builders® program in 
2018, which supports nonprofits and 
nonprofit leaders who address economic 
mobility, we expanded the number of 
annual program awards from 66 to 98. 
The awards offer selected nonprofits 
$200,000 in flexible funding, in-person 
leadership development, a network of 
peer organizations, and the opportunity 
to access capital. A complementary 
program, Neighborhood Champions, will 
be introduced in 42 new cities in 2019 
to support nonprofit leadership across 
the U.S. Each nonprofit awardee will 
receive $50,000 in flexible funding and 
virtual leadership development for the 
organization.

26 | BANK OF AMERICA 2018

>$220M

Through Neighborhood Builders, 
we’ve invested more than 
$220 million in 1,000+ local  
nonprofits and provided leader-
ship development to 2,000+ 
nonprofit executives since 2004.

Investing in  
women

Women play a vital role in driving the economic growth that fuels the global economy. Through our partnerships, women 
entrepreneurs have the power to succeed through mentoring, training and access to capital; we have helped more than 
10,000 women from 80 countries grow their businesses.

Global Ambassadors 
Program
Through our Global Ambassadors 
Program, a partnership with Vital 
Voices, more than 160 women 
leaders of small businesses and 
social enterprises from 66 coun-
tries have been connected to 
mentoring and workshops to build 
organizational management, finan-
cial acumen and leadership skills.

Cherie Blair 
Foundation 
We partner with the Cherie Blair 
Foundation on its Mentoring 
Women in Business program, which 
has matched more than 2,000 
women in developing and emerg-
ing countries to online mentors, 
including more than 500 mentors 
from Bank of America.

Tory Burch Foundation 
Capital Program 
Our $50 million investment in the 
Tory Burch Foundation Capital 
Program, which connects women 
business owners to affordable 
loans, has delivered capital through 
CDFIs to more than 1,800 women 
in 16 states.

Kiva 
Through our partnership with 
Kiva, we are providing more than 
$1 million in funds to women busi-
ness owners, and have assisted 
more than 7,200 women entrepre-
neurs in more than 30 countries.

The Bank of America 
Institute for Women’s 
Entrepreneurship  
at Cornell 
The Bank of America Institute 
for Women’s Entrepreneurship 
at Cornell offers the only online 
certificate program that helps 
women entrepreneurs develop the 
skills and knowledge they need to 
build, manage and grow successful 
businesses. The institute will train 
5,000 women entrepreneurs over 
the next four years.

BANK OF AMERICA 2018 | 27

Sharing our success — ESG highlights

Environmental, social and governance (ESG) principles help define how Bank of America delivers 
responsible, sustainable growth, how we contribute to the global economy, and how we share success 
with the clients and communities we serve.

Capital deployment

ESG client balances

In 2018, we mobilized, conservatively, 
more than $50 billion that impacted 
a key subset of the SDGs.

Environmental business 
commitment

Deployed $21.5 billion in capital to 
support low-carbon, sustainable business 
activities through lending, investing, 
capital raising, and developing financial 
solutions for clients around the world 
as part of our environmental business 
commitment to deploy $125 billion by 
2025. Since 2013, we have delivered 
nearly $105 billion toward this goal.

Green bonds and 
social bonds

Issued our fourth and largest green 
bond for $2.25 billion and issued a 
$500 million social bond —  the first 
social bond issued by a U.S. bank. 

“Our green bond and social bond 
programs demonstrate that 
the bank is truly committed 
to the communities we serve, 
while also giving us access 
to investors that would not 
typically be funding sources for 
a bank. Fundamentally, these are 
a means for society to advocate 
for a sustainable composition 
of the asset side of the balance 
sheet.”
Andrei Magasiner
Treasurer

$17.9 billion in assets with a clearly 
defined ESG investment approach.

CDFI lending 

We originated $200 million in loans 
as part of our more than $1.5 billion 
investment in 255 CDFIs.

Announced a $20 million Veteran 
Entrepreneur Lending Program to 
connect veteran business owners with 
affordable capital through participating 
CDFIs to help grow their businesses.

Community 
Development Banking 

Through Community Development 
Banking, we deployed more than 
$4.7 billion in loans, tax credit equity 
investments and other real estate 
development solutions in 2018.

Small business lending 

One of the top small business lenders 
with $34.7 billion total outstanding 
small business loan balances as of Q3 
2018, according to the FDIC.

Bank of America 
Art Conservation 
Project

Through the Bank of America Art 
Conservation Project, we provided grants 
to fund 21 conservation projects 
in nine countries to conserve paintings, 
sculptures, and archaeological pieces that 
are important to cultural heritage.

Better Money 
Habits 

In 2018, visitors to Better Money Habits 
home loans content were 13 times 
more likely to obtain a home loan 
within 30 days.

In 2018, visitors to Better Money Habits 
college content were five times more 
likely to open a savings account within 
30 days.

BetterMoneyHabits.com Spanish 
content has resulted in higher average 
time on site, up 37%, and visitors are 
more likely to return to the site by 
4 percentage points.

Philanthropic giving 

Invested more than $200 million in 
philanthropic capital from the Bank of 
America Charitable Foundation as part of 
our $2 billion, 10-year giving goal.

Employee giving 
and volunteering

Last year, employees volunteered 
2 million hours, and donated or pledged 
$23 million to causes they care about. 
The impact of employee giving and 
matching gifts from the bank totaled 
$53 million in support of the communi-
ties we serve.

28 |   BANK OF AMERICA 2018

Being a great place to work — 2018 highlights

A critical component of how we drive responsible growth is making Bank of America a great place to work. 
We deliver on our commitment to be a great place to work by recognizing and rewarding performance, 
ensuring an inclusive workplace for our employees around the world, creating opportunities for our 
employees to develop and grow, and supporting employees’ physical, emotional and financial wellness.

Being an inclusive workplace 
for all of our employees around 
the world

Creating opportunities 
for employees to grow
and develop

Recognizing and
rewarding performance

• More than 50% of our global 
workforce are women and more than 
45% of our U.S.-based workforce 
are people of color.
• Our 11 Employee Networks, with more 
than 250 chapters made up of over 
120,000 memberships worldwide, 
connect employees with shared interests 
and those who support them. 
• 60,000+ employees have par-
ticipated in courageous conversations, 
group and one-on-one discussions which 
encourage employees to discuss topics 
that are important to them, like race and 
gender dynamics, social justice, LGBT+ 
equality and mental health.

• In 2018, more than 27,000 new 
teammates joined our company, includ-
ing more than 3,500 future leaders who 
were recent college graduates.
• We have invested in leading platforms, 
including The Learning Hub, 
myLearning and myCareer, to help 
employees develop their skills and grow 
their careers at Bank of America.
• 86% of eligible managers 
participated in some form of manager 
development training in 2018.
• Our tuition reimbursement program 
provides employees up to $5,250 per 
year for courses related to current or 
future roles at our company.
• Bank of America supports employees’ 
commitment to improving their commu-
nities, and allows individuals up to two 
paid hours per week for volunteering 
with nonprofi t organizations.

• We have been an industry leader in 
establishing an internal minimum rate 
of pay for our U.S. hourly employees and 
have made regular increases over many 
years. Two years ago, we raised 
our minimum wage to $15 per 
hour and our minimum wage is 
higher today. Our average rate for 
all U.S. hourly employees is signifi cantly 
above this level. 
• In 2017 and 2018, 90% and 95% of 
our employees, respectively, shared in 
our success by receiving special compen-
sation awards. We’re a leader in providing 
this type of award for two consecutive 
years.
• We had 4 million+ recognition 
moments (eCards given and received) in 
2018. That’s more than eight recognition 
moments every minute.

Supporting employees’
physical, emotional and 
financial wellness

• There has been no increase in 
medical premiums for employees earning 
less than $50,000 since 2012. For higher- 
paid employees, the average contribution 
increase since 2012 has been below the 
national health care trend.

• On average, 85% of employees 
and their partners have completed 
annual health screenings over the past 
fi ve years; in 2018, nearly 200,000 
employees, spouses/partners 
completed their annual health screenings. 
• In 2018, we doubled the number 
of free, in-person confi dential 
counseling sessions available 
through our Employee Assistance Pro-
gram for our U.S. employees and eligible 
family members.

• Since 2014, 85,000+ employees 
have been supported by our Life Event 
Services team, an internal, highly special-
ized group providing resources, benefi ts, 
counseling and other personalized 
support to employees who faced major 
life events. 
• We provide 401(k) matching contribu-
tions of up to 5% of eligible pay a er 
one year of service, plus 2% or 3% in 
annual company contributions.

BANK OF AMERICA 2018   | 29

We ask our  
teammates, too

A message from Sheri Bronstein
Chief Human Resources Officer

Listening to our teammates answer the question “What 
would you like the power to do?” has helped us shape 
all we do to be a great place to work. To serve our 
customers and communities well, we have built a 
great team. And we are investing in our teammates 
so they can deliver for our clients and customers and 
impact the communities where we live and work.

30 | BANK OF AMERICA 2018

Our focus includes recognizing and 
rewarding performance, ensuring a 
diverse and inclusive workplace for our 
employees around the world, creating 
opportunities for our employees to 
develop and grow, and supporting 
employees’ physical, emotional and 
financial wellness.

Rewarding our  
teammates’ performance
We offer fair, competitive compensa-
tion based on market rates by role and 
performance. We regularly benchmark 
compensation against other companies, 
both within and outside our industry, 
to ensure our pay is competitive with 
comparable roles in the market.

We’re committed to supporting a competi-
tive minimum rate of pay. We have been an 
industry leader in establishing an internal 
minimum rate of pay for our U.S. hourly 
employees and have made regular increases 
over many years. Two years ago, we raised 
our minimum wage to $15 per hour, and our 
minimum wage is higher today. Our average 
rate for all U.S. hourly employees is signifi-
cantly above this level.

For the last two 
years, we’ve shared 
our success with our  
employees through 
special compensation  
awards for approxi-
mately 90 percent  
and 95 percent, 
respectively, of our 
teammates globally.

We’re proud to be a leader among compa-
nies providing awards of this type to our 
employees for two consecutive years, from 
cash bonuses to stock, totaling more than 
$1 billion. These awards were in addition 
to the compensation these teammates 
otherwise received. These awards recognize 
the contributions of our employees to 
drive responsible growth, and reflect the 
continuing benefits of U.S. tax reform to 
our company.

Bringing our whole selves to work 
We are proud to be a team that mirrors 
the diversity of our customers, clients and 
communities: More than 50 percent of our 
global workforce are women, and more than 
45 percent of our U.S.-based workforce are 
people of color. Our commitment comes 
from the top: Our CEO chairs the company’s 
Global Diversity and Inclusion Council, 
which is composed of leaders representing 
every line of business and geography, and is 
responsible for setting and upholding diver-
sity and inclusion goals and practices. And 
at every level, we drive a culture of inclusion 
through a range of programs to connect 
employees, executives, and thought leaders 

across our company, including our 11 Employee Networks with over 120,000 
memberships worldwide. We also encourage our teammates to have coura-
geous conversations, which foster inclusion, understanding, and positive action 
by creating awareness of employees’ experiences and perspectives related to 
differences in background, experience or viewpoints.

Providing opportunities for development and growth
We provide resources, programs and tools to help employees develop and grow 
at the company. Our tuition reimbursement program provides employees up to 
$5,250 per year for courses related to current or future roles at our company. 
We also offer online learning courses, professional growth, and development 
of our managers through programs like Manager Excellence and access to the 
myCareer website to view open positions. In 2018, we helped support more 
than 17,000 employees find new roles within the company, and we had  
historically low employee turnover.

Supporting wellness 
We support the physical, emotional and financial wellness of our teammates 
by providing quality health care with annual premium increases below the 
national U.S. average. We offer health care coverage for all U.S. benefits- 
eligible employees that costs them no more than 7 percent of their wages. 
We also provide industry-leading benefits such as 16 weeks of paid parental 
leave —  maternity, paternity, and adoption; 20 days of paid bereavement leave 
for full-time employees who lose a spouse, partner or child; and confidential 
counseling through our Employee Assistance Program. And for the moments 
when employees and their families need support the most, our internal, 
highly specialized Life Event Services (LES) group provides personalized 
support to them. More than 85,000 team members have worked with the 
highly trained and empathetic LES team members for needs around survivor 
support, domestic violence, natural and man-made disasters, transition 
related to military service, and other major life events. The team provides 
resources, benefits, counseling and other support, tapping experts inside and 
outside the company. Overall, employee satisfaction with our benefits is at an 
all-time high. You can read more about our benefits, resources and programs 
on the previous page. 

We are proud that others have recognized us for our focus on our teammates. 
For instance, Euromoney recognized us as the World’s Best Bank for Diversity 
and Inclusion, and we were awarded the 2019 Catalyst Award for our innova-
tive organizational efforts to advance women in the workplace. We were also 
named as one of the 100 Best Companies to Work For by Fortune magazine 
and the global research and consulting firm, Great Place to Work® for our focus 
on being a great place to work and delivering value for our customers and  
clients, and named as the only financial services company on Fortune’s  
inaugural Best Big Companies to Work For list, which recognized seven  
companies with more than 100,000 U.S.-based employees that passed the 
Great Place to Work Certification bar. You can read more about the external 
recognition we have received in our proxy statement.

We had one of our best years ever in 2018: strong recognition for customer 
service in every category, the highest levels of customer satisfaction, and 
record financial results that allowed us to keep investing in how we serve our 
clients and customers. We attracted more than 27,000 new teammates to our 
company, including more than 3,500 future leaders who were recent college 
graduates. Our teammates’ consistent commitment to our purpose allows us  
to deliver for our customers, communities and shareholders. Our commitment 
to our teammates is demonstrated by our continued investment in making 
Bank of America a great place to work.

BANK OF AMERICA 2018 | 31

Bank of America Corporation —  Financial Highlights
Bank of America Corporation (NYSE: BAC) is headquartered in Charlotte, North Carolina. As of December 31, 2018, we operated in 
all 50 states, the District of Columbia, the U.S. Virgin Islands, Puerto Rico and more than 35 countries. Through our banking and 
various nonbank subsidiaries throughout the United States and in international markets, we provide a diversified range of banking 
and nonbank financial services and products through four business segments: Consumer Banking, Global Wealth and Investment 
Management, Global Banking, and Global Markets.

Financial Highlights ($ in millions, except per share information)

For the year
Revenue, net of interest expense
Net income

Earnings per common share

Diluted earnings per common share

Dividends paid per common share

Return on average assets
Return on average tangible common shareholders’ equity 1
Effi  ciency ratio

Average diluted common shares issued and outstanding

At year-end
Total loans and leases

Total assets

Total deposits

Total shareholders’ equity

Book value per common share
Tangible book value per common share 1
Market price per common share

Common shares issued and outstanding
Tangible common equity ratio 1

 $

2018
91,247 
 28,147 
 2.64 
 2.61 
 0.54 
          1.21%
 15.55 
 58.50 
 10,237 

 $

2018
946,895 
 2,354,507 
 1,381,476 
 265,325 
 25.13 
 17.91 
 24.64 
 9,669 
7.6%

 $

2017
87,352 

 18,232 

 1.63 

 1.56 

 0.39 
0.80%

 9.41 

 62.67 

 10,778 

2017
936,749 

 $

 2,281,234 

 1,309,545 

 267,146 

 23.80 

 16.96 

 29.52 

 10,287 

7.9%

 $

2016
83,701 

 17,822 

 1.57 

 1.49 

 0.25 
           0.81%

 9.51 

 65.81 

 11,047 

2016
906,683 

 $

 2,188,067 

 1,260,934 

 266,195 

 23.97 

 16.89 

 22.10 

 10,053 

8.0%

 1Represents a non-GAAP financial measure. For more information on these measures and ratios, and a corresponding reconciliation to GAAP financial measures, see Supplemental Financial 
Data on page 39 and Non-GAAP Reconciliations on page 40 of the 2018 Financial Review section. 

Total Cumulative Shareholder Return2

BAC Five-Year Stock Performance

$250

$200

$150

$100

$50

$0

2013

2014

2015

2016

2017

2018

December 31 

2013  2014  2015  2016  2017  2018

 Bank of America Corporation 
 S&P 500 
 KBW Bank Sector Index 

$100  $116  $110  $147  $199  $169
150
100 
138
100 

114 
109 

157 
167 

129 
141 

115 
110 

2 This graph compares the yearly change in the Corporation’s total cumulative shareholder return 
on its common stock with (i) the Standard & Poor’s 500 Index and (ii) the KBW Bank Index for 
the years ended December 31, 2013 through 2018. The graph assumes an initial investment of 
$100 at the end of 2013 and the reinvestment of all dividends during the years indicated.

32 |   BANK OF AMERICA 2018

$35
$30
$25
$20
$15
$10
$5
$0

2014 

2015 

2016 

2017 

  HIGH  $18.13 

$18.45 

$23.16 

$29.88 

  LOW 

14.51 

  CLOSE  17.89 

15.15 

16.83 

11.16 

22.10 

22.05 

29.52 

2018
$32.84
22.73
24.64

Book Value Per Share/
Tangible Book Value Per Share

.

2
3
1
2
$

3
4

.

4
1
$

8
4

.

2
2
$

6
5

.

5
1
$

.

7
9
3
2
$

.

9
8
6
1
$

0
8

.

3
2
$

.

6
9
6
1
$

3
1

.

5
2
$

.

1
9
7
1
$

2014

2015

2016

2017

2018

Book Value Per Share

Tangible Book Value Per Share 3

3Tangible book value per share is a non-GAAP fi nancial measure.

 
 
Table 10 Average Balances and Interest Rates - FTE Basis

(Dollars in millions)

Earning assets

Interest-bearing deposits with the Federal Reserve, non-U.S.

Average
Balance

Interest
Income/
Expense

2018

Yield/
Rate

Average
Balance

Interest
Income/
Expense

2017

Yield/
Rate

Average
Balance

Interest
Income/
Expense

2016

Yield/
Rate

central banks and other banks

$

139,848

$

1,926

1.38% $

127,431

$

1,122

0.88% $

133,374

$

Time deposits placed and other short-term investments

9,446

216

Federal funds sold and securities borrowed or purchased under 

12,112

241

1.99

9,026

agreements to resell (1)

Trading account assets
Debt securities
Loans and leases (2):

Residential mortgage
Home equity
U.S. credit card

Non-U.S. credit card (3)
Direct/Indirect and other consumer (4)

Total consumer

U.S. commercial

Non-U.S. commercial

Commercial real estate (5)

Commercial lease financing

Total commercial

Total loans and leases (3)

Other earning assets (1)

Total earning assets (1,6)

Cash and due from banks

251,328

132,724
437,312

207,523
53,886
94,612
—
93,036

449,057

304,387

97,664

60,384

21,557

3,176

4,901
11,837

7,294
2,573
9,579
—
3,104

22,550

11,937

3,220

2,618

698

483,992

18,473

2.29

1.26

3.69
2.66

3.51
4.77
10.12
—
3.34

5.02

3.92

3.30

4.34

3.24

3.82

222,818

129,007
435,005

197,766
62,260
91,068
3,929
96,002

451,025

292,452

95,005

58,502

21,747

1,806

4,618
10,626

6,831
2,608
8,791
358
2,734

21,322

9,765

2,566

2,116

706

467,706

15,153

0.81

3.58
2.44

3.45
4.19
9.65
9.12
2.85

4.73

3.34

2.70

3.62

3.25

3.24

2018 Financial Review

1,922,061

1,980,231

918,731

933,049

58,112

36,475

76,957

67,379

76,524

41,023

3,224

4,300

5.62

3.40

4.40

3.97

4.19

3.02

Other assets, less allowance for loan and lease losses

Total assets

Interest-bearing liabilities

U.S. interest-bearing deposits:

Savings

NOW and money market deposit accounts

Consumer CDs and IRAs

Negotiable CDs, public funds and other deposits

Total U.S. interest-bearing deposits

Non-U.S. interest-bearing deposits:

Banks located in non-U.S. countries

Governments and official institutions

Time, savings and other

Total non-U.S. interest-bearing deposits

Total interest-bearing deposits

Federal funds purchased, securities loaned or sold under 

agreements to repurchase, short-term borrowings and other 
interest-bearing liabilities (1)

Trading account liabilities

Long-term debt

Total interest-bearing liabilities (1,6)

Noninterest-bearing sources:

Noninterest-bearing deposits
Other liabilities (1)

Shareholders’ equity

Total liabilities and shareholders’ equity

Net interest spread
Impact of noninterest-bearing sources

25,830

319,185

$ 2,325,246

$

54,226

$

676,382

39,823

50,593

821,024

2,312

810

65,097

68,219

6

2,636

157

991

3,790

39

—

666

705

889,243

4,495

269,748

50,928

230,693
1,440,612

5,839

1,358

7,645
19,337

425,698

194,188
264,748
$ 2,325,246

27,995

318,577

$ 2,268,633

0.01% $
0.39

0.39

1.96

0.46

1.69

0.01

1.02

1.03

0.51

2.17

2.67

3.31
1.34

53,783

$

628,647

44,794

36,782

764,006

2,442

1,006

62,386

65,834

5

873

121

354

1,353

21

10

547

578

829,840

1,931

274,975

45,518

225,133
1,375,466

3,146

1,204

6,239
12,520

439,956

181,922
271,289
$ 2,268,633

0.14

0.27

0.96

0.18

0.85

0.95

0.88

0.88

0.23

1.14

2.64

2.77
0.91

605

140

967

4,563
9,263

6,488
2,713
8,170
926

2,371
20,668

8,101

2,337

1,773
627

12,838

33,506

2,496
51,540

5
294

133

160

592

32

9
382

423

216,161

129,766
418,289

188,250
71,760
87,905

9,527
94,148

451,590

276,887
93,263

57,547

21,146

448,843

900,433
59,775

1,866,824

27,893

295,501
$ 2,190,218

589,737
48,594

32,889

720,715

3,891

1,437
59,183

64,511

785,226

1,015

1,933

1,018

5,578
9,544

252,585

37,897

228,617
1,304,325

437,335

182,715
265,843
$ 2,190,218

0.01% $

49,495

$

0.45%

1.55

0.45

3.52
2.23

3.45
3.78
9.29
9.72
2.52

4.58

2.93

2.51

3.08

2.97

2.86

3.72

4.18

2.76

0.01%

0.05

0.27

0.49

0.08

0.82

0.64

0.65

0.66

0.13

0.77

2.69

2.44
0.73

2.03%
0.22

2.25%

2.06%
0.36

2.42%

2.11%
0.26

2.37%

$ 45,592

$ 41,996

Net interest income/yield on earning assets (7)

$ 48,042

(1)  Certain prior-period amounts have been reclassified to conform to current period presentation.
(2)  Nonperforming loans are included in the respective average loan balances. Income on these nonperforming loans is generally recognized on a cost recovery basis.
(3) 

Includes assets of the Corporation’s non-U.S. consumer credit card business, which was sold during the second quarter of 2017.
Includes non-U.S. consumer loans of $2.8 billion, $2.9 billion and $3.4 billion in 2018, 2017 and 2016, respectively.
Includes U.S. commercial real estate loans of $56.4 billion, $55.0 billion and $54.2 billion, and non-U.S. commercial real estate loans of $4.0 billion, $3.5 billion and $3.4 billion in 2018, 2017
and 2016, respectively.
Interest income includes the impact of interest rate risk management contracts, which decreased interest income on the underlying assets by $171 million, $44 million and $176 million in 2018, 
2017 and 2016, respectively. Interest expense includes the impact of interest rate risk management contracts, which decreased interest expense on the underlying liabilities by $130 million, $1.4 
billion and $2.1 billion in 2018, 2017 and 2016, respectively. For more information, see Interest Rate Risk Management for the Banking Book on page 89.

(4) 

(5) 

(6) 

(7)  Net interest income includes FTE adjustments of $610 million, $925 million and $900 million in 2018, 2017 and 2016, respectively.

Bank of America 2018     33 

Financial Review
Table of Contents

Executive Summary

Recent Developments
Financial Highlights
Balance Sheet Overview
Supplemental Financial Data
Business Segment Operations

Consumer Banking
Global Wealth & Investment Management
Global Banking
Global Markets
All Other

Off-Balance Sheet Arrangements and Contractual Obligations
Managing Risk
Strategic Risk Management
Capital Management
Liquidity Risk
Credit Risk Management

Consumer Portfolio Credit Risk Management
Commercial Portfolio Credit Risk Management
Non-U.S. Portfolio
Provision for Credit Losses
Allowance for Credit Losses

Market Risk Management

Trading Risk Management
Interest Rate Risk Management for the Banking Book
Mortgage Banking Risk Management

Compliance and Operational Risk Management
Reputational Risk Management
Complex Accounting Estimates
2017 Compared to 2016
Statistical Tables

Page
35
36
36
38
39
45
46
48
50
52
53
54
55
58
58
62
66
66
74
80
82
82
85
86
89
91
91
92
92
94
96

34     Bank of America 2018

Management’s Discussion and Analysis of Financial Condition and Results of Operations

(the  “Corporation”)  and 

its 
Bank  of  America  Corporation 
management  may  make  certain  statements  that  constitute 
“forward-looking  statements”  within  the  meaning  of  the  Private 
Securities Litigation Reform Act of 1995. These statements can be 
identified by the fact that they do not relate strictly to historical or 
current facts. Forward-looking statements often use words such as 
“anticipates,”  “targets,”  “expects,”  “hopes,”  “estimates,”  “intends,” 
“plans,” “goals,” “believes,” “continue” and other similar expressions 
or future or conditional verbs such as “will,” “may,” “might,” “should,” 
“would”  and  “could.”  Forward-looking  statements  represent  the 
Corporation’s current expectations, plans or forecasts of its future 
results,  revenues,  expenses,  efficiency  ratio,  capital  measures, 
strategy  and  future  business  and  economic  conditions  more 
generally,  and  other  future  matters.  These  statements  are  not 
guarantees  of  future  results  or  performance  and  involve  certain 
known and unknown risks, uncertainties and assumptions that are 
difficult to predict and are often beyond the Corporation’s control. 
Actual  outcomes  and  results  may  differ  materially  from  those 
expressed in, or implied by, any of these forward-looking statements. 
You  should  not  place  undue  reliance  on  any  forward-looking 
statement and should consider the following uncertainties and risks, 
as well as the risks and uncertainties more fully discussed under 
Item 1A. Risk Factors of our 2018 Annual Report on Form 10-K: the 
Corporation’s  potential  claims,  damages,  penalties,  fines  and 
reputational  damage  resulting  from  pending  or  future  litigation, 
regulatory proceedings and enforcement actions and the possibility 
that amounts may be in excess of the Corporation’s recorded liability 
and estimated range of possible loss for litigation and regulatory 
exposures; the possibility that the Corporation could face increased 
servicing, securities, fraud, indemnity, contribution or other claims 
from one or more counterparties, including trustees, purchasers of 
loans, underwriters, issuers, other parties involved in securitizations, 
monolines or private-label and other investors; the possibility that 
future representations and warranties losses may occur in excess 
of  the  Corporation’s  recorded  liability  and  estimated  range  of 
possible loss for its representations and warranties exposures; the 
Corporation’s  ability  to  resolve  representations  and  warranties 
repurchase and related claims, including claims brought by investors 
or trustees seeking to avoid the statute of limitations for repurchase 
claims;  the  risks  related  to  the  discontinuation  of  the  London 
InterBank  Offered  Rate  and  other  reference  rates,  including 
increased expenses and litigation and the effectiveness of hedging 
strategies;  uncertainties  about  the  financial  stability  and  growth 
rates of non-U.S. jurisdictions, the risk that those jurisdictions may 
face difficulties servicing their sovereign debt, and related stresses 
on financial markets, currencies and trade, and the Corporation’s 
exposures to such risks, including direct, indirect and operational; 
the  impact  of  U.S.  and  global  interest  rates,  inflation,  currency 
exchange  rates,  economic  conditions,  trade  policies,  including 
tariffs,  and  potential  geopolitical  instability;  the  impact  on  the 
Corporation’s business, financial condition and results of operations 
of a potential higher interest rate environment; the possibility that 
future credit losses may be higher than currently expected due to 
changes  in  economic  assumptions,  customer  behavior,  adverse 
developments with respect to U.S. or global economic conditions 
and  other  uncertainties;  the  Corporation’s  ability  to  achieve  its 
expense  targets  and  expectations  regarding  net  interest  income, 
net charge-offs, loan growth or other projections; adverse changes 
to  the  Corporation’s  credit  ratings  from  the  major  credit  rating 
agencies; an inability to access capital markets or maintain deposits; 
estimates of the fair value and other accounting values, subject to 

impairment assessments, of certain of the Corporation’s assets and 
liabilities; uncertainty regarding the content, timing and impact of 
regulatory capital and liquidity requirements; the impact of adverse 
changes to total loss-absorbing capacity requirements and/or global 
systemically  important  bank  surcharges;  the  success  of  our 
reorganization of Merrill Lynch, Pierce, Fenner & Smith Incorporated; 
the potential impact of actions of the Board of Governors of the 
Federal  Reserve  System  on  the  Corporation’s  capital  plans;  the 
effect of regulations, other guidance or additional information on 
the  impact  from  the  Tax  Cuts  and  Jobs  Act;  the  impact  of 
implementation and compliance with U.S. and international laws, 
regulations and regulatory interpretations, including, but not limited 
to, recovery and resolution planning requirements, Federal Deposit 
Insurance  Corporation  assessments,  the  Volcker  Rule,  fiduciary 
standards and derivatives regulations; a failure in or breach of the 
Corporation’s operational or security systems or infrastructure, or 
those  of  third  parties,  including  as  a  result  of  cyber-attacks;  the 
impact on the Corporation’s business, financial condition and results 
of operations from the planned exit of the United Kingdom from the 
European  Union;  the  impact  of  a  prolonged  federal  government 
shutdown and uncertainty regarding the federal government’s debt 
limit; and other similar matters.

Forward-looking statements speak only as of the date they are 
made, and the Corporation undertakes no obligation to update any 
forward-looking statement to reflect the impact of circumstances or 
events that arise after the date the forward-looking statement was 
made.

Notes to the Consolidated Financial Statements referred to in 
the Management’s Discussion and Analysis of Financial Condition 
and Results of Operations (MD&A) are incorporated by reference 
into the MD&A. Certain prior-year amounts have been reclassified 
to conform to current-year presentation. Throughout the MD&A, 
the Corporation uses certain acronyms and abbreviations which 
are defined in the Glossary.

Executive Summary

Business Overview
The Corporation is a Delaware corporation, a bank holding company 
(BHC) and a financial holding company. When used in this report, 
“the  Corporation”  may  refer  to  Bank  of  America  Corporation 
individually, Bank of America Corporation and its subsidiaries, or 
certain of Bank of America Corporation’s subsidiaries or affiliates. 
Our  principal  executive  offices  are  located  in  Charlotte,  North 
Carolina. Through our banking and various nonbank subsidiaries 
throughout  the  U.S.  and  in  international  markets,  we  provide  a 
diversified range of banking and nonbank financial services and 
products  through  four  business  segments:  Consumer  Banking, 
Global Wealth & Investment Management (GWIM), Global Banking
and Global Markets, with the remaining operations recorded in All 
Other. We operate our banking activities primarily under the Bank 
of America, National Association (Bank of America, N.A. or BANA) 
charter. At December 31, 2018, the Corporation had approximately 
$2.4 trillion in assets and a headcount of approximately 204,000
employees.

As  of  December  31,  2018,  we  served  clients  through 
operations  across  the  U.S.,  its  territories  and  more  than  35
countries.  Our  retail  banking  footprint  covers  approximately  85 
percent of the U.S. population, and we serve approximately 66 
million consumer and small business clients with approximately 
4,300  retail  financial  centers,  approximately  16,300  ATMs,  and

Bank of America 2018     35 

leading digital banking platforms (www.bankofamerica.com) with 
more than 36 million active users, including over 26 million active 
mobile users. We offer industry-leading support to approximately 
three  million  small  business  owners.  Our  wealth  management 
businesses,  with  client  balances  of  approximately  $2.6  trillion, 
provide tailored solutions to meet client needs through a full set 
of  investment  management,  brokerage,  banking,  trust  and 
retirement  products.  We  are  a  global  leader  in  corporate  and 
investment  banking  and  trading  across  a  broad  range  of  asset 
classes  serving  corporations,  governments,  institutions  and 
individuals around the world.

Recent Developments

Capital Management
During  2018,  we  repurchased  $20.1  billion  of  common  stock 
pursuant  to  the  Board  of  Directors’  (the  Board)  repurchase 
authorizations under our 2018 and 2017 Comprehensive Capital 
Analysis and Review (CCAR) plans, including repurchases to offset 
equity-based  compensation  awards.  Also,  in  addition  to  the 
previously  announced  repurchases  associated  with  the  2018 
CCAR capital plan, on February 7, 2019, we announced a plan to 
repurchase an additional $2.5 billion of common stock through 
June 30, 2019, which was approved by the Board of Governors of 
the  Federal  Reserve  System  (Federal  Reserve).  For  additional 
information, see Capital Management on page 58. 

U.K. Exit from the EU
We  conduct  business  in  Europe,  the  Middle  East  and  Africa 
primarily  through  our  subsidiaries  in  the  U.K.  and  Ireland.  A 
referendum held in the U.K. in 2016 resulted in a majority vote in 
favor of exiting the European Union (EU). In March 2017, the U.K. 
notified  the  EU  of  its  intent  to  withdraw  from  the  EU,  which  is 
scheduled to occur on March 29, 2019. Negotiations between the 
U.K. and the EU regarding the terms, conditions and timing of the 
withdrawal  are  ongoing  and  the  outcome  remains  uncertain.  In 
preparation for the withdrawal, we have implemented changes to 
our  operating  model  in  the  region,  including  establishing  our 
principal EU banking and broker-dealer operations outside the U.K. 
The changes are expected to enable us to continue to service our 
clients  with  minimal  disruption,  retain  operational  flexibility, 
minimize transition risks and maximize legal entity efficiencies, 
independent of the outcome and timing of the withdrawal. 

LIBOR and Other Benchmark Rates
The U.K. Financial Conduct Authority (FCA), which regulates the 
London InterBank Offered Rate (LIBOR), announced in July 2017 
that it will no longer persuade or require banks to submit rates for 
LIBOR  after  2021.  This  announcement  along  with  financial 
benchmark reforms more generally and changes in the interbank 
lending markets have resulted in uncertainty about the future of 
LIBOR  and  certain  other  rates  or  indices  used  as  interest  rate 
“benchmarks.” These actions and uncertainties may trigger future 
changes  in  the  rules  or  methodologies  used  to  calculate 
benchmarks  or  lead  to  the  discontinuation  or  unavailability  of 
benchmarks. 

The Corporation has established an enterprise-wide initiative 
to identify, assess and monitor risks associated with the potential 
discontinuation or unavailability of benchmarks, including LIBOR, 
and the transition to alternative reference rates. As part of this 
initiative,  the  Corporation  is  actively  engaged  with  global 
regulators,  industry  working  groups  and  trade  associations  to 
develop  strategies  for  transitions  from  current  benchmarks  to 
alternative  reference  rates.  We  are  updating  our  operational 
processes and models to support new alternative reference rate 

36     Bank of America 2018

activity. In addition, we continue to analyze and evaluate legacy 
contracts  across  all  products  to  determine  the  impact  of  a 
discontinuation  of  LIBOR  or  other  benchmarks  and  to  address 
consequential changes to those legacy contracts. Certain actions 
required  to  mitigate  risks  associated  with  the  unavailability  of 
benchmarks  and  implementation  of  new  methodologies  and 
contractual  mechanics  are  dependent  on  a  consensus  being 
reached  by  the  industry  or  the  markets  in  various  jurisdictions 
around  the  world.  As  a  result,  there  is  uncertainty  as  to  the 
solutions that will be developed to address the unavailability of 
LIBOR or other benchmarks, as well as the overall impact to our 
businesses,  operations  and  results.  Additionally,  any  transition 
from current benchmarks may alter the Corporation’s risk profiles 
and models, valuation tools, product design and effectiveness of 
hedging strategies, as well as increase the costs and risks related 
to potential regulatory requirements.

Financial Highlights

Table 1 Summary Income Statement and Selected 

Financial Data

(Dollars in millions, except per share information)

2018

2017

Income statement

Net interest income
Noninterest income

Total revenue, net of interest expense

Provision for credit losses
Noninterest expense

Income before income taxes

Income tax expense

Net income

Preferred stock dividends

Net income applicable to common

Per common share information

Earnings
Diluted earnings
Dividends paid
Performance ratios

Return on average assets
Return on average common shareholders’

equity

Return on average tangible common 

shareholders’ equity (1)

Efficiency ratio

Balance sheet at year end
Total loans and leases
Total assets
Total deposits
Total common shareholders’ equity
Total shareholders’ equity

$

$

$

47,432
43,815
91,247
3,282
53,381
34,584
6,437
28,147
1,451
26,696

2.64
2.61
0.54

$

$

$

44,667
42,685
87,352
3,396
54,743
29,213
10,981
18,232
1,614
16,618

1.63
1.56
0.39

1.21%

0.80%

11.04

15.55

58.50

6.72

9.41

62.67

$ 946,895
2,354,507
1,381,476
242,999
265,325

$ 936,749
2,281,234
1,309,545
244,823
267,146

(1)   Return on average tangible common shareholders’ equity is a non-GAAP financial measure. For 
more information and a corresponding reconciliation to accounting principles generally accepted 
in the United States of America (GAAP) financial measures, see Non-GAAP Reconciliations on 
page 40. 

Net income was $28.1 billion, or $2.61 per diluted share in 2018
compared to $18.2 billion, or $1.56 per diluted share in 2017. 
The improvement in net income was driven by a decrease in income 
tax expense due to the impacts of the Tax Cuts and Jobs Act (the 
Tax Act), an increase in net interest income, higher noninterest 
income,  lower  provision  for  credit  losses  and  a  decline  in 
noninterest expense. Impacts from the Tax Act include a reduction 
in the federal corporate income tax rate to 21 percent from 35 
percent. In addition, results for 2017 included a reduction in net 
income of $2.9 billion due to the Tax Act, driven largely by a lower 
valuation of certain U.S. deferred tax assets and liabilities.

Net Interest Income
Net interest income increased $2.8 billion to $47.4 billion in 2018 
compared to 2017. Net interest yield on a fully taxable-equivalent 
(FTE) basis increased five basis points (bps) to 2.42 percent for 
2018.  These  increases  were  primarily  driven  by  higher  interest 
rates  as  well  as  loan  and  deposit  growth,  partially  offset  by 
tightening spreads, higher Global Markets funding costs and the 
impact of the sale of the non-U.S. consumer credit card business 
in 2017. For more information on net interest yield and the FTE 
basis, see Supplemental Financial Data on page 39, and for more 
information on interest rate risk management, see Interest Rate 
Risk Management for the Banking Book on page 89.

Provision for Credit Losses
The provision for credit losses decreased $114 million to $3.3 
billion  in  2018  compared  to  2017,  primarily  reflecting  a  2017 
single-name non-U.S. commercial charge-off and improvement in 
the commercial portfolio. In the consumer portfolio, the impact of 
the sale of the non-U.S. consumer credit card business in 2017 
was  more  than  offset  by  a  slower  pace  of  improvement  in  the 
consumer real estate portfolio, and portfolio seasoning and loan 
growth in the U.S. credit card portfolio. For more information on 
the provision for credit losses, see Provision for Credit Losses on 
page 82.

Noninterest Expense

Table 3 Noninterest Expense

Noninterest Income

Table 2 Noninterest Income

(Dollars in millions)

Card income
Service charges
Investment and brokerage services
Investment banking income
Trading account profits
Other income

Total noninterest income

2018

2017

$

$

6,051
7,767
14,160
5,327
8,540
1,970
43,815

$

$

5,902
7,818
13,836
6,011
7,277
1,841
42,685

(Dollars in millions)

Personnel
Occupancy
Equipment
Marketing
Professional fees
Data processing
Telecommunications
Other general operating

Total noninterest expense

2018

2017

$

$

31,880
4,066
1,705
1,674
1,699
3,222
699
8,436
53,381

$

$

31,931
4,009
1,692
1,746
1,888
3,139
699
9,639
54,743

Noninterest income increased $1.1 billion to $43.8 billion in 2018 
compared  to  2017.  The  following  highlights  the  significant 
changes.

Card  income  increased  $149  million  primarily  driven  by  an 
increase in credit and debit card spending, as well as increased 
late fees and annual fees, partially offset by higher rewards 
costs, lower cash advance fees, and the impact of the sale of 
the non-U.S. consumer credit card business in 2017.
Investment  and  brokerage  services  income  increased  $324 
million primarily due to assets under management (AUM) flows 
and higher market valuations, partially offset by the impact of 
changing market dynamics on transactional revenue and AUM 
pricing.
Investment banking income decreased $684 million primarily 
due  to  declines  in  advisory  fees  and  debt  underwriting,  the 
latter of which was driven by lower fee pools. 
Trading account profits increased $1.3 billion primarily due to 
increased  client  activity  in  equity  financing  and  derivatives, 
higher market interest rates and strong trading performance 
in  equity  derivatives,  partially  offset  by  weakness  in  credit 
products.
Other income increased $129 million primarily due to gains on 
sales  of  consumer  real  estate  loans,  primarily  non-core,  of 
$731 million, offset by a $729 million charge related to the 
redemption of certain trust preferred securities in 2018. Other 
income for 2017 included a downward valuation adjustment 
of  $946  million  on  tax-advantaged  energy  investments  in 
connection  with  the  Tax  Act  and  a  $793  million  pretax  gain 
recognized  in  connection  with  the  sale  of  the  non-U.S. 
consumer credit card business.

Noninterest  expense  decreased  $1.4  billion  to  $53.4  billion  in 
2018 compared to 2017. The decrease was primarily due to lower 
other general operating expense, primarily driven by a decline in 
litigation  and  Federal  Deposit  Insurance  Corporation  (FDIC) 
expense as well as a $316 million impairment charge in 2017
related to certain data centers.

Income Tax Expense

Table 4 Income Tax Expense

(Dollars in millions)

Income before income taxes
Income tax expense
Effective tax rate

2018
$ 34,584
6,437

2017
$ 29,213
10,981

18.6%

37.6%

Tax expense for 2018 reflected the new 21 percent federal income 
tax rate and the other provisions of the Tax Act, as well as our 
recurring tax preference benefits.

Tax  expense  for  2017  included  a  charge  of  $1.9  billion 
reflecting the initial impact of the Tax Act, including a tax charge 
of  $2.3  billion  related  primarily  to  a  lower  valuation  of  certain 
deferred tax assets and liabilities and a $347 million tax benefit 
on the pretax loss from the lower valuation of our tax-advantaged 
energy  investments.  Other  than  the  impact  of  the  Tax  Act,  the 
effective  tax  rate  for  2017  was  driven  by  our  recurring  tax 
preference benefits as well as an expense from the sale of the 
non-U.S. consumer credit card business, largely offset by benefits 
related  to  stock-based  compensation  and  the  restructuring  of 
certain subsidiaries.

We expect the effective tax rate for 2019 to be approximately 

19 percent, absent unusual items.

Bank of America 2018     37 

Balance Sheet Overview

Table 5 Selected Balance Sheet Data

(Dollars in millions)

Assets

Cash and cash equivalents
Federal funds sold and securities borrowed or purchased under agreements to resell
Trading account assets
Debt securities
Loans and leases
Allowance for loan and lease losses
All other assets
Total assets

Liabilities

Deposits
Federal funds purchased and securities loaned or sold under agreements to repurchase
Trading account liabilities
Short-term borrowings
Long-term debt
All other liabilities
Total liabilities
Shareholders’ equity

Total liabilities and shareholders’ equity

December 31

2018

2017

% Change

$

$

$

$

177,404
261,131
214,348
441,753
946,895
(9,601)
322,577
2,354,507

$

157,434
212,747
209,358
440,130
936,749
(10,393)
335,209
$ 2,281,234

1,381,476
186,988
68,220
20,189
229,340
202,969
2,089,182
265,325
2,354,507

$ 1,309,545
176,865
81,187
32,666
227,402
186,423
2,014,088
267,146
$ 2,281,234

13%
23
2
—
1
(8)
(4)
3

5
6
(16)
(38)
1
9
4
(1)
3

Assets
At  December  31,  2018,  total  assets  were  approximately  $2.4 
trillion, up $73.3 billion from December 31, 2017. The increase 
in  assets  was  primarily  due  to  higher  securities  borrowed  or 
purchased under agreements to resell due to investment of excess 
cash levels in higher yielding assets and increased client activity, 
and higher cash and cash equivalents driven by deposit growth. 

and liquidity risk and to take advantage of market conditions that 
create economically attractive returns on these investments. Debt 
securities increased $1.6 billion primarily driven by the deployment 
of deposit inflows. In 2018, the Corporation transferred available-
for-sale  (AFS)  debt  securities  with  an  amortized  cost  of  $64.5 
billion to held to maturity. For more information on debt securities, 
see Note 4 – Securities to the Consolidated Financial Statements.

Cash and Cash Equivalents
Cash and cash equivalents increased $20.0 billion primarily driven 
by  deposit  growth,  partially  offset  by  investment  of  short-term 
excess cash into securities purchased under agreements to resell, 
and loan growth.

Loans and Leases
Loans and leases increased $10.1 billion primarily due to net loan 
growth driven by client demand for commercial loans and increases 
in residential mortgage. For more information on the loan portfolio, 
see Credit Risk Management on page 66.

Federal Funds Sold and Securities Borrowed or Purchased 
Under Agreements to Resell
Federal funds transactions involve lending reserve balances on a 
short-term  basis.  Securities  borrowed  or  purchased  under 
agreements  to  resell  are  collateralized  lending  transactions 
utilized to accommodate customer transactions, earn interest rate 
spreads, and obtain securities for settlement and for collateral. 
Federal funds sold and securities borrowed or purchased under 
agreements to resell increased $48.4 billion due to investment of 
excess cash levels in higher yielding assets and a higher level of 
customer financing activity.

Trading Account Assets
Trading account assets consist primarily of long positions in equity 
and fixed-income securities including U.S. government and agency 
securities,  corporate  securities  and  non-U.S.  sovereign  debt. 
Trading account assets increased $5.0 billion primarily driven by 
additional inventory in fixed-income, currencies and commodities 
(FICC) to meet expected client demand.

Debt Securities
Debt  securities  primarily  include  U.S.  Treasury  and  agency 
securities, mortgage-backed securities (MBS), principally agency 
MBS, non-U.S. bonds, corporate bonds and municipal debt. We 
use the debt securities portfolio primarily to manage interest rate 

Allowance for Loan and Lease Losses
The allowance for loan and lease losses decreased $792 million 
primarily due to the impact of improvements in credit quality from 
a stronger economy and continued runoff and sales in the non-
core  consumer  real  estate  portfolio.  For  additional  information, 
see Allowance for Credit Losses on page 82.

Liabilities
At December 31, 2018, total liabilities were approximately $2.1 
trillion, up $75.1 billion from December 31, 2017, primarily due 
to deposit growth.

Deposits
Deposits increased $71.9 billion primarily due to an increase in 
retail deposits. 

Federal  Funds  Purchased  and  Securities  Loaned  or  Sold 
Under Agreements to Repurchase
Federal funds transactions involve borrowing reserve balances on 
a short-term basis. Securities loaned or sold under agreements 
to repurchase are collateralized borrowing transactions utilized to 
accommodate customer transactions, earn interest rate spreads 
and finance assets on the balance sheet. Federal funds purchased 
and  securities  loaned  or  sold  under  agreements  to  repurchase 
increased $10.1 billion primarily due to an increase in matched 
book funding within Global Markets.

38     Bank of America 2018

 
 
 
Trading Account Liabilities
Trading account liabilities consist primarily of short positions in 
equity  and  fixed-income  securities  including  U.S.  Treasury  and 
agency  securities,  corporate  securities  and  non-U.S.  sovereign 
debt. Trading account liabilities decreased $13.0 billion primarily 
due to lower levels of short positions in government and corporate 
bonds driven by expected client demand within Global Markets.

Short-term Borrowings
Short-term borrowings provide an additional funding source and 
primarily consist of Federal Home Loan Bank (FHLB) short-term 
borrowings,  notes  payable  and  various  other  borrowings  that 
generally  have  maturities  of  one  year  or  less.  Short-term 
borrowings decreased $12.5 billion primarily due to a decrease 
in short-term FHLB advances. For more information on short-term 
borrowings,  see  Note  10  –  Federal  Funds  Sold  or  Purchased, 
Securities  Financing  Agreements,  Short-term  Borrowings  and 
Restricted Cash to the Consolidated Financial Statements.

Long-term Debt
Long-term debt increased $1.9 billion primarily driven by issuances 
outpacing maturities and redemptions. For more information on 
long-term debt, see Note 11 – Long-term Debt to the Consolidated 
Financial Statements.

Shareholders’ Equity
Shareholders’ equity decreased $1.8 billion driven by returns of 
capital  to  shareholders  of  $27.0  billion  through  common  and 
preferred stock dividends and share repurchases and a $4.0 billion 
after-tax decrease in the fair value of AFS debt securities recorded 
in accumulated other comprehensive income (OCI), largely offset 
by earnings.

Cash Flows Overview
The  Corporation’s  operating  assets  and  liabilities  support  our 
global markets and lending activities. We believe that cash flows 
from  operations,  available  cash  balances  and  our  ability  to 
generate cash through short- and long-term debt are sufficient to 
fund our operating liquidity needs. Our investing activities primarily 
include the debt securities portfolio and loans and leases. Our 
financing activities reflect cash flows primarily related to customer 
deposits, securities financing agreements and long-term debt. For 
more information on liquidity, see Liquidity Risk on page 62.

Supplemental Financial Data
In  this  Form  10-K,  we  present  certain  non-GAAP  financial 
measures. Non-GAAP financial measures exclude certain items or 
otherwise include components that differ from the most directly 
comparable measures calculated in accordance with GAAP. Non-
GAAP  financial  measures  are  provided  as  additional  useful 
information to assess our financial condition, results of operations 
(including period-to-period operating performance) or compliance 
with  prospective  regulatory  requirements.  These  non-GAAP 
financial  measures  are  not  intended  as  a  substitute  for  GAAP 
financial measures and may not be defined or calculated the same 
way as non-GAAP financial measures used by other companies.

We view net interest income and related ratios and analyses 
on an FTE basis, which when presented on a consolidated basis, 
are  non-GAAP  financial  measures.  To  derive  the  FTE  basis,  net 
interest income is adjusted to reflect tax-exempt income on an 
equivalent  before-tax  basis  with  a  corresponding  increase  in 
income tax expense. For purposes of this calculation, we used the 
federal statutory tax rate of 21 percent for 2018 (35 percent for 
all prior periods) and a representative state tax rate. Net interest 
yield, which measures the basis points we earn over the cost of 
funds, utilizes net interest income (and thus total revenue) on an 
FTE basis. We believe that presentation of these items on an FTE 
basis allows for comparison of amounts from both taxable and 
tax-exempt sources and is consistent with industry practices.

We may present certain key performance indicators and ratios 
excluding  certain  items  (e.g.,  debit  valuation  adjustment  (DVA) 
gains (losses)) which result in non-GAAP financial measures. We 
believe that the presentation of measures that exclude these items 
is useful because such measures provide additional information 
to assess the underlying operational performance and trends of 
our businesses and to allow better comparison of period-to-period 
operating performance.

We also evaluate our business based on certain ratios that 
utilize  tangible  equity,  a  non-GAAP  financial  measure.  Tangible 
equity  represents  an  adjusted  shareholders’  equity  or  common 
shareholders’ equity amount which has been reduced by goodwill 
and  certain  acquired  intangible  assets  (excluding  mortgage 
servicing  rights  (MSRs)),  net  of  related  deferred  tax  liabilities. 
These measures are used to evaluate our use of equity. In addition, 
profitability, relationship and investment models use both return 
on average tangible common shareholders’ equity and return on 
average tangible shareholders’ equity as key measures to support 
our overall growth goals. These ratios are as follows:
  Return  on  average  tangible  common  shareholders’  equity 
measures  our  earnings  contribution  as  a  percentage  of 
adjusted common shareholders’ equity. The tangible common 
equity ratio represents adjusted ending common shareholders’ 
equity divided by total assets less goodwill and certain acquired 
intangible assets (excluding MSRs), net of related deferred tax 
liabilities.

  Return on average tangible shareholders’ equity measures our 
earnings contribution as a percentage of adjusted average total 
shareholders’  equity.  The  tangible  equity  ratio  represents 
adjusted ending shareholders’ equity divided by total assets 
less goodwill and certain acquired intangible assets (excluding 
MSRs), net of related deferred tax liabilities.

  Tangible book value per common share represents adjusted 
ending  common  shareholders’  equity  divided  by  ending 
common shares outstanding.
We believe that the use of ratios that utilize tangible equity 
provides  additional  useful  information  because  they  present 
measures  of  those  assets  that  can  generate  income.  Tangible 
book value per share provides additional useful information about 
the level of tangible assets in relation to outstanding shares of 
common stock.

The  aforementioned  supplemental  data  and  performance 

measures are presented in Tables 8 and 9.

Bank of America 2018     39 

Non-GAAP Reconciliations
Tables 6 and 7 provide reconciliations of certain non-GAAP financial measures to GAAP financial measures.

Table 6 Five-year Reconciliations to GAAP Financial Measures (1)

(Dollars in millions, shares in thousands)
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and

average tangible common shareholders’ equity

Shareholders’ equity
Goodwill
Intangible assets (excluding MSRs)
Related deferred tax liabilities
Tangible shareholders’ equity

Preferred stock

Tangible common shareholders’ equity

Reconciliation of year-end shareholders’ equity to year-end tangible shareholders’ equity and

year-end tangible common shareholders’ equity

Shareholders’ equity
Goodwill
Intangible assets (excluding MSRs)
Related deferred tax liabilities
Tangible shareholders’ equity

Preferred stock

Tangible common shareholders’ equity

Reconciliation of year-end assets to year-end tangible assets

Assets
Goodwill
Intangible assets (excluding MSRs)
Related deferred tax liabilities

Tangible assets

2018

2017

2016

2015

2014

$

$

$

$

$

$

264,748
(68,951)
(2,058)
906
194,645
(22,949)
171,696

$ 271,289
(69,286)
(2,652)
1,463
$ 200,814
(24,188)
$ 176,626

$ 265,843
(69,750)
(3,382)
1,644
$ 194,355
(24,656)
$ 169,699

$ 251,384
(69,772)
(4,201)
1,852
$ 179,263
(21,808)
$ 157,455

$ 238,317
(69,809)
(5,109)
2,090
$ 165,489
(15,410)
$ 150,079

265,325
(68,951)
(1,774)
858
195,458
(22,326)
173,132

$ 267,146
(68,951)
(2,312)
943
$ 196,826
(22,323)
$ 174,503

$ 266,195
(69,744)
(2,989)
1,545
$ 195,007
(25,220)
$ 169,787

$ 255,615
(69,761)
(3,768)
1,716
$ 183,802
(22,272)
$ 161,530

$ 243,476
(69,777)
(4,612)
1,960
$ 171,047
(19,309)
$ 151,738

$ 2,354,507
(68,951)
(1,774)
858
$ 2,284,640

$ 2,281,234
(68,951)
(2,312)
943
$ 2,210,914

$ 2,188,067
(69,744)
(2,989)
1,545
$ 2,116,879

$ 2,144,606
(69,761)
(3,768)
1,716
$ 2,072,793

$ 2,104,539
(69,777)
(4,612)
1,960
$ 2,032,110

(1)  Presents reconciliations of non-GAAP financial measures to GAAP financial measures. For more information on non-GAAP financial measures and ratios we use in assessing the results of the 

Corporation, see Supplemental Financial Data on page 39.

Table 7 Quarterly Reconciliations to GAAP Financial Measures (1)

(Dollars in millions)

Fourth

Third

Second

First

Fourth

Third

Second

First

2018 Quarters

2017 Quarters

Reconciliation of average shareholders’ equity to average tangible
shareholders’ equity and average tangible common shareholders’
equity

Shareholders’ equity

Goodwill

Intangible assets (excluding MSRs)

Related deferred tax liabilities

Tangible shareholders’ equity

Preferred stock

$ 263,698

$ 264,653

$ 265,181

$ 265,480

$ 273,162

$ 273,238

$ 270,977

$ 267,700

(68,951)

(1,857)

874

(68,951)

(68,951)

(68,951)

(68,954)

(68,969)

(69,489)

(69,744)

(1,992)

896

(2,126)

(2,261)

916

939

(2,399)

1,344

(2,549)

1,465

(2,743)

1,506

(2,923)

1,539

$ 193,764

$ 194,606

$ 195,020

$ 195,207

$ 203,153

$ 203,185

$ 200,251

$ 196,572

(22,326)

(22,841)

(23,868)

(22,767)

(22,324)

(24,024)

(25,221)

(25,220)

Tangible common shareholders’ equity

$ 171,438

$ 171,765

$ 171,152

$ 172,440

$ 180,829

$ 179,161

$ 175,030

$ 171,352

Reconciliation of period-end shareholders’ equity to period-end

tangible shareholders’ equity and period-end tangible common
shareholders’ equity

Shareholders’ equity

Goodwill

Intangible assets (excluding MSRs)

Related deferred tax liabilities

Tangible shareholders’ equity

Preferred stock

$ 265,325

$ 262,158

$ 264,216

$ 266,224

$ 267,146

$ 271,969

$ 270,660

$ 267,990

(68,951)

(1,774)

858

(68,951)

(68,951)

(68,951)

(68,951)

(68,968)

(68,969)

(69,744)

(1,908)

878

(2,043)

(2,177)

(2,312)

900

920

943

(2,459)

1,435

(2,610)

1,471

(2,827)

1,513

$ 195,458

$ 192,177

$ 194,122

$ 196,016

$ 196,826

$ 201,977

$ 200,552

$ 196,932

(22,326)

(22,326)

(23,181)

(24,672)

(22,323)

(22,323)

(25,220)

(25,220)

Tangible common shareholders’ equity

$ 173,132

$ 169,851

$ 170,941

$ 171,344

$ 174,503

$ 179,654

$ 175,332

$ 171,712

Reconciliation of period-end assets to period-end tangible assets

Assets

Goodwill

Intangible assets (excluding MSRs)

Related deferred tax liabilities

Tangible assets

$ 2,354,507

$ 2,338,833

$ 2,291,670

$ 2,328,478

$ 2,281,234

$ 2,284,174

$ 2,254,714

$ 2,247,794

(68,951)

(1,774)

858

(68,951)

(68,951)

(68,951)

(68,951)

(68,968)

(68,969)

(69,744)

(1,908)

878

(2,043)

(2,177)

(2,312)

900

920

943

(2,459)

1,435

(2,610)

1,471

(2,827)

1,513

$ 2,284,640

$ 2,268,852

$ 2,221,576

$ 2,258,270

$ 2,210,914

$ 2,214,182

$ 2,184,606

$ 2,176,736

(1)  Presents reconciliations of non-GAAP financial measures to GAAP financial measures. For more information on non-GAAP financial measures and ratios we use in assessing the results of the 

Corporation, see Supplemental Financial Data on page 39.

40     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 8 Five-year Summary of Selected Financial Data

(In millions, except per share information)

Income statement

Net interest income
Noninterest income
Total revenue, net of interest expense
Provision for credit losses
Noninterest expense
Income before income taxes
Income tax expense
Net income
Net income applicable to common shareholders
Average common shares issued and outstanding
Average diluted common shares issued and outstanding

Performance ratios

Return on average assets
Return on average common shareholders’ equity
Return on average tangible common shareholders’ equity (1)
Return on average shareholders’ equity
Return on average tangible shareholders’ equity (1)
Total ending equity to total ending assets
Total average equity to total average assets
Dividend payout

Per common share data

Earnings
Diluted earnings
Dividends paid
Book value
Tangible book value (1)

Market capitalization
Average balance sheet

Total loans and leases
Total assets
Total deposits
Long-term debt
Common shareholders’ equity
Total shareholders’ equity

Asset quality (2) 

Allowance for credit losses (3)
Nonperforming loans, leases and foreclosed properties (4)
Allowance for loan and lease losses as a percentage of total loans and leases 

outstanding (4)

Allowance for loan and lease losses as a percentage of total nonperforming loans 

and leases (4)

Net charge-offs (5)
Net charge-offs as a percentage of average loans and leases outstanding (4, 5)

Capital ratios at year end (6)

Common equity tier 1 capital
Tier 1 capital
Total capital
Tier 1 leverage
Supplementary leverage ratio
Tangible equity (1)
Tangible common equity (1)

$

$

$

$

$

2018

2017

2016

2015

2014

47,432
43,815
91,247
3,282
53,381
34,584
6,437
28,147
26,696
10,096.5
10,236.9

$

44,667
42,685
87,352
3,396
54,743
29,213
10,981
18,232
16,618
10,195.6
10,778.4

$

41,096
42,605
83,701
3,597
55,083
25,021
7,199
17,822
16,140
10,284.1
11,046.8

$

38,958
44,007
82,965
3,161
57,617
22,187
6,277
15,910
14,427
10,462.3
11,236.2

$

40,779
45,115
85,894
2,275
75,656
7,963
2,443
5,520
4,476
10,527.8
10,584.5

1.21%

11.04
15.55
10.63
14.46
11.27
11.39
20.31

0.80%
6.72
9.41
6.72
9.08
11.71
11.96
24.24

0.81%
6.69
9.51
6.70
9.17
12.17
12.14
15.94

0.74%
6.28
9.16
6.33
8.88
11.92
11.64
14.49

0.26%
2.01
2.98
2.32
3.34
11.57
11.11
28.20

2.64
2.61
0.54
25.13
17.91
238,251

933,049
2,325,246
1,314,941
230,693
241,799
264,748

$

$

$

1.63
1.56
0.39
23.80
16.96
303,681

918,731
2,268,633
1,269,796
225,133
247,101
271,289

$

$

$

1.57
1.49
0.25
23.97
16.89
222,163

900,433
2,190,218
1,222,561
228,617
241,187
265,843

$

$

$

1.38
1.31
0.20
22.48
15.56
174,700

876,787
2,160,536
1,155,860
240,059
229,576
251,384

$

$

$

0.43
0.42
0.12
21.32
14.43
188,141

898,703
2,145,393
1,124,207
253,607
222,907
238,317

10,398
5,244

$

11,170
6,758

$

11,999
8,084

$

12,880
9,836

$

14,947
12,629

1.02%

1.12%

1.26%

1.37%

1.66%

194

161

149

130

$

3,763

$

3,979

$

3,821

$

4,338

$

0.44%

0.43%

0.50%

121

4,383

0.49%

0.41%

11.6%
13.2
15.1
8.4
6.8
8.6
7.6

11.5%
13.0
14.8
8.6
n/a
8.9
7.9

10.8%
12.4
14.2
8.8
n/a
9.2
8.0

9.8%

9.6%

11.2
12.8
8.4
n/a
8.9
7.8

11.0
12.7
7.8
n/a
8.4
7.5

(1)  Tangible equity ratios and tangible book value per share of common stock are non-GAAP financial measures. For more information on these ratios and corresponding reconciliations to GAAP financial 

measures, see Supplemental Financial Data on page 39.

(2)  Asset quality metrics include $75 million of non-U.S. consumer credit card net charge-offs in 2017 and $243 million of non-U.S. consumer credit card allowance for loan and lease losses, $9.2 
billion of non-U.S. consumer credit card loans and $175 million of non-U.S. consumer credit card net charge-offs in 2016. The Corporation sold its non-U.S. consumer credit card business in 2017.
Includes the allowance for loan and leases losses and the reserve for unfunded lending commitments. 

(3) 

(4)  Balances and ratios do not include loans accounted for under the fair value option. For additional exclusions from nonperforming loans, leases and foreclosed properties, see Consumer Portfolio 
Credit Risk Management – Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity on page 73 and corresponding Table 31 and Commercial Portfolio Credit Risk Management – 
Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 78 and corresponding Table 38.

(5)  Net charge-offs exclude $273 million, $207 million, $340 million, $808 million and $810 million of write-offs in the purchased credit-impaired (PCI) loan portfolio for 2018, 2017, 2016, 2015 and 

2014, respectively. 

(6)  Basel 3 transition provisions for regulatory capital adjustments and deductions were fully phased-in as of January 1, 2018. Prior periods are presented on a fully phased-in basis. For additional 

information, including which approach is used to assess capital adequacy, see Capital Management on page 58.

n/a = not applicable

Bank of America 2018     41 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 9 Selected Quarterly Financial Data

(In millions, except per share information)
Income statement

Net interest income
Noninterest income (1)
Total revenue, net of interest expense
Provision for credit losses
Noninterest expense
Income before income taxes
Income tax expense (1)
Net income (1)
Net income applicable to common shareholders
Average common shares issued and outstanding
Average diluted common shares issued and outstanding

Performance ratios

Return on average assets
Four-quarter trailing return on average assets (2)
Return on average common shareholders’ equity
Return on average tangible common shareholders’ equity (3)
Return on average shareholders’ equity
Return on average tangible shareholders’ equity (3)
Total ending equity to total ending assets
Total average equity to total average assets
Dividend payout

Per common share data

Earnings
Diluted earnings
Dividends paid
Book value
Tangible book value (3)

Market capitalization
Average balance sheet

Total loans and leases
Total assets
Total deposits
Long-term debt
Common shareholders’ equity
Total shareholders’ equity

Asset quality (4)

Allowance for credit losses (5)
Nonperforming loans, leases and foreclosed properties (6)
Allowance for loan and lease losses as a percentage of total loans 

and leases outstanding (6)

Allowance for loan and lease losses as a percentage of total 

nonperforming loans and leases (6)

Net charge-offs (7)
Annualized net charge-offs as a percentage of average loans and 

leases outstanding (6, 7)

Capital ratios at period end (8)

Common equity tier 1 capital
Tier 1 capital
Total capital
Tier 1 leverage
Supplementary leverage ratio
Tangible equity (3)
Tangible common equity (3)

2018 Quarters

2017 Quarters

Fourth

Third

Second

First

Fourth

Third

Second

First

$ 12,304
10,432
22,736
905
13,133
8,698
1,420
7,278
7,039
9,855.8
9,996.0

$ 11,870
10,907
22,777
716
13,067
8,994
1,827
7,167
6,701
10,031.6
10,170.8

$ 11,650
10,959
22,609
827
13,284
8,498
1,714
6,784
6,466
10,181.7
10,309.4

$ 11,608
11,517
23,125
834
13,897
8,394
1,476
6,918
6,490
10,322.4
10,472.7

$ 11,462
8,974
20,436
1,001
13,274
6,161
3,796
2,365
2,079
10,470.7
10,621.8

$ 11,161
10,678
21,839
834
13,394
7,611
2,187
5,424
4,959
10,197.9
10,746.7

$ 10,986
11,843
22,829
726
13,982
8,121
3,015
5,106
4,745
10,013.5
10,834.8

$ 11,058
11,190
22,248
835
14,093
7,320
1,983
5,337
4,835
10,099.6
10,919.7

1.24%
1.21
11.57
16.29
10.95
14.90
11.27
11.30
20.90

0.71
0.70
0.15
25.13
17.91

$

1.23%
1.00
10.99
15.48
10.74
14.61
11.21
11.42
22.35

0.67
0.66
0.15
24.33
17.23

$

1.17%
0.93
10.75
15.15
10.26
13.95
11.53
11.42
18.83

0.64
0.63
0.12
24.07
17.07

$

1.21%
0.86
10.85
15.26
10.57
14.37
11.43
11.41
19.06

0.63
0.62
0.12
23.74
16.84

$

0.41%
0.80
3.29
4.56
3.43
4.62
11.71
11.87
60.35

0.20
0.20
0.12
23.80
16.96

$

0.95%
0.91
7.89
10.98
7.88
10.59
11.91
12.03
25.59

0.49
0.46
0.12
23.87
17.18

$

0.90%
0.89
7.75
10.87
7.56
10.23
12.00
11.94
15.78

0.47
0.44
0.075
24.85
17.75

$

0.97%
0.88
8.09
11.44
8.09
11.01
11.92
12.00
15.64

0.48
0.45
0.075
24.34
17.22

$

$ 238,251

$ 290,424

$ 282,259

$ 305,176

$ 303,681

$ 264,992

$ 239,643

$ 235,291

$ 934,721
2,334,586
1,344,951
230,616
241,372
263,698

$ 930,736
2,317,829
1,316,345
233,475
241,812
264,653

$ 934,818
2,322,678
1,300,659
229,037
241,313
265,181

$ 931,915
2,325,878
1,297,268
229,603
242,713
265,480

$ 927,790
2,301,687
1,293,572
227,644
250,838
273,162

$ 918,129
2,271,104
1,271,711
227,309
249,214
273,238

$ 914,717
2,269,293
1,256,838
224,019
245,756
270,977

$ 914,144
2,231,649
1,256,632
221,468
242,480
267,700

$ 10,398
5,244

$ 10,526
5,449

$ 10,837
6,181

$ 11,042
6,694

$ 11,170
6,758

$ 11,455
6,869

$ 11,632
7,127

$ 11,869
7,637

1.02%

1.05%

1.08%

1.11%

1.12%

1.16%

1.20%

1.25%

194

924

$

189

932

$

170

996

$

161

911

$

161

$

1,237

$

163

900

$

160

908

$

156

934

0.39%

0.40%

0.43%

0.40%

0.53%

0.39%

0.40%

0.42%

11.6%
13.2
15.1
8.4
6.8
8.6
7.6

11.4%
12.9
14.7
8.3
6.7
8.5
7.5

11.4%
13.0
14.8
8.4
6.7
8.7
7.7

11.3%
13.0
14.8
8.4
6.8
8.7
7.6

11.5%
13.0
14.8
8.6
n/a
8.9
7.9

11.9%
13.4
15.1
8.9
n/a
9.1
8.1

11.5%
13.2
15.0
8.8
n/a
9.2
8.0

11.0%
12.6
14.3
8.8
n/a
9.1
7.9

(1)  Net income for the fourth quarter of 2017 included a charge of $2.9 billion related to the Tax Act effects which consisted of $946 million in noninterest income and $1.9 billion in income tax expense. 
(2)  Calculated as total net income for four consecutive quarters divided by annualized average assets for four consecutive quarters.
(3)  Tangible equity ratios and tangible book value per share of common stock are non-GAAP financial measures. For more information on these ratios and corresponding reconciliations to GAAP financial 

measures, see Supplemental Financial Data on page 39.

(4)  Asset quality metrics include $31 million of non-U.S. consumer credit card net charge-offs for the second quarter of 2017 and $242 million of non-U.S. consumer credit card allowance for loan and 
lease losses, $9.5 billion of non-U.S. consumer credit card loans and $44 million of non-U.S. consumer credit card net charge-offs for the first quarter of 2017. The Corporation sold its non-U.S. 
consumer credit card business in the second quarter of 2017.
Includes the allowance for loan and lease losses and the reserve for unfunded lending commitments.

(5) 

(6)  Balances and ratios do not include loans accounted for under the fair value option. For additional exclusions from nonperforming loans, leases and foreclosed properties, see Consumer Portfolio 
Credit Risk Management – Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity on page 73 and corresponding Table 31 and Commercial Portfolio Credit Risk Management – 
Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 78 and corresponding Table 38.

(7)  Net charge-offs exclude $107 million, $95 million, $36 million and $35 million of write-offs in the PCI loan portfolio in the fourth, third, second and first quarters of 2018, and $46 million, $73 million, 

$55 million and $33 million in the fourth, third, second and first quarters of 2017, respectively.

(8)  Basel 3 transition provisions for regulatory capital adjustments and deductions were fully phased-in as of January 1, 2018. Prior periods are presented on a fully phased-in basis. For additional 

information, including which approach is used to assess capital adequacy, see Capital Management on page 58.

n/a = not applicable

42     Bank of America 2018

Table 10 Average Balances and Interest Rates - FTE Basis

(Dollars in millions)

Earning assets

Interest-bearing deposits with the Federal Reserve, non-U.S.

Average
Balance

Interest
Income/
Expense

2018

Yield/
Rate

Average
Balance

Interest
Income/
Expense

2017

Yield/
Rate

Average
Balance

Interest
Income/
Expense

2016

Yield/
Rate

central banks and other banks

$

139,848

$

1,926

1.38% $

127,431

$

1,122

0.88% $

133,374

$

12,112

241

1.99

9,026

Time deposits placed and other short-term investments

9,446

216

Federal funds sold and securities borrowed or purchased under 

agreements to resell (1)

Trading account assets
Debt securities
Loans and leases (2):

Residential mortgage
Home equity
U.S. credit card
Non-U.S. credit card (3)
Direct/Indirect and other consumer (4)

Total consumer

U.S. commercial

Non-U.S. commercial

Commercial real estate (5)

Commercial lease financing

Total commercial

Total loans and leases (3)

Other earning assets (1)

Total earning assets (1,6)

Cash and due from banks

Other assets, less allowance for loan and lease losses

Total assets

Interest-bearing liabilities

U.S. interest-bearing deposits:

Savings

NOW and money market deposit accounts

Consumer CDs and IRAs

Negotiable CDs, public funds and other deposits

Total U.S. interest-bearing deposits

Non-U.S. interest-bearing deposits:

Banks located in non-U.S. countries

Governments and official institutions

Time, savings and other

Total non-U.S. interest-bearing deposits

Total interest-bearing deposits

Federal funds purchased, securities loaned or sold under 

agreements to repurchase, short-term borrowings and other 
interest-bearing liabilities (1)

Trading account liabilities

Long-term debt

Total interest-bearing liabilities (1,6)

Noninterest-bearing sources:

Noninterest-bearing deposits
Other liabilities (1)

Shareholders’ equity

Total liabilities and shareholders’ equity

Net interest spread
Impact of noninterest-bearing sources

251,328

132,724
437,312

207,523
53,886
94,612
—

93,036

449,057

304,387

97,664

60,384

21,557

483,992

933,049
76,524

1,980,231

25,830

319,185

$ 2,325,246

$

54,226

$

676,382

39,823

50,593

821,024

2,312

810

65,097

68,219

3,176

4,901
11,837

7,294
2,573
9,579
—

3,104

22,550

11,937

3,220

2,618

698

18,473

41,023
4,300

67,379

6

2,636

157

991

3,790

39

—

666

705

889,243

4,495

269,748

50,928

230,693
1,440,612

5,839

1,358

7,645
19,337

425,698

194,188
264,748
$ 2,325,246

Net interest income/yield on earning assets (7)

$ 48,042

2.29

1.26

3.69
2.66

3.51
4.77
10.12
—

3.34

5.02

3.92

3.30

4.34

3.24

3.82

4.40
5.62

3.40

1,806

4,618
10,626

6,831
2,608
8,791
358

2,734

21,322

9,765

2,566

2,116

706

15,153

36,475
3,224

58,112

222,818

129,007
435,005

197,766
62,260
91,068
3,929

96,002

451,025

292,452

95,005

58,502

21,747

467,706

918,731
76,957

1,922,061

27,995

318,577

$ 2,268,633

0.01% $
0.39

0.39

1.96

0.46

1.69

0.01

1.02

1.03

0.51

2.17

2.67

3.31
1.34

53,783

$

628,647

44,794

36,782

764,006

2,442

1,006

62,386

65,834

5

873

121

354

1,353

21

10

547

578

829,840

1,931

274,975

45,518

225,133
1,375,466

3,146

1,204

6,239
12,520

439,956

181,922
271,289
$ 2,268,633

605

140

967

4,563
9,263

6,488
2,713
8,170
926

2,371
20,668

8,101

2,337

1,773
627

12,838

33,506

2,496
51,540

5
294

133

160

592

32

9
382

423

0.81

3.58
2.44

3.45
4.19
9.65
9.12

2.85

4.73

3.34

2.70

3.62

3.25

3.24

3.97
4.19

3.02

216,161

129,766
418,289

188,250
71,760
87,905

9,527
94,148

451,590

276,887
93,263

57,547

21,146

448,843

900,433
59,775

1,866,824

27,893

295,501
$ 2,190,218

0.01% $

49,495

$

589,737
48,594

32,889

720,715

3,891

1,437
59,183

64,511

0.14

0.27

0.96

0.18

0.85

0.95

0.88

0.88

0.23

1.14

2.64

2.77
0.91

785,226

1,015

1,933

1,018

5,578
9,544

252,585

37,897

228,617
1,304,325

437,335

182,715
265,843
$ 2,190,218

0.45%

1.55

0.45

3.52
2.23

3.45
3.78
9.29
9.72

2.52

4.58

2.93

2.51

3.08

2.97

2.86

3.72
4.18

2.76

0.01%

0.05

0.27

0.49

0.08

0.82

0.64

0.65

0.66

0.13

0.77

2.69

2.44
0.73

2.03%
0.22

2.25%

2.06%
0.36

2.42%

2.11%
0.26

2.37%

$ 45,592

$ 41,996

(1)  Certain prior-period amounts have been reclassified to conform to current period presentation.
(2)  Nonperforming loans are included in the respective average loan balances. Income on these nonperforming loans is generally recognized on a cost recovery basis.
(3) 

Includes assets of the Corporation’s non-U.S. consumer credit card business, which was sold during the second quarter of 2017.
Includes non-U.S. consumer loans of $2.8 billion, $2.9 billion and $3.4 billion in 2018, 2017 and 2016, respectively.
Includes U.S. commercial real estate loans of $56.4 billion, $55.0 billion and $54.2 billion, and non-U.S. commercial real estate loans of $4.0 billion, $3.5 billion and $3.4 billion in 2018, 2017
and 2016, respectively.
Interest income includes the impact of interest rate risk management contracts, which decreased interest income on the underlying assets by $171 million, $44 million and $176 million in 2018, 
2017 and 2016, respectively. Interest expense includes the impact of interest rate risk management contracts, which decreased interest expense on the underlying liabilities by $130 million, $1.4 
billion and $2.1 billion in 2018, 2017 and 2016, respectively. For more information, see Interest Rate Risk Management for the Banking Book on page 89.

(4) 

(5) 

(6) 

(7)  Net interest income includes FTE adjustments of $610 million, $925 million and $900 million in 2018, 2017 and 2016, respectively.

Bank of America 2018     43 

Table 11 Analysis of Changes in Net Interest Income - FTE Basis

(Dollars in millions)
Increase (decrease) in interest income
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other

Due to Change in (1)
Rate
Volume
From 2017 to 2018

Net Change

Due to Change in (1)
Rate
Volume
From 2016 to 2017

Net Change

banks

$

109

$

695

$

804

$

(32) $

Time deposits placed and other short-term investments
Federal funds sold and securities borrowed or purchased under agreements to resell
Trading account assets
Debt securities
Loans and leases:

Residential mortgage
Home equity
U.S. credit card
Non-U.S. credit card (2)
Direct/Indirect and other consumer

Total consumer
U.S. commercial
Non-U.S. commercial
Commercial real estate
Commercial lease financing

Total commercial
Total loans and leases

Other earning assets

Total interest income

Increase (decrease) in interest expense
U.S. interest-bearing deposits:

Savings
NOW and money market deposit accounts
Consumer CDs and IRAs
Negotiable CDs, public funds and other deposits

Total U.S. interest-bearing deposits

Non-U.S. interest-bearing deposits:

Banks located in non-U.S. countries
Governments and official institutions
Time, savings and other

Total non-U.S. interest-bearing deposits
Total interest-bearing deposits

Federal funds purchased, securities loaned or sold under agreements to repurchase,

short-term borrowings and other interest-bearing liabilities

Trading account liabilities
Long-term debt

Total interest expense
Net increase in net interest income (3)

(53)
230
134
44

329
(350)
339
(358)
(82)

402
71
70
(5)

28
1,140
149
1,167

134
315
449
—
452

1,770
583
432
(3)

(18)

1,094

  $

$

$

— $
74
(13)
132

1
1,689
49
505

(1)
(2)
26

(71)

140
151

19
(8)
93

2,764

14
1,255

  $

(25)
1,370
283
1,211

463
(35)
788
(358)
370
1,228
2,172
654
502
(8)
3,320
4,548
1,076
9,267

1
1,763
36
637
2,437

18
(10)
119
127
2,564

2,693

154
1,406
6,817
2,450

48
36
(22)
438

335
(360)
290
(544)
48

468
48
29
19

721

$

— $
20
(12)
20

(12)
(3)
24

184

206
(85)

$

549

53
803
77
925

8
255
331
(24)
315

1,196
181
314
60

7
  $

— $

559
—
174

1
4
141

517

101
839
55
1,363

343
(105)
621
(568)
363
654
1,664
229
343
79
2,315
2,969
728
6,572

—
579
(12)
194
761

(11)
1
165
155
916

1,029

(20)
746

  $

1,213

186
661
2,976
3,596

(1)  The changes for each category of interest income and expense are divided between the portion of change attributable to the variance in volume and the portion of change attributable to the variance 

in rate for that category. The unallocated change in rate or volume variance is allocated between the rate and volume variances.

(2)  The Corporation sold its non-U.S. credit card business in the second quarter of 2017.
(3) 

Includes changes in FTE basis adjustments of a $315 million decrease from 2017 to 2018 and a $25 million increase from 2016 to 2017.

44     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Business Segment Operations
Business Segment Operations
Business Segment Operations
Segment Description and Basis of Presentation
Segment Description and Basis of Presentation
Segment Description and Basis of Presentation
We report our results of operations through the following four business segments: Consumer Banking, GWIM, Global Banking and Global 
We report our results of operations through the following four business segments: Consumer Banking, GWIM, Global Banking and Global 
We report our results of operations through the following four business segments: Consumer Banking, GWIM, Global Banking and Global 
Markets, with the remaining operations recorded in All Other. We manage our segments and report their results on an FTE basis. For 
Markets, with the remaining operations recorded in All Other. We manage our segments and report their results on an FTE basis. For 
Markets, with the remaining operations recorded in All Other. We manage our segments and report their results on an FTE basis. For 
more information on our presentation of financial information on an FTE basis, see Supplemental Financial Data on page 39. The 
more information on our presentation of financial information on an FTE basis, see Supplemental Financial Data on page 39. The 
more information on our presentation of financial information on an FTE basis, see Supplemental Financial Data on page 39. The 
primary activities, products and businesses of the business segments and All Other are shown below.
primary activities, products and businesses of the business segments and All Other are shown below.
primary activities, products and businesses of the business segments and All Other are shown below.

Bank of America Corporation 
Bank of America Corporation 
Bank of America Corporation 

Consumer 
Consumer 
Consumer 
Banking 
Banking 
Banking 

Global Wealth & 
Global Wealth & 
Global Wealth & 
Investment 
Investment 
Investment 
Management 
Management 
Management 

Deposits 
Deposits 
Deposits 

•  Consumer 
•  Consumer 
•  Consumer 
Deposits 
Deposits 
Deposits 
•  Merrill Edge 
•  Merrill Edge 
•  Merrill Edge 
•  Small Business 
•  Small Business 
•  Small Business 
Client 
Client 
Client 
Management 
Management 
Management 

•  Merrill Lynch Global 
•  Merrill Lynch Global 
•  Merrill Lynch Global 

Wealth 
Wealth 
Wealth 
Management 
Management 
Management 

•  U.S. Trust, Bank of 
•  U.S. Trust, Bank of 
•  U.S. Trust, Bank of 
America Private 
America Private 
America Private 
Wealth 
Wealth 
Wealth 
Management 
Management 
Management 

Consumer Lending 
Consumer Lending 
Consumer Lending 
•  Consumer and 
•  Consumer and 
•  Consumer and 
Small Business 
Small Business 
Small Business 
Credit Card 
Credit Card 
Credit Card 
•  Debit Card 
•  Debit Card 
•  Debit Card 
•  Core Consumer 
•  Core Consumer 
•  Core Consumer 

Real Estate Loans 
Real Estate Loans 
Real Estate Loans 
•  Consumer Vehicle 
•  Consumer Vehicle 
•  Consumer Vehicle 

Lending 
Lending 
Lending 

Global Banking 
Global Banking 
Global Banking 

Global Markets 
Global Markets 
Global Markets 

All Other 
All Other 
All Other 

•  Fixed Income, 
•  Fixed Income, 
•  Fixed Income, 
Currencies and 
Currencies and 
Currencies and 
Commodities 
Commodities 
Commodities 
Markets 
Markets 
Markets 

•  Equity Markets 
•  Equity Markets 
•  Equity Markets 

•  Investment 
•  Investment 
•  Investment 
Banking 
Banking 
Banking 

•  Global Corporate 
•  Global Corporate 
•  Global Corporate 

Banking 
Banking 
Banking 

•  Global 
•  Global 
•  Global 

Commercial 
Commercial 
Commercial 
Banking 
Banking 
Banking 

•  Business Banking 
•  Business Banking 
•  Business Banking 

•  ALM Activities 
•  ALM Activities 
•  ALM Activities 
•  Non-Core Mortgage 
•  Non-Core Mortgage 
•  Non-Core Mortgage 

Loans 
Loans 
Loans 

•  MSR Valuations 
•  MSR Valuations 
•  MSR Valuations 
•  Liquidating 
•  Liquidating 
•  Liquidating 
Businesses 
Businesses 
Businesses 

•  Equity Investments 
•  Equity Investments 
•  Equity Investments 
•  Corporate Activities 
•  Corporate Activities 
•  Corporate Activities 
and Residual 
and Residual 
and Residual 
Expense Allocations 
Expense Allocations 
Expense Allocations 

•  Accounting 
•  Accounting 
•  Accounting 

Reclassifications 
Reclassifications 
Reclassifications 
and Eliminations 
and Eliminations 
and Eliminations 
•  Initial Impact of  
•  Initial Impact of  
•  Initial Impact of  

Tax Act 
Tax Act 
Tax Act 

We periodically review capital allocated to our businesses and 
We periodically review capital allocated to our businesses and 
We periodically review capital allocated to our businesses and 
allocate capital annually during the strategic and capital planning 
allocate capital annually during the strategic and capital planning 
allocate capital annually during the strategic and capital planning 
processes. We utilize a methodology that considers the effect of 
processes. We utilize a methodology that considers the effect of 
processes. We utilize a methodology that considers the effect of 
regulatory capital requirements in addition to internal risk-based 
regulatory capital requirements in addition to internal risk-based 
regulatory capital requirements in addition to internal risk-based 
capital models. Our internal risk-based capital models use a risk-
capital models. Our internal risk-based capital models use a risk-
capital models. Our internal risk-based capital models use a risk-
adjusted  methodology  incorporating  each  segment’s  credit, 
adjusted  methodology  incorporating  each  segment’s  credit, 
adjusted  methodology  incorporating  each  segment’s  credit, 
market, interest rate, business and operational risk components. 
market, interest rate, business and operational risk components. 
market, interest rate, business and operational risk components. 
For more information on the nature of these risks, see Managing 
For more information on the nature of these risks, see Managing 
For more information on the nature of these risks, see Managing 
Risk on page 55. The capital allocated to the business segments 
Risk on page 55. The capital allocated to the business segments 
Risk on page 55. The capital allocated to the business segments 
is referred to as allocated capital. Allocated equity in the reporting 
is referred to as allocated capital. Allocated equity in the reporting 
is referred to as allocated capital. Allocated equity in the reporting 

units is comprised of allocated capital plus capital for the portion 
units is comprised of allocated capital plus capital for the portion 
units is comprised of allocated capital plus capital for the portion 
of goodwill and intangibles specifically assigned to the reporting 
of goodwill and intangibles specifically assigned to the reporting 
of goodwill and intangibles specifically assigned to the reporting 
unit. For more information, including the definition of reporting unit, 
unit. For more information, including the definition of reporting unit, 
unit. For more information, including the definition of reporting unit, 
see Note 8 – Goodwill and Intangible Assets to the Consolidated 
see Note 8 – Goodwill and Intangible Assets to the Consolidated 
see Note 8 – Goodwill and Intangible Assets to the Consolidated 
Financial Statements.
Financial Statements.
Financial Statements.

For more information on the basis of presentation for business 
For more information on the basis of presentation for business 
For more information on the basis of presentation for business 
segments and reconciliations to consolidated total revenue, net 
segments and reconciliations to consolidated total revenue, net 
segments and reconciliations to consolidated total revenue, net 
income and year-end total assets, see Note 23 – Business Segment 
income and year-end total assets, see Note 23 – Business Segment 
income and year-end total assets, see Note 23 – Business Segment 
Information to the Consolidated Financial Statements.
Information to the Consolidated Financial Statements.
Information to the Consolidated Financial Statements.

Bank of America 2018     45 
Bank of America 2018     45 
Bank of America 2018     45 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consumer Banking

(Dollars in millions)

Net interest income
Noninterest income:

Card income
Service charges
All other income

Total noninterest income
Total revenue, net of interest expense

Provision for credit losses
Noninterest expense

Income before income taxes

Income tax expense
Net income

Effective tax rate (1)

Net interest yield
Return on average allocated capital
Efficiency ratio

Balance Sheet

Average
Total loans and leases
Total earning assets (2)
Total assets (2)
Total deposits
Allocated capital

Year end
Total loans and leases
Total earning assets (2)
Total assets (2)
Total deposits
(1)  Estimated at the segment level only.
(2) 

Deposits

2018
16,024

2017
13,353

$

$

Consumer Lending

2018

2017

Total Consumer Banking
2017

2018

% Change

$

11,099

$

10,954

$

27,123

$

24,307

12%

8
4,298
430
4,736
20,760

195
10,522
10,043
2,561
7,482

2.35%
62
50.68

5,233
682,600
710,925
678,640
12,000

5,470
694,676
724,015
691,666

8
4,265
391
4,664
18,017

201
10,388
7,428
2,813
4,615

2.05%
38
57.66

5,084
651,963
679,306
646,930
12,000

5,143
675,485
703,330
670,802

$

$

$

$

$

$

$

$

$

5,281
2
381
5,664
16,763

3,469
7,191
6,103
1,556
4,547

3.97%
18
42.90

278,574
279,217
290,068
5,533
25,000

288,865
289,249
299,970
4,480

$

$

$

5,062
1
487
5,550
16,504

3,324
7,407
5,773
2,186
3,587

4.18%
14
44.88

260,974
261,802
273,253
6,390
25,000

275,330
275,742
287,390
5,728

$

$

$

5,289
4,300
811
10,400
37,523

3,664
17,713
16,146
4,117
12,029

$

5,070
4,266
878
10,214
34,521

3,525
17,795
13,201
4,999
8,202

25.5%

37.9%

3.78
33
47.20

3.54
22
51.55

$

$

283,807
717,197
756,373
684,173
37,000

294,335
728,817
768,877
696,146

266,058
686,612
725,406
653,320
37,000

280,473
709,832
749,325
676,530

4
1
(8)
2
9

4
—
22
(18)
47

7%
4
4
5
—

5%
3
3
3

In segments and businesses where the total of liabilities and equity exceeds assets, we allocate assets from All Other to match the segments’ and businesses’ liabilities and allocated shareholders’ 
equity. As a result, total earning assets and total assets of the businesses may not equal total Consumer Banking.

Consumer Banking, which is comprised of Deposits and Consumer 
Lending,  offers  a  diversified  range  of  credit,  banking  and 
investment  products  and  services  to  consumers  and  small 
businesses.  Deposits  and  Consumer  Lending  include  the  net 
impact  of  migrating  customers  and  their  related  deposit, 
brokerage asset and loan balances between Deposits, Consumer 
Lending and GWIM, as well as other client-managed businesses. 
Our customers and clients have access to a coast to coast network 
including  financial  centers  in  34  states  and  the  District  of 
Columbia.  Our  network  includes  approximately  4,300  financial 
centers, approximately 16,300 ATMs, nationwide call centers, and 
leading digital banking platforms with more than 36 million active 
users, including over 26 million active mobile users.

Consumer Banking Results
Net income for Consumer Banking increased $3.8 billion to $12.0 
billion in 2018 compared to 2017 primarily driven by higher pretax 
income and lower income tax expense from the reduction in the 
federal income tax rate. The increase in pretax income was driven 
by higher revenue and lower noninterest expense, partially offset 
by  higher  provision  for  credit  losses.  Net  interest  income 
increased  $2.8  billion  to  $27.1  billion  primarily  due  to  the 
beneficial impact of an increase in investable assets as a result 
of an increase in deposits, as well as higher interest rates, pricing 
discipline and loan growth. Noninterest income increased $186 
million  to  $10.4  billion  driven  by  higher  card  income,  partially 
offset by lower mortgage banking income, which is included in all 
other income. 

46     Bank of America 2018

The provision for credit losses increased $139 million to $3.7 
billion driven by portfolio seasoning and loan growth in the U.S. 
credit card portfolio. Noninterest expense decreased $82 million
to $17.7 billion driven by operating efficiencies and lower litigation 
and  FDIC  expense.  These  decreases  were  partially  offset  by 
investments in digital capabilities and business growth, including 
primary sales professionals, combined with investments in new 
financial centers and renovations. 

The return on average allocated capital was 33 percent, up 
from 22 percent, driven by higher net income. For more information 
on  capital  allocated  to  the  business  segments,  see  Business 
Segment Operations on page 45.

Deposits
Deposits includes the results of consumer deposit activities which 
consist  of  a  comprehensive  range  of  products  provided  to 
consumers and small businesses. Our deposit products include 
traditional  savings  accounts,  money  market  savings  accounts, 
CDs  and  IRAs,  and  noninterest-  and  interest-bearing  checking 
accounts,  as  well  as  investment  accounts  and  products.  Net 
interest  income  is  allocated  to  the  deposit  products  using  our 
funds transfer pricing process that matches assets and liabilities 
with similar interest rate sensitivity and maturity characteristics. 
Deposits  generates  fees  such  as  account  service  fees,  non-
sufficient funds fees, overdraft charges and ATM fees, as well as 
investment and brokerage fees from Merrill Edge accounts. Merrill 
Edge is an integrated investing and banking service targeted at 
customers with less than $250,000 in investable assets. Merrill 

Edge provides investment advice and guidance, client brokerage 
asset services, a self-directed online investing platform and key 
banking capabilities including access to the Corporation’s network 
of financial centers and ATMs.

Net income for Deposits increased $2.9 billion to $7.5 billion 
in 2018 driven by higher revenue and lower income tax expense, 
partially offset by higher noninterest expense. Net interest income 
increased  $2.7  billion  to  $16.0  billion  primarily  due  to  the 
beneficial impact of an increase in investable assets as a result 
of  higher  deposits,  and  pricing  discipline.  Noninterest  income 
increased $72 million to $4.7 billion primarily driven by higher 
service charges.

The provision for credit losses decreased $6 million to $195 
million in 2018. Noninterest expense increased $134 million to 
$10.5 billion primarily driven by investments in digital capabilities 
and  business  growth,  including  primary  sales  professionals, 
combined  with  investments  in  new  financial  centers  and 
renovations.  These  increases  were  partially  offset  by  lower 
litigation and FDIC expense.

Average deposits increased $31.7 billion to $678.6 billion in 
2018 driven by strong organic growth. Growth in checking, money 
market  savings  and  traditional  savings  of  $36.3  billion  was 
partially offset by a decline in time deposits of $4.6 billion. 

Key Statistics – Deposits

Total deposit spreads (excludes noninterest costs) (1)

2.14%

1.84%

2018

2017

servicing residential mortgages and home equity loans in the core 
portfolio, including loans held on the balance sheet of Consumer 
Lending and loans serviced for others.

Net income for Consumer Lending increased $960 million to 
$4.5 billion in 2018 driven by lower income tax expense, higher 
revenue and lower noninterest expense, partially offset by higher 
provision for credit losses. Net interest income increased $145 
million to $11.1 billion primarily driven by higher interest rates 
and  the  impact  of  an  increase  in  loan  balances.  Noninterest 
income increased $114 million to $5.7 billion driven by higher 
card income, partially offset by lower mortgage banking income.
The provision for credit losses increased $145 million to $3.5 
billion driven by portfolio seasoning and loan growth in the U.S. 
credit card portfolio. Noninterest expense decreased $216 million
to $7.2 billion primarily driven by operating efficiencies.

Average  loans  increased  $17.6  billion  to  $278.6  billion  in 
2018 driven by increases in residential mortgages and U.S. credit 
card loans, partially offset by lower home equity balances. 

Key Statistics – Consumer Lending

(Dollars in millions)

Total U.S. credit card (1)
Gross interest yield
Risk-adjusted margin
New accounts (in thousands)
Purchase volumes

Debit card purchase volumes
(1) 

2018

2017

10.12%
8.34
4,544
$ 264,706
$ 318,562

9.65%
8.67
4,939
$244,753
$298,641

In addition to the U.S. credit card portfolio in Consumer Banking, the remaining U.S. credit 
card portfolio is in GWIM.

Year end
Client brokerage assets (in millions)
Active digital banking users (units in thousands) (2)
Active mobile banking users (units in thousands)
Financial centers
ATMs
(1) 

Includes deposits held in Consumer Lending.

$ 185,881
36,264
26,433
4,341
16,255

$177,045
34,855
24,238
4,477
16,039

(2)  Digital users represents mobile and/or online users across consumer businesses.

During 2018, the total U.S. credit card risk-adjusted margin 
decreased  33  bps  compared  to  2017,  primarily  driven  by 
increased net charge-offs and higher credit card rewards costs. 
Total U.S. credit card purchase volumes increased $20.0 billion
to  $264.7  billion,  and  debit  card  purchase  volumes  increased
$19.9  billion  to  $318.6  billion,  reflecting  higher  levels  of 
consumer spending.

Client brokerage assets increased $8.8 billion in 2018 driven 
by  strong  client  flows,  partially  offset  by  market  performance. 
Active  mobile  banking  users  increased  2.2  million  reflecting 
continuing changes in our customers’ banking preferences. The 
number  of  financial  centers  declined  by  a  net  136  reflecting 
changes in customer preferences to self-service options as we 
continue to optimize our consumer banking network and improve 
our cost to serve.

Consumer Lending
Consumer  Lending  offers  products  to  consumers  and  small 
businesses across the U.S. The products offered include credit 
and debit cards, residential mortgages and home equity loans, 
and  direct  and  indirect  loans  such  as  automotive,  recreational 
vehicle and consumer personal loans. In addition to earning net 
interest  spread  revenue  on  its  lending  activities,  Consumer 
Lending generates interchange revenue from credit and debit card 
transactions,  late  fees,  cash  advance  fees,  annual  credit  card 
fees, mortgage banking fee income and other miscellaneous fees. 
Consumer  Lending  products  are  available  to  our  customers 
through our retail network, direct telephone, and online and mobile 
channels. Consumer Lending results also include the impact of 

Key Statistics – Loan Production (1)

(Dollars in millions)

Total (2):

First mortgage
Home equity

2018

2017

$

41,195
14,869

$ 50,581
16,924

Consumer Banking:
First mortgage
Home equity

$ 34,065
15,199
(1)  The loan production amounts represent the unpaid principal balance of loans and, in the case 

27,280
13,251

$

(2) 

of home equity, the principal amount of the total line of credit.
In addition to loan production in Consumer Banking, there is also first mortgage and home 
equity loan production in GWIM.

First mortgage loan originations in Consumer Banking and for 
the total Corporation decreased $6.8 billion and $9.4 billion in 
2018 primarily driven by a higher interest rate environment driving 
lower first-lien mortgage refinances.

Home equity production in Consumer Banking and for the total 
Corporation  decreased  $1.9  billion  and  $2.1  billion  in  2018 
primarily driven by lower demand.

Bank of America 2018     47 

 
Global Wealth & Investment Management

(Dollars in millions)

Net interest income
Noninterest income:

Investment and brokerage services
All other income

Total noninterest income
Total revenue, net of interest expense

Provision for credit losses
Noninterest expense

Income before income taxes

Income tax expense
Net income

Effective tax rate

Net interest yield
Return on average allocated capital
Efficiency ratio

Balance Sheet

Average
Total loans and leases
Total earning assets
Total assets
Total deposits
Allocated capital

Year end
Total loans and leases
Total earning assets
Total assets
Total deposits

2018

2017

% Change

$

6,294

$

6,173

2%

11,959
1,085
13,044
19,338

86
13,777
5,475
1,396
4,079

$

11,394
1,023
12,417
18,590

56
13,556
4,978
1,885
3,093

25.5%

37.9%

2.42
28
71.24

2.32
22
72.92

$

$

161,342
259,807
277,219
241,256
14,500

164,854
287,197
305,906
268,700

152,682
265,670
281,517
245,559
14,000

159,378
267,026
284,321
246,994

$

$

$

5
6
5
4

54
2
10
(26)
32

6%
(2)
(2)
(2)
4

3%
8
8
9

GWIM consists of two primary businesses: Merrill Lynch Global 
Wealth Management (MLGWM) and U.S. Trust, Bank of America 
Private Wealth Management (U.S. Trust).

MLGWM’s  advisory  business  provides  a  high-touch  client 
experience  through  a  network  of  financial  advisors  focused  on 
clients with over $250,000 in total investable assets. MLGWM 
provides tailored solutions to meet clients’ needs through a full 
set  of  investment  management,  brokerage,  banking  and 
retirement products. 

U.S.  Trust,  together  with  MLGWM’s  Private  Banking  & 
Investments Group, provides comprehensive wealth management 
solutions  targeted  to  high  net  worth  and  ultra  high  net  worth 
clients, as well as customized solutions to meet clients’ wealth 
structuring, investment management, trust and banking needs, 
including specialty asset management services. 

Net income for GWIM increased $986 million to $4.1 billion 
in  2018  compared  to  2017  due  to  higher  revenue  and  lower 
income tax expense from the reduction in the federal income tax 
rate, partially offset by an increase in noninterest expense and 
provision for credit losses. The operating margin was 28 percent 
compared to 27 percent a year ago.

Net interest income increased $121 million to $6.3 billion due 
to higher deposit spreads and average loan balances, partially 
offset by lower loan spreads and average deposit balances.

Noninterest income, which primarily includes investment and 
brokerage  services  income,  increased  $627  million  to  $13.0 
billion. The increase was driven by the impact of AUM flows and 
higher market valuations, partially offset by the impact of changing 
market dynamics on transactional revenue and AUM pricing. 

Noninterest expense increased $221 million to $13.8 billion
primarily  due  to  higher  revenue-related  incentive  expense  and 
investments  for  business  growth,  partially  offset  by  continued 
expense discipline.

The return on average allocated capital was 28 percent, up 
from 22 percent, as higher net income was partially offset by an 
increased  capital  allocation.  For  more  information  on  capital 
allocated  to  the  business  segments,  see  Business  Segment 
Operations on page 45.

Revenue from MLGWM of $15.9 billion and revenue from U.S. 
Trust of $3.4 billion both increased four percent due to higher 
asset management fees driven by higher net flows and market 
valuations, and an increase in net interest income. The increase 
in MLGWM revenue was partially offset by lower AUM pricing and 
transactional revenue. 

48     Bank of America 2018

Key Indicators and Metrics

(Dollars in millions, except as noted)

Revenue by Business
Merrill Lynch Global Wealth Management
U.S. Trust
Other

Total revenue, net of interest expense

Client Balances by Business, at year end
Merrill Lynch Global Wealth Management
U.S. Trust

Total client balances

Client Balances by Type, at year end
Assets under management
Brokerage and other assets
Deposits
Loans and leases (1)

Total client balances

Assets Under Management Rollforward
Assets under management, beginning of year
Net client flows
Market valuation/other 

Total assets under management, end of year

Associates, at year end (2)
Number of financial advisors
Total wealth advisors, including financial advisors
Total primary sales professionals, including financial advisors and wealth advisors

Merrill Lynch Global Wealth Management Metric
Financial advisor productivity (3) (in thousands)

U.S. Trust Metric, at year end
Primary sales professionals
(1) 

Includes margin receivables which are classified in customer and other receivables on the Consolidated Balance Sheet.

$

$

$

$

$

$

$

$

2018

2017

15,895
3,432
11
19,338

2,193,562
427,294
2,620,856

1,021,221
1,162,997
268,700
167,938
2,620,856

1,080,747
36,406
(95,932)
1,021,221

$

$

$

$

$

$

$

$

15,288
3,295
7
18,590

2,305,664
446,199
2,751,863

1,080,747
1,261,990
246,994
162,132
2,751,863

886,148
95,707
98,892
1,080,747

17,518
19,459
20,556

17,355
19,238
20,318

$

1,034

$

1,005

1,747

1,714

(2)   Includes financial advisors in the Consumer Banking segment of 2,722 and 2,402 at December 31, 2018 and 2017.
(3)   Financial advisor productivity is defined as MLGWM total revenue, excluding the allocation of certain asset and liability management (ALM) activities, divided by the total average number of financial 

advisors (excluding financial advisors in the Consumer Banking segment).

Client Balances 
Client  balances  managed  under  advisory  and/or  discretion  of 
GWIM are AUM and are typically held in diversified portfolios. Fees 
earned on AUM are calculated as a percentage of clients’ AUM 
balances. The asset management fees charged to clients per year 
depend on various factors, but are commonly driven by the breadth 
of the client’s relationship. The net client AUM flows represent 
the net change in clients’ AUM balances over a specified period 

of  time,  excluding  market  appreciation/depreciation  and  other 
adjustments.

Client balances decreased $131.0 billion, or five percent, in 
2018 to $2.6 trillion, primarily due to lower market valuations on 
AUM  and  brokerage  balances,  as  measured  at  December  31, 
2018, partially offset by positive flows.

Bank of America 2018     49 

Global Banking

(Dollars in millions)

Net interest income
Noninterest income:
Service charges
Investment banking fees
All other income

Total noninterest income
Total revenue, net of interest expense

Provision for credit losses
Noninterest expense

Income before income taxes

Income tax expense
Net income

Effective tax rate

Net interest yield
Return on average allocated capital
Efficiency ratio

Balance Sheet

Average
Total loans and leases
Total earning assets
Total assets
Total deposits
Allocated capital

Year end
Total loans and leases
Total earning assets
Total assets
Total deposits

2018

2017

% Change

$

10,881

$

10,504

4%

3,027
2,891
2,845
8,763
19,644

8
8,591
11,045
2,872
8,173

$

3,125
3,471
2,899
9,495
19,999

212
8,596
11,191
4,238
6,953

26.0%

37.9%

2.98
20
43.73

2.93
17
42.98

$

$

354,236
364,748
424,353
336,337
41,000

365,717
377,812
441,477
360,248

346,089
358,302
416,038
312,859
40,000

350,668
365,560
424,533
329,273

$

$

$

(3)
(17)
(2)
(8)
(2)

(96)
—
(1)
(32)
18

2%
2
2
8
3

4%
3
4
9

Global Banking, which includes Global Corporate Banking, Global 
Commercial  Banking,  Business  Banking  and  Global  Investment 
Banking, provides a wide range of lending-related products and 
services,  integrated  working  capital  management  and  treasury 
solutions,  and  underwriting  and  advisory  services  through  our 
network  of  offices  and  client  relationship  teams.  Our  lending 
products  and  services  include  commercial  loans,  leases, 
commitment  facilities,  trade  finance,  commercial  real  estate 
lending and asset-based lending. Our treasury solutions business 
includes treasury management, foreign exchange and short-term 
investing options. We also provide investment banking products 
to our clients such as debt and equity underwriting and distribution, 
and merger-related and other advisory services. Underwriting debt 
and  equity  issuances,  fixed-income  and  equity  research,  and 
certain market-based activities are executed through our global 
broker-dealer affiliates, which are our primary dealers in several 
countries.  Within  Global  Banking,  Global  Commercial  Banking 
clients  generally  include  middle-market  companies,  commercial 
real estate firms and not-for-profit companies. Global Corporate 
Banking  clients  generally  include  large  global  corporations, 
financial institutions and leasing clients. Business Banking clients 
include  mid-sized  U.S.-based  businesses  requiring  customized 
and integrated financial advice and solutions. 

Net income for Global Banking increased $1.2 billion to $8.2 
billion in 2018 compared to 2017 primarily driven by lower income 
tax expense from the reduction in the federal income tax rate and 
lower provision for credit losses, partially offset by lower revenue. 
Noninterest expense was relatively unchanged.

50     Bank of America 2018

Revenue  decreased  $355  million  to  $19.6  billion  driven  by 
lower  noninterest  income,  partially  offset  by  higher  net  interest 
income.  Net  interest  income  increased  $377  million  to  $10.9 
billion primarily due to the impact of higher interest rates, as well 
as loan and deposit growth. Noninterest income decreased $732 
million to $8.8 billion primarily due to lower investment banking 
fees. The provision for credit losses improved $204 million to $8 
million primarily driven by Global Banking’s portion of a 2017 single-
name non-U.S. commercial charge-off and continued improvement 
in the commercial portfolio.

The  return  on  average  allocated  capital  was  20  percent,  up 
from 17 percent, as higher net income was partially offset by an 
increased  capital  allocation.  For  more  information  on  capital 
allocated  to  the  business  segments,  see  Business  Segment 
Operations on page 45.

Global Corporate, Global Commercial and Business 
Banking 
Global Corporate, Global Commercial and Business Banking each 
include  Business  Lending  and  Global  Transaction  Services 
activities.  Business  Lending  includes  various  lending-related 
products  and  services,  and  related  hedging  activities,  including 
commercial loans, leases, commitment facilities, trade finance, 
real estate lending and asset-based lending. Global Transaction 
Services  includes  deposits,  treasury  management,  credit  card, 
foreign exchange and short-term investment products.

The table below and following discussion present a summary of the results, which exclude certain investment banking activities in 

Global Banking.

Global Corporate, Global Commercial and Business Banking

(Dollars in millions)

Revenue

Business Lending
Global Transaction Services

Total revenue, net of interest expense

Balance Sheet

Average
Total loans and leases
Total deposits

Year end
Total loans and leases
Total deposits

Global Corporate Banking

Global Commercial Banking

Business Banking

Total

2018

2017

2018

2017

2018

2017

2018

2017

$

$

$

$

4,122
3,656
7,778

$

$

4,387
3,322
7,709

163,516
163,559

$ 158,292
148,704

174,378
173,183

$ 163,184
155,614

$

$

$

$

4,039
3,288
7,327

$

$

4,280
3,017
7,297

174,279
135,337

$ 170,101
127,720

175,937
149,118

$ 169,997
137,538

$

$

$

$

393
973
1,366

16,432
37,462

15,402
37,973

$

$

$

$

404
849
1,253

17,682
36,435

17,500
36,120

$

$

$

$

8,554
7,917
16,471

$

$

9,071
7,188
16,259

354,227
336,358

$ 346,075
312,859

365,717
360,274

$ 350,681
329,272

Business  Lending  revenue  decreased  $517  million  in  2018 
compared  to  2017.  The  decrease  was  primarily  driven  by  the 
impact of tax reform on certain tax-advantaged investments and 
lower leasing-related revenues.

Global Transaction Services revenue increased $729 million 
to $7.9 billion in 2018 compared to 2017 driven by higher short-
term rates and increased deposits.

Average  loans  and  leases  increased  two  percent  in  2018 
compared  to  2017  driven  by  growth  in  the  commercial  and 
industrial, and commercial real estate portfolios. Average deposits 
increased  eight  percent  due  to  growth  in  domestic  and 
international interest-bearing balances.

Global Investment Banking
Client  teams  and  product  specialists  underwrite  and  distribute 
debt, equity and loan products, and provide advisory services and 
tailored  risk  management  solutions.  The  economics  of  certain 
investment banking and underwriting activities are shared primarily 
between  Global  Banking  and  Global  Markets  under  an  internal 
revenue-sharing  arrangement.  Global  Banking  originates  certain 
deal-related  transactions  with  our  corporate  and  commercial 
clients  that  are  executed  and  distributed  by  Global  Markets.  To 
provide  a  complete  discussion  of  our  consolidated  investment 

banking  fees,  the  following  table  presents  total  Corporation 
investment  banking  fees  and  the  portion  attributable  to  Global 
Banking.

Investment Banking Fees

(Dollars in millions)

Products

Advisory
Debt issuance
Equity issuance
Gross investment
banking fees

Self-led deals

Total investment
banking fees

Global Banking

2018

2017

Total Corporation
2018
2017

$

$

$

1,152
1,327
412

2,891

(68)

1,557
1,506
408

3,471

(113)

$

1,258
3,084
1,183

5,525

(198)

1,691
3,635
940

6,266

(255)

$

2,823

$

3,358

$

5,327

$

6,011

Total Corporation investment banking fees, excluding self-led 
deals, of $5.3 billion, which are primarily included within Global 
Banking  and  Global  Markets,  decreased  11  percent  in  2018 
compared to 2017 primarily due to declines in advisory fees and 
debt underwriting, the latter of which was driven by lower fee pools.

Bank of America 2018     51 

Global Markets

(Dollars in millions)

Net interest income
Noninterest income:

Investment and brokerage services
Investment banking fees
Trading account profits
All other income

Total noninterest income
Total revenue, net of interest expense

Provision for credit losses
Noninterest expense

Income before income taxes

Income tax expense
Net income

Effective tax rate

Return on average allocated capital
Efficiency ratio

Balance Sheet

Average
Trading-related assets:

Trading account securities
Reverse repurchases
Securities borrowed
Derivative assets

Total trading-related assets

Total loans and leases
Total earning assets
Total assets
Total deposits
Allocated capital

Year end
Total trading-related assets
Total loans and leases
Total earning assets
Total assets
Total deposits

2018

2017

% Change

$

3,171

$

3,744

(15)%

1,780
2,296
7,932
884
12,892
16,063

—
10,686
5,377
1,398
3,979

$

2,049
2,476
6,710
972
12,207
15,951

164
10,731
5,056
1,763
3,293

26.0%

34.9%

11
66.53

9
67.27

$

$

215,112
125,084
78,889
46,047
465,132
72,651
473,383
666,003
31,209
35,000

447,998
73,928
457,224
641,922
37,841

216,996
101,795
82,210
40,811
441,812
71,413
449,441
638,673
32,864
35,000

419,375
76,778
449,314
629,013
34,029

$

$

$

(13)
(7)
18
(9)
6
1

(100)
—
6
(21)
21

(1)%
23
(4)
13
5
2
5
4
(5)
—

7 %
(4)
2
2
11

Global  Markets  offers  sales  and  trading  services  and  research 
services  to  institutional  clients  across  fixed-income,  credit, 
currency,  commodity  and  equity  businesses.  Global  Markets 
product coverage includes securities and derivative products in 
both the primary and secondary markets. Global Markets provides 
market-making,  financing,  securities  clearing,  settlement  and 
custody  services  globally  to  our  institutional  investor  clients  in 
support of their investing and trading activities. We also work with 
our commercial and corporate clients to provide risk management 
products using interest rate, equity, credit, currency and commodity 
derivatives, foreign exchange, fixed-income and mortgage-related 
products.  As  a  result  of  our  market-making  activities  in  these 
products, we may be required to manage risk in a broad range of 
financial  products  including  government  securities,  equity  and 
equity-linked securities, high-grade and high-yield corporate debt 
securities, syndicated loans, MBS, commodities and asset-backed 
securities.  The  economics  of  certain  investment  banking  and 
underwriting activities are shared primarily between Global Markets 

and  Global  Banking  under  an 
revenue-sharing 
arrangement.  Global  Banking  originates  certain  deal-related 
transactions with our corporate and commercial clients that are 
executed  and  distributed  by  Global  Markets.  For  information  on 
investment banking fees on a consolidated basis, see page 51.

internal 

Net income for Global Markets increased $686 million to $4.0 
billion  in  2018  compared  to  2017.  Net  DVA  losses  were  $162 
million compared to losses of $428 million in 2017. Excluding net 
DVA,  net  income  increased  $544  million  to  $4.1  billion.  These 
increases were primarily driven by lower income tax expense from 
the reduction in the federal income tax rate, a decrease in the 
provision for credit losses and modestly higher revenue.

Sales and trading revenue, excluding net DVA, increased $19 
million due to higher Equities revenue, largely offset by lower FICC 
revenue. The provision for credit losses decreased $164 million 
driven  by  Global  Markets’  portion  of  a  single-name  non-U.S. 
commercial charge-off in 2017. Noninterest expense decreased
$45 million to $10.7 billion primarily due to lower operating costs.

52     Bank of America 2018

Average total assets increased $27.3 billion to $666.0 billion 
in 2018 primarily driven by increased levels of inventory in FICC 
to facilitate client demand and growth in Equities derivative client 
financing activities. Total year-end assets increased $12.9 billion 
to $641.9 billion at December 31, 2018 due to increased levels 
of inventory in FICC.

The  return  on  average  allocated  capital  was  11  percent,  up 
from 9 percent, reflecting higher net income. For more information 
on  capital  allocated  to  the  business  segments,  see  Business 
Segment Operations on page 45.

Sales and Trading Revenue
Sales and trading revenue includes unrealized and realized gains 
and losses on trading and other assets, net interest income, and 
fees primarily from commissions on equity securities. Sales and 
trading revenue is segregated into fixed-income (government debt 
obligations, investment and non-investment grade corporate debt 
residential  mortgage-backed 
obligations,  commercial  MBS, 
securities, collateralized loan obligations, interest rate and credit 
derivative  contracts),  currencies  (interest  rate  and  foreign 
exchange  contracts),  commodities  (primarily  futures,  forwards, 
swaps  and  options)  and  equities  (equity-linked  derivatives  and 
cash equity activity). The following table and related discussion 
present sales and trading revenue, substantially all of which is in 
Global Markets, with the remainder in Global Banking. In addition, 
the  following  table  and  related  discussion  present  sales  and 
trading revenue, excluding net DVA, which is a non-GAAP financial 
measure.  For  more  information  on  net  DVA,  see  Supplemental 
Financial Data on page 39.

All Other

(Dollars in millions)

Net interest income
Noninterest income (loss)

Total revenue, net of interest expense

Provision for credit losses
Noninterest expense

Loss before income taxes

Income tax benefit

Net loss

Balance Sheet

Average
Total loans and leases
Total assets (1)
Total deposits

Year end

Total loans and leases
Total assets (1)
Total deposits
(1) 

Sales and Trading Revenue (1, 2)

(Dollars in millions)

Sales and trading revenue

2018

2017

Fixed-income, currencies and commodities
Equities

Total sales and trading revenue

$

8,186
4,876
$ 13,062

$

8,657
4,120
$ 12,777

Sales and trading revenue, excluding net DVA (3)
Fixed-income, currencies and commodities
Equities

8,328
4,896
Total sales and trading revenue, excluding net DVA $ 13,224

$

$

9,051
4,154
$ 13,205

(1) 

(2) 

Includes  FTE  adjustments  of  $249  million  and  $236  million  for  2018  and  2017.  For  more 
information on sales and trading revenue, see Note 3 – Derivatives to the Consolidated Financial 
Statements.
Includes Global Banking sales and trading revenue of $430 million and $236 million for 2018
and 2017.

(3)  FICC and Equities sales and trading revenue, excluding net DVA, is a non-GAAP financial measure. 
FICC net DVA losses were $142 million and $394 million for 2018 and 2017. Equities net DVA 
losses were $20 million and $34 million for 2018 and 2017.

The following explanations for year-over-year changes in sales 
and trading, FICC and Equities revenue exclude net DVA, but would 
be  the  same  whether  net  DVA  was  included  or  excluded.  FICC 
revenue decreased $723 million in 2018 primarily due to lower 
activity and a less favorable market in credit-related products. The 
decline in FICC revenue was also impacted by higher funding costs, 
which were driven by increases in market interest rates. Equities 
revenue increased $742 million in 2018 driven by strength in client 
financing and derivatives.

2018

2017

% Change

$

$

$

$

$

573
(1,284)
(711)

(476)
2,614
(2,849)
(2,736)

(113) $

864
(1,648)
(784)

(561)
4,065
(4,288)
(979)
(3,309)

$

$

61,013
201,298
21,966

48,061
196,325
18,541

82,489
206,999
25,194

69,452
194,042
22,719

(34)%
(22)
(9)

(15)
(36)
(34)
n/m
(97)

(26)%
(3)
(13)

(31)%
1
(18)

In segments where the total of liabilities and equity exceeds assets, which are generally deposit-taking segments, we allocate assets from All Other to those segments to match liabilities (i.e., 
deposits) and allocated shareholders’ equity. Average allocated assets were $517.0 billion and $515.6 billion for 2018 and 2017, and year-end allocated assets were $540.8 billion and $520.4 
billion at December 31, 2018 and 2017.

n/m = not meaningful

All Other consists of ALM activities, equity investments, non-core 
mortgage loans and servicing activities, the net impact of periodic 
revisions to the MSR valuation model for core and non-core MSRs 
and the related economic hedge results, liquidating businesses 
and  residual  expense  allocations.  ALM  activities  encompass 
certain residential mortgages, debt securities, interest rate and 
foreign currency risk management activities, the impact of certain 

allocation methodologies and hedge ineffectiveness. The results 
of certain ALM activities are allocated to our business segments. 
For more information on our ALM activities, see Note 23 – Business 
Segment Information to  the  Consolidated  Financial  Statements. 
Equity investments include our merchant services joint venture as 
well  as  a  portfolio  of  equity,  real  estate  and  other  alternative 
investments. For more information on our merchant services joint 

Bank of America 2018     53 

venture,  see  Note  12  –  Commitments  and  Contingencies  to  the 
Consolidated Financial Statements.

The Corporation classifies consumer real estate loans as core 
or non-core based on loan and customer characteristics. For more 
information on the core and non-core portfolios, see Consumer 
Portfolio  Credit  Risk  Management  on  page  66.  Residential 
mortgage loans that are held for ALM purposes, including interest 
rate or liquidity risk management, are classified as core and are 
presented  on  the  balance  sheet  of  All  Other.  During  2018, 
residential mortgage loans held for ALM activities decreased $3.6 
billion to $24.9 billion at December 31, 2018 primarily as a result 
of payoffs and paydowns. Non-core residential mortgage and home 
equity loans, which are principally runoff portfolios, are also held 
in All Other. During 2018, total non-core loans decreased $17.8 
billion to $23.5 billion at December 31, 2018 due primarily to loan 
sales of $10.8 billion, as well as payoffs and paydowns. 

The net loss for All Other improved $3.2 billion to a loss of 
$113 million, driven by a charge of $2.9 billion in 2017 due to 
enactment of the Tax Act. The pretax loss for 2018 compared to 
2017 decreased $1.4 billion primarily due to lower noninterest 
expense.

Revenue  increased  $73  million  to  a  loss  of  $711  million 
primarily due to gains of $731 million from the sale of consumer 
real  estate  loans,  primarily  non-core,  offset  by  a  $729  million 
charge  related  to  the  redemption  of  certain  trust  preferred 
securities  in  2018.  Results  for  2017  included  a  downward 
valuation adjustment of $946 million on tax-advantaged energy 
investments in connection with the Tax Act and a pretax gain of 
$793 million recognized in connection with the sale of the non-
U.S. consumer credit card business in 2017.

Noninterest  expense  decreased  $1.5  billion  to  $2.6  billion 
primarily  due  to  lower  non-core  mortgage  costs  and  reduced 
operational costs from the sale of the non-U.S. consumer credit 
card business. Also, the prior-year period included a $316 million 
impairment charge related to certain data centers.

The income tax benefit was $2.7 billion in 2018 compared to 
a benefit of $1.0 billion in 2017. The increase in the tax benefit 
was primarily driven by a charge of $1.9 billion in 2017 related to 
impacts of the Tax Act for the lower valuation of certain deferred 
tax assets and liabilities. Both periods included income tax benefit 
adjustments to eliminate the FTE treatment of certain tax credits 
recorded in Global Banking.

Table 12 Contractual Obligations

Off-Balance Sheet Arrangements and 
Contractual Obligations
We have contractual obligations to make future payments on debt 
and  lease  agreements.  Additionally,  in  the  normal  course  of 
business,  we  enter  into  contractual  arrangements  whereby  we 
commit  to  future  purchases  of  products  or  services  from 
unaffiliated  parties.  Purchase  obligations  are  defined  as 
obligations that are legally binding agreements whereby we agree 
to purchase products or services with a specific minimum quantity 
at a fixed, minimum or variable price over a specified period of 
time. Included in purchase obligations are vendor contracts, the 
most  significant  of  which  include  communication  services, 
processing services and software contracts. Debt, lease and other 
obligations are more fully discussed in Note 11 – Long-term Debt
and Note 12 – Commitments and Contingencies to the Consolidated 
Financial Statements. 

Other  long-term  liabilities  include  our  contractual  funding 
obligations related to the Non-U.S. Pension Plans and Nonqualified 
and Other Pension Plans (together, the Plans). Obligations to the 
Plans are based on the current and projected obligations of the 
Plans,  performance  of  the  Plans’  assets,  and  any  participant 
contributions, if applicable. During 2018 and 2017, we contributed 
$156 million and $514 million to the Plans, and we expect to make 
$127 million of contributions during 2019. The Plans are more 
fully  discussed  in  Note  17  –  Employee  Benefit  Plans  to  the 
Consolidated Financial Statements.

We  enter  into  commitments  to  extend  credit  such  as  loan 
commitments, standby letters of credit (SBLCs) and commercial 
letters of credit to meet the financing needs of our customers. For 
a  summary  of  the  total  unfunded,  or  off-balance  sheet,  credit 
extension  commitment  amounts  by  expiration  date,  see  Credit 
Extension  Commitments  in  Note  12  –  Commitments  and 
Contingencies to the Consolidated Financial Statements.

We also utilize variable interest entities (VIEs) in the ordinary 
course of business to support our financing and investing needs 
as well as those of our customers. For more information on our 
involvement with unconsolidated VIEs, see Note 7 – Securitizations 
and Other Variable Interest Entities to the Consolidated Financial 
Statements.

Table 12 includes certain contractual obligations at December 

31, 2018 and 2017.

(Dollars in millions)

December 31, 2018

Due in One
Year or Less

Due After
One Year
Through
Three Years

Due After
Three Years
Through
Five Years

December 31
2017

Due After
Five Years

Total

Total

Long-term debt
Operating lease obligations
Purchase obligations
Time deposits
Other long-term liabilities
Estimated interest expense on long-term debt and time deposits (1)

Total contractual obligations

$

$

37,975
2,370
1,288
53,482
1,611
6,795
103,521

$

$

43,685
4,197
1,162
5,477
1,049
10,778
66,348

$

$

41,603
3,043

507
1,473
729
8,407
55,762

$

$

106,077
6,160
1,091
607
544
30,872
145,351

$

$

229,340
15,770
4,048
61,039
3,933
56,852
370,982

$

$

227,402
14,520
4,219
67,844
4,972
49,123
368,080

(1)  Represents forecasted net interest expense on long-term debt and time deposits based on interest rates at December 31, 2018 and 2017. Forecasts are based on the contractual maturity dates 

of each liability, and are net of derivative hedges, where applicable.

54     Bank of America 2018

Representations and Warranties Obligations
information  on  representations  and  warranties 
For  more 
obligations  in  connection  with  the  sale  of  mortgage  loans,  see 
Note 12 – Commitments and Contingencies to the Consolidated 
Financial  Statements.  For  more  information  related  to  the 
sensitivity of the assumptions used to estimate our reserve for 
representations  and  warranties,  see  Complex  Accounting 
Estimates – Representations and Warranties Liability on page 94.

Managing Risk

Overview
Risk  is  inherent  in  all  our  business  activities.  Sound  risk 
management enables us to serve our customers and deliver for 
our shareholders. If not managed well, risks can result in financial 
loss,  regulatory  sanctions  and  penalties,  and  damage  to  our 
reputation,  each  of  which  may  adversely  impact  our  ability  to 
execute  our  business  strategies.  We  take  a  comprehensive 
approach to risk management with a defined Risk Framework and 
an  articulated  Risk  Appetite  Statement  which  are  approved 
annually by the Enterprise Risk Committee (ERC) and the Board.
The  seven  key  types  of  risk  faced  by  the  Corporation  are 
strategic,  credit,  market,  liquidity,  compliance,  operational  and 
reputational.

Strategic risk is the risk resulting from incorrect assumptions 
about  external  or  internal  factors,  inappropriate  business 
plans,  ineffective  business  strategy  execution,  or  failure  to 
respond  in  a  timely  manner  to  changes  in  the  regulatory, 
macroeconomic or competitive environments in the geographic 
locations in which we operate.
Credit risk is the risk of loss arising from the inability or failure 
of a borrower or counterparty to meet its obligations.
Market risk is the risk that changes in market conditions may 
adversely impact the value of assets or liabilities, or otherwise 
negatively impact earnings.
Liquidity risk is the inability to meet expected or unexpected 
cash flow and collateral needs while continuing to support our 
businesses  and  customers  under  a  range  of  economic 
conditions.
Compliance  risk  is  the  risk  of  legal  or  regulatory  sanctions, 
material  financial  loss  or  damage  to  the  reputation  of  the 
Corporation arising from the failure of the Corporation to comply 
with the requirements of applicable laws, rules and regulations 
and our internal policies and procedures.
Operational risk is the risk of loss resulting from inadequate 
or  failed  processes,  people  and  systems,  or  from  external 
events.
Reputational risk is the risk that negative perceptions of the 
Corporation’s  conduct  or  business  practices  may  adversely 
impact its profitability or operations.
The  following  sections  address  in  more  detail  the  specific 
procedures, measures and analyses of the major categories of 
risk. This discussion of managing risk focuses on the current Risk 
Framework that, as part of its annual review process, was approved 
by the ERC and the Board.

As set forth in our Risk Framework, a culture of managing risk 
well is fundamental to fulfilling our purpose and our values and 
delivering responsible growth. It requires us to focus on risk in all 
activities and encourages the necessary mindset and behavior to 
enable effective risk management, and promotes sound risk-taking 

within our risk appetite. Sustaining a culture of managing risk well 
throughout the organization is critical to our success and is a clear 
expectation of our executive management team and the Board.

Our Risk Framework serves as the foundation for the consistent 
and  effective  management  of  risks  facing  the  Corporation.  The 
Risk  Framework  sets  forth  clear  roles,  responsibilities  and 
accountability for the management of risk and provides a blueprint 
for how the Board, through delegation of authority to committees 
and executive officers, establishes risk appetite and associated 
limits for our activities.

Executive  management  assesses,  with  Board  oversight,  the 
risk-adjusted returns of each business. Management reviews and 
approves the strategic and financial operating plans, as well as 
the capital plan and Risk Appetite Statement, and recommends 
them annually to the Board for approval. Our strategic plan takes 
into consideration return objectives and financial resources, which 
must align with risk capacity and risk appetite. Management sets 
financial  objectives  for  each  business  by  allocating  capital  and 
setting a target for return on capital for each business. Capital 
allocations and operating limits are regularly evaluated as part of 
our  overall  governance  processes  as  the  businesses  and  the 
economic environment in which we operate continue to evolve. For 
more  information  regarding  capital  allocations,  see  Business 
Segment Operations on page 45.

The Corporation’s risk appetite indicates the amount of capital, 
earnings or liquidity we are willing to put at risk to achieve our 
strategic objectives and business plans, consistent with applicable 
regulatory requirements. Our risk appetite provides a common and 
comparable set of measures for senior management and the Board 
to clearly indicate our aggregate level of risk and to monitor whether 
the  Corporation’s  risk  profile  remains  in  alignment  with  our 
strategic and capital plans. Our risk appetite is formally articulated 
in the Risk Appetite Statement, which includes both qualitative 
components and quantitative limits.

Our overall capacity to take risk is limited; therefore, we prioritize 
the risks we take in order to maintain a strong and flexible financial 
position so we can withstand challenging economic conditions and 
take advantage of organic growth opportunities. Therefore, we set 
objectives and targets for capital and liquidity that are intended 
to permit us to continue to operate in a safe and sound manner, 
including during periods of stress.

Our lines of business operate with risk limits (which may include 
credit, market and/or operational limits, as applicable) that align 
with  the  Corporation’s  risk  appetite.  Executive  management  is 
responsible for tracking and reporting performance measurements 
as well as any exceptions to guidelines or limits. The Board, and 
its committees when appropriate, oversees financial performance, 
execution of the strategic and financial operating plans, adherence 
to risk appetite limits and the adequacy of internal controls.

For  a  more  detailed  discussion  of  our  risk  management 

activities, see the discussion below and pages 58 through 92. 

Risk Management Governance
The Risk Framework describes delegations of authority whereby 
the  Board  and  its  committees  may  delegate  authority  to 
management-level  committees  or  executive  officers.  Such 
delegations may authorize certain decision-making and approval 
functions,  which  may  be  evidenced  in,  for  example,  committee 
charters, job descriptions, meeting minutes and resolutions.

Bank of America 2018     55 

The chart below illustrates the inter-relationship among the Board, Board committees and management committees that have the 
The chart below illustrates the inter-relationship among the Board, Board committees and management committees that have the 
The chart below illustrates the inter-relationship among the Board, Board committees and management committees that have the 

majority of risk oversight responsibilities for the Corporation. 
majority of risk oversight responsibilities for the Corporation. 
majority of risk oversight responsibilities for the Corporation. 

Board of Directors (1)
Board of Directors (1)
Board of Directors (1)

Board 
Board 
Board 
Committees
Committees
Committees

Audit 
Audit 
Audit 
Committee
Committee
Committee

Enterprise 
Enterprise 
Enterprise 
Risk
Risk
Risk
Committee
Committee
Committee

Corporate 
Corporate 
Corporate 
Governance
Governance
Governance
Committee
Committee
Committee

Compensation 
Compensation 
Compensation 
and Benefits
and Benefits
and Benefits
Committee
Committee
Committee

Management
Management
Management
Committees
Committees
Committees

Disclosure 
Disclosure 
Disclosure 
Committee (2)
Committee (2)
Committee (2)

Management 
Management 
Management 
Risk
Risk
Risk
Committee
Committee
Committee

Reg O
Reg O
Reg O
Committee
Committee
Committee

Corporate 
Corporate 
Corporate 
Benefits 
Benefits 
Benefits 
Committee
Committee
Committee

Management 
Management 
Management 
Compensation 
Compensation 
Compensation 
Committee
Committee
Committee

(1) This presentation does not include committees for other legal entities.
(1) This presentation does not include committees for other legal entities.
(1) This presentation does not include committees for other legal entities.
(2) Reports to the CEO and CFO with oversight by the Audit Committee.
(2) Reports to the CEO and CFO with oversight by the Audit Committee.
(2) Reports to the CEO and CFO with oversight by the Audit Committee.
Board of Directors and Board Committees
Board of Directors and Board Committees
Board of Directors and Board Committees
The Board is composed of 16 directors, all but one of whom are 
The Board is composed of 16 directors, all but one of whom are 
The Board is composed of 16 directors, all but one of whom are 
independent. The Board authorizes management to maintain an 
independent. The Board authorizes management to maintain an 
independent. The Board authorizes management to maintain an 
effective Risk Framework, and oversees compliance with safe and 
effective Risk Framework, and oversees compliance with safe and 
effective Risk Framework, and oversees compliance with safe and 
sound banking practices. In addition, the Board or its committees 
sound banking practices. In addition, the Board or its committees 
sound banking practices. In addition, the Board or its committees 
conduct  inquiries  of,  and  receive  reports  from  management  on 
conduct  inquiries  of,  and  receive  reports  from  management  on 
conduct  inquiries  of,  and  receive  reports  from  management  on 
risk-related matters to assess scope or resource limitations that 
risk-related matters to assess scope or resource limitations that 
risk-related matters to assess scope or resource limitations that 
could impede the ability of Independent Risk Management (IRM) 
could impede the ability of Independent Risk Management (IRM) 
could impede the ability of Independent Risk Management (IRM) 
and/or Corporate Audit to execute its responsibilities. The Board 
and/or Corporate Audit to execute its responsibilities. The Board 
and/or Corporate Audit to execute its responsibilities. The Board 
committees discussed below have the principal responsibility for 
committees discussed below have the principal responsibility for 
committees discussed below have the principal responsibility for 
enterprise-wide  oversight  of  our  risk  management  activities. 
enterprise-wide  oversight  of  our  risk  management  activities. 
enterprise-wide  oversight  of  our  risk  management  activities. 
Through these activities, the Board and applicable committees are 
Through these activities, the Board and applicable committees are 
Through these activities, the Board and applicable committees are 
provided with information on our risk profile and oversee executive 
provided with information on our risk profile and oversee executive 
provided with information on our risk profile and oversee executive 
management  addressing  key  risks  we  face.  Other  Board 
management  addressing  key  risks  we  face.  Other  Board 
management  addressing  key  risks  we  face.  Other  Board 
committees, as described below, provide additional oversight of 
committees, as described below, provide additional oversight of 
committees, as described below, provide additional oversight of 
specific risks.
specific risks.
specific risks.

Each of the committees shown on the above chart regularly 
Each of the committees shown on the above chart regularly 
Each of the committees shown on the above chart regularly 
reports to the Board on risk-related matters within the committee’s 
reports to the Board on risk-related matters within the committee’s 
reports to the Board on risk-related matters within the committee’s 
responsibilities, which is intended to collectively provide the Board 
responsibilities, which is intended to collectively provide the Board 
responsibilities, which is intended to collectively provide the Board 
with integrated insight about our management of enterprise-wide 
with integrated insight about our management of enterprise-wide 
with integrated insight about our management of enterprise-wide 
risks.
risks.
risks.
Audit Committee
Audit Committee
Audit Committee
The Audit Committee oversees the qualifications, performance and 
The Audit Committee oversees the qualifications, performance and 
The Audit Committee oversees the qualifications, performance and 
independence of the Independent Registered Public Accounting 
independence of the Independent Registered Public Accounting 
independence of the Independent Registered Public Accounting 
Firm, the performance of our corporate audit function, the integrity 
Firm, the performance of our corporate audit function, the integrity 
Firm, the performance of our corporate audit function, the integrity 
of our consolidated financial statements, our compliance with legal 
of our consolidated financial statements, our compliance with legal 
of our consolidated financial statements, our compliance with legal 
and regulatory requirements, and makes inquiries of management 
and regulatory requirements, and makes inquiries of management 
and regulatory requirements, and makes inquiries of management 
or the Corporate General Auditor (CGA) to determine whether there 
or the Corporate General Auditor (CGA) to determine whether there 
or the Corporate General Auditor (CGA) to determine whether there 
are  scope  or  resource  limitations  that  impede  the  ability  of 
are  scope  or  resource  limitations  that  impede  the  ability  of 
are  scope  or  resource  limitations  that  impede  the  ability  of 
Corporate  Audit  to  execute  its  responsibilities.  The  Audit 
Corporate  Audit  to  execute  its  responsibilities.  The  Audit 
Corporate  Audit  to  execute  its  responsibilities.  The  Audit 
Committee  is  also  responsible  for  overseeing  compliance  risk 
Committee  is  also  responsible  for  overseeing  compliance  risk 
Committee  is  also  responsible  for  overseeing  compliance  risk 
pursuant to the New York Stock Exchange listing standards.
pursuant to the New York Stock Exchange listing standards.
pursuant to the New York Stock Exchange listing standards.
Enterprise Risk Committee 
Enterprise Risk Committee 
Enterprise Risk Committee 
The  ERC  has  primary  responsibility  for  oversight  of  the  Risk 
The  ERC  has  primary  responsibility  for  oversight  of  the  Risk 
The  ERC  has  primary  responsibility  for  oversight  of  the  Risk 
Framework and key risks we face and of the Corporation’s overall 
Framework and key risks we face and of the Corporation’s overall 
Framework and key risks we face and of the Corporation’s overall 
risk appetite. It approves the Risk Framework and the Risk Appetite 
risk appetite. It approves the Risk Framework and the Risk Appetite 
risk appetite. It approves the Risk Framework and the Risk Appetite 
Statement and further recommends these documents to the Board 
Statement and further recommends these documents to the Board 
Statement and further recommends these documents to the Board 
for  approval.  The  ERC  oversees  senior  management’s 
for  approval.  The  ERC  oversees  senior  management’s 
for  approval.  The  ERC  oversees  senior  management’s 

56     Bank of America 2018
56     Bank of America 2018
56     Bank of America 2018

responsibilities  for  the  identification,  measurement,  monitoring 
responsibilities  for  the  identification,  measurement,  monitoring 
responsibilities  for  the  identification,  measurement,  monitoring 
and control of key risks we face. The ERC may consult with other 
and control of key risks we face. The ERC may consult with other 
and control of key risks we face. The ERC may consult with other 
Board committees on risk-related matters.
Board committees on risk-related matters.
Board committees on risk-related matters.
Other Board Committees
Other Board Committees
Other Board Committees
Our  Corporate  Governance  Committee  oversees  our  Board’s 
Our  Corporate  Governance  Committee  oversees  our  Board’s 
Our  Corporate  Governance  Committee  oversees  our  Board’s 
governance processes, identifies and reviews the qualifications of 
governance processes, identifies and reviews the qualifications of 
governance processes, identifies and reviews the qualifications of 
potential Board members, recommends nominees for election to 
potential Board members, recommends nominees for election to 
potential Board members, recommends nominees for election to 
our  Board,  recommends  committee  appointments  for  Board 
our  Board,  recommends  committee  appointments  for  Board 
our  Board,  recommends  committee  appointments  for  Board 
approval and reviews our Environmental, Social and Governance 
approval and reviews our Environmental, Social and Governance 
approval and reviews our Environmental, Social and Governance 
and stockholder engagement activities.
and stockholder engagement activities.
and stockholder engagement activities.

Our  Compensation  and  Benefits  Committee  oversees 
Our  Compensation  and  Benefits  Committee  oversees 
Our  Compensation  and  Benefits  Committee  oversees 
establishing,  maintaining  and  administering  our  compensation 
establishing,  maintaining  and  administering  our  compensation 
establishing,  maintaining  and  administering  our  compensation 
programs  and  employee  benefit  plans,  including  approving  and 
programs  and  employee  benefit  plans,  including  approving  and 
programs  and  employee  benefit  plans,  including  approving  and 
recommending our Chief Executive Officer’s (CEO) compensation 
recommending our Chief Executive Officer’s (CEO) compensation 
recommending our Chief Executive Officer’s (CEO) compensation 
to our Board for further approval by all independent directors, and 
to our Board for further approval by all independent directors, and 
to our Board for further approval by all independent directors, and 
reviewing  and  approving  all  of  our  executive  officers’ 
reviewing  and  approving  all  of  our  executive  officers’ 
reviewing  and  approving  all  of  our  executive  officers’ 
compensation,  as  well  as  compensation  for  non-management 
compensation,  as  well  as  compensation  for  non-management 
compensation,  as  well  as  compensation  for  non-management 
directors.
directors.
directors.
Management Committees
Management Committees
Management Committees
Management  committees  may  receive  their  authority  from  the 
Management  committees  may  receive  their  authority  from  the 
Management  committees  may  receive  their  authority  from  the 
Board,  a  Board  committee,  another  management  committee  or 
Board,  a  Board  committee,  another  management  committee  or 
Board,  a  Board  committee,  another  management  committee  or 
from one  or  more executive  officers.  Our primary management-
from one  or  more executive  officers.  Our primary management-
from one  or  more executive  officers.  Our primary management-
level risk committee is the Management Risk Committee (MRC). 
level risk committee is the Management Risk Committee (MRC). 
level risk committee is the Management Risk Committee (MRC). 
Subject  to  Board  oversight,  the  MRC  is  responsible  for 
Subject  to  Board  oversight,  the  MRC  is  responsible  for 
Subject  to  Board  oversight,  the  MRC  is  responsible  for 
management oversight of key risks facing the Corporation. This 
management oversight of key risks facing the Corporation. This 
management oversight of key risks facing the Corporation. This 
includes providing management oversight of our compliance and 
includes providing management oversight of our compliance and 
includes providing management oversight of our compliance and 
risk  programs,  balance  sheet  and  capital 
operational 
risk  programs,  balance  sheet  and  capital 
operational 
risk  programs,  balance  sheet  and  capital 
operational 
management, funding activities and other liquidity activities, stress 
management, funding activities and other liquidity activities, stress 
management, funding activities and other liquidity activities, stress 
testing, trading activities, recovery and resolution planning, model 
testing, trading activities, recovery and resolution planning, model 
testing, trading activities, recovery and resolution planning, model 
risk, subsidiary governance and activities between member banks 
risk, subsidiary governance and activities between member banks 
risk, subsidiary governance and activities between member banks 
and their nonbank affiliates pursuant to Federal Reserve rules and 
and their nonbank affiliates pursuant to Federal Reserve rules and 
and their nonbank affiliates pursuant to Federal Reserve rules and 
regulations, among other things.
regulations, among other things.
regulations, among other things.
Lines of Defense
Lines of Defense
Lines of Defense
We have clear ownership and accountability across three lines of 
We have clear ownership and accountability across three lines of 
We have clear ownership and accountability across three lines of 
defense:  Front  Line  Units  (FLUs),  IRM  and  Corporate  Audit.  We 
defense:  Front  Line  Units  (FLUs),  IRM  and  Corporate  Audit.  We 
defense:  Front  Line  Units  (FLUs),  IRM  and  Corporate  Audit.  We 
also have control functions outside of FLUs and IRM (e.g., Legal 
also have control functions outside of FLUs and IRM (e.g., Legal 
also have control functions outside of FLUs and IRM (e.g., Legal 
and  Global  Human  Resources).  The  three  lines  of  defense  are 
and  Global  Human  Resources).  The  three  lines  of  defense  are 
and  Global  Human  Resources).  The  three  lines  of  defense  are 

integrated into our management-level governance structure. Each 
of these functional roles is described in more detail below.

the  Corporation,  with  a  goal  of  ensuring  risks  are  appropriately 
considered, evaluated and responded to in a timely manner.

Executive Officers
Executive  officers  lead  various  functions  representing  the 
functional roles. Authority for functional roles may be delegated 
to  executive  officers  from  the  Board,  Board  committees  or 
management-level  committees.  Executive  officers,  in  turn,  may 
further delegate responsibilities, as appropriate, to management-
level committees, management routines or individuals. Executive 
officers  review  our  activities  for  consistency  with  our  Risk 
Framework,  Risk  Appetite  Statement  and  applicable  strategic, 
capital and financial operating plans, as well as applicable policies, 
standards,  procedures  and  processes.  Executive  officers  and 
other employees make decisions individually on a day-to-day basis, 
consistent with the authority they have been delegated. Executive 
officers and other employees may also serve on committees and 
participate in committee decisions.

Front Line Units
FLUs, which include the lines of business as well as the Global 
Technology  and  Operations  Group,  are 
for 
appropriately assessing and effectively managing all of the risks 
associated with their activities. 

responsible 

Three  organizational  units  that  include  FLU  activities  and 
control function activities, but are not part of IRM are the Chief 
Financial  Officer  (CFO)  Group,  Global  Marketing  and  Corporate 
Affairs (GM&CA) and the Chief Administrative Officer (CAO) Group.

Independent Risk Management
IRM  is  part  of  our  control  functions  and  includes  Global  Risk 
Management  and  Global  Compliance  and  Operational  Risk.  We 
have other control functions that are not part of IRM (other control 
functions may also provide oversight to FLU activities), including 
Legal, Global Human Resources and certain activities within the 
CAO Group, CFO Group and GM&CA. IRM, led by the Chief Risk 
Officer  (CRO),  is  responsible  for  independently  assessing  and 
overseeing  risks  within  FLUs  and  other  control  functions.  IRM 
establishes written enterprise policies and procedures that include 
concentration  risk  limits,  where  appropriate.  Such  policies  and 
procedures outline how aggregate risks are identified, measured, 
monitored and controlled.

The  CRO  has  the  stature,  authority  and  independence  to 
develop and implement a meaningful risk management framework. 
The CRO has unrestricted access to the Board and reports directly 
to  both  the  ERC  and  to  the  CEO.  Global  Risk  Management  is 
organized into horizontal risk teams, front line unit risk teams and 
control function risk teams that work collaboratively in executing 
their respective duties.

Corporate Audit
Corporate Audit and the CGA maintain their independence from 
the FLUs, IRM and other control functions by reporting directly to 
the  Audit  Committee  or  the  Board.  The  CGA  administratively 
reports  to  the  CEO.  Corporate  Audit  provides  independent 
assessment and validation through testing of key processes and 
controls across the Corporation. Corporate Audit includes Credit 
Review which periodically tests and examines credit portfolios and 
processes.

Risk Management Processes
The  Risk  Framework  requires  that  strong  risk  management 
practices  are  integrated  in  key  strategic,  capital  and  financial 
planning processes and in day-to-day business processes across 

We  employ  our  risk  management  process,  referred  to  as 
Identify,  Measure,  Monitor  and  Control,  as  part  of  our  daily 
activities.

Identify – To be effectively managed, risks must be clearly defined 
and proactively identified. Proper risk identification focuses on 
recognizing  and  understanding  key  risks  inherent  in  our 
business activities or key risks that may arise from external 
factors. Each employee is expected to identify and escalate 
risks  promptly.  Risk  identification  is  an  ongoing  process, 
incorporating input from FLUs and control functions, designed 
to be forward looking and capture relevant risk factors across 
all of our lines of business. 

Measure  –  Once  a  risk  is  identified,  it  must  be  prioritized  and 
accurately measured through a systematic risk quantification 
process  including  quantitative  and  qualitative  components. 
Risk is measured at various levels including, but not limited 
to, risk type, FLU, legal entity and on an aggregate basis. This 
risk quantification process helps to capture changes in our risk 
profile due to changes in strategic direction, concentrations, 
portfolio quality and the overall economic environment. Senior 
management considers how risk exposures might evolve under 
a variety of stress scenarios. 

Monitor – We monitor risk levels regularly to track adherence to 
risk appetite, policies, standards, procedures and processes. 
We  also  regularly  update  risk  assessments  and  review  risk 
exposures. Through our monitoring, we can determine our level 
of risk relative to limits and can take action in a timely manner. 
We also can determine when risk limits are breached and have 
processes  to  appropriately  report  and  escalate  exceptions. 
This includes requests for approval to managers and alerts to 
executive management, management-level committees or the 
Board (directly or through an appropriate committee).

Control – We establish and communicate risk limits and controls 
through  policies,  standards,  procedures  and  processes  that 
define  the  responsibilities  and  authority  for  risk-taking.  The 
limits  and  controls  can  be  adjusted  by  the  Board  or 
management  when  conditions  or  risk  tolerances  warrant. 
These  limits  may  be  absolute  (e.g.,  loan  amount,  trading 
volume) or relative (e.g., percentage of loan book in higher-risk 
categories).  Our  lines  of  business  are  held  accountable  to 
perform within the established limits.

risk  well 

The formal processes used to manage risk represent a part of 
our  overall  risk  management  process.  We  instill  a  strong  and 
comprehensive  culture  of  managing 
through 
communications, training, policies, procedures and organizational 
roles and responsibilities. Establishing a culture reflective of our 
purpose to help make our customers’ financial lives better and 
delivering  our  responsible  growth  strategy  are  also  critical  to 
effective risk management. We understand that improper actions, 
behaviors or practices that are illegal, unethical or contrary to our 
core  values  could  result  in  harm  to  the  Corporation,  our 
shareholders  or  our  customers,  damage  the  integrity  of  the 
financial markets, or negatively impact our reputation, and have 
established protocols and structures so that such conduct risk is 
governed and reported across the Corporation. Specifically, our 
Code of Conduct provides a framework for all of our employees to 
conduct  themselves  with  the  highest  integrity.  Additionally,  we 
continue to strengthen the link between the employee performance 
management process and individual compensation to encourage 
employees to work toward enterprise-wide risk goals.

Bank of America 2018     57 

Corporation-wide Stress Testing
Integral to our Capital Planning, Financial Planning and Strategic 
Planning processes, we conduct capital scenario management and 
stress forecasting on a periodic basis to better understand balance 
sheet, earnings and capital sensitivities to certain economic and 
business  scenarios,  including  economic  and  market  conditions 
that  are  more  severe  than  anticipated.  These  stress  forecasts 
provide an understanding of the potential impacts from our risk 
profile on the balance sheet, earnings and capital, and serve as 
a key component of our capital and risk management practices. 
The  intent  of  stress  testing  is  to  develop  a  comprehensive 
understanding of potential impacts of on- and off-balance sheet 
risks at the Corporation and how they impact financial resiliency, 
which  provides  confidence  to  management,  regulators  and  our 
investors. 

Contingency Planning
We  have  developed  and  maintain  contingency  plans  that  are 
designed  to  prepare  us  in  advance  to  respond  in  the  event  of 
potential  adverse  economic,  financial  or  market  stress.  These 
contingency  plans  include  our  Capital  Contingency  Plan  and 
Financial  Contingency  and  Recovery  Plan,  which  provide 
monitoring, escalation, actions and routines designed to enable 
us to increase capital, access funding sources and reduce risk 
through consideration of potential options that include asset sales, 
business  sales,  capital  or  debt  issuances,  or  other  de-risking 
strategies. We also maintain a Resolution Plan to limit adverse 
systemic  impacts  that  could  be  associated  with  a  potential 
resolution of Bank of America.

Strategic Risk Management
Strategic risk is embedded in every business and is one of the 
major  risk  categories  along  with  credit,  market,  liquidity, 
compliance, operational and reputational risks. This risk results 
from  incorrect  assumptions  about  external  or  internal  factors, 
inappropriate  business  plans,  ineffective  business  strategy 
execution, or failure to respond in a timely manner to changes in 
the regulatory, macroeconomic or competitive environments, in the 
geographic  locations  in  which  we  operate,  such  as  competitor 
actions,  changing  customer  preferences,  product  obsolescence 
and  technology  developments.  Our  strategic  plan  is  consistent 
with our risk appetite, capital plan and liquidity requirements, and 
specifically addresses strategic risks.

On  an  annual  basis,  the  Board  reviews  and  approves  the 
strategic  plan,  capital  plan,  financial  operating  plan  and  Risk 
Appetite  Statement.  With  oversight  by  the  Board,  executive 
management directs the lines of business to execute our strategic 
plan consistent with our core operating principles and risk appetite. 
The executive management team monitors business performance 
throughout the year and provides the Board with regular progress 
reports on whether strategic objectives and timelines are being 
met,  including  reports  on  strategic  risks  and  if  additional  or 
alternative actions need to be considered or implemented. The 
regular executive reviews focus on assessing forecasted earnings 
and returns on capital, the current risk profile, current capital and 
liquidity  requirements,  staffing  levels  and  changes  required  to 
support  the  strategic  plan,  stress  testing  results,  and  other 
qualitative factors such as market growth rates and peer analysis. 
Significant strategic actions, such as capital actions, material 
acquisitions or divestitures, and resolution plans are reviewed and 
approved by the Board. At the business level, processes are in 
place to discuss the strategic risk implications of new, expanded 
or modified businesses, products or services and other strategic 
initiatives,  and  to  provide  formal  review  and  approval  where 

58     Bank of America 2018

required.  With  oversight  by  the  Board  and  the  ERC,  executive 
management performs similar analyses throughout the year, and 
evaluates changes to the financial forecast or the risk, capital or 
liquidity positions as deemed appropriate to balance and optimize 
achieving  the  targeted  risk  appetite,  shareholder  returns  and 
maintaining the targeted financial strength. Proprietary models are 
used  to  measure  the  capital  requirements  for  credit,  country, 
market,  operational  and  strategic  risks.  The  allocated  capital 
assigned to each business is based on its unique risk profile. With 
oversight by the Board, executive management assesses the risk-
adjusted  returns  of  each  business  in  approving  strategic  and 
financial operating plans. The businesses use allocated capital to 
define business strategies, and price products and transactions.

Capital Management
The Corporation manages its capital position so that its capital is 
more than adequate to support its business activities and aligns 
with risk, risk appetite and strategic planning. Additionally, we seek 
to maintain safety and soundness at all times, even under adverse 
scenarios, take advantage of organic growth opportunities, meet 
obligations to creditors and counterparties, maintain ready access 
to financial markets, continue to serve as a credit intermediary, 
remain a source of strength for our subsidiaries, and satisfy current 
and future regulatory capital requirements. Capital management 
is integrated into our risk and governance processes, as capital 
is a key consideration in the development of our strategic plan, 
risk appetite and risk limits.

We conduct an Internal Capital Adequacy Assessment Process 
(ICAAP)  on  a  periodic  basis.  The  ICAAP  is  a  forward-looking 
assessment  of  our  projected  capital  needs  and  resources, 
incorporating  earnings,  balance  sheet  and  risk  forecasts  under 
baseline and adverse economic and market conditions. We utilize 
periodic  stress  tests  to  assess  the  potential  impacts  to  our 
balance sheet, earnings, regulatory capital and liquidity under a 
variety  of  stress  scenarios.  We  perform  qualitative  risk 
assessments  to  identify  and  assess  material  risks  not  fully 
captured in our forecasts or stress tests. We assess the potential 
capital  impacts  of  proposed  changes  to  regulatory  capital 
requirements. Management assesses ICAAP results and provides 
documented quarterly assessments of the adequacy of our capital 
guidelines and capital position to the Board or its committees. 

We periodically review capital allocated to our businesses and 
allocate capital annually during the strategic and capital planning 
processes.  For  additional  information,  see  Business  Segment 
Operations on page 45.

CCAR and Capital Planning
The Federal Reserve requires BHCs to submit a capital plan and 
requests for capital actions on an annual basis, consistent with 
the rules governing the CCAR capital plan.

On  June  28,  2018,  following  the  Federal  Reserve’s  non-
objection to our 2018 CCAR capital plan, the Board authorized the 
repurchase of approximately $20.6 billion in common stock from 
July 1, 2018 through June 30, 2019, which includes approximately 
$600 million in repurchases to offset shares awarded under equity-
based compensation plans during the same period. In addition to 
the previously announced repurchases associated with the 2018 
CCAR capital plan, on February 7, 2019, we announced a plan to 
repurchase an additional $2.5 billion of common stock through 
June 30, 2019, which was approved by the Federal Reserve.

During 2018, pursuant to the Board’s authorizations, including 
those related to our 2017 CCAR capital plan that expired June 30, 
2018,  we  repurchased  $20.1  billion  of  common  stock,  which 
includes  common  stock  repurchases  to  offset  equity-based 

compensation awards. At December 31, 2018, our remaining stock 
repurchase authorization was $10.3 billion.

Our stock repurchases are subject to various factors, including 
the Corporation’s capital position, liquidity, financial performance 
and alternative uses of capital, stock trading price and general 
market  conditions,  and  may  be  suspended  at  any  time.  The 
repurchases may be effected through open market purchases or 
privately negotiated transactions, including repurchase plans that 
satisfy the conditions of Rule 10b5-1 of the Securities Exchange 
Act of 1934, as amended. As a “well-capitalized” BHC, we may 
notify  the  Federal  Reserve  of  our  intention  to  make  additional 
capital distributions not to exceed 0.25 percent of Tier 1 capital, 
and which were not contemplated in our capital plan, subject to 
the Federal Reserve’s non-objection.

Regulatory Capital
As  a  financial  services  holding  company,  we  are  subject  to 
regulatory capital rules, including Basel 3, issued by U.S. banking 
regulators. Basel 3 established minimum capital ratios and buffer 
requirements  and  outlined  two  methods  of  calculating  risk-
weighted assets, the Standardized approach and the Advanced 
approaches.  The  Standardized  approach  relies  primarily  on 
supervisory  risk  weights  based  on  exposure  type,  and  the 
Advanced approaches determine risk weights based on internal 
models. 

The Corporation and its primary affiliated banking entity, BANA, 
are  Advanced  approaches  institutions  under  Basel  3  and  are 
required  to  report  regulatory  risk-based  capital  ratios  and  risk-
weighted  assets  under  both  the  Standardized  and  Advanced 
approaches. The approach that yields the lower ratio is used to 
assess capital adequacy including under the Prompt Corrective 
Action (PCA) framework. As of December 31, 2018, Common equity 
tier  1  (CET1)  and  Tier  1  capital  ratios  for  the  Corporation  were 
lower  under  the  Standardized  approach  whereas  the  Advanced 
approaches yielded a lower Total capital ratio. 

Minimum Capital Requirements
Minimum  capital  requirements  and  related  buffers  were  fully 
phased in as of January 1, 2019. The PCA framework established 
categories of capitalization, including well capitalized, based on 
the Basel 3 regulatory ratio requirements. U.S. banking regulators 
are required to take certain mandatory actions depending on the 
category of capitalization, with no mandatory actions required for 
well-capitalized banking organizations.

ratio 

requirements 

In  order  to  avoid  restrictions  on  capital  distributions  and 
discretionary bonus payments, the Corporation must meet risk-
based  capital 
include  a  capital 
conservation buffer greater than 2.5 percent, plus any applicable 
countercyclical capital buffer and a global systemically important 
bank  (G-SIB)  surcharge.  The  buffers  and  surcharge  must  be 
comprised solely of CET1 capital and were phased in over a three-
year period that ended January 1, 2019. 

that 

The  Corporation  is  also  required  to  maintain  a  minimum 
supplementary leverage ratio (SLR) of 3.0 percent plus a leverage 
buffer of 2.0 percent in order to avoid certain restrictions on capital 
distributions  and  discretionary  bonus  payments.  Our  insured 
depository  institution  subsidiaries  are  required  to  maintain  a 
minimum 6.0 percent SLR to be considered well capitalized under 
the PCA framework. The numerator of the SLR is quarter-end Basel 
3 Tier 1 capital. The denominator is total leverage exposure based 
on the daily average of the sum of on-balance sheet exposures 
less permitted Tier 1 deductions, as well as the simple average 
of certain off-balance sheet exposures, as of the end of each month 
in a quarter.

Capital Composition and Ratios
Table  13 presents  Bank  of  America Corporation’s  capital  ratios 
and related information in accordance with Basel 3 Standardized 
and Advanced approaches as measured at December 31, 2018 
and 2017. As of the periods presented, the Corporation met the 
definition of well capitalized under current regulatory requirements.

Bank of America 2018     59 

Table 13 Bank of America Corporation Regulatory Capital under Basel 3 (1)

(Dollars in millions, except as noted)

Risk-based capital metrics:

Common equity tier 1 capital
Tier 1 capital
Total capital (4)
Risk-weighted assets (in billions)
Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio

Leverage-based metrics:

Adjusted quarterly average assets (in billions) (5)
Tier 1 leverage ratio

SLR leverage exposure (in billions)
SLR

Risk-based capital metrics:

Common equity tier 1 capital
Tier 1 capital
Total capital (4)
Risk-weighted assets (in billions)
Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio

Leverage-based metrics:

Adjusted quarterly average assets (in billions) (5)
Tier 1 leverage ratio

Standardized
Approach

Advanced
Approaches

Current 
Regulatory 
Minimum (2)

2019 
Regulatory 
Minimum (3)

December 31, 2018

$

$

$

$

$

167,272
189,038
221,304
1,437

11.6%
13.2
15.4

$

2,258

8.4%

$

168,461
190,189
224,209
1,443

11.7%
13.2
15.5

167,272
189,038
212,878
1,409

11.9%
13.4
15.1

2,258

8.4%

2,791

6.8%

8.25%
9.75
11.75

4.0

5.0

9.5%

11.0
13.0

4.0

5.0

December 31, 2017

168,461
190,189
215,311
1,459

11.5%
13.0
14.8

7.25%
8.75
10.75

9.5%

11.0
13.0

$

2,223

$

2,223

8.6%

8.6%

4.0

4.0

(1)  Basel 3 transition provisions for regulatory capital adjustments and deductions were fully phased in as of January 1, 2018. Prior periods are presented on a fully phased-in basis.
(2)  The December 31, 2018 and 2017 amounts include a transition capital conservation buffer of 1.875 percent and 1.25 percent and a transition G-SIB surcharge of 1.875 percent and 1.5 percent. 

The countercyclical capital buffer for both periods is zero.

(3)  The 2019 regulatory minimums include a capital conservation buffer of 2.5 percent and G-SIB surcharge of 2.5 percent. The countercyclical capital buffer is zero. We became subject to these 

regulatory minimums on January 1, 2019. The SLR minimum includes a leverage buffer of 2.0 percent and was applicable beginning on January 1, 2018.

(4)  Total capital under the Advanced approaches differs from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.
(5)  Reflects adjusted average total assets for the three months ended December 31, 2018 and 2017.

CET1  capital  was  $167.3  billion  at  December  31,  2018,  a 
decrease  of  $1.2  billion  from  December  31,  2017,  driven  by 
common stock repurchases, dividends and market value declines 
on AFS debt securities included in accumulated OCI, partially offset 
by  earnings.  During  2018,  Total  capital  under  the  Advanced 
approaches decreased $2.4 billion driven by the same factors as 
CET1 capital and a decrease in subordinated debt included in Tier 

2  capital.  Standardized  risk-weighted  assets,  which  yielded  the 
lower CET1 capital ratio for December 31, 2018, decreased $5.5 
billion during 2018 to $1,437 billion primarily due to sales of non-
core mortgage loans and a decrease in market risk, partially offset 
by an increase in commercial loans.

Table 14 shows the capital composition at December 31, 2018 

and 2017.

Table 14 Capital Composition under Basel 3 (1)

(Dollars in millions)

Total common shareholders’ equity
Goodwill, net of related deferred tax liabilities
Deferred tax assets arising from net operating loss and tax credit carryforwards
Intangibles, other than mortgage servicing rights and goodwill, net of related deferred tax liabilities
Other

$

Common equity tier 1 capital

Qualifying preferred stock, net of issuance cost
Other

Tier 1 capital

Tier 2 capital instruments
Eligible credit reserves included in Tier 2 capital
Other

December 31

2018

2017

$

242,999
(68,572)
(5,981)
(1,294)
120
167,272
22,326
(560)
189,038
21,887
1,972
(19)
212,878

244,823
(68,576)
(6,555)
(1,743)
512
168,461
22,323
(595)
190,189
22,938
2,272
(88)
215,311

Total capital under the Advanced approaches

$
(1)  Basel 3 transition provisions for regulatory capital adjustments and deductions were fully phased in as of January 1, 2018. Prior periods are presented on a fully phased-in basis.

$

60     Bank of America 2018

Table 15 shows the components of risk-weighted assets as measured under Basel 3 at December 31, 2018 and 2017.

Table 15 Risk-weighted Assets under Basel 3 (1)

Standardized
Approach

Advanced
Approaches

Standardized
Approach

Advanced
Approaches

December 31

(Dollars in billions)

Credit risk
Market risk
Operational risk
Risks related to credit valuation adjustments

$

2018
$

1,384
53
n/a
n/a
1,437

$

827
52
500
30
1,409

2017
$

1,384
59
n/a
n/a
1,443

867
58
500
34
1,459

Total risk-weighted assets

$
(1)  Basel 3 transition provisions for regulatory capital adjustments and deductions were fully phased in as of January 1, 2018. Prior periods are presented on a fully phased-in basis.
n/a = not applicable

$

$

$

Bank of America, N.A. Regulatory Capital
Table 16 presents regulatory capital information for BANA in accordance with Basel 3 Standardized and Advanced approaches as 
measured at December 31, 2018 and 2017. BANA met the definition of well capitalized under the PCA framework for both periods.

Table 16 Bank of America, N.A. Regulatory Capital under Basel 3

(Dollars in millions)

Common equity tier 1 capital
Tier 1 capital
Total capital
Tier 1 leverage
SLR

Common equity tier 1 capital
Tier 1 capital
Total capital
Tier 1 leverage
(1)  Percent required to meet guidelines to be considered well capitalized under the PCA framework.

Regulatory Developments

Minimum Total Loss-Absorbing Capacity
The Federal Reserve’s final rule, which was effective January 1, 
2019,  includes  minimum  external  total  loss-absorbing  capacity 
(TLAC) and long-term debt requirements to improve the resolvability 
and resiliency of large, interconnected BHCs. As of December 31, 
2018, the Corporation’s TLAC and long-term debt exceeded our 
estimated 2019 minimum requirements.

Stress Buffer Requirements
On April 10, 2018, the Federal Reserve announced a proposal to 
integrate the annual quantitative assessment of the CCAR program 
with  the  buffer  requirements  in  the  Basel  3  capital  rule  by 
introducing stress buffer requirements as a replacement of the 
CCAR  quantitative  objection.  Under  the  Standardized  approach, 
the  proposal  replaces  the  existing  static  2.5  percent  capital 
conservation buffer with a stress capital buffer, calculated as the 
decrease  in  the  CET1  capital  ratio  in  the  supervisory  severely 
adverse  scenario  of  the  modified  CCAR  stress  test  plus  four 
quarters of planned common stock dividend payments, floored at 
2.5  percent.  The  static  2.5  percent  capital  conservation  buffer 
would be retained under the Advanced approaches. The proposal 
also introduces a stress leverage buffer requirement which would 
be calculated as the decrease in the Tier 1 leverage ratio in the 
supervisory severely adverse scenario of the modified CCAR stress 
test plus four quarters of planned common stock dividends, with

Standardized Approach

Advanced Approaches

Ratio

Amount

Ratio

Amount

December 31, 2018

Minimum
Required (1)

12.5% $
12.5
13.5
8.7

149,824
149,824
161,760
149,824

15.6% $
15.6
16.0
8.7
7.1

149,824
149,824
153,627
149,824
149,824

December 31, 2017

12.5% $
12.5
13.6
9.0

150,552
150,552
163,243
150,552

14.9% $
14.9
15.4
9.0

150,552
150,552
154,675
150,552

6.5%
8.0
10.0
5.0
6.0

6.5%
8.0
10.0
5.0

no  floor.  The  SLR  would  not  incorporate  a  stress  buffer 
requirement. The proposal  also updates  the  capital distribution 
assumptions used in the CCAR stress test to better align with a 
firm’s expected actions in stress, notably removing the assumption 
that a BHC will carry out all of its planned capital actions under 
stress.

Enhanced Supplementary Leverage Ratio and TLAC 
Requirements
On  April  11,  2018,  the  Federal  Reserve  and  Office  of  the 
Comptroller of the Currency announced a proposal to modify the 
enhanced  SLR  standards  applicable  to  U.S.  G-SIBs  and  their 
insured depository institution subsidiaries. The proposal replaces 
the  existing  2.0  percent  leverage  buffer  with  a  leverage  buffer 
tailored to each G-SIB, set at 50 percent of the applicable G-SIB 
surcharge. This  proposal  also  replaces  the  current 6.0  percent 
threshold  at  which  a  G-SIB’s  insured  depository  institution 
subsidiaries  are  considered  well  capitalized  under  the  PCA 
framework with a threshold set at 3.0 percent plus 50 percent of 
the G-SIB surcharge applicable to the subsidiary’s G-SIB holding 
company. Correspondingly, the proposal updates the external TLAC 
leverage buffer for each G-SIB to 50 percent of the applicable G-
SIB surcharge and revises the leverage component of the minimum 
external  long-term  debt  requirement  from  4.5  percent  to  2.5 
percent plus 50 percent of the applicable G-SIB surcharge.

Bank of America 2018     61 

Revisions to Basel 3 to Address Current Expected Credit 
Loss Accounting
On December 18, 2018, the U.S. banking regulators issued a final 
rule to address the regulatory capital impact of using the current 
expected  credit  loss  methodology  to  measure  credit  reserves 
under a new accounting standard that is effective on January 1, 
2020.  For  more  information  on  this  standard,  see  Note  1  – 
Summary of Significant Accounting Principles to the Consolidated 
Financial Statements. The final rule provides an option to phase 
in the impact to regulatory capital over a three-year period on a 
straight-line basis. It also updates the existing regulatory capital 
framework by creating a new defined term, adjusted allowance for 
credit losses, which would include credit losses on all financial 
instruments  measured  at  amortized  cost  with  the  exception  of 
purchased credit-deteriorated assets. The final rule continues to 
allow a limited amount of credit losses to be recognized in Tier 2 
capital and maintains the existing limits under the Standardized 
and Advanced approaches.

Single-Counterparty Credit Limits
On  June  14,  2018,  the  Federal  Reserve  published  a  final  rule 
establishing single-counterparty credit limits (SCCL) for BHCs with 
total consolidated assets of $250 billion or more. The SCCL rule 
is designed to ensure that the maximum possible loss that a BHC 
could incur due to the default of a single counterparty or a group 
of  connected  counterparties  would  not  endanger  the  BHC’s 
survival, thereby reducing the probability of future financial crises. 
Beginning January 1, 2020, G-SIBs must calculate SCCL on a daily 
basis  by  dividing  the  aggregate  net  credit  exposure  to  a  given 
counterparty by the G-SIB’s Tier 1 capital, ensuring that exposures 
to other G-SIBs and nonbank financial institutions regulated by the 
Federal Reserve do not breach 15 percent of Tier 1 capital and 
exposures to most other counterparties do not breach 25 percent 
of Tier 1 capital. Certain exposures, including exposures to the 
U.S.  government,  U.S.  government-sponsored  entities  and 
qualifying central counterparties, are exempt from the credit limits.

Broker-dealer Regulatory Capital and Securities 
Regulation 
The  Corporation’s  principal  U.S.  broker-dealer  subsidiaries  are 
Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S) and 
Merrill Lynch Professional Clearing Corp (MLPCC). MLPCC is a fully-
guaranteed  subsidiary  of  MLPF&S  and  provides  clearing  and 
settlement services. Both entities are subject to the net capital 
requirements of Securities and Exchange Commission (SEC) Rule 
15c3-1. Both entities are also registered as futures commission 
merchants  and  are  subject  to  the  Commodity  Futures  Trading 
Commission Regulation 1.17.

MLPF&S  has  elected  to  compute  the  minimum  capital 
requirement  in  accordance  with  the  Alternative  Net  Capital 
Requirement as permitted by SEC Rule 15c3-1. At December 31, 
2018, MLPF&S’ regulatory net capital as defined by Rule 15c3-1 
was $13.4 billion and exceeded the minimum requirement of $2.0 
billion  by  $11.4  billion.  MLPCC’s  net  capital  of  $4.4  billion 
exceeded  the  minimum  requirement  of  $617  million  by  $3.8 
billion.

In accordance with the Alternative Net Capital Requirements, 
MLPF&S is required to maintain tentative net capital in excess of 
$1.0 billion, net capital in excess of $500 million and notify the 
SEC in the event its tentative net capital is less than $5.0 billion. 
At December 31, 2018, MLPF&S had tentative net capital and net 
capital in excess of the minimum and notification requirements.

As  a  result  of  resolution  planning,  the  current  business  of 
MLPF&S is expected to be reorganized into two affiliated broker-

62     Bank of America 2018

dealers: MLPF&S and BofA Securities, Inc., a newly formed broker-
dealer. Under the contemplated reorganization, which is expected 
to occur during 2019, BofA Securities, Inc. would become the legal 
entity  for  the  institutional  services  that  are  now  provided  by 
MLPF&S. MLPF&S’ retail services would remain with MLPF&S. The 
contemplated reorganization is subject to regulatory approval. For 
more information on resolution planning, see Item 1. Business – 
Resolution Planning of our 2018 Annual Report on Form 10-K.

Merrill  Lynch  International  (MLI),  a  U.K.  investment  firm,  is 
regulated by the Prudential Regulation Authority and the FCA, and 
is subject to certain regulatory capital requirements. At December 
31,  2018,  MLI’s  capital  resources  were  $35.0  billion,  which 
exceeded the minimum Pillar 1 requirement of $12.7 billion.

Liquidity Risk

Funding and Liquidity Risk Management
Our  primary  liquidity  risk  management  objective  is  to  meet 
expected  or  unexpected  cash  flow  and  collateral  needs  while 
continuing to support our businesses and customers under a range 
of economic conditions. To achieve that objective, we analyze and 
monitor our liquidity risk under expected and stressed conditions, 
maintain liquidity and access to diverse funding sources, including 
our  stable  deposit  base,  and  seek  to  align  liquidity-related 
incentives and risks.

We define liquidity as readily available assets, limited to cash 
and high-quality, liquid, unencumbered securities that we can use 
to  meet  our contractual  and contingent  financial  obligations  as 
those obligations arise. We manage our liquidity position through 
line of business and ALM activities, as well as through our legal 
entity funding strategy, on both a forward and current (including 
intraday) basis under both expected and stressed conditions. We 
believe  that  a  centralized  approach  to  funding  and  liquidity 
management  enhances  our  ability 
liquidity 
requirements, maximizes access to funding sources, minimizes 
borrowing  costs  and  facilitates  timely  responses  to  liquidity 
events. 

to  monitor 

The Board approves our liquidity risk policy and the Financial 
Contingency and Recovery Plan. The ERC establishes our liquidity 
risk  tolerance  levels.  The  MRC  is  responsible  for  overseeing 
liquidity risks and directing management to maintain exposures 
within  the  established  tolerance  levels.  The  MRC  reviews  and 
monitors our liquidity position and stress testing results, approves 
certain  liquidity  risk  limits  and  reviews  the  impact  of  strategic 
decisions on our liquidity. For more information, see Managing Risk 
on page 55. Under this governance framework, we have developed 
certain  funding  and  liquidity  risk  management  practices  which 
include: maintaining liquidity at the parent company and selected 
subsidiaries, including our bank subsidiaries and other regulated 
entities; determining what amounts of liquidity are appropriate for 
these  entities  based  on  analysis  of  debt  maturities  and  other 
potential cash outflows, including those that we may experience 
during stressed market conditions; diversifying funding sources, 
considering  our  asset  profile  and  legal  entity  structure;  and 
performing contingency planning.

NB Holdings Corporation
We have intercompany arrangements with certain key subsidiaries 
under  which  we  transferred  certain  assets  of  Bank  of  America 
Corporation,  as  the  parent  company,  which  is  a  separate  and 
distinct legal entity from our banking and nonbank subsidiaries, 
and agreed to transfer certain additional parent company assets 
not needed to satisfy anticipated near-term expenditures, to NB 
Holdings Corporation, a wholly-owned holding company subsidiary 

(NB Holdings). The parent company is expected to continue to have 
access to the same flow of dividends, interest and other amounts 
of cash necessary to service its debt, pay dividends and perform 
other obligations as it would have had if it had not entered into 
these arrangements and transferred any assets.

In consideration for the transfer of assets, NB Holdings issued 
a subordinated note to the parent company in a principal amount 
equal  to  the  value  of  the  transferred  assets.  The  aggregate 
principal amount of the note will increase by the amount of any 
future  asset  transfers.  NB  Holdings  also  provided  the  parent 
company with a committed line of credit that allows the parent 
company  to  draw  funds  necessary  to  service  near-term  cash 
needs. These arrangements support our preferred single point of 
entry  resolution  strategy,  under  which  only  the  parent  company 
would  be  resolved  under  the  U.S.  Bankruptcy  Code.  These 
arrangements include provisions to terminate the line of credit, 
forgive the subordinated note and require the parent company to 
transfer  its  remaining  financial  assets  to  NB  Holdings  if  our 
projected liquidity resources deteriorate so severely that resolution 
of the parent company becomes imminent.

Global Liquidity Sources and Other Unencumbered Assets
We maintain liquidity available to the Corporation, including the 
parent company and selected subsidiaries, in the form of cash 
and  high-quality,  liquid,  unencumbered  securities.  Our  liquidity 
buffer, referred to as Global Liquidity Sources (GLS), is comprised 
of  assets  that  are  readily  available  to  the  parent  company  and 
selected subsidiaries, including holding company, bank and broker-
dealer subsidiaries, even during stressed market conditions. Our 
cash is primarily on deposit with the Federal Reserve Bank and, 
to a lesser extent, central banks outside of the U.S. We limit the 
composition  of  high-quality,  liquid,  unencumbered  securities  to 
U.S. government securities, U.S. agency securities, U.S. agency 
MBS and a select group of non-U.S. government securities. We 
can  quickly  obtain  cash  for  these  securities,  even  in  stressed 
conditions, through repurchase agreements or outright sales. We 
hold our GLS in legal entities that allow us to meet the liquidity 
requirements of our global businesses, and we consider the impact 
of potential regulatory, tax, legal and other restrictions that could 
limit the transferability of funds among entities.

Table 17 presents average GLS for the three months ended 

December 31, 2018 and 2017.

Table 17 Average Global Liquidity Sources

(Dollars in billions)

Parent company and NB Holdings
Bank subsidiaries
Other regulated entities

Total Average Global Liquidity Sources

Three Months Ended
December 31

2018

2017

$

$

76
420
48
544

$

$

79
394
49
522

Typically, parent company and NB Holdings liquidity is in the 

form of cash deposited with BANA.

Our bank subsidiaries’ liquidity is primarily driven by deposit 
and lending activity, as well as securities valuation and net debt 
activity. Liquidity at bank subsidiaries excludes the cash deposited 
by the parent company and NB Holdings. Our bank subsidiaries 
can  also  generate  incremental  liquidity  by  pledging  a  range  of 
unencumbered  loans  and  securities  to  certain  FHLBs  and  the 
Federal  Reserve  Discount  Window.  The  cash  we  could  have 
obtained by borrowing against this pool of specifically-identified 
eligible assets was $344 billion and $308 billion at December 31, 

2018 and 2017. We have established operational procedures to 
enable  us  to  borrow  against  these  assets,  including  regularly 
monitoring our total pool of eligible loans and securities collateral. 
Eligibility is defined in guidelines from the FHLBs and the Federal 
Reserve  and  is  subject  to  change  at  their  discretion.  Due  to 
regulatory restrictions, liquidity generated by the bank subsidiaries 
can  generally  be  used  only  to  fund  obligations  within  the  bank 
subsidiaries,  and  transfers  to  the  parent  company  or  nonbank 
subsidiaries may be subject to prior regulatory approval.

Liquidity held in other regulated entities, comprised primarily 
of  broker-dealer  subsidiaries,  is  primarily  available  to  meet  the 
obligations of that entity and transfers to the parent company or 
to any other subsidiary may be subject to prior regulatory approval 
due  to  regulatory  restrictions  and  minimum  requirements.  Our 
other regulated entities also hold unencumbered investment-grade 
securities and equities that we believe could be used to generate 
additional liquidity.

Table 18 presents the composition of average GLS for the three 

months ended December 31, 2018 and 2017.

Table 18 Average Global Liquidity Sources Composition

(Dollars in billions)

Cash on deposit
U.S. Treasury securities
U.S. agency securities and mortgage-backed

securities

Non-U.S. government securities

Total Average Global Liquidity Sources

Three Months Ended
December 31

2018

2017

$

$

113
81

340

10
544

$

$

118
62

330

12
522

Our  GLS  are  substantially  the  same  in  composition  to  what 
qualifies as High Quality Liquid Assets (HQLA) under the final U.S. 
Liquidity Coverage Ratio (LCR) rules. However, HQLA for purposes 
of calculating LCR is not reported at market value, but at a lower 
value that incorporates regulatory deductions and the exclusion 
of  excess  liquidity  held  at  certain  subsidiaries.  The  LCR  is 
calculated as the amount of a financial institution’s unencumbered 
HQLA relative to the estimated net cash outflows the institution 
could encounter over a 30-day period of significant liquidity stress, 
expressed as a percentage. Our average consolidated HQLA, on 
a net basis, was $446 billion and $439 billion for the three months 
ended December 31, 2018 and 2017. For the same periods, the 
average consolidated LCR was 118 percent and 125 percent. Our 
LCR will fluctuate due to normal business flows from customer 
activity.

Liquidity Stress Analysis
We utilize liquidity stress analysis to assist us in determining the 
appropriate amounts of liquidity to maintain at the parent company 
and  our  subsidiaries  to  meet  contractual  and  contingent  cash 
outflows under a range of scenarios. The scenarios we consider 
and  utilize  incorporate  market-wide  and  Corporation-specific 
events, including potential credit rating downgrades for the parent 
company and our subsidiaries, and more severe events including 
potential resolution scenarios. The scenarios are based on our 
historical experience, experience of distressed and failed financial 
institutions,  regulatory  guidance,  and  both  expected  and 
unexpected future events.

The types of potential contractual and contingent cash outflows 
we consider in our scenarios may include, but are not limited to, 
upcoming contractual maturities of unsecured debt and reductions 
in  new  debt  issuance;  diminished  access  to  secured  financing 
markets; potential deposit withdrawals; increased draws on loan 

Bank of America 2018     63 

commitments, liquidity facilities and letters of credit; additional 
collateral that counterparties could call if our credit ratings were 
downgraded;  collateral  and  margin  requirements  arising  from 
market value changes; and potential liquidity required to maintain 
businesses and finance customer activities. Changes in certain 
market  factors,  including,  but  not  limited  to,  credit  rating 
downgrades,  could  negatively  impact  potential  contractual  and 
contingent outflows and the related financial instruments, and in 
some  cases  these  impacts  could  be  material  to  our  financial 
results.

We consider all sources of funds that we could access during 
each stress scenario and focus particularly on matching available 
sources with corresponding liquidity requirements by legal entity. 
We also use the stress modeling results to manage our asset and 
liability  profile  and  establish  limits  and  guidelines  on  certain 
funding sources and businesses.

Net Stable Funding Ratio
U.S. banking regulators issued a proposal for a Net Stable Funding 
Ratio (NSFR) requirement applicable to U.S. financial institutions 
following the Basel Committee’s final standard. The proposed U.S. 
NSFR would apply to the Corporation on a consolidated basis and 
to our insured depository institutions. While the final requirement 
remains pending and is subject to change, if finalized as proposed, 
we expect to be in compliance within the regulatory timeline. The 
standard  is  intended  to  reduce  funding  risk  over  a  longer  time 
horizon. The NSFR is designed to provide an appropriate amount 
of stable funding, generally capital and liabilities maturing beyond 
one year, given the mix of assets and off-balance sheet items.

Diversified Funding Sources
We fund our assets primarily with a mix of deposits, and secured 
through  a  centralized,  globally 
and  unsecured 
coordinated  funding  approach  diversified  across  products, 
programs, markets, currencies and investor groups.

liabilities 

The  primary  benefits  of  our  centralized  funding  approach 
include  greater  control,  reduced  funding  costs,  wider  name 
recognition by investors and greater flexibility to meet the variable 
funding  requirements  of  subsidiaries.  Where  regulations,  time 
zone differences or other business considerations make parent 
company funding impractical, certain other subsidiaries may issue 
their own debt.

We fund a substantial portion of our lending activities through 
our  deposits,  which  were  $1.38  trillion  and  $1.31  trillion  at 
December 31, 2018 and 2017. Deposits are primarily generated 
by our Consumer Banking, GWIM and Global Banking segments. 
These  deposits  are  diversified  by  clients,  product  type  and 
geography, and the majority of our U.S. deposits are insured by 
the FDIC. We consider a substantial portion of our deposits to be 
a stable, low-cost and consistent source of funding. We believe 
this  deposit  funding  is  generally  less  sensitive  to  interest  rate 
changes,  market  volatility  or  changes  in  our  credit  ratings  than 
wholesale  funding  sources.  Our  lending  activities  may  also  be 
financed  through  secured  borrowings,  including  credit  card 
securitizations  and  securitizations  with  government-sponsored 
enterprises (GSE), the Federal Housing Administration (FHA) and 
private-label investors, as well as FHLB loans.

Our trading activities in other regulated entities are primarily 
funded  on  a  secured  basis  through  securities  lending  and 
repurchase agreements, and these amounts will vary based on 
customer activity and market conditions. We believe funding these 
activities in the secured financing markets is more cost-efficient 
and less sensitive to changes in our credit ratings than unsecured 
financing. Repurchase agreements are generally short-term and 

64     Bank of America 2018

often  overnight.  Disruptions  in  secured  financing  markets  for 
financial institutions have occurred in prior market cycles which 
resulted in adverse changes in terms or significant reductions in 
the availability of such financing. We manage the liquidity risks 
arising from secured funding by sourcing funding globally from a 
diverse group of counterparties, providing a range of securities 
collateral  and  pursuing  longer  durations,  when  appropriate.  For 
more information on secured financing agreements, see Note 10 
–  Federal  Funds  Sold  or  Purchased,  Securities  Financing 
Agreements,  Short-term  Borrowings  and  Restricted  Cash  to  the 
Consolidated Financial Statements.

We issue long-term unsecured debt in a variety of maturities 
and currencies to achieve cost-efficient funding and to maintain 
an appropriate maturity profile. While the cost and availability of 
unsecured funding may be negatively impacted by general market 
conditions or by matters specific to the financial services industry 
or the Corporation, we seek to mitigate refinancing risk by actively 
managing  the  amount  of  our  borrowings  that  we  anticipate  will 
mature within any month or quarter.

Table  19  presents  our  long-term  debt  by  major  currency  at 

December 31, 2018 and 2017.

Table 19 Long-term Debt by Major Currency

(Dollars in millions)

U.S. dollar
Euro
British pound
Japanese yen
Canadian dollar
Australian dollar
Other

Total long-term debt

December 31

2018

2017

180,709
34,296
5,450
3,036
2,935
1,722
1,192
229,340

$ 175,623
35,481
7,016
2,993
1,966
3,046
1,277
$ 227,402

$

$

Total  long-term  debt  increased  $1.9  billion  during  2018, 
primarily due to issuances outpacing maturities and redemptions. 
We may, from time to time, purchase outstanding debt instruments 
in various transactions, depending on market conditions, liquidity 
and  other  factors.  Our  other  regulated  entities  may  also  make 
markets in our debt instruments to provide liquidity for investors. 
For more information on long-term debt funding, see Note 11 – 
Long-term Debt to the Consolidated Financial Statements.

During  2018,  we  issued  $64.4  billion  of  long-term  debt 
consisting  of  $30.7  billion  for  Bank  of  America  Corporation, 
substantially all of which was TLAC compliant, $18.7 billion for 
Bank of America, N.A. and $15.0 billion of other debt. During 2017, 
we  issued  $53.3  billion  of  long-term  debt  consisting  of  $37.7 
billion for Bank of America Corporation, substantially all of which 
was TLAC compliant, $8.2 billion for Bank of America, N.A. and 
$7.4 billion of other debt.

During  2018,  we  had  total  long-term  debt  maturities  and 
redemptions in the aggregate of $53.3 billion consisting of $29.8 
billion for Bank of America Corporation, $11.2 billion for Bank of 
America, N.A. and $12.3 billion of other debt. During 2017, we 
had  total  long-term  debt  maturities  and  redemptions  in  the 
aggregate of $48.8 billion consisting of $29.1 billion for Bank of 
America Corporation, $13.3 billion for Bank of America, N.A. and 
$6.4 billion of other debt.

During  2018,  we  redeemed  trust  preferred  securities  of  11 
trusts with a carrying value of $3.1 billion and recorded a charge 
of $729 million in other income. We also collapsed two trusts, 
with  no  financial  statement  impact,  that  held  fixed-rate  junior 
subordinated notes with a carrying value of $741 million that were 

outstanding at December 31, 2018. At December 31, 2018, we 
had one remaining floating-rate junior subordinated note held in 
trust.

We use derivative transactions to manage the duration, interest 
rate  and  currency  risks  of  our  borrowings,  considering  the 
characteristics of the assets they are funding. For more information 
on our ALM activities, see Interest Rate Risk Management for the 
Banking Book on page 89.

We may also issue unsecured debt in the form of structured 
notes for client purposes, certain of which qualify as TLAC eligible 
debt.  During  2018,  we  issued  $6.9  billion  of  structured  notes, 
which are debt obligations that pay investors returns linked to other 
debt or equity securities, indices, currencies or commodities. We 
typically  hedge  the  returns  we  are  obligated  to  pay  on  these 
liabilities  with  derivatives  and/or  investments  in  the  underlying 
instruments, so that from a funding perspective, the cost is similar 
to our other unsecured long-term debt. We could be required to 
settle  certain  structured  note  obligations  for  cash  or  other 
securities prior to maturity under certain circumstances, which we 
consider for liquidity planning purposes. We believe, however, that 
a portion of such borrowings will remain outstanding beyond the 
earliest put or redemption date.

Substantially  all  of  our  senior  and  subordinated  debt 
obligations contain no provisions that could trigger a requirement 
for an early repayment, require additional collateral support, result 
in  changes  to  terms,  accelerate  maturity  or  create  additional 
financial obligations upon an adverse change in our credit ratings, 
financial ratios, earnings, cash flows or stock price. 

Contingency Planning
We maintain contingency funding plans that outline our potential 
responses to liquidity stress events at various levels of severity. 
These  policies  and  plans  are  based  on  stress  scenarios  and 
include  potential  funding  strategies  and  communication  and 
notification procedures that we would implement in the event we 
experienced stressed liquidity conditions. We periodically review 
and test the contingency funding plans to validate efficacy and 
assess readiness.

Our  U.S.  bank  subsidiaries  can  access  contingency  funding 
through the Federal Reserve Discount Window. Certain non-U.S. 
subsidiaries  have  access  to  central  bank  facilities  in  the 
jurisdictions in which they operate. While we do not rely on these 
sources  in  our  liquidity  modeling,  we  maintain  the  policies, 
procedures and governance processes that would enable us to 
access these sources if necessary.

Credit Ratings
Our borrowing costs and ability to raise funds are impacted by our 
credit  ratings.  In  addition,  credit  ratings  may  be  important  to 
customers or counterparties when we compete in certain markets 
and  when  we  seek  to  engage  in  certain  transactions,  including 
over-the-counter  (OTC)  derivatives.  Thus,  it  is  our  objective  to 
maintain high-quality credit ratings, and management maintains 
an active dialogue with the major rating agencies.

Credit ratings and outlooks are opinions expressed by rating 
agencies  on  our  creditworthiness  and  that  of  our  obligations 

or  securities,  including  long-term  debt,  short-term  borrowings, 
preferred  stock  and  other  securities, 
including  asset 
securitizations. Our credit ratings are subject to ongoing review by 
the  rating  agencies,  and  they  consider  a  number  of  factors, 
including our own financial strength, performance, prospects and 
operations  as  well  as  factors  not  under  our  control.  The  rating 
agencies could make adjustments to our ratings at any time, and 
they provide no assurances that they will maintain our ratings at 
current levels.

Other factors that influence our credit ratings include changes 
to the rating agencies’ methodologies for our industry or certain 
security  types;  the  rating  agencies’  assessment  of  the  general 
operating  environment  for  financial  services  companies;  our 
relative positions in the markets in which we compete; our various 
risk  exposures  and  risk  management  policies  and  activities; 
pending litigation and other contingencies or potential tail risks; 
our reputation; our liquidity position, diversity of funding sources 
and funding costs; the current and expected level and volatility of 
our  earnings;  our  capital  position  and  capital  management 
practices; our corporate governance; the sovereign credit ratings 
of the U.S. government; current or future regulatory and legislative 
initiatives;  and  the  agencies’  views  on  whether  the  U.S. 
government would provide meaningful support to the Corporation 
or its subsidiaries in a crisis.

On December 5, 2018, Moody’s Investors Service (Moody’s) 
placed the long-term and short-term ratings of the Corporation as 
well as the long-term ratings of its rated subsidiaries, including 
BANA, on review for upgrade. The agency cited the Corporation’s 
strengthening profitability, continued adherence to a conservative 
risk profile, and stable capital ratios as drivers of the review. A 
rating review indicates that those ratings are under consideration 
for a change in the near term, which typically concludes within 90 
days. Moody’s concurrently affirmed the short-term ratings of the 
Corporation’s rated subsidiaries, including BANA. 

The ratings from Standard & Poor’s Global Ratings (S&P) for 
the Corporation and its subsidiaries did not change during 2018. 
The last change to the ratings from S&P was a one-notch upgrade 
of the Corporation’s long-term ratings in November 2017.

On  June  21,  2018,  Fitch  Ratings  (Fitch)  upgraded  the 
Corporation’s long-term senior debt rating to A+ from A as part of 
the agency’s latest review of 12 Global Trading & Investment Banks, 
citing our sustained and improved risk-adjusted earnings, lower 
risk appetite relative to peers, overall franchise strength and solid 
liquidity position. The Corporation’s short-term debt rating of F1 
was affirmed. Additionally, Fitch upgraded the long- and short-term 
debt ratings of the Corporation’s rated U.S. subsidiaries, including 
BANA and MLPF&S, and upgraded the long-term debt ratings of 
our rated international subsidiaries, including MLI. The outlook at 
Fitch remains stable for all long-term debt ratings.

Table 20 presents the Corporation’s current long-term/short-
term  senior  debt  ratings  and  outlooks  expressed  by  the  rating 
agencies.

Bank of America 2018     65 

Table 20 Senior Debt Ratings

Moody’s Investors Service
Short-term

Long-term

Outlook
Review for
upgrade
Review for 
upgrade (1)

Standard & Poor’s Global Ratings
Short-term

Outlook

Long-term

Long-term

Fitch Ratings
Short-term

Outlook

         A-

        A-2

      Stable

         A+

         F1

      Stable

         A+

        A-1

      Stable

        AA-

         F1+

      Stable

       NR

       NR

         A+

         A+

        A-1

        A-1

      Stable

      Stable

        AA-

         A+

         F1+

      Stable

         F1

      Stable

Bank of America Corporation

        A3

        P-2

Bank of America, N.A.

       Aa3

        P-1

Merrill Lynch, Pierce, Fenner &

Smith Incorporated

       NR

        NR

Merrill Lynch International
(1)   Review for upgrade only applies to BANA’s long-term rating.
NR = not rated

       NR

        NR

A  reduction  in  certain  of  our  credit  ratings  or  the  ratings  of 
certain asset-backed securitizations may have a material adverse 
effect on our liquidity, potential loss of access to credit markets, 
the related cost of funds, our businesses and on certain trading 
revenues,  particularly  in  those  businesses  where  counterparty 
creditworthiness is critical. In addition, under the terms of certain 
OTC  derivative  contracts  and  other  trading  agreements,  in  the 
event of downgrades of our or our rated subsidiaries’ credit ratings, 
the counterparties to those agreements may require us to provide 
additional  collateral,  or  to  terminate  these  contracts  or 
agreements,  which  could  cause  us  to  sustain  losses  and/or 
adversely impact our liquidity. If the short-term credit ratings of 
our  parent  company,  bank  or  broker-dealer  subsidiaries  were 
downgraded by one or more levels, the potential loss of access to 
short-term funding sources such as repo financing and the effect 
on our incremental cost of funds could be material.

While  certain  potential 

impacts  are  contractual  and 
quantifiable, the full scope of the consequences of a credit rating 
downgrade to a financial institution is inherently uncertain, as it 
depends  upon  numerous  dynamic,  complex  and  inter-related 
factors and assumptions, including whether any downgrade of a 
company’s long-term credit ratings precipitates downgrades to its 
short-term  credit  ratings,  and  assumptions  about  the  potential 
behaviors of various customers, investors and counterparties. For 
more information on potential impacts of credit rating downgrades, 
see Liquidity Risk – Liquidity Stress Analysis on page 63.

For more information on additional collateral and termination 
payments that could be required in connection with certain OTC 
derivative contracts and other trading agreements as a result of 
such a credit rating downgrade, see Note 3 – Derivatives to the 
Consolidated Financial Statements and Item 1A. Risk Factors of 
our 2018 Annual Report on Form 10-K.

Common Stock Dividends
For  a  summary  of  our  declared  quarterly  cash  dividends  on 
common stock during 2018 and through February 26, 2019, see 
Note  13  –  Shareholders’  Equity  to  the  Consolidated  Financial 
Statements.

Credit Risk Management
Credit risk is the risk of loss arising from the inability or failure of 
a borrower or counterparty to meet its obligations. Credit risk can 
also  arise from operational  failures  that result in  an  erroneous 
advance, commitment or investment of funds. We define the credit 
exposure to a borrower or counterparty as the loss potential arising 
from all product classifications including loans and leases, deposit 
overdrafts, derivatives, assets held-for-sale and unfunded lending 
commitments which include loan commitments, letters of credit 
and financial guarantees. Derivative positions are recorded at fair 
value and assets held-for-sale are recorded at either fair value or 
the  lower  of  cost  or  fair  value.  Certain  loans  and  unfunded 

66     Bank of America 2018

commitments are accounted for under the fair value option. Credit 
risk for categories of assets carried at fair value is not accounted 
for as part of the allowance for credit losses but as part of the fair 
value adjustments recorded in earnings. For derivative positions, 
our  credit  risk  is  measured  as  the  net  cost  in  the  event  the 
counterparties with contracts in which we are in a gain position 
fail to perform under the terms of those contracts. We use the 
current  fair  value  to  represent  credit  exposure  without  giving 
consideration to future mark-to-market changes. The credit risk 
amounts take into consideration the effects of legally enforceable 
master netting agreements and cash collateral. Our consumer and 
commercial credit extension and review procedures encompass 
funded and unfunded credit exposures. For more information on 
derivatives  and  credit  extension  commitments,  see  Note  3  – 
Derivatives and Note 12 – Commitments and Contingencies to the 
Consolidated Financial Statements.

We manage credit risk based on the risk profile of the borrower 
or  counterparty,  repayment  sources,  the  nature  of  underlying 
collateral, and other support given current events, conditions and 
expectations.  We  classify  our  portfolios  as  either  consumer  or 
commercial and monitor credit risk in each as discussed below.

We  refine  our  underwriting  and  credit  risk  management 
practices  as  well  as  credit  standards  to  meet  the  changing 
economic environment. To mitigate losses and enhance customer 
support in our consumer businesses, we have in place collection 
programs  and  loan  modification  and  customer  assistance 
infrastructures. We utilize a number of actions to mitigate losses 
in the commercial businesses including increasing the frequency 
and  intensity  of  portfolio  monitoring,  hedging  activity  and  our 
practice of transferring management of deteriorating commercial 
exposures to independent special asset officers as credits enter 
criticized categories.

For more information on our credit risk management activities, 
see  Consumer  Portfolio  Credit  Risk  Management  below, 
Commercial Portfolio Credit Risk Management on page 74, Non-
U.S. Portfolio on page 80, Provision for Credit Losses on page 82, 
Allowance for Credit Losses on page 82, and Note 5 – Outstanding 
Loans and Leases and Note 6 – Allowance for Credit Losses to the 
Consolidated Financial Statements.

Consumer Portfolio Credit Risk Management
Credit  risk  management  for  the  consumer  portfolio  begins  with 
initial underwriting and continues throughout a borrower’s credit 
cycle.  Statistical  techniques  in  conjunction  with  experiential 
judgment  are  used  in  all  aspects  of  portfolio  management 
including underwriting, product pricing, risk appetite, setting credit 
limits,  and  establishing  operating  processes  and  metrics  to 
quantify and balance risks and returns. Statistical models are built 
using detailed behavioral information from external sources such 
as credit bureaus and/or internal historical experience and are a 
component  of  our  consumer  credit  risk  management  process. 

These models are used in part to assist in making both new and 
ongoing  credit  decisions,  as  well  as  portfolio  management 
strategies,  including  authorizations  and  line  management, 
collection  practices  and  strategies,  and  determination  of  the 
allowance for loan and lease losses and allocated capital for credit 
risk.

Consumer Credit Portfolio
Improvement in home prices continued during 2018 resulting in 
improved credit quality and lower credit losses in the home equity 
portfolio, partially offset by seasoning and loan growth in the U.S. 
credit card portfolio compared to 2017. 

Improved  credit  quality,  continued  loan  balance  runoff  and 
sales  primarily  in  the  non-core  consumer  real  estate  portfolio, 
partially offset by seasoning within the U.S. credit card portfolio, 
drove a $581 million decrease in the consumer allowance for loan 
and lease losses in 2018 to $4.8 billion at December 31, 2018. 
For  additional  information,  see  Allowance  for  Credit  Losses  on 
page 82.

For  more  information  on  our  accounting  policies  regarding 
delinquencies,  nonperforming  status,  charge-offs,  troubled  debt 
restructurings (TDRs) for the consumer portfolio and PCI loans, 
see  Note  1 – Summary  of  Significant  Accounting  Principles  and

Note  5  –  Outstanding  Loans  and  Leases  to  the  Consolidated 
Financial Statements. 

Table 21 presents our outstanding consumer loans and leases, 
consumer nonperforming loans and accruing consumer loans past 
due 90 days or more. Nonperforming loans do not include past 
due  consumer  credit  card  loans,  other  unsecured  loans  and  in 
general, consumer loans not secured by real estate (bankruptcy 
loans  are  included)  as  these  loans  are  typically  charged  off  no 
later than the end of the month in which the loan becomes 180 
days past due. Real estate-secured past due consumer loans that 
are  insured  by  the  FHA  or  individually  insured  under  long-term 
standby agreements with Fannie Mae and Freddie Mac (collectively, 
the  fully-insured  loan  portfolio)  are  reported  as  accruing  as 
opposed  to  nonperforming  since  the  principal  repayment  is 
insured. Fully-insured loans included in accruing past due 90 days 
or more are primarily from our repurchases of delinquent FHA loans 
pursuant  to  our  servicing  agreements  with  the  Government 
Additionally, 
Association 
National  Mortgage 
nonperforming loans and accruing balances past due 90 days or 
more do not include the PCI loan portfolio or loans accounted for 
under  the  fair  value  option  even  though  the  customer  may  be 
contractually past due.

(GNMA). 

Table 21 Consumer Credit Quality

(Dollars in millions)

Residential mortgage (1)
Home equity 
U.S. credit card
Direct/Indirect consumer (2)
Other consumer (3)

Consumer loans excluding loans accounted for under the fair value option

Loans accounted for under the fair value option (4)

Total consumer loans and leases

Percentage of outstanding consumer loans and leases (5)
Percentage of outstanding consumer loans and leases, excluding PCI and fully-

Outstandings

Nonperforming

December 31

Accruing Past Due
90 Days or More

2018
$ 208,557
48,286
98,338
91,166
202
$ 446,549
682
$ 447,231
n/a

2017
$ 203,811
57,744
96,285
96,342
166
$ 454,348
928
$ 455,276
n/a

2018

2017

2018

2017

$

$

1,893
1,893
n/a
56
—
3,842

$

$

2,476
2,644
n/a
46
—
5,166

$

$

1,884
—
994
38
—
2,916

$

$

3,230
—
900
40
—
4,170

0.86%

1.14%

0.65%

0.92%

insured loan portfolios (5)

n/a

n/a

0.91

1.23

0.24

0.22

(1)  Residential mortgage loans accruing past due 90 days or more are fully-insured loans. At December 31, 2018 and 2017, residential mortgage includes $1.4 billion and $2.2 billion of loans on which 
interest had been curtailed by the FHA, and therefore were no longer accruing interest, although principal was still insured, and $498 million and $1.0 billion of loans on which interest was still 
accruing.

(2)  Outstandings include auto and specialty lending loans and leases of $50.1 billion and $52.4 billion, unsecured consumer lending loans of $383 million and $469 million, U.S. securities-based 
lending loans of $37.0 billion and $39.8 billion, non-U.S. consumer loans of $2.9 billion and $3.0 billion and other consumer loans of $746 million and $684 million at December 31, 2018 and 
2017.

(3)  Substantially all of other consumer at December 31, 2018 and 2017 is consumer overdrafts.
(4)  Consumer loans accounted for under the fair value option include residential mortgage loans of $336 million and $567 million and home equity loans of $346 million and $361 million at December 

31, 2018 and 2017. For more information on the fair value option, see Note 21 – Fair Value Option to the Consolidated Financial Statements.

(5)  Excludes consumer loans accounted for under the fair value option. At December 31, 2018 and 2017, $12 million and $26 million of loans accounted for under the fair value option were past due 

90 days or more and not accruing interest.

n/a = not applicable

Table 22 presents net charge-offs and related ratios for consumer loans and leases.

Table 22 Consumer Net Charge-offs and Related Ratios

(Dollars in millions)
Residential mortgage
Home equity
U.S. credit card
Non-U.S. credit card (3)
Direct/Indirect consumer
Other consumer

Total

Net Charge-offs (1)

Net Charge-off Ratios (1, 2)

2018

2017

2018

2017

$

$

28
(2)
2,837
—
195
182
3,240

$

$

(100)
213
2,513
75
214
163
3,078

0.01%
—
3.00
—
0.21
n/m
0.72

(0.05)%
0.34
2.76
1.91
0.22

n/m

0.68

(1)  Net charge-offs exclude write-offs in the PCI loan portfolio. For more information, see Consumer Portfolio Credit Risk Management – Purchased Credit-impaired Loan Portfolio on page 72.
(2)  Net charge-off ratios are calculated as net charge-offs divided by average outstanding loans and leases excluding loans accounted for under the fair value option.
(3)  Represents net charge-offs related to the non-U.S. credit card loan portfolio, which was sold during the second quarter of 2017.
n/m = not meaningful

Bank of America 2018     67 

 
Net charge-offs, as shown in Tables 22 and 23, exclude write-
offs in the PCI loan portfolio of $154 million and $131 million in 
residential mortgage and $119 million and $76 million in home 
equity for 2018 and 2017. Net charge-off ratios including the PCI 
write-offs  were  0.09  percent  and  0.02  percent  for  residential 
mortgage and 0.22 percent and 0.47 percent for home equity in 
2018 and 2017. 

Table 23 presents outstandings, nonperforming balances, net 
charge-offs, allowance for loan and lease losses and provision for 
loan and lease losses for the core and non-core portfolios within 
the consumer real estate portfolio. We categorize consumer real 
estate loans as core and non-core based on loan and customer 
characteristics such as origination date, product type, loan-to-value 
(LTV), Fair Isaac Corporation (FICO) score and delinquency status 
consistent  with  our  current  consumer  and  mortgage  servicing 
strategy. Generally,  loans  that  were  originated  after  January  1, 

2010, qualified under GSE underwriting guidelines, or otherwise 
met our underwriting guidelines in place in 2015 are characterized 
as core loans. All other loans are generally characterized as non-
core loans and represent runoff portfolios. Core loans as reported 
in Table 23 include loans held in the Consumer Banking and GWIM 
segments, as well as loans held for ALM activities in All Other. 

As shown in Table 23, outstanding core consumer real estate 
loans increased $12.8 billion during 2018 driven by an increase
of $17.1 billion in residential mortgage, partially offset by a $4.2 
billion decrease in home equity. 

During 2018, we sold $11.6 billion of consumer real estate 
loans compared to $4.0 billion in 2017. In addition to recurring 
loan sales, the 2018 amount includes sales of loans, primarily 
non-core, with a carrying value of $9.6 billion and related gains of 
$731  million  recorded  in  other  income  in  the  Consolidated 
Statement of Income.

Table 23 Consumer Real Estate Portfolio (1)

(Dollars in millions)

Core portfolio

Residential mortgage
Home equity

Total core portfolio

Non-core portfolio

Residential mortgage
Home equity

Total non-core portfolio
Consumer real estate portfolio

Residential mortgage
Home equity

Total consumer real estate portfolio

Core portfolio

Residential mortgage
Home equity

Total core portfolio

Non-core portfolio

Residential mortgage
Home equity

Total non-core portfolio
Consumer real estate portfolio

Outstandings

Nonperforming

2018

2017

2018

2017

2018

2017

December 31

Net Charge-offs (2)

$

$

$

193,695
40,010
233,705

$

176,618
44,245
220,863

14,862
8,276
23,138

27,193
13,499
40,692

208,557
48,286
256,843

$

203,811
57,744
261,555

$

$

$

$

$

1,010
955
1,965

883
938
1,821

1,893
1,893
3,786

$

$

1,087
1,079
2,166

1,389
1,565
2,954

2,476
2,644
5,120

Allowance for Loan 
and Lease Losses

December 31

2018

2017

$

214
228
442

208
278
486

218
367
585

483
652
1,135

11
78
89

17
(80)
(63)

28
(2)
26

$

$

(45)
100
55

(55)
113
58

(100)
213
113

Provision for Loan
and Lease Losses

2018

2017

$

7
(60)
(53)

(104)
(335)
(439)

(79)
(91)
(170)

(201)
(339)
(540)

Residential mortgage
Home equity

(280)
(430)
(710)
(1)  Outstandings and nonperforming loans exclude loans accounted for under the fair value option. Consumer loans accounted for under the fair value option included residential mortgage loans of 
$336 million and $567 million and home equity loans of $346 million and $361 million at December 31, 2018 and 2017. For additional information, see Note 21 – Fair Value Option to the Consolidated 
Financial Statements.

Total consumer real estate portfolio

(97)
(395)
(492) $

701
1,019
1,720

422
506
928

$

$

$

(2)  Net charge-offs exclude write-offs in the PCI loan portfolio. For more information, see Consumer Portfolio Credit Risk Management – Purchased Credit-impaired Loan Portfolio on page 72.

We  believe  that  the  presentation  of  information  adjusted  to 
exclude the impact of the PCI loan portfolio, the fully-insured loan 
portfolio and loans accounted for under the fair value option is 
more representative of the ongoing operations and credit quality 
of the business. As a result, in the following tables and discussions 
of the residential mortgage and home equity portfolios, we exclude 
loans  accounted  for  under  the  fair  value  option  and  provide 
information that excludes the impact of the PCI loan portfolio and 
the fully-insured loan portfolio in certain credit quality statistics. 
We separately disclose information on the PCI loan portfolio on 
page 72.

Residential Mortgage
The residential mortgage portfolio made up the largest percentage 
of our consumer loan portfolio at 47 percent of consumer loans 
and leases at December 31, 2018. Approximately 44 percent of 
the residential mortgage portfolio was in Consumer Banking and 
37 percent was in GWIM. The remaining portion was in All Other
and was comprised of originated loans, purchased loans used in 
our  overall  ALM  activities,  delinquent  FHA  loans  repurchased 
pursuant to our servicing agreements with GNMA as well as loans 
repurchased related to our representations and warranties. 

68     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Outstanding  balances  in  the  residential  mortgage  portfolio 
increased $4.7 billion in 2018 as retention of new originations 
was partially offset by loan sales of $8.9 billion and runoff. 

At December 31, 2018 and 2017, the residential mortgage 
portfolio included $20.1 billion and $23.7 billion of outstanding 
fully-insured loans, of which $14.0 billion and $17.4 billion had 
FHA insurance with the remainder protected by long-term standby 
agreements. At December 31, 2018 and 2017, $3.5 billion and 
$5.2 billion of the FHA-insured loan population were repurchases 
of delinquent FHA loans pursuant to our servicing agreements with 
GNMA.

Table 24 Residential Mortgage – Key Credit Statistics

Table  24  presents  certain  residential  mortgage  key  credit 
statistics  on  both  a  reported  basis  and  excluding  the  PCI  loan 
portfolio  and  the  fully-insured  loan  portfolio.  Additionally,  in  the 
“Reported  Basis”  columns  in  the  following  table,  accruing 
balances past due and nonperforming loans do not include the 
PCI loan portfolio, in accordance with our accounting policies, even 
though the customer may be contractually past due. As such, the 
following discussion presents the residential mortgage portfolio 
excluding the PCI loan portfolio and the fully-insured loan portfolio. 

(Dollars in millions)

Outstandings
Accruing past due 30 days or more
Accruing past due 90 days or more
Nonperforming loans
Percent of portfolio

Refreshed LTV greater than 90 but less than or equal to 100
Refreshed LTV greater than 100
Refreshed FICO below 620
2006 and 2007 vintages (2)

Reported Basis (1)

December 31

Excluding Purchased
Credit-impaired and
Fully-insured Loans (1)

$

2018
208,557
3,945
1,884
1,893

$

2017
203,811
5,987
3,230
2,476

$

2018
184,627
1,155
—
1,893

$

2017
172,069
1,521
—
2,476

2%
1
4
6

3 %
2
6
10

1%
1
2
5

2 %
1
3
8

2018

2017

2018

2017

Net charge-off ratio (3)
(1)  Outstandings, accruing past due, nonperforming loans and percentages of portfolio exclude loans accounted for under the fair value option. 
(2)  These vintages of loans accounted for $536 million, or 28 percent, and $825 million, or 33 percent, of nonperforming residential mortgage loans at December 31, 2018 and 2017.
(3)  Net charge-off ratios are calculated as net charge-offs divided by average outstanding loans excluding loans accounted for under the fair value option.

(0.05)%

0.01%

0.02%

(0.06)%

Nonperforming  residential  mortgage  loans  decreased  $583 
million in  2018 primarily  driven  by  sales.  Of  the  nonperforming 
residential mortgage loans at December 31, 2018, $716 million, 
or  38  percent,  were  current  on  contractual  payments.  Loans 
accruing past due 30 days or more decreased $366 million due 
to continued improvement in credit quality as well as loan sales 
in the non-core portfolio. 

Net charge-offs increased $128 million to $28 million in 2018 
compared to $100 million of net recoveries in 2017 primarily due 
to net recoveries related to loan sales in 2017. 

Loans  with  a  refreshed  LTV  greater  than  100  percent 
represented one percent of the residential mortgage loan portfolio 
at  both  December  31,  2018  and  2017.  Of  the  loans  with  a 
refreshed LTV greater than 100 percent, 99 percent and 98 percent 
were performing at December 31, 2018 and 2017. Loans with a 
refreshed LTV greater than 100 percent reflect loans where the 
outstanding carrying value of the loan is greater than the most 
recent valuation of the property securing the loan. 

Of  the  $184.6  billion  in  total  residential  mortgage  loans 
outstanding  at  December  31,  2018,  as  shown  in  Table  24,  30 
percent were originated as interest-only  loans.  The  outstanding 
balance  of  interest-only  residential  mortgage  loans  that  have 

entered the amortization period was $8.6 billion, or 16 percent, 
at  December  31,  2018.  Residential  mortgage  loans  that  have 
entered  the  amortization  period  generally  have  experienced  a 
higher rate of early stage delinquencies and nonperforming status 
compared  to  the  residential  mortgage  portfolio  as  a  whole.  At 
December 31, 2018, $177 million, or two percent, of outstanding 
interest-only  residential  mortgages  that  had  entered  the 
amortization  period  were  accruing  past  due  30  days  or  more 
compared to $1.2 billion, or one percent, for the entire residential 
mortgage  portfolio.  In  addition,  at  December  31,  2018,  $365 
million,  or  four  percent,  of  outstanding  interest-only  residential 
mortgage  loans  that  had  entered  the  amortization  period  were 
nonperforming, of which $128 million were contractually current, 
compared to $1.9 billion, or one percent, for the entire residential 
mortgage portfolio. Loans that have yet to enter the amortization 
period  in  our  interest-only  residential  mortgage  portfolio  are 
primarily  well-collateralized  loans  to  our  wealth  management 
clients  and  have  an  interest-only  period  of  three  to  ten  years. 
Approximately 90 percent of these loans that have yet to enter the 
amortization period will not be required to make a fully-amortizing 
payment until 2022 or later.

Bank of America 2018     69 

 
 
 
 
Table 25 presents outstandings, nonperforming loans and net charge-offs by certain state concentrations for the residential mortgage 
portfolio.  The  Los  Angeles-Long  Beach-Santa  Ana  Metropolitan  Statistical  Area  (MSA) within  California  represented  16  percent  of 
outstandings at both December 31, 2018 and 2017. In the New York area, the New York-Northern New Jersey-Long Island MSA made 
up 13 percent of outstandings at both December 31, 2018 and 2017. 

Table 25 Residential Mortgage State Concentrations

(Dollars in millions)

California
New York (3)
Florida (3)
Texas
New Jersey (3)
Other

Residential mortgage loans (4)

Fully-insured loan portfolio
Purchased credit-impaired residential mortgage loan portfolio (5)

Total residential mortgage loan portfolio

Outstandings (1)

Nonperforming (1)

2018

2017

2018

2017

2018

2017

December 31

Net Charge-offs (2)

$

$

$

74,463
19,085
11,296
7,747
6,959
65,077
184,627
20,130
3,800
208,557

$

$

$

$

$

68,455
17,239
10,880
7,237
6,099
62,159
172,069
23,741
8,001
203,811

314
222
221
102
98
936
1,893

$

$

433
227
280
126
130
1,280
2,476

$

$

(22) $
10
(6)
4
8
34
28

$

(103)
(2)
(13)
1
—
17
(100)

(1)  Outstandings and nonperforming loans exclude loans accounted for under the fair value option.
(2)  Net charge-offs exclude $154 million and $131 million of write-offs in the residential mortgage PCI loan portfolio in 2018 and 2017. For more information on PCI write-offs, see Consumer Portfolio 

Credit Risk Management – Purchased Credit-impaired Loan Portfolio on page 72.
In these states, foreclosure requires a court order following a legal proceeding (judicial states).

(3) 

(4)  Amounts exclude the PCI residential mortgage and fully-insured loan portfolios.
(5)  At December 31, 2018 and 2017, 49 percent and 47 percent of PCI residential mortgage loans were in California. There were no other significant single state concentrations.

Home Equity 
At December 31, 2018, the home equity portfolio made up 11 
percent  of  the  consumer  portfolio  and  was  comprised  of  home 
equity  lines of  credit  (HELOCs),  home  equity  loans  and  reverse 
mortgages.

At December 31, 2018, our HELOC portfolio had an outstanding 
balance of $44.3 billion, or 92 percent of the total home equity 
portfolio, compared to $51.2 billion, or 89 percent, at December 
31,  2017.  HELOCs  generally  have  an  initial  draw  period  of  10 
years, and after the initial draw period ends, the loans generally 
convert to 15-year amortizing loans.

At December 31, 2018, our home equity loan portfolio had an 
outstanding balance of $1.8 billion, or four percent of the total 
home equity portfolio, compared to $4.4 billion, or seven percent, 
at December 31, 2017. Home equity loans are almost all fixed-
rate loans with amortizing payment terms of 10 to 30 years, and 
of the $1.8 billion at December 31, 2018, 68 percent have 25- to 
30-year  terms.  At  December  31,  2018,  our  reverse  mortgage 
portfolio had an outstanding balance of $2.2 billion, or four percent 
of the total home equity portfolio, compared to $2.1 billion, or four 
percent, at December 31, 2017. We no longer originate reverse 
mortgages.

At December 31, 2018, 75 percent of the home equity portfolio 
was in Consumer Banking, 17 percent was in All Other and the 
remainder  of  the  portfolio  was  primarily  in  GWIM.  Outstanding 

balances in the home equity portfolio decreased $9.5 billion in 
2018  primarily  due  to paydowns and  loan  sales  of  $2.7  billion
outpacing new originations and draws on existing lines. Of the total 
home equity portfolio at December 31, 2018 and 2017, $17.3 
billion and $18.7 billion, or 36 percent and 32 percent, were in 
first-lien positions. At December 31, 2018, outstanding balances 
in the home equity portfolio that were in a second-lien or more 
junior-lien position and where we also held the first-lien loan totaled 
$7.9  billion,  or  17  percent  of  our  total  home  equity  portfolio 
excluding the PCI loan portfolio.

Unused  HELOCs  totaled  $43.1  billion  and  $44.2  billion  at 
December 31, 2018 and 2017. The decrease was primarily due 
to  accounts  reaching  the  end  of  their  draw  period,  which 
automatically  eliminates  open  line  exposure,  and  customers 
choosing to close accounts. Both of these more than offset the 
impact  of  new  production.  The  HELOC  utilization  rate  was  51 
percent and 54 percent at December 31, 2018 and 2017.

Table  26  presents  certain  home  equity  portfolio  key  credit 
statistics  on  both  a  reported  basis  and  excluding  the  PCI  loan 
portfolio.  Additionally,  in  the  “Reported  Basis”  columns  in  the 
following table, accruing balances past due 30 days or more and 
nonperforming  loans  do  not  include  the  PCI  loan  portfolio,  in 
accordance with our accounting policies, even though the customer 
may be contractually past due. As such, the following discussion 
presents the home equity portfolio excluding the PCI loan portfolio. 

70     Bank of America 2018

 
 
 
 
 
 
Table 26 Home Equity – Key Credit Statistics

(Dollars in millions)

Outstandings
Accruing past due 30 days or more (2)
Nonperforming loans (2)
Percent of portfolio

Refreshed CLTV greater than 90 but less than or equal to 100
Refreshed CLTV greater than 100
Refreshed FICO below 620
2006 and 2007 vintages (3)

Reported Basis (1)

Excluding Purchased 
Credit-impaired Loans (1)

December 31

2018

2017

2018

2017

$

$

48,286
363
1,893

$

57,744
502
2,644

47,441
363
1,893

$

55,028
502
2,644

2%
3
5
22

3%
5
6
29

2%
3
5
21

3%
4
6
27

2018

2017

2018

2017

Net charge-off ratio (4)
(1)  Outstandings, accruing past due, nonperforming loans and percentages of the portfolio exclude loans accounted for under the fair value option.
(2)  Accruing past due 30 days or more include $48 million and $67 million and nonperforming loans include $218 million and $344 million of loans where we serviced the underlying first lien at December 

0.34%

0.36%

—%

—%

31, 2018 and 2017.

(3)  These vintages of loans have higher refreshed combined loan-to-value (CLTV) ratios and accounted for 49 percent and 52 percent of nonperforming home equity loans at December 31, 2018 and 

2017, and $11 million and $193 million of net charge-offs in 2018 and 2017.

(4)  Net charge-off ratios are calculated as net charge-offs divided by average outstanding loans excluding loans accounted for under the fair value option.

Nonperforming  outstanding  balances  in  the  home  equity 
portfolio decreased $751 million in 2018 as outflows, including 
sales, outpaced new inflows. Of the nonperforming home equity 
loans at December 31, 2018, $1.1 billion, or 59 percent, were 
current on contractual payments. Nonperforming loans that are 
contractually  current  primarily  consist  of  collateral-dependent 
TDRs,  including  those  that  have  been  discharged  in  Chapter  7 
bankruptcy, junior-lien loans where the underlying first lien is 90 
days  or  more  past  due,  as  well  as  loans  that  have  not  yet 
demonstrated  a  sustained  period  of  payment  performance 
following  a  TDR.  In  addition,  $463  million,  or  24  percent,  of 
nonperforming home equity loans were 180 days or more past due 
and  had  been  written  down  to  the  estimated  fair  value  of  the 
collateral, less costs to sell. Accruing loans that were 30 days or 
more past due decreased $139 million in 2018.

In some cases, the junior-lien home equity outstanding balance 
that we hold is performing, but the underlying first lien is not. For 
outstanding balances in the home equity portfolio on which we 
service the first-lien loan, we are able to track whether the first-
lien loan is in default. For loans where the first lien is serviced by 
a  third  party,  we  utilize  credit  bureau  data  to  estimate  the 
delinquency status of the first lien. At December 31, 2018, we 
estimate that $610 million of current and $83 million of 30 to 89 
days past due junior-lien loans were behind a delinquent first-lien 
loan.  We  service  the  first-lien  loans  on  $114 million  of  these 
combined amounts, with the remaining $579 million serviced by 
third parties. Of the $693 million of current to 89 days past due 
junior-lien loans, based on available credit bureau data and our 
own internal servicing data, we estimate that approximately $221 
million had first-lien loans that were 90 days or more past due. 

Net charge-offs decreased $215 million to a net recovery of $2 
million in 2018 compared to net charge-offs of $213 million in 
2017  driven  by  favorable  portfolio  trends  due  in  part  to 
improvement in home prices and the U.S. economy. 

Outstanding balances with a refreshed CLTV greater than 100 
percent comprised three percent and four percent of the home 
equity  portfolio  at  December  31,  2018  and  2017.  Outstanding 
balances with a refreshed CLTV greater than 100 percent reflect 
loans where our loan and available line of credit combined with 
any outstanding senior liens against the property are equal to or 
greater than the most recent valuation of the property securing 
the loan. Depending on the value of the property, there may be 
collateral in excess of the first lien that is available to reduce the 

severity of loss on the second lien. Of those outstanding balances 
with a refreshed CLTV greater than 100 percent, 96 percent of the 
customers were current on their home equity loan and 91 percent 
of  second-lien  loans  with  a  refreshed  CLTV  greater  than  100 
percent were current on both their second-lien and underlying first-
lien loans at December 31, 2018. 

Of the $47.4 billion in total home equity portfolio outstandings 
at December 31, 2018, as shown in Table 26, 20 percent require 
interest-only payments. The outstanding balance of HELOCs that 
have reached the end of their draw period and have entered the 
amortization period was $15.8 billion at December 31, 2018. The 
HELOCs  that  have  entered  the  amortization  period  have 
experienced a higher percentage of early stage delinquencies and 
nonperforming status when compared to the HELOC portfolio as 
a whole. At December 31, 2018, $267 million, or two percent, of 
outstanding HELOCs that had entered the amortization period were 
accruing past due 30 days or more. In addition, at December 31, 
2018, $1.7 billion, or 11 percent, of outstanding HELOCs that had 
entered the amortization period were nonperforming. Loans that 
have  yet  to  enter  the  amortization  period  in  our  interest-only 
portfolio  are  primarily  post-2008  vintages  and  generally  have 
better credit quality than the previous vintages that had entered 
the amortization period. We communicate to contractually current 
customers more than a year prior to the end of their draw period 
to inform them of the potential change to the payment structure 
before  entering  the  amortization  period,  and  provide  payment 
options to customers prior to the end of the draw period.

Although we do not actively track how many of our home equity 
customers pay only the minimum amount due on their home equity 
loans and lines, we can infer some of this information through a 
review of our HELOC portfolio that we service and that is still in 
its revolving period. During 2018, 14 percent of these customers 
with  an  outstanding  balance  did  not  pay  any  principal  on  their 
HELOCs.

Table 27 presents outstandings, nonperforming balances and 
net charge-offs by certain state concentrations for the home equity 
portfolio. In the New York area, the New York-Northern New Jersey-
Long Island MSA made up 13 percent of the outstanding home 
equity  portfolio  at  both  December  31,  2018  and  2017.  Loans 
within this MSA contributed $35 million and $58 million of net 
charge-offs in 2018 and 2017 within the home equity portfolio. 
The  Los  Angeles-Long  Beach-Santa  Ana  MSA  within  California 
made  up  11  percent  of  the  outstanding  home  equity  portfolio 

Bank of America 2018     71 

at both December 31, 2018 and 2017. Loans within this MSA contributed net recoveries of $23 million and $20 million within the 
home equity portfolio in 2018 and 2017. 

Table 27 Home Equity State Concentrations

(Dollars in millions)

California
Florida (3)
New Jersey (3)
New York (3)
Massachusetts
Other

Home equity loans (4)

Purchased credit-impaired home equity portfolio (5)

Total home equity loan portfolio

Outstandings (1)

Nonperforming (1)

2018

2017

2018

2017

2018

2017

December 31

Net Charge-offs (2)

$

$

$

13,228
5,363
3,833
3,549
2,376
19,092
47,441
845
48,286

$

$

$

$

$

15,145
6,308
4,546
4,195
2,751
22,083
55,028
2,716
57,744

536
315
150
194
65
633
1,893

$

$

766
411
191
252
92
932
2,644

$

$

(54) $
1
25
23
5
(2)
(2) $

(37)
38
44
35
9
124
213

(1)  Outstandings and nonperforming loans exclude loans accounted for under the fair value option.
(2)  Net charge-offs exclude $119 million and $76 million of write-offs in the home equity PCI loan portfolio in 2018 and 2017. For more information on PCI write-offs, see Consumer Portfolio Credit Risk 

Management – Purchased Credit-impaired Loan Portfolio.
In these states, foreclosure requires a court order following a legal proceeding (judicial states). 

(3) 

(4)  Amount excludes the PCI home equity portfolio.
(5)  At December 31, 2018 and 2017, 34 percent and 28 percent of PCI home equity loans were in California. There were no other significant single state concentrations.

Purchased Credit-impaired Loan Portfolio
Loans acquired with evidence of credit quality deterioration since 
origination and for which it is probable at purchase that we will be 
unable to collect all contractually required payments are accounted 
for under the accounting standards for PCI loans. 

Table 28 presents the unpaid principal balance, carrying value, 
related  valuation  allowance  and  the  net  carrying  value  as  a 
percentage  of  the  unpaid  principal  balance  for  the  PCI  loan 
portfolio.

Table 28 Purchased Credit-impaired Loan Portfolio

(Dollars in millions)

Residential mortgage (1)
Home equity

Total purchased credit-impaired loan portfolio

Residential mortgage (1)
Home equity

Total purchased credit-impaired loan portfolio

Unpaid
Principal
Balance

Gross 
Carrying
Value

Related
Valuation
Allowance

Carrying Value 
Net of Valuation 
Allowance

Percent of
Unpaid Principal
Balance

$

$

$

$

3,872
896
4,768

8,117
2,787
10,904

$

$

$

$

December 31, 2018

3,800
845
4,645

$

$

30
61
91

December 31, 2017

8,001
2,716
10,717

$

$

117
172
289

$

$

$

$

3,770
784
4,554

7,884
2,544
10,428

97.37%
87.50
95.51

97.13%
91.28
95.63

(1)  At December 31, 2018 and 2017, pay option loans had an unpaid principal balance of $757 million and $1.4 billion and a carrying value of $744 million and $1.4 billion. This includes $645 million 
and $1.2 billion of loans that were credit-impaired upon acquisition and $67 million and $141 million of loans that were 90 days or more past due. The total unpaid principal balance of pay option 
loans with accumulated negative amortization was $73 million and $160 million, including $4 million and $9 million of negative amortization at December 31, 2018 and 2017.

The total PCI unpaid principal balance decreased $6.1 billion, 
or 56 percent, in 2018 primarily driven by loan sales with a carrying 
value of $4.4 billion compared to sales of $803 million in 2017. 
Of the unpaid principal balance of $4.8 billion at December 31, 
2018,  $4.3  billion,  or  90  percent,  was  current  based  on  the 
contractual terms, $208 million, or four percent, was in early stage 
delinquency and $205 million was 180 days or more past due, 
including $172 million of first-lien mortgages and $33 million of 
home equity loans.

The PCI residential mortgage loan and home equity portfolios 
represented  82  percent  and  18  percent  of  the  total  PCI  loan 
portfolio at December 31, 2018. Those loans to borrowers with a 
refreshed FICO score below 620 represented 19 percent and 21 
percent  of  the  PCI  residential  mortgage  loan  and  home  equity 
portfolios at December 31, 2018. Residential mortgage and home 
equity loans with a refreshed LTV or CLTV greater than 90 percent, 
after consideration of purchase accounting adjustments and the 
related  valuation  allowance,  represented  10  percent  and  28 
percent of their respective PCI loan portfolios and 11 percent and 

32 percent based on the unpaid principal balance at December 
31, 2018.

U.S. Credit Card
At December 31, 2018, 97 percent of the U.S. credit card portfolio 
was managed in Consumer Banking with the remainder in GWIM. 
Outstandings in the U.S. credit card portfolio increased $2.1 billion
in 2018 to $98.3 billion due to higher retail volume partially offset 
by payments as well as the sale of a small portfolio. In 2018, net 
charge-offs increased $324 million to $2.8 billion, and U.S. credit 
card loans 30 days or more past due and still accruing interest 
increased $142 million and loans 90 days or more past due and 
still  accruing  interest  increased  $94  million,  each  driven  by 
portfolio seasoning and loan growth.

Unused lines of credit for U.S. credit card totaled $334.8 billion 
and $326.3 billion at December 31, 2018 and 2017. The increase 
was driven by account growth and lines of credit increases.

Table  29  presents  certain  state  concentrations  for  the  U.S. 

credit card portfolio.

72     Bank of America 2018

 
 
 
 
 
Table 29 U.S. Credit Card State Concentrations

(Dollars in millions)

California
Florida
Texas
New York
Washington
Other

Total U.S. credit card portfolio

Outstandings

Accruing Past Due
90 Days or More

2018

2017

2018

2017

2018

2017

December 31

Net Charge-offs

$

$

16,062
8,840
7,730
6,066
4,558
55,082
98,338

$

$

15,254
8,359
7,451
5,977
4,350
54,894
96,285

$

$

163
119
84
81
24
523
994

$

$

136
94
76
91
20
483
900

$

$

479
332
224
268
63
1,471
2,837

$

$

412
259
194
218
56
1,374
2,513

Direct/Indirect Consumer
At December 31, 2018, 55 percent of the direct/indirect portfolio 
was included in Consumer Banking (consumer auto and specialty 
lending – automotive, marine, aircraft, recreational vehicle loans 
and consumer personal loans) and 45 percent was included in 
GWIM (principally securities-based lending loans). 

Outstandings in the direct/indirect portfolio decreased $5.2 
billion  in  2018  to  $91.2  billion  primarily  due  to  declines  in 

Table 30 Direct/Indirect State Concentrations

securities-based lending due to higher paydowns, and in our auto 
portfolio  as  paydowns  outpaced  originations.  Net  charge-offs 
decreased  $19  million  to  $195  million  in  2018  due  largely  to 
to  bankruptcy  and 
clarifying 
repossession issued during 2017.

regulatory  guidance 

related 

Table 30 presents certain state concentrations for the direct/

indirect consumer loan portfolio.

(Dollars in millions)

California
Florida
Texas
New York
New Jersey
Other

Total direct/indirect loan portfolio

Outstandings

Accruing Past Due
90 Days or More

2018

2017

2018

2017

2018

2017

December 31

Net Charge-offs

$

$

11,734
10,240
9,876
6,296
3,308
49,712
91,166

$

$

12,897
11,184
10,676
6,557
3,449
51,579
96,342

$

$

4
4
6
2
1
21
38

$

$

3
5
5
2
1
24
40

$

$

21
36
30
9
2
97
195

$

$

21
43
38
7
6
99
214

Nonperforming Consumer Loans, Leases and Foreclosed 
Properties Activity
Table  31  presents  nonperforming  consumer  loans,  leases  and 
foreclosed properties activity during 2018 and 2017. During 2018, 
nonperforming consumer loans declined $1.3 billion to $3.8 billion 
primarily driven by loan sales of $969 million.

At  December  31,  2018,  $1.1  billion,  or  29  percent,  of 
nonperforming loans were 180 days or more past due and had 
been written down to their estimated property value less costs to 
sell. In addition, at December 31, 2018, $1.9 billion, or 49 percent, 
of  nonperforming  consumer  loans  were  modified  and  are  now 
current after successful trial periods, or are current loans classified 
as nonperforming loans in accordance with applicable policies.

Foreclosed properties increased $8 million in 2018 to $244 
million as additions outpaced liquidations. PCI loans are excluded 
from nonperforming loans as these loans were written down to fair 
value  at  the  acquisition  date;  however,  once  we  acquire  the 
underlying real estate upon foreclosure of the delinquent PCI loan, 

it  is  included  in  foreclosed  properties.  Certain  delinquent 
government-guaranteed loans (principally FHA-insured loans) are 
excluded from our nonperforming loans and foreclosed properties 
activity as we expect we will be reimbursed once the property is 
conveyed to the guarantor for principal and, up to certain limits, 
costs incurred during the foreclosure process and interest accrued 
during the holding period. 

We  classify  junior-lien  home  equity  loans  as  nonperforming 
when  the  first-lien  loan  becomes  90  days  past  due  even  if  the 
junior-lien loan is performing. At December 31, 2018 and 2017, 
$221  million  and  $330  million  of  such  junior-lien  home  equity 
loans were included in nonperforming loans and leases. 

Nonperforming loans also include certain loans that have been 
modified in TDRs where economic concessions have been granted 
to  borrowers  experiencing  financial  difficulties.  Nonperforming 
TDRs, excluding those modified loans in the PCI loan portfolio, are 
included in Table 31.

Bank of America 2018     73 

Table 31 Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity 

(Dollars in millions)

Nonperforming loans and leases, January 1
Additions
Reductions:

Paydowns and payoffs
Sales
Returns to performing status (1)
Charge-offs
Transfers to foreclosed properties
Transfers to loans held-for-sale

Total net reductions to nonperforming loans and leases
Total nonperforming loans and leases, December 31

Foreclosed properties, December 31 (2)

2018

2017

$

5,166
2,440

$

6,004
3,254

(1,052)
(511)
(1,438)
(676)
(217)
(198)
(838)
5,166
236
5,402

1.14%

1.19

(958)
(969)
(1,283)
(401)
(151)
(2)
(1,324)
3,842
244
4,086

0.86%

0.92

$

Nonperforming consumer loans, leases and foreclosed properties, December 31

$

Nonperforming consumer loans and leases as a percentage of outstanding consumer loans and leases (3)
Nonperforming consumer loans, leases and foreclosed properties as a percentage of outstanding consumer loans, leases and 

foreclosed properties (3)

(1)  Consumer loans may be returned to performing status when all principal and interest is current and full repayment of the remaining contractual principal and interest is expected, or when the loan 

otherwise becomes well-secured and is in the process of collection.

(2)  Foreclosed property balances do not include properties insured by certain government-guaranteed loans, principally FHA-insured, of $488 million and $801 million at December 31, 2018 and 2017. 
(3)  Outstanding consumer loans and leases exclude loans accounted for under the fair value option.

Table 32 presents TDRs for the consumer real estate portfolio. Performing TDR balances are excluded from nonperforming loans 

and leases in Table 31.

Table 32 Consumer Real Estate Troubled Debt Restructurings

(Dollars in millions)

Residential mortgage (1, 2)
Home equity (3)

Total consumer real estate troubled debt restructurings $

Nonperforming
1,209
$
1,107
2,316

December 31, 2018
Performing

Total

$

$

4,988
1,252
6,240

$

$

6,197
2,359
8,556

Nonperforming
1,535
$
1,457
2,992

$

December 31, 2017
Performing

$

$

8,163
1,399
9,562

$

$

Total

9,698
2,856
12,554

(1)  At December 31, 2018 and 2017, residential mortgage TDRs deemed collateral dependent totaled $1.6 billion and $2.8 billion, and included $960 million and $1.2 billion of loans classified as 

nonperforming and $605 million and $1.6 billion of loans classified as performing.

(2)  Residential mortgage performing TDRs included $2.8 billion and $3.7 billion of loans that were fully-insured at December 31, 2018 and 2017.
(3)  At December 31, 2018 and 2017, home equity TDRs deemed collateral dependent totaled $1.3 billion and $1.6 billion, and included $961 million and $1.2 billion of loans classified as nonperforming 

and $322 million and $388 million of loans classified as performing.

In addition to modifying consumer real estate loans, we work 
with  customers  who  are  experiencing  financial  difficulty  by 
modifying credit card and other consumer loans. Credit card and 
other consumer loan modifications generally involve a reduction 
in  the  customer’s  interest  rate  on  the  account  and  placing  the 
customer on a fixed payment plan not exceeding 60 months, all 
of which are considered TDRs (the renegotiated TDR portfolio).

Modifications  of  credit  card  and  other  consumer  loans  are 
made  through  renegotiation  programs  utilizing  direct  customer 
contact, but may also utilize external renegotiation programs. The 
renegotiated TDR portfolio is excluded in large part from Table 31 
as  substantially  all  of  the  loans  remain  on  accrual  status  until 
either charged off or paid in full. At December 31, 2018 and 2017, 
our renegotiated TDR portfolio was $566 million and $490 million, 
of which $481 million and $426 million were current or less than 
30 days past due under the modified terms. The increase in the 
renegotiated  TDR  portfolio  was  primarily  driven  by  new 
renegotiated enrollments outpacing runoff of existing portfolios. 

Commercial Portfolio Credit Risk Management
Credit risk management for the commercial portfolio begins with 
an  assessment  of  the  credit  risk  profile  of  the  borrower  or 
counterparty based on an analysis of its financial position. As part 
of  the  overall  credit  risk  assessment,  our  commercial  credit 
exposures are assigned a risk rating and are subject to approval 
based on defined credit approval standards. Subsequent to loan 
origination, risk ratings are monitored on an ongoing basis, and if 
necessary, adjusted to reflect changes in the financial condition, 

74     Bank of America 2018

cash flow, risk profile or outlook of a borrower or counterparty. In 
making credit decisions, we consider risk rating, collateral, country, 
industry and single-name concentration limits while also balancing 
these  considerations  with  the  total  borrower  or  counterparty 
relationship. We use a variety of tools to continuously monitor the 
ability  of  a  borrower  or  counterparty  to  perform  under  its 
obligations.  We  use  risk  rating  aggregations  to  measure  and 
evaluate concentrations within portfolios. In addition, risk ratings 
are a factor in determining the level of allocated capital and the 
allowance for credit losses.

As part of our ongoing risk mitigation initiatives, we attempt to 
work with clients experiencing financial difficulty to modify their 
loans to terms that better align with their current ability to pay. In 
situations where an economic concession has been granted to a 
borrower experiencing financial difficulty, we identify these loans 
as TDRs. For more information on our accounting policies regarding 
delinquencies, nonperforming status and net charge-offs for the 
commercial  portfolio,  see  Note  1  –  Summary  of  Significant 
Accounting Principles to the Consolidated Financial Statements.

Management of Commercial Credit Risk 
Concentrations
Commercial credit risk is evaluated and managed with the goal 
that concentrations of credit exposure continue to be aligned with 
our risk appetite. We review, measure and manage concentrations 
of  credit  exposure  by  industry,  product,  geography,  customer 
relationship and loan size. We also review, measure and manage 
commercial real estate loans by geographic location and property 

type.  In  addition,  within  our  non-U.S.  portfolio,  we  evaluate 
exposures by region and by country. Tables  37,  40,  43  and 44 
summarize  our  concentrations.  We  also  utilize  syndications  of 
exposure  to  third  parties,  loan  sales,  hedging  and  other  risk 
mitigation techniques to manage the size and risk profile of the 
commercial credit portfolio. For more information on our industry 
concentrations, see Commercial Portfolio Credit Risk Management 
– Industry Concentrations on page 78 and Table 40.

We  account  for  certain  large  corporate  loans  and  loan 
commitments,  including  issued  but  unfunded  letters  of  credit 
which are considered utilized for credit risk management purposes, 
that exceed our single-name credit risk concentration guidelines 
under the fair value option. Lending commitments, both funded 
and  unfunded,  are  actively  managed  and  monitored,  and  as 
appropriate,  credit  risk  for  these  lending  relationships  may  be 
mitigated through the use of credit derivatives, with our credit view 
and market perspectives determining the size and timing of the 
hedging activity. In addition, we purchase credit protection to cover 
the funded portion as well as the unfunded portion of certain other 
credit exposures. To lessen the cost of obtaining our desired credit 
protection levels, credit exposure may be added within an industry, 
borrower or counterparty group by selling protection. These credit 
derivatives  do  not  meet  the  requirements  for  treatment  as 
accounting hedges. They are carried at fair value with changes in 
fair value recorded in other income.

In  addition,  we  are  a  member  of  various  securities  and 
derivative  exchanges  and  clearinghouses,  both  in  the  U.S.  and 

other countries. As a member, we may be required to pay a pro-
rata share of the losses incurred by some of these organizations 
as  a  result  of  another  member  default  and  under  other  loss 
scenarios. For additional information, see Note 12 – Commitments 
and Contingencies to the Consolidated Financial Statements.

Commercial Credit Portfolio
During 2018, credit quality among large corporate borrowers was 
strong,  and  there  was  continued  improvement  in  the  energy 
portfolio.  Credit  quality  of  commercial  real  estate  borrowers  in 
most  sectors  remained  stable  with  conservative  LTV  ratios. 
However, some of the commercial real estate markets experienced 
slowing tenant demand and decelerating rental income.

Total  commercial  utilized  credit  exposure  increased  $20.2 
billion in 2018 to $621.0 billion primarily driven by commercial 
loan growth. The utilization rate for loans and leases, SBLCs and 
financial  guarantees,  and  commercial  letters  of  credit,  in  the 
aggregate, was 59 percent at both December 31, 2018 and 2017.
Table  33  presents  commercial  credit  exposure  by  type  for 
utilized, unfunded and total binding committed credit exposure. 
Commercial utilized credit exposure includes SBLCs and financial 
guarantees and commercial letters of credit that have been issued 
and  for  which  we  are  legally  bound  to  advance  funds  under 
prescribed conditions during a specified time period, and excludes 
exposure related to trading account assets. Although funds have 
not  yet  been  advanced,  these  exposure  types  are  considered 
utilized for credit risk management purposes.

Table 33 Commercial Credit Exposure by Type

(Dollars in millions)

Loans and leases (5)
Derivative assets (6)
Standby letters of credit and financial guarantees
Debt securities and other investments
Loans held-for-sale
Commercial letters of credit
Other

$

Commercial Utilized (1)

Commercial Unfunded (2, 3, 4)
December 31

Total Commercial Committed

2018

2017

2018

2017

2018

2017

$

$

$

$

$

505,724
43,725
34,941
25,425
9,090
1,210
898
621,013

487,748
37,762
34,517
28,161
10,257
1,467
888
600,800

369,282
—
491
4,250
14,812
168
—
389,003

364,743
—
863
4,864
9,742
155
—
380,367

875,006
43,725
35,432
29,675
23,902
1,378
898
1,010,016

852,491
37,762
35,380
33,025
19,999
1,622
888
981,167

Total

$
(1)  Commercial utilized exposure includes loans of $3.7 billion and $4.8 billion and issued letters of credit with a notional amount of $100 million and $232 million accounted for under the fair value 

$

$

$

$

$

option at December 31, 2018 and 2017.

(2)  Commercial unfunded exposure includes commitments accounted for under the fair value option with a notional amount of $3.0 billion and $4.6 billion at December 31, 2018 and 2017.
(3)  Excludes unused business card lines, which are not legally binding.
(4) 

Includes the notional amount of unfunded legally binding lending commitments net of amounts distributed (i.e., syndicated or participated) to other financial institutions. The distributed amounts 
were $10.7 billion and $11.0 billion at December 31, 2018 and 2017.
Includes credit risk exposure associated with assets under operating lease arrangements of $6.1 billion and $6.3 billion at December 31, 2018 and 2017.

(5) 

(6)  Derivative assets are carried at fair value, reflect the effects of legally enforceable master netting agreements and have been reduced by cash collateral of $32.4 billion and $34.6 billion at December 
31, 2018 and 2017. Not reflected in utilized and committed exposure is additional non-cash derivative collateral held of $33.0 billion and $26.2 billion at December 31, 2018 and 2017, which 
consists primarily of other marketable securities.

Outstanding  commercial  loans  and  leases  increased  $18.2  billion  during  2018  primarily  in  the  U.S.  commercial  portfolio.  The 
allowance for loan and lease losses for the commercial portfolio decreased $211 million to $4.8 billion at December 31, 2018. For 
additional information, see Allowance for Credit Losses on page 82. Table 34 presents our commercial loans and leases portfolio and 
related credit quality information at December 31, 2018 and 2017.

Bank of America 2018     75 

 
Table 34 Commercial Credit Quality

(Dollars in millions)

Commercial and industrial:

U.S. commercial
Non-U.S. commercial

Total commercial and industrial

Commercial real estate (1)
Commercial lease financing

U.S. small business commercial (2)

Commercial loans excluding loans accounted for under

the fair value option

Outstandings

Nonperforming

December 31

Accruing Past Due
90 Days or More

2018

2017

2018

2017

2018

2017

$

$

299,277
98,776
398,053
60,845
22,534
481,432
14,565

$

284,836
97,792
382,628
58,298
22,116
463,042
13,649

495,997

476,691

$

794
80
874
156
18
1,048
54

1,102

$

814
299
1,113
112
24
1,249
55

1,304

197
—
197
4
29
230
84

314

$

$

144
3
147
4
19
170
75

245

—
245

Total commercial loans and leases

Loans accounted for under the fair value option (3)

—
314
Includes U.S. commercial real estate of $56.6 billion and $54.8 billion and non-U.S. commercial real estate of $4.2 billion and $3.5 billion at December 31, 2018 and 2017.
Includes card-related products.

4,782
481,473

3,667
499,664

43
1,347

—
1,102

$

$

$

$

$

(1) 

(2) 

(3)  Commercial loans accounted for under the fair value option include U.S. commercial of $2.5 billion and $2.6 billion and non-U.S. commercial of $1.1 billion and $2.2 billion at December 31, 2018 

and 2017. For more information on the fair value option, see Note 21 – Fair Value Option to the Consolidated Financial Statements.

Table 35 presents net charge-offs and related ratios for our commercial loans and leases for 2018 and 2017. The decrease in net 

charge-offs of $378 million for 2018 was primarily driven by a single-name non-U.S. commercial charge-off of $292 million in 2017.

Table 35 Commercial Net Charge-offs and Related Ratios

(Dollars in millions)

Commercial and industrial:

U.S. commercial
Non-U.S. commercial

Total commercial and industrial

Commercial real estate
Commercial lease financing

U.S. small business commercial

Total commercial

Net Charge-offs

2018

2017

Net Charge-off Ratios (1)
2018
2017

$

$

215
68
283
1
(1)
283
240
523

$

$

232
440
672
9
5
686
215
901

0.07%
0.07
0.07
—
(0.01)
0.06
1.70
0.11

0.08%
0.48
0.18
0.02
0.02
0.15
1.60
0.20

(1)  Net charge-off ratios are calculated as net charge-offs divided by average outstanding loans and leases excluding loans accounted for under the fair value option.

Table 36 presents commercial reservable criticized utilized exposure by loan type. Criticized exposure corresponds to the Special 
Mention, Substandard and Doubtful asset categories as defined by regulatory authorities. Total commercial reservable criticized utilized 
exposure  decreased  $2.5  billion,  or  18  percent,  during  2018  driven  by  broad-based  improvements  including  the  energy  sector.  At 
December 31, 2018 and 2017, 91 percent and 84 percent of commercial reservable criticized utilized exposure was secured.

Table 36 Commercial Reservable Criticized Utilized Exposure (1, 2)

(Dollars in millions)

Commercial and industrial:

U.S. commercial
Non-U.S. commercial

Total commercial and industrial

Commercial real estate
Commercial lease financing

U.S. small business commercial

Total commercial reservable criticized utilized exposure (1)

December 31

2018

2017

$

$

7,986
1,013
8,999
936
366
10,301
760
11,061

2.43% $
0.97
2.08
1.50
1.62
1.99
5.22
2.08

$

9,891
1,766
11,657
566
581
12,804
759
13,563

3.15%
1.70
2.79
0.95
2.63
2.57
5.56
2.65

(1)  Total commercial reservable criticized utilized exposure includes loans and leases of $10.3 billion and $12.5 billion and commercial letters of credit of $781 million and $1.1 billion at December 

31, 2018 and 2017.

(2)  Percentages are calculated as commercial reservable criticized utilized exposure divided by total commercial reservable utilized exposure for each exposure category.

76     Bank of America 2018

 
 
 
Commercial and Industrial
Commercial and industrial loans include U.S. commercial and non-
U.S. commercial portfolios.

U.S. Commercial
At December 31, 2018, 70 percent of the U.S. commercial loan 
portfolio,  excluding  small  business,  was  managed  in  Global 
Banking,  16  percent  in  Global  Markets,  12  percent  in  GWIM 
(generally business-purpose loans for high net worth clients) and 
the  remainder  primarily  in  Consumer  Banking.  U.S.  commercial 
loans increased $14.4 billion in 2018 primarily in Global Banking. 
Reservable criticized utilized exposure decreased $1.9 billion, or 
19  percent,  driven  by  broad-based  improvements  including  the 
energy sector.

Non-U.S. Commercial
At December 31, 2018, 81 percent of the non-U.S. commercial 
loan portfolio was managed in Global Banking and 19 percent in 
Global Markets. Reservable criticized utilized exposure decreased 
$753 million, or 43 percent, and nonperforming loans and leases 
decreased $219 million, or 73 percent, due primarily to paydowns, 
sales and charge-offs. Net charge-offs decreased $372 million in 
2018 primarily due to a single-name non-U.S. commercial charge-
off of $292 million in 2017. For more information on the non-U.S. 
commercial portfolio, see Non-U.S. Portfolio on page 80.

Commercial Real Estate
Commercial real estate primarily includes commercial loans and 
leases  secured  by  non-owner-occupied  real  estate  and  is 

Table 37 Outstanding Commercial Real Estate Loans

dependent on the sale or lease of the real estate as the primary 
source  of  repayment.  The  portfolio  remains  diversified  across 
property types and geographic regions. California represented the 
largest state concentration at 23 percent of the commercial real 
estate loans and leases portfolio at both December 31, 2018 and 
2017.  The  commercial  real  estate  portfolio  is  predominantly 
managed in Global Banking and consists of loans made primarily 
to public and private developers, and commercial real estate firms. 
Outstanding loans increased $2.5 billion, or four percent, during 
2018 to $60.8 billion due to new originations, including higher 
hold levels on syndicated loans, outpacing paydowns.

During 2018, we continued to see low default rates and solid 
credit quality in both the residential and non-residential portfolios. 
We use a number of proactive risk mitigation initiatives to reduce 
adversely rated exposure in the commercial real estate portfolio, 
including transfers of deteriorating exposures to management by 
independent  special  asset  officers  and  the  pursuit  of  loan 
restructurings or asset sales to achieve the best results for our 
customers and the Corporation.

Nonperforming commercial real estate loans and foreclosed 
properties increased $48 million, or 29 percent, during 2018 to 
$212 million, primarily due to a single-name downgrade.

Table 37 presents outstanding commercial real estate loans 
by  geographic  region,  based  on  the  geographic  location  of  the 
collateral, and by property type.

(Dollars in millions)

By Geographic Region 

California
Northeast
Southwest
Southeast
Midwest
Florida
Illinois
Midsouth
Northwest
Non-U.S. 
Other (1)

Total outstanding commercial real estate loans

By Property Type
Non-residential

Office
Shopping centers / Retail
Multi-family rental
Hotels / Motels
Industrial / Warehouse
Unsecured
Multi-use
Other

Total non-residential

Residential

Total outstanding commercial real estate loans

December 31

2018

2017

14,002
10,895
7,339
5,726
3,772
3,680
2,989
2,919
2,178
4,240
3,105
60,845

17,246
8,798
7,762
7,248
5,379
2,956
2,848
7,029
59,266
1,579
60,845

$

$

$

$

13,607
10,072
6,970
5,487
3,769
3,170
3,263
2,962
2,657
3,538
2,803
58,298

16,718
8,825
8,280
6,344
6,070
2,187
2,771
5,645
56,840
1,458
58,298

$

$

$

$

(1) 

Includes unsecured loans to real estate investment trusts and national home builders whose portfolios of properties span multiple geographic regions and properties in the states of Colorado, Utah, 
Hawaii, Wyoming and Montana.

U.S. Small Business Commercial
The U.S. small business commercial loan portfolio is comprised of small business card loans and small business loans managed in 
Consumer Banking. Credit card-related products were 51 percent and 50 percent of the U.S. small business commercial portfolio at 
December 31, 2018 and 2017. Of the U.S. small business commercial net charge-offs, 95 percent and 90 percent were credit card-
related products in 2018 and 2017.

Bank of America 2018     77 

 
 
 
 
Nonperforming Commercial Loans, Leases and Foreclosed 
Properties Activity
Table 38 presents the nonperforming commercial loans, leases 
and  foreclosed  properties  activity  during  2018  and  2017. 
Nonperforming loans do not include loans accounted for under the 
fair value option. During 2018, nonperforming commercial loans 
and leases decreased $202 million to $1.1 billion. At December 

31, 2018, 93 percent of commercial nonperforming loans, leases 
and  foreclosed  properties  were  secured  and  55  percent  were 
contractually  current.  Commercial  nonperforming  loans  were 
carried  at  89  percent  of  their  unpaid  principal  balance  before 
consideration of the allowance for loan and lease losses as the 
carrying value of these loans has been reduced to the estimated 
collateral value less costs to sell.

Table 38 Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity (1, 2)

2018

2017

$

1,304
1,415

$

1,703
1,616

(930)
(136)
(280)
(455)
(40)
(174)
(399)
1,304
52
1,356

0.27%

0.28

(771)
(210)
(246)
(361)
(12)
(17)
(202)
1,102
56
1,158

0.22%

0.23

$

(Dollars in millions)

Nonperforming loans and leases, January 1
Additions
Reductions:
Paydowns
Sales
Returns to performing status (3)
Charge-offs
Transfers to foreclosed properties
Transfers to loans held-for-sale

Total net reductions to nonperforming loans and leases
Total nonperforming loans and leases, December 31

Foreclosed properties, December 31

Nonperforming commercial loans, leases and foreclosed properties, December 31

$

Nonperforming commercial loans and leases as a percentage of outstanding commercial loans and leases (4)
Nonperforming commercial loans, leases and foreclosed properties as a percentage of outstanding commercial loans, leases and 

foreclosed properties (4)

(1)  Balances do not include nonperforming loans held-for-sale of $292 million and $339 million at December 31, 2018 and 2017.
(2) 

Includes U.S. small business commercial activity. Small business card loans are excluded as they are not classified as nonperforming.

(3)  Commercial loans and leases may be returned to performing status when all principal and interest is current and full repayment of the remaining contractual principal and interest is expected, or 
when the loan otherwise becomes well-secured and is in the process of collection. TDRs are generally classified as performing after a sustained period of demonstrated payment performance.

(4)  Outstanding commercial loans exclude loans accounted for under the fair value option.

Table 39 presents our commercial TDRs by product type and performing status. U.S. small business commercial TDRs are comprised 
of renegotiated small business card loans and small business loans. The renegotiated small business card loans are not classified 
as nonperforming as they are charged off no later than the end of the month in which the loan becomes 180 days past due. For more 
information on TDRs, see Note 5 – Outstanding Loans and Leases to the Consolidated Financial Statements.

Table 39 Commercial Troubled Debt Restructurings

(Dollars in millions)

Commercial and industrial:

U.S. commercial
Non-U.S. commercial

Total commercial and industrial

Commercial real estate
Commercial lease financing

U.S. small business commercial

Total commercial troubled debt restructurings

Nonperforming

December 31, 2018
Performing

Total

Nonperforming

December 31, 2017
Performing

Total

$

$

306
78
384
114
3
501
3
504

$

$

1,092
162
1,254
6
68
1,328
18
1,346

$

$

1,398
240
1,638
120
71
1,829
21
1,850

$

$

370
11
381
38
5
424
4
428

$

$

866
219
1,085
9
13
1,107
15
1,122

$

$

1,236
230
1,466
47
18
1,531
19
1,550

Industry Concentrations 
Table  40  presents  commercial  committed  and  utilized  credit 
exposure by industry and the total net credit default protection 
purchased to cover the funded and unfunded portions of certain 
credit exposures. Our commercial credit exposure is diversified 
across a broad range of industries. Total commercial committed 
exposure increased $28.8 billion, or three percent, during 2018 
to $1.0 trillion. The increase in commercial committed exposure 
the  Asset  Managers  and  Funds, 
was  concentrated 
Pharmaceuticals and Biotechnology, and Capital Goods industry 
sectors. Increases were partially offset by reduced exposure to 
the  Media,  Food  and  Staples  Retailing,  and  Energy  industry 
sectors.

in 

Industry  limits  are  used  internally  to  manage  industry 
concentrations  and  are  based  on  committed  exposure  that  is 

78     Bank of America 2018

allocated  on  an  industry-by-industry  basis.  A  risk  management 
framework is in place to set and approve industry limits as well 
as to provide ongoing monitoring. The MRC oversees industry limit 
governance.

Asset Managers and Funds, our largest industry concentration 
with  committed  exposure  of  $107.9  billion,  increased  $16.8 
billion, or 18 percent, during 2018. The change reflects an increase
in exposure to several counterparties.

Real  Estate,  our  second  largest  industry  concentration  with 
committed exposure of $86.5 billion, increased $2.7 billion, or 
three  percent,  during  2018.  For  more  information  on  the 
commercial  real  estate  and  related  portfolios,  see  Commercial 
Portfolio Credit Risk Management – Commercial Real Estate on 
page 77.

 
Capital  Goods,  our  third  largest  industry  concentration  with 
committed exposure of $75.1 billion, increased $4.7 billion, or 
seven percent, during 2018. The increase in committed exposure 
occurred primarily as a result of increases in large conglomerates, 
as well as trading companies, distributors and electrical equipment 
companies, partially offset by a decrease in machinery companies.
Our energy-related committed exposure decreased $4.5 billion, 
or  12  percent,  during  2018  to  $32.3  billion.  Energy  sector  net 

Table 40 Commercial Credit Exposure by Industry (1)

charge-offs were $31 million in 2018 compared to $156 million 
in 2017. Energy sector reservable criticized exposure decreased 
$833 million during 2018 to $787 million due to improvement in 
credit  quality  coupled  with  exposure  reductions.  The  energy 
allowance for credit losses decreased $225 million during 2018
to $335 million.

Commercial 
Utilized

Total Commercial 
Committed (2)

December 31

2018

2017

2018

2017

$

$

$

$

(Dollars in millions)

Asset managers and funds
Real estate (3)
Capital goods
Finance companies
Healthcare equipment and services
Government and public education
Materials
Retailing
Consumer services
Food, beverage and tobacco
Commercial services and supplies
Energy
Transportation
Global commercial banks
Utilities
Technology hardware and equipment
Individuals and trusts
Media
Pharmaceuticals and biotechnology
Vehicle dealers
Consumer durables and apparel
Software and services
Insurance
Telecommunication services
Automobiles and components
Food and staples retailing
Religious and social organizations
Financial markets infrastructure (clearinghouses)
Other 

71,756
65,328
39,192
36,662
35,763
43,675
27,347
25,333
25,702
23,586
22,623
13,727
22,814
26,269
12,035
13,014
18,643
12,132
7,430
17,603
9,904
8,809
8,674
8,686
7,131
4,787
3,757
2,382
6,249
621,013

59,190
61,940
36,705
34,050
37,780
48,684
24,001
26,117
27,191
23,252
22,100
16,345
21,704
29,491
11,342
10,728
18,549
19,155
5,653
16,896
8,859
8,562
6,411
6,389
5,988
4,955
4,454
688
3,621
600,800

107,888
86,514
75,080
56,659
56,489
54,749
51,865
47,507
43,298
42,745
39,349
32,279
31,523
28,321
27,623
26,228
25,019
24,502
23,634
20,446
20,199
19,172
15,807
14,166
13,893
9,093
5,620
4,107
6,241
1,010,016

91,092
83,773
70,417
53,107
57,256
58,067
47,386
48,796
43,605
42,815
35,496
36,765
29,946
31,764
27,935
22,071
25,097
33,955
18,623
20,361
17,296
18,202
12,990
13,108
13,318
15,589
6,318
2,403
3,616
981,167
(2,129)

Total commercial credit exposure by industry
Net credit default protection purchased on total commitments (4)
Includes U.S. small business commercial exposure.
Includes the notional amount of unfunded legally binding lending commitments net of amounts distributed (i.e., syndicated or participated) to other financial institutions. The distributed amounts 
were $10.7 billion and $11.0 billion at December 31, 2018 and 2017.
Industries are viewed from a variety of perspectives to best isolate the perceived risks. For purposes of this table, the real estate industry is defined based on the primary business activity of the 
borrowers or counterparties using operating cash flows and primary source of repayment as key factors.

$
(2,663) $

$
  $

$

$

(1) 

(2) 

(3) 

(4)  Represents net notional credit protection purchased. For additional information, see Commercial Portfolio Credit Risk Management – Risk Mitigation.

Risk Mitigation
We purchase credit protection to cover the funded portion as well 
as the unfunded portion of certain credit exposures. To lower the 
cost of obtaining our desired credit protection levels, we may add 
credit exposure within an industry, borrower or counterparty group 
by selling protection.

At December 31, 2018 and 2017, net notional credit default 
protection purchased in our credit derivatives portfolio to hedge 
our funded and unfunded exposures for which we elected the fair 

value option, as well as certain other credit exposures, was $2.7 
billion and $2.1 billion. We recorded net losses of $2 million for 
2018 compared to net losses of $66 million in 2017 on these 
positions. The gains and losses on these instruments were offset 
by gains and losses on the related exposures. The Value-at-Risk 
(VaR) results for these exposures are included in the fair value 
option portfolio information in Table 47. For additional information, 
see Trading Risk Management on page 86.

Bank of America 2018     79 

 
In most cases, credit derivative transactions are executed on 
a daily margin basis. Therefore, events such as a credit downgrade, 
depending  on  the  ultimate  rating  level,  or  a  breach  of  credit 
covenants  would  typically  require  an  increase  in  the  amount  of 
collateral required by the counterparty, where applicable, and/or 
allow  us  to  take  additional  protective  measures  such  as  early 
termination of all trades. For more information on credit derivatives 
and counterparty credit risk valuation adjustments, see Note 3 – 
Derivatives to the Consolidated Financial Statements.

Non-U.S. Portfolio
Our non-U.S. credit and trading portfolios are subject to country 
risk. We define country risk as the risk of loss from unfavorable 
economic  and  political  conditions,  currency  fluctuations,  social 
instability and changes in government policies. A risk management 
framework is in place to measure, monitor and manage non-U.S. 
risk and exposures. In addition to the direct risk of doing business 
in a country, we also are exposed to indirect country risks (e.g., 
related to the collateral received on secured financing transactions 
or related to client clearing activities). These indirect exposures 
are  managed  in  the  normal  course  of  business  through  credit, 
market  and  operational  risk  governance,  rather  than  through 
country risk governance.

Table 43 presents our 20 largest non-U.S. country exposures 
at December 31, 2018. These exposures accounted for 89 percent
and 86 percent of our total non-U.S. exposure at December 31, 
2018  and  2017.  Net  country  exposure  for  these  20  countries 
increased  $44.1  billion  in  2018,  primarily  driven  by  increased 
placements with central banks in the U.K., Japan and Germany.

Non-U.S.  exposure 

risk 
management  basis  and  includes  sovereign  and  non-sovereign 
credit  exposure,  securities  and  other  investments  issued  by  or 
domiciled in countries other than the U.S.

is  presented  on  an 

internal 

Funded loans and loan equivalents include loans, leases, and 
other extensions of credit and funds, including letters of credit and 
due from placements. Unfunded commitments are the undrawn 
portion of legally binding commitments related to loans and loan 
equivalents. Net counterparty exposure includes the fair value of 
derivatives, including the counterparty risk associated with credit 
default  swaps  (CDS),  and  secured  financing  transactions. 
Securities and other investments are carried at fair value and long 
securities exposures are netted against short exposures with the 
same  underlying  issuer  to,  but  not  below,  zero.  Net  country 
exposure  represents  country  exposure  less  hedges  and  credit 
default protection purchased, net of credit default protection sold. 

Tables 41 and 42 present the maturity profiles and the credit 
exposure debt ratings of the net credit default protection portfolio 
at December 31, 2018 and 2017.

Table 41 Net Credit Default Protection by Maturity

Less than or equal to one year
Greater than one year and less than or equal

to five years

Greater than five years

Total net credit default protection

December 31

2018

2017

20%

78

2
100%

42%

58

—
100%

Table 42 Net Credit Default Protection by Credit

Exposure Debt Rating

Net
Notional (1)

Percent of
Total

Net
Notional (1)

Percent of
Total

December 31

2018

2017

$

(700)
(501)
(804)
(422)
(205)
(31)

26.3% $
18.8
30.2
15.8
7.7
1.2

(280)
(459)
(893)
(403)
(84)
(10)

13.2%
21.6
41.9
18.9
3.9
0.5

(Dollars in millions)

Ratings (2, 3)
A
BBB
BB
B
CCC and below
NR (4)

Total net credit 

default protection

$

(2,663)

100.0% $

(2,129)

100.0%

(1)  Represents net credit default protection purchased.
(2)  Ratings are refreshed on a quarterly basis.
(3)  Ratings of BBB- or higher are considered to meet the definition of investment grade.
(4)  NR is comprised of index positions held and any names that have not been rated.

In  addition  to  our  net  notional  credit  default  protection 
purchased to cover the funded and unfunded portion of certain 
credit exposures, credit derivatives are used for market-making 
activities for clients and establishing positions intended to profit 
from directional or relative value changes. We execute the majority 
of  our  credit  derivative  trades  in  the  OTC  market  with  large, 
multinational financial institutions, including broker-dealers and, 
to a lesser degree, with a variety of other investors. Because these 
transactions are executed in the OTC market, we are subject to 
settlement risk. We are also subject to credit risk in the event that 
these  counterparties  fail  to  perform  under  the  terms  of  these 
contracts. In order to properly reflect counterparty credit risk, we 
record counterparty credit risk valuation adjustments on certain 
including  our  purchased  credit  default 
derivative  assets, 
protection. 

80     Bank of America 2018

 
 
 
 
 
Table 43 Top 20 Non-U.S. Countries Exposure

(Dollars in millions)

United Kingdom
Germany
Japan
Canada
China
France
Netherlands
India
Brazil
Australia
South Korea
Switzerland
Hong Kong
Mexico
Belgium
Singapore
Spain
United Arab Emirates
Taiwan
Italy

Total top 20 non-U.S.
countries exposure

Funded Loans
and Loan
Equivalents

Unfunded
Loan
Commitments

Net
Counterparty
Exposure

Securities/
Other
Investments

Country
Exposure at
December 31
2018

Hedges and
Credit Default
Protection

Net Country
Exposure at
December 31
2018

Increase
(Decrease) from
December 31
2017

$

$

28,833
24,856
17,762
7,388
12,774
7,137
8,405
7,147
6,651
5,173
5,634
5,494
5,287
3,506
4,684
3,330
3,769
3,371
2,311
2,372

$

20,410
6,823
1,316
7,234
681
5,849
2,992
451
544
3,132
463
2,580
442
1,275
1,016
125
1,138
135
13
1,065

$

6,419
1,835
1,023
1,641
975
1,331
389
312
209
571
897
335
321
140
103
362
290
138
288
491

$

2,639
443
1,341
3,773
495
1,214
973
3,379
3,172
1,507
2,456
201
1,224
1,444
147
1,770
792
55
623
597

$

58,301
33,957
21,442
20,036
14,925
15,531
12,759
11,289
10,576
10,383
9,450
8,610
7,274
6,365
5,950
5,587
5,989
3,699
3,235
4,525

(3,447) $
(5,300)
(1,419)
(521)
(284)
(2,880)
(1,182)
(177)
(327)
(453)
(280)
(846)
(38)
(129)
(372)
(70)
(1,339)
(50)
—
(1,444)

$

54,854
28,657
20,023
19,515
14,641
12,651
11,577
11,112
10,249
9,930
9,170
7,764
7,236
6,236
5,578
5,517
4,650
3,649
3,235
3,081

17,259
7,154
10,933
792
(1,284)
2,108
3,110
615
(467)
(659)
1,269
1,967
(1,442)
749
1,613
(746)
1,542
262
523
(1,165)

$

165,884

$

57,684

$

18,070

$

28,245

$

269,883

$

(20,558) $

249,325

$

44,133

A number of economic conditions and geopolitical events have 
given rise to risk aversion in certain emerging markets. Our largest 
emerging market country exposure at December 31, 2018 was 
China, with net exposure of $14.6 billion, concentrated in large 
of  multinational 
state-owned 
corporations and commercial banks. 

subsidiaries 

companies, 

The  outlook  for  policy  direction  and  therefore  economic 
performance in the EU remains uncertain as a consequence of 
reduced political cohesion among EU countries. Additionally, we 
believe  that  the  uncertainty  in  the  U.K.’s  ability  to  negotiate  a 
favorable  exit  from  the  EU  will  further  weigh  on  economic 
performance. Our largest EU country exposure at December 31, 
2018 was the U.K. with net exposure of $54.9 billion, a $17.3 
billion increase from December 31, 2017. The increase was driven 
by  corporate  loan  growth  and  increased  placements  with  the 
central bank as part of liquidity management.

Markets  have  reacted  negatively  to  the  escalating  tensions 
between the U.S. and several key trading partners. We are closely 

monitoring  our  exposures  to  tariff-sensitive  industries  and  our 
international exposure, particularly to countries that account for 
a large percentage of U.S. trade. 

Table 44 presents countries where total cross-border exposure 
exceeded one percent of our total assets. At December 31, 2018, 
the  U.K.  and  France  were  the  only  countries  where  total  cross-
border  exposure  exceeded  one  percent  of  our  total  assets.  At 
December 31, 2018, Germany and China had total cross-border 
exposure  of  $20.4  billion  and  $19.5  billion  representing  0.87
percent and 0.83 percent of our total assets. No other countries 
had total cross-border exposure that exceeded 0.75 percent of 
our total assets at December 31, 2018.

Cross-border  exposure  includes  the  components  of  Country 
Risk  Exposure  as  detailed  in  Table  43  as  well  as  the  notional 
amount of cash loaned under secured financing agreements. Local 
exposure,  defined  as  exposure  booked  in  local  offices  of  a 
respective country with clients in the same country, is excluded.

Table 44 Total Cross-border Exposure Exceeding One Percent of Total Assets

(Dollars in millions)

United Kingdom

France

December 31

Public Sector

Banks

Private Sector

Cross-border
Exposure

Exposure as a
Percent of
Total Assets

$

2018
2017
2016
2018
2017
2016

$

1,505
923
2,975
633
2,964
4,956

$

3,458
2,984
4,557
2,385
1,521
1,205

$

46,191
47,205
42,105
29,847
27,903
23,193

51,154
51,112
49,637
32,865
32,388
29,354

2.17%
2.24
2.27
1.40
1.42
1.34

Bank of America 2018     81 

Provision for Credit Losses
The provision for credit losses decreased $114 million to $3.3 
billion in 2018 compared to 2017 primarily due to improvement 
in the commercial portfolio, partially offset by an increase in the 
consumer  portfolio.  The  provision  for  credit  losses  was  $481 
million lower than net charge-offs for 2018, resulting in a reduction 
in the allowance for credit losses. This compared to a reduction 
of $583 million in the allowance for credit losses in 2017.

The  provision  for  credit  losses  for  the  consumer  portfolio 
increased $222 million to $2.9 billion in 2018 compared to 2017. 
The increase was primarily driven by a slower pace of improvement 
in the consumer real estate portfolio, and portfolio seasoning and 
loan growth in the U.S. credit card portfolio, partially offset by the 
impact of the sale of the non-U.S. consumer credit card business 
in 2017. 

The  provision  for  credit  losses  for  the  commercial  portfolio, 
including unfunded lending commitments, decreased $336 million 
to $333 million in 2018 compared to 2017. The decrease was 
primarily  driven  by  a  2017  single-name  non-U.S.  commercial 
charge-off and improvement in the commercial portfolio. 

Allowance for Credit Losses

Allowance for Loan and Lease Losses
The  allowance  for  loan  and  lease  losses  is  comprised  of  two 
components.  The 
first  component  covers  nonperforming 
commercial loans and TDRs. The second component covers loans 
and leases on which there are incurred losses that are not yet 
individually identifiable, as well as incurred losses that may not 
be  represented  in  the  loss  forecast  models.  We  evaluate  the 
adequacy of the allowance for loan and lease losses based on the 
total of these two components, each of which is described in more 
detail below. The allowance for loan and lease losses excludes 
loans held-for-sale (LHFS) and loans accounted for under the fair 
value option as the fair value reflects a credit risk component. 

The first component of the allowance for loan and lease losses 
covers both nonperforming commercial loans and all TDRs within 
the consumer and commercial portfolios. These loans are subject 
to  impairment  measurement  based  on  the  present  value  of 
projected  future  cash  flows  discounted  at  the  loan’s  original 
effective  interest  rate,  or  in  certain  circumstances,  impairment 
may  also  be  based  upon  the  collateral  value  or  the  loan’s 
observable market price if available. Impairment measurement for 
the renegotiated consumer credit card, small business credit card 
and unsecured consumer TDR portfolios is based on the present 
value  of  projected  cash  flows  discounted  using  the  average 
portfolio contractual interest rate, excluding promotionally priced 
loans, in effect prior to restructuring. For purposes of computing 
this  specific  loss  component  of  the  allowance,  larger  impaired 
loans are evaluated individually and smaller impaired loans are 
evaluated as a pool using historical experience for the respective 
product types and risk ratings of the loans.

The  second  component  of  the  allowance  for  loan  and  lease 
losses covers the remaining consumer and commercial loans and 
leases  that  have  incurred  losses  that  are  not  yet  individually 
identifiable. The allowance for consumer (including credit card and 
other consumer loans) and certain homogeneous commercial loan 
and lease products is based on aggregated portfolio evaluations, 
which  include  both  quantitative  and  qualitative  components, 
generally by product type. Loss forecast models are utilized that 
consider a variety of factors including, but not limited to, historical 
loss  experience,  estimated  defaults  or  foreclosures  based  on 
portfolio  trends,  delinquencies,  economic  trends  and  credit 
scores. Our consumer real estate loss forecast model estimates 

82     Bank of America 2018

the  portion  of  loans  that  will  default  based  on  individual  loan 
attributes, the most significant of which are refreshed LTV or CLTV, 
and borrower credit score as well as vintage and geography, all of 
which  are  further  broken  down  into  current  delinquency  status. 
Additionally, we incorporate the delinquency status of underlying 
first-lien  loans  on  our  junior-lien  home  equity  portfolio  in  our 
allowance process. Incorporating refreshed LTV and CLTV into our 
probability of default allows us to factor the impact of changes in 
home prices into our allowance for loan and lease losses. These 
loss  forecast  models  are  updated  on  a  quarterly  basis  to 
incorporate 
the  current  economic 
reflecting 
environment. As of December 31, 2018, the loss forecast process 
resulted in reductions in the allowance related to the residential 
mortgage and home equity portfolios compared to December 31, 
2017.

information 

and 

trends, 

geographic 

performance 

The  allowance  for  commercial  loan  and  lease  losses  is 
established  by  product  type  after  analyzing  historical  loss 
experience,  internal  risk  rating,  current  economic  conditions, 
industry 
obligor 
concentrations  within  each  portfolio  and  any  other  pertinent 
information.  The  statistical  models  for  commercial  loans  are 
generally updated annually and utilize our historical database of 
actual defaults and other data, including external default data. The 
loan  risk  ratings  and  composition  of  the  commercial  portfolios 
used  to  calculate  the  allowance  are  updated  quarterly  to 
incorporate the most recent data reflecting the current economic 
environment.  For  risk-rated  commercial  loans,  we  estimate  the 
probability of default and the loss given default (LGD) based on 
our  historical  experience  of  defaults  and  credit  losses.  Factors 
considered  when  assessing  the  internal  risk  rating  include  the 
value of the underlying collateral, if applicable, the industry in which 
the  obligor  operates,  the  obligor’s  liquidity  and  other  financial 
indicators, and other quantitative and qualitative factors relevant 
to the obligor’s credit risk. As of December 31, 2018, the allowance 
for  the  U.S.  commercial  and  non-U.S.  commercial  portfolios 
decreased compared to December 31, 2017.

Also included within the second component of the allowance 
for loan and lease losses are reserves to cover losses that are 
incurred  but,  in  our  assessment,  may  not  be  adequately 
represented in the historical loss data used in the loss forecast 
models.  For  example,  factors  that  we  consider  include,  among 
others, changes in lending policies and procedures, changes in 
economic and business conditions, changes in the nature and size 
of the portfolio, changes in portfolio concentrations, changes in 
the volume and severity of past due loans and nonaccrual loans, 
the effect of external factors such as competition, and legal and 
regulatory  requirements.  Further,  we  consider  the  inherent 
uncertainty in mathematical models that are built upon historical 
data.

During 2018, the factors that impacted the allowance for loan 
and lease losses included improvement in the credit quality of the 
consumer real estate portfolios driven by continuing improvements 
in the U.S. economy and strong labor markets, proactive credit 
risk management initiatives and the impact of high credit quality 
originations. Evidencing the improvements in the U.S. economy 
and  strong  labor  markets  are  low  levels  of  unemployment  and 
increases in home prices. In addition to these improvements, in 
the consumer portfolio, nonperforming consumer loans decreased
$1.3 billion in 2018 as returns to performing status, loan sales, 
paydowns and charge-offs continued to outpace new nonaccrual 
loans. During 2018, the allowance for loan and lease losses in 
the  commercial  portfolio  reflected  decreased  energy  reserves 
primarily  driven  by  improvement  in  energy  exposures  including 
reservable criticized utilized exposures.

We monitor differences between estimated and actual incurred 
loan and lease losses. This monitoring process includes periodic 
assessments by senior management of loan and lease portfolios 
and  the  models  used  to  estimate  incurred  losses  in  those 
portfolios.

The  allowance  for  loan  and  lease  losses  for  the  consumer 
portfolio, as presented in Table 45, was $4.8 billion at December 
31, 2018, a decrease of $581 million from December 31, 2017. 
The decrease was primarily in the consumer real estate portfolio, 
partially offset by an increase in the U.S. credit card portfolio. The 
reduction in the allowance for the consumer real estate portfolio 
was due to improved home prices, lower nonperforming loans and 
a decrease in loan balances in our non-core portfolio. The increase 
in the allowance for the U.S. credit card portfolio was driven by 
portfolio seasoning and loan growth. 

The allowance for loan and lease losses for the commercial 
portfolio, as presented in Table 45, was $4.8 billion at December 
31, 2018, a decrease of $211 million from December 31, 2017 
primarily driven by improvement in energy exposures. Commercial 
reservable criticized utilized exposure decreased to $11.1 billion 
at December 31, 2018 from $13.6 billion (to 2.08 percent from 
2.65 percent of total commercial reservable utilized exposure) at 
December  31,  2017,  driven  by  broad-based  improvements 
including  the  energy  sector.  Nonperforming  commercial  loans 
decreased to $1.1 billion at December 31, 2018 from $1.3 billion 
(to  0.22  percent  from  0.27  percent  of  outstanding  commercial 
loans excluding loans accounted for under the fair value option) 

at December 31, 2017. See Tables 34, 35 and 36 for more details 
on key commercial credit statistics.

The allowance for loan and lease losses as a percentage of 
total loans and leases outstanding was 1.02 percent at December 
31, 2018 compared to 1.12 percent at December 31, 2017. 

losses 

related 

to  unfunded 

Reserve for Unfunded Lending Commitments
In addition to the allowance for loan and lease losses, we also 
estimate  probable 
lending 
commitments  such  as  letters  of  credit,  financial  guarantees, 
unfunded bankers’ acceptances and binding loan commitments, 
excluding commitments accounted for under the fair value option. 
Unfunded  lending  commitments  are  subject  to  the  same 
assessment as funded loans, including estimates of probability 
of default and LGD. Due to the nature of unfunded commitments, 
the estimate of probable losses must also consider utilization. To 
estimate the portion of these undrawn commitments that is likely 
to be drawn by a borrower at the time of estimated default, analyses 
of  our  historical  experience  are  applied  to  the  unfunded 
commitments to estimate the funded exposure at default (EAD). 
The  expected  loss  for  unfunded  lending  commitments  is  the 
product of the probability of default, the LGD and the EAD, adjusted 
for  any  qualitative  factors  including  economic  uncertainty  and 
inherent imprecision in models.

The  reserve  for  unfunded  lending  commitments  was  $797 
million  at  December  31,  2018  compared  to  $777  million  at 
December 31, 2017.

Table 45 Allocation of the Allowance for Credit Losses by Product Type

(Dollars in millions)

Allowance for loan and lease losses

Residential mortgage
Home equity
U.S. credit card
Direct/Indirect consumer
Other consumer

Total consumer
U.S. commercial (2)
Non-U.S. commercial
Commercial real estate
Commercial lease financing

Total commercial
Allowance for loan and lease losses (3)
Reserve for unfunded lending commitments

Allowance for credit losses

Amount

Percent of
Total

Percent of
Loans and
Leases
Outstanding (1)

Amount

Percent of
Total

Percent of
Loans and
Leases
Outstanding (1)

December 31, 2018

December 31, 2017

$

$

422
506
3,597
248
29
4,802
3,010
677
958
154
4,799
9,601
797
10,398

4.40%
5.27
37.47
2.58
0.30
50.02
31.35
7.05
9.98
1.60
49.98
100.00%

0.20% $
1.05
3.66
0.27
n/m
1.08
0.96
0.69
1.57
0.68
0.97
1.02

$

701
1,019
3,368
264
31
5,383
3,113
803
935
159
5,010
10,393
777
11,170

6.74%
9.80
32.41
2.54
0.30
51.79
29.95
7.73
9.00
1.53
48.21
100.00%

0.34%
1.76
3.50
0.27
n/m
1.18
1.04
0.82
1.60
0.72
1.05
1.12

(1)  Ratios are calculated as allowance for loan and lease losses as a percentage of loans and leases outstanding excluding loans accounted for under the fair value option. Consumer loans accounted 
for under the fair value option include residential mortgage loans of $336 million and $567 million and home equity loans of $346 million and $361 million at December 31, 2018 and 2017. 
Commercial loans accounted for under the fair value option include U.S. commercial loans of $2.5 billion and $2.6 billion and non-U.S. commercial loans of $1.1 billion and $2.2 billion at December 
31, 2018 and 2017.
Includes allowance for loan and lease losses for U.S. small business commercial loans of $474 million and $439 million at December 31, 2018 and 2017.
Includes $91 million and $289 million of valuation allowance presented with the allowance for loan and lease losses related to PCI loans at December 31, 2018 and 2017.
n/m = not meaningful

(2) 

(3) 

Bank of America 2018     83 

 
 
 
 
 
 
 
Table 46 presents a rollforward of the allowance for credit losses, which includes the allowance for loan and lease losses and the 

reserve for unfunded lending commitments, for 2018 and 2017.

Table 46 Allowance for Credit Losses

(Dollars in millions)

Allowance for loan and lease losses, January 1
Loans and leases charged off

Residential mortgage
Home equity
U.S. credit card
Non-U.S. credit card (1)
Direct/Indirect consumer
Other consumer

Total consumer charge-offs

U.S. commercial (2)
Non-U.S. commercial
Commercial real estate
Commercial lease financing

Total commercial charge-offs
Total loans and leases charged off

Recoveries of loans and leases previously charged off

Residential mortgage
Home equity
U.S. credit card
Non-U.S. credit card (1)
Direct/Indirect consumer
Other consumer

Total consumer recoveries

U.S. commercial (3)
Non-U.S. commercial
Commercial real estate
Commercial lease financing

Total commercial recoveries
Total recoveries of loans and leases previously charged off
Net charge-offs
Write-offs of PCI loans
Provision for loan and lease losses
Other (4)

Allowance for loan and lease losses, December 31
Reserve for unfunded lending commitments, January 1
Provision for unfunded lending commitments

Reserve for unfunded lending commitments, December 31
Allowance for credit losses, December 31

Loan and allowance ratios:

2018

$

10,393

$

2017
11,237

(207)
(483)
(3,345)
—
(495)
(197)
(4,727)
(575)
(82)
(10)
(8)
(675)
(5,402)

179
485
508
—
300
15
1,487
120
14
9
9
152
1,639
(3,763)
(273)
3,262
(18)
9,601
777
20
797
10,398

$

(188)
(582)
(2,968)
(103)
(491)
(212)
(4,544)
(589)
(446)
(24)
(16)
(1,075)
(5,619)

288
369
455
28
277
49
1,466
142
6
15
11
174
1,640
(3,979)
(207)
3,381
(39)
10,393
762
15
777
11,170

$

Loans and leases outstanding at December 31 (5)
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (5)
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (6)
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (7)
Average loans and leases outstanding (5)
Net charge-offs as a percentage of average loans and leases outstanding (5, 8)
Net charge-offs and PCI write-offs as a percentage of average loans and leases outstanding (5)
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31 (5)
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs (8)
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs and PCI write-offs
Amounts included in allowance for loan and lease losses for loans and leases that are excluded from nonperforming loans and leases 

at December 31 (9)

$ 942,546

$ 931,039

1.02%
1.08
0.97
$ 927,531

1.12%
1.18
1.05
$ 911,988

0.41%
0.44
194
2.55
2.38

0.44%
0.46
161
2.61
2.48

$

4,031

$

3,971

Allowance for loan and lease losses as a percentage of total nonperforming loans and leases, excluding the allowance for loan and 

lease losses for loans and leases that are excluded from nonperforming loans and leases at December 31 (5, 9)

113%

99%

(1)  Represents net charge-offs related to the non-U.S. credit card loan portfolio, which was sold in 2017.
(2) 

Includes U.S. small business commercial charge-offs of $287 million and $258 million in 2018 and 2017.
Includes U.S. small business commercial recoveries of $47 million and $43 million in 2018 and 2017.

(3) 

(4)  Primarily represents the net impact of portfolio sales, consolidations and deconsolidations, foreign currency translation adjustments, transfers to held for sale and certain other reclassifications.
(5)  Outstanding loan and lease balances and ratios do not include loans accounted for under the fair value option of $4.3 billion and $5.7 billion at December 31, 2018 and 2017. Average loans 

accounted for under the fair value option were $5.5 billion and $6.7 billion in 2018 and 2017.

(6)  Excludes consumer loans accounted for under the fair value option of $682 million and $928 million at December 31, 2018 and 2017.
(7)  Excludes commercial loans accounted for under the fair value option of $3.7 billion and $4.8 billion at December 31, 2018 and 2017.
(8)  Net charge-offs exclude $273 million and $207 million of write-offs in the PCI loan portfolio in 2018 and 2017. For more information on PCI write-offs, see Consumer Portfolio Credit Risk Management 

– Purchased Credit-impaired Loan Portfolio on page 72.

(9)  Primarily includes amounts allocated to U.S. credit card and unsecured consumer lending portfolios in Consumer Banking and PCI loans in All Other.

84     Bank of America 2018

Market Risk Management
Market  risk  is  the  risk  that  changes  in  market  conditions  may 
adversely impact the value of assets or liabilities, or otherwise 
negatively impact earnings. This risk is inherent in the financial 
instruments associated with our operations, primarily within our 
Global Markets segment. We are also exposed to these risks in 
other areas of the Corporation (e.g.,  our  ALM  activities).  In  the 
event of market stress, these risks could have a material impact 
on  our  results.  For  more  information,  see  Interest  Rate  Risk 
Management for the Banking Book on page 89.

Our  traditional  banking  loan  and  deposit  products  are  non-
trading positions and are generally reported at amortized cost for 
assets or the amount owed for liabilities (historical cost). However, 
these  positions  are  still  subject  to  changes  in  economic  value 
based on varying market conditions, with one of the primary risks 
being changes in the levels of interest rates. The risk of adverse 
changes in the economic value of our non-trading positions arising 
from  changes  in  interest  rates  is  managed  through  our  ALM 
activities.  We  have  elected  to  account  for  certain  assets  and 
liabilities under the fair value option.

Our trading positions are reported at fair value with changes 
reflected  in  income.  Trading  positions  are  subject  to  various 
changes in market-based risk factors. The majority of this risk is 
generated by our activities in the interest rate, foreign exchange, 
credit, equity and commodities markets. In addition, the values of 
assets  and  liabilities  could  change  due  to  market  liquidity, 
correlations across markets and expectations of market volatility. 
We  seek  to  manage  these  risk  exposures  by  using  a  variety  of 
techniques 
financial 
instruments. The key risk management techniques are discussed 
in more detail in the Trading Risk Management section.

that  encompass  a  broad 

range  of 

Global  Risk  Management  is  responsible  for  providing  senior 
management with a clear and comprehensive understanding of 
the trading risks to which we are exposed. These responsibilities 
include ownership of market risk policy, developing and maintaining 
quantitative risk models, calculating aggregated risk measures, 
establishing  and  monitoring  position  limits  consistent  with  risk 
appetite, conducting daily reviews and analysis of trading inventory, 
approving  material  risk  exposures  and  fulfilling  regulatory 
requirements.  Market  risks  that  impact  businesses  outside  of 
Global  Markets  are  monitored  and  governed  by  their  respective 
governance functions.

Quantitative  risk  models,  such  as  VaR,  are  an  essential 
component in evaluating the market risks within a portfolio. The 
Enterprise Model Risk Committee (EMRC), a subcommittee of the 
MRC,  is  responsible  for  providing  management  oversight  and 
approval of model risk management and governance. The EMRC 
defines model risk standards, consistent with our risk framework 
and risk appetite, prevailing regulatory guidance and industry best 
practice. Models must meet certain validation criteria, including 
effective  challenge  of  the  model  development  process  and  a 
sufficient demonstration of developmental evidence incorporating 
a comparison of alternative theories and approaches. The EMRC 
oversees  that  model  standards  are  consistent  with  model  risk 
requirements and monitors the effective challenge in the model 
validation process across the Corporation. In addition, the relevant 
stakeholders must agree on any required actions or restrictions 
to  the  models  and  maintain  a  stringent  monitoring  process  for 
continued compliance.

Interest Rate Risk
Interest  rate  risk  represents  exposures  to  instruments  whose 
values  vary  with  the  level  or  volatility  of  interest  rates.  These 
instruments include, but are not limited to, loans, debt securities, 

certain trading-related assets and liabilities, deposits, borrowings 
and derivatives. Hedging instruments used to mitigate these risks 
include derivatives such as options, futures, forwards and swaps.

Foreign Exchange Risk
Foreign  exchange  risk  represents  exposures  to  changes  in  the 
values of current holdings and future cash flows denominated in 
currencies other than the U.S. dollar. The types of instruments 
exposed to this risk include investments in non-U.S. subsidiaries, 
foreign  currency-denominated  loans  and  securities,  future  cash 
flows  in  foreign  currencies  arising  from  foreign  exchange 
transactions,  foreign  currency-denominated  debt  and  various 
foreign exchange derivatives whose values fluctuate with changes 
in  the  level  or  volatility  of  currency  exchange  rates  or  non-
U.S. interest rates. Hedging instruments used to mitigate this risk 
include  foreign  exchange  options,  currency  swaps,  futures, 
forwards, and foreign currency-denominated debt and deposits.

certificates, 

Mortgage Risk
Mortgage risk represents exposures to changes in the values of 
mortgage-related instruments. The values of these instruments 
are sensitive to prepayment rates, mortgage rates, agency debt 
ratings,  default,  market  liquidity,  government  participation  and 
interest rate volatility. Our exposure to these instruments takes 
several forms. For example, we trade and engage in market-making 
activities in a variety of mortgage securities including whole loans, 
pass-through 
and 
collateralized  mortgage  obligations  including  collateralized  debt 
obligations using mortgages as underlying collateral. In addition, 
we originate a variety of MBS, which involves the accumulation of 
mortgage-related loans in anticipation of eventual securitization, 
and we may hold positions in mortgage securities and residential 
mortgage loans as part of the ALM portfolio. We also record MSRs 
as part of our mortgage origination activities. Hedging instruments 
used  to  mitigate  this  risk  include  derivatives  such  as  options, 
swaps, futures and forwards as well as securities including MBS 
and U.S. Treasury securities. For more information, see Mortgage 
Banking Risk Management on page 91.

commercial  mortgages 

Equity Market Risk
Equity  market  risk  represents  exposures  to  securities  that 
represent an ownership interest in a corporation in the form of 
domestic  and  foreign  common  stock  or  other  equity-linked 
instruments. Instruments that would lead to this exposure include, 
but  are  not  limited  to,  the  following:  common  stock,  exchange-
traded funds, American Depositary Receipts, convertible bonds, 
listed equity options (puts and calls), OTC equity options, equity 
total return swaps, equity index futures and other equity derivative 
products. Hedging instruments used to mitigate this risk include 
options, futures, swaps, convertible bonds and cash positions.

Commodity Risk
Commodity  risk  represents  exposures  to  instruments  traded  in 
the  petroleum,  natural  gas,  power  and  metals  markets.  These 
instruments  consist  primarily  of  futures,  forwards,  swaps  and 
options. Hedging instruments used to mitigate this risk include 
options,  futures  and  swaps  in  the  same  or  similar  commodity 
product, as well as cash positions.

Issuer Credit Risk
Issuer  credit  risk  represents  exposures  to  changes  in  the 
creditworthiness of individual issuers or groups of issuers. Our 
portfolio is exposed to issuer credit risk where the value of an 
asset may be adversely impacted by changes in the levels of credit 
spreads, by credit migration or by defaults. Hedging instruments 

Bank of America 2018     85 

used  to  mitigate  this  risk  include  bonds,  CDS  and  other  credit 
fixed-income instruments.

Market Liquidity Risk
Market liquidity risk represents the risk that the level of expected 
market activity changes dramatically and, in certain cases, may 
even cease. This exposes us to the risk that we will not be able 
to  transact  business  and  execute  trades  in  an  orderly  manner 
which  may  impact  our  results.  This  impact  could  be  further 
exacerbated  if  expected  hedging  or  pricing  correlations  are 
compromised by disproportionate demand or lack of demand for 
certain instruments. We utilize various risk mitigating techniques 
as discussed in more detail in Trading Risk Management.

Trading Risk Management
To evaluate risk in our trading activities, we focus on the actual 
and  potential  volatility  of  revenues  generated  by  individual 
positions as well as portfolios of positions. Various techniques 
and  procedures  are  utilized  to  enable  the  most  complete 
understanding  of these  risks.  Quantitative  measures  of  market 
risk are evaluated on a daily basis from a single position to the 
portfolio of the Corporation. These measures include sensitivities 
of positions to various market risk factors, such as the potential 
impact on revenue from a one basis point change in interest rates, 
and  statistical  measures  utilizing  both  actual  and  hypothetical 
market moves, such as VaR and stress testing. Periods of extreme 
market  stress  influence  the  reliability  of  these  techniques  to 
varying degrees. Qualitative evaluations of market risk utilize the 
suite of quantitative risk measures while understanding each of 
their 
risk  managers 
limitations.  Additionally, 
independently evaluate the risk of the portfolios under the current 
market environment and potential future environments.

respective 

VaR is a common statistic used to measure market risk as it 
allows the aggregation of market risk factors, including the effects 
of portfolio diversification. A VaR model simulates the value of a 
portfolio  under  a  range  of  scenarios  in  order  to  generate  a 
distribution of potential gains and losses. VaR represents the loss 
a portfolio is not expected to exceed more than a certain number 
of  times  per  period,  based  on  a  specified  holding  period, 
confidence level and window of historical data. We use one VaR 
model  consistently  across  the  trading  portfolios  and  it  uses  a 
historical simulation approach based on a three-year window of 
historical  data.  Our  primary  VaR  statistic  is  equivalent  to  a  99 
percent confidence level. This means that for a VaR with a one-
day holding period, there should not be losses in excess of VaR, 
on average, 99 out of 100 trading days.

Within  any  VaR  model,  there  are  significant  and  numerous 
assumptions  that  will  differ  from  company  to  company.  The 
accuracy of a VaR model depends on the availability and quality 
of historical data for each of the risk factors in the portfolio. A VaR 
model  may  require  additional  modeling  assumptions  for  new 
products that do not have the necessary historical market data or 
for  less  liquid  positions  for  which  accurate  daily  prices  are  not 
consistently  available.  For  positions  with  insufficient  historical 
data  for  the  VaR  calculation,  the  process  for  establishing  an 
appropriate proxy is based on fundamental and statistical analysis 
of the new product or less liquid position. This analysis identifies 
reasonable alternatives that replicate both the expected volatility 
and correlation to other market risk factors that the missing data 
would be expected to experience.

VaR  may  not  be  indicative  of  realized  revenue  volatility  as 
changes in market conditions or in the composition of the portfolio 
can  have  a  material  impact  on  the  results.  In  particular,  the 
historical data used for the VaR calculation might indicate higher 

86     Bank of America 2018

or lower levels of portfolio diversification than will be experienced. 
In order for the VaR model to reflect current market conditions, we 
update the historical data underlying our VaR model on a weekly 
basis,  or  more  frequently  during  periods  of  market  stress,  and 
regularly review the assumptions underlying the model. A minor 
portion of risks related to our trading positions is not included in 
VaR.  These  risks  are  reviewed  as  part  of  our  ICAAP.  For  more 
information regarding ICAAP, see Capital Management on page 58.
Global  Risk  Management  continually  reviews,  evaluates  and 
enhances our VaR model so that it reflects the material risks in 
our trading portfolio. Changes to the VaR model are reviewed and 
approved prior to implementation and any material changes are 
reported  to  management  through  the  appropriate  management 
committees.

Trading limits on quantitative risk measures, including VaR, are 
independently  set  by  Global  Markets  Risk  Management  and 
reviewed on a regular basis so that trading limits remain relevant 
and within our overall risk appetite for market risks. Trading limits 
are  reviewed  in  the  context  of  market  liquidity,  volatility  and 
strategic  business  priorities.  Trading  limits  are  set  at  both  a 
granular level to allow for extensive coverage of risks as well as 
at  aggregated  portfolios  to  account  for  correlations  among  risk 
factors. All trading limits are approved at least annually. Approved 
trading  limits  are  stored  and  tracked  in  a  centralized  limits 
management system. Trading limit excesses are communicated 
to  management  for  review.  Certain  quantitative  market  risk 
measures and corresponding limits have been identified as critical 
in the Corporation’s Risk Appetite Statement. These risk appetite 
limits  are  reported  on  a  daily  basis  and  are  approved  at  least 
annually by the ERC and the Board.

In periods of market stress, Global Markets senior leadership 
communicates daily to discuss losses, key risk positions and any 
limit excesses. As a result of this process, the businesses may 
selectively reduce risk.

Table 47 presents the total market-based portfolio VaR which 
is the combination of the total covered positions (and less liquid 
trading  positions)  portfolio  and  the  fair  value  option  portfolio. 
Covered positions are defined by regulatory standards as trading 
assets and liabilities, both on- and off-balance sheet, that meet a 
defined  set  of  specifications.  These  specifications  identify  the 
most liquid trading positions which are intended to be held for a 
short-term horizon and where we are able to hedge the material 
risk elements in a two-way market. Positions in less liquid markets, 
or where there are restrictions on the ability to trade the positions, 
typically do not qualify as covered positions. Foreign exchange and 
commodity  positions  are  always  considered  covered  positions, 
except for structural foreign currency positions that are excluded 
with prior regulatory approval. In addition, Table 47 presents our 
fair value option portfolio, which includes substantially all of the 
funded and unfunded exposures for which we elect the fair value 
option, and their corresponding hedges. Additionally, market risk 
VaR for trading activities as presented in Table 47 differs from VaR 
used for regulatory capital calculations due to the holding period 
being used. The holding period for VaR used for regulatory capital 
calculations is 10 days, while for the market risk VaR presented 
below, it is one day. Both measures utilize the same process and 
methodology.

The total market-based portfolio VaR results in Table 47 include 
market risk to which we are exposed from all business segments, 
excluding  credit  valuation  adjustment  (CVA),  DVA  and  related 
hedges. The majority of this portfolio is within the Global Markets 
segment.

Table 47 presents year-end, average, high and low daily trading 
VaR for 2018 and 2017 using a 99 percent confidence level. The 
amounts disclosed in Table 47 and Table 48 align to the view of 
covered positions used in the Basel 3 capital calculations. Foreign 
exchange and commodity positions are always considered covered 
positions, regardless of trading or banking treatment for the trade, 

except for structural foreign currency positions that are excluded 
with prior regulatory approval.

The  average  total  covered  positions  and  less  liquid  trading 
positions portfolio VaR decreased during 2018 primarily due to a 
decrease  in  credit  risk  along  with  an  increase  in  portfolio 
diversification.

Table 47 Market Risk VaR for Trading Activities

(Dollars in millions)

Foreign exchange

Interest rate

Credit

Equity

Commodities

Portfolio diversification

Total covered positions portfolio

Impact from less liquid exposures

Total covered positions and less liquid trading positions portfolio

Fair value option loans

Fair value option hedges

Fair value option portfolio diversification

Total fair value option portfolio

Portfolio diversification

Total market-based portfolio

2018

2017

Year End

Average

High (1)

Low (1)

Year End

Average

High (1)

Low (1)

$

$

9

36

26

20

13

$

8

25

25

20

8

(59)

(55)

45

5

50

8

5

(7)

6

(3)

$

53

$

31

3

34

11

9

(11)

9

(5)

38

$

15

45

31

40

15

—

45

—

51

18

17

—

16

—

57

2

15

20

11

3

—

20

—

23

8

4

—

5

—

26

$

$

7

22

29

19

5

$

11

21

26

18

5

(49)

(47)

33

5

38

9

7

(7)

9

(4)

$

43

$

34

6

40

10

7

(8)

9

(4)

45

$

25

41

33

33

9

—

53

—

63

14

11

—

11

—

69

3

11

21

12

3

—

23

—

26

7

4

—

6

—

29

(1)  The high and low for each portfolio may have occurred on different trading days than the high and low for the components. Therefore the impact from less liquid exposures and the amount of portfolio 

diversification, which is the difference between the total portfolio and the sum of the individual components, is not relevant.

The graph below presents the daily covered positions and less liquid trading positions portfolio VaR for 2018, corresponding to the 

data in Table 47.

Daily Total Covered Positions and Less Liquid Trading Portfolio VaR History 

s
n
o

i
l
l
i

M
n

i

s
r
a

l
l

o
D

80

70

60

50

40

30

20

10

0

VaR 

12/31/2017

3/31/2018

6/30/2018

9/30/2018

12/31/2018

Bank of America 2018     87 

 
 
 
Additional VaR statistics produced within our single VaR model are provided in Table 48 at the same level of detail as in Table 47. 
Evaluating VaR with additional statistics allows for an increased understanding of the risks in the portfolio as the historical market 
data used in the VaR calculation does not necessarily follow a predefined statistical distribution. Table 48 presents average trading 
VaR statistics at 99 percent and 95 percent confidence levels for 2018 and 2017.

Table 48 Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics

(Dollars in millions)

Foreign exchange
Interest rate
Credit
Equity
Commodities
Portfolio diversification

Total covered positions portfolio
Impact from less liquid exposures

Total covered positions and less liquid trading positions portfolio

Fair value option loans
Fair value option hedges
Fair value option portfolio diversification

Total fair value option portfolio

Portfolio diversification

Total market-based portfolio

Backtesting 
The accuracy of the VaR methodology is evaluated by backtesting, 
which compares the daily VaR results, utilizing a one-day holding 
period,  against  a  comparable  subset  of  trading  revenue.  A 
backtesting excess occurs when a trading loss exceeds the VaR 
for  the  corresponding  day.  These  excesses  are  evaluated  to 
understand the positions and market moves that produced the 
trading  loss  with  a  goal  to  ensure  that  the  VaR  methodology 
accurately represents those losses. We expect the frequency of 
trading losses in excess of VaR to be in line with the confidence 
level  of  the  VaR  statistic  being  tested.  For  example,  with  a  99 
percent confidence level, we expect one trading loss in excess of 
VaR  every  100  days  or  between  two  to  three  trading  losses  in 
excess of VaR over the course of a year. The number of backtesting 
excesses  observed  can  differ  from  the  statistically  expected 
number  of  excesses  if  the  current  level  of  market  volatility  is 
materially different than the level of market volatility that existed 
during the three years of historical data used in the VaR calculation. 
The  trading  revenue  used  for  backtesting  is  defined  by 
regulatory agencies  in  order to  most closely  align  with the  VaR 
component  of  the  regulatory  capital  calculation.  This  revenue 
differs from total trading-related revenue in that it excludes revenue 
from trading activities that either do not generate market risk or 
the market risk cannot be included in VaR. Some examples of the 
types of revenue excluded for backtesting are fees, commissions, 
reserves, net interest income and intraday trading revenues.

We  conduct  daily  backtesting  on  the  VaR  results  used  for 
regulatory capital calculations as well as the VaR results for key 
legal entities, regions and risk factors. These results are reported 
to senior market risk management. Senior management regularly 
reviews and evaluates the results of these tests.

During  2018,  there  were  three  days  in  which  there  was  a 
backtesting excess for our total covered portfolio VaR, utilizing a 
one-day holding period.

88     Bank of America 2018

2018

2017

99 percent

95 percent

99 percent

95 percent

$

$

8
25
25
20
8
(55)
31
3
34
11
9
(11)
9
(5)
38

$

$

5
16
15
11
4
(33)
18
1
19
6
6
(7)
5
(3)
21

$

$

11
21
26
18
5
(47)
34
6
40
10
7
(8)
9
(4)
45

$

$

6
14
15
10
3
(30)
18
2
20
6
5
(6)
5
(3)
22

Total Trading-related Revenue
Total trading-related revenue, excluding brokerage fees, and CVA, 
DVA and funding valuation adjustment gains (losses), represents 
the total amount earned from trading positions, including market-
based net interest income, which are taken in a diverse range of 
financial instruments and markets. Trading account assets and 
liabilities are reported at fair value. For more information on fair 
value, see Note 20 – Fair Value Measurements to the Consolidated 
Financial Statements. Trading-related revenue can be volatile and 
is  largely  driven  by  general  market  conditions  and  customer 
demand. Also, trading-related revenue is dependent on the volume 
and  type  of  transactions,  the  level  of  risk  assumed,  and  the 
volatility of price and rate movements at any given time within the 
ever-changing  market  environment.  Significant  daily  revenue  by 
business  is  monitored  and  the  primary  drivers  of  these  are 
reviewed.

The  following  histogram  is  a  graphic  depiction  of  trading 
volatility and illustrates the daily level of trading-related revenue 
for 2018 and 2017. During 2018, positive trading-related revenue 
was  recorded  for  98  percent  of  the  trading  days,  of  which  79 
percent were daily trading gains of over $25 million. This compares 
to 2017 where positive trading-related revenue was recorded for 
100 percent of the trading days, of which 77 percent were daily 
trading gains of over $25 million.

Histogram of Daily Trading-related Revenue 

s
y
a
D

f
o
r
e
b
m
u
N

160

140

120

100

80

60

40

20

0

-25 to 0

0 to 25

25 to 50

50 to 75

75 to 100

greater than 100

Year Ended December 31, 2017

Year Ended December 31, 2018

Revenue (dollars in millions) 

 
 
 
Trading Portfolio Stress Testing
Because  the  very  nature  of  a  VaR  model  suggests  results  can 
exceed our estimates and it is dependent on a limited historical 
window, we also stress test our portfolio using scenario analysis. 
This  analysis  estimates  the  change  in  the  value  of  our  trading 
portfolio that may result from abnormal market movements. 

A  set  of  scenarios,  categorized  as  either  historical  or 
hypothetical, are computed daily for the overall trading portfolio 
and  individual  businesses.  These  scenarios  include  shocks  to 
underlying market risk factors that may be well beyond the shocks 
found  in  the  historical  data  used  to  calculate  VaR.  Historical 
scenarios simulate the impact of the market moves that occurred 
during a period of extended historical market stress. Generally, a 
multi-week  period  representing  the  most  severe  point  during  a 
crisis  is  selected  for  each  historical  scenario.  Hypothetical 
scenarios  provide  estimated  portfolio  impacts  from  potential 
future market stress events. Scenarios are reviewed and updated 
in response to changing positions and new economic or political 
information. In addition, new or ad hoc scenarios are developed 
to  address  specific  potential  market  events  or  particular 
vulnerabilities in the portfolio. The stress tests are reviewed on a 
regular basis and the results are presented to senior management.
Stress  testing  for  the  trading  portfolio  is  integrated  with 
enterprise-wide  stress  testing  and  incorporated  into  the  limits 
framework.  The  macroeconomic  scenarios  used  for  enterprise-
wide stress testing purposes differ from the typical trading portfolio 
scenarios in that they have a longer time horizon and the results 
are forecasted over multiple periods for use in consolidated capital 
and liquidity planning. For more information, see Managing Risk 
on page 55.

Interest Rate Risk Management for the Banking 
Book
The following discussion presents net interest income for banking 
book activities.

Interest rate risk represents the most significant market risk 
exposure to our banking book balance sheet. Interest rate risk is 
measured as the potential change in net interest income caused 
by  movements  in  market  interest  rates.  Client-facing  activities, 
primarily lending and deposit-taking, create interest rate sensitive 
positions on our balance sheet.

We prepare forward-looking forecasts of net interest income. 
The  baseline  forecast  takes  into  consideration  expected  future 
business growth, ALM positioning and the direction of interest rate 
movements  as  implied  by  the  market-based  forward  curve.  We 
then measure and evaluate the impact that alternative interest 
rate scenarios have on the baseline forecast in order to assess 
interest rate sensitivity under varied conditions. The net interest 
income forecast is frequently updated for changing assumptions 
and  differing  outlooks  based  on  economic  trends,  market 
conditions and business strategies. Thus, we continually monitor 
our balance sheet position in order to maintain an acceptable level 
of exposure to interest rate changes.

The interest rate scenarios that we analyze incorporate balance 
sheet assumptions such as loan and deposit growth and pricing, 
changes in funding mix, product repricing, maturity characteristics 
and investment securities premium amortization. Our overall goal 
is to manage interest rate risk so that movements in interest rates 
do not significantly adversely affect earnings and capital.

Table 49 presents the spot and 12-month forward rates used 

in our baseline forecasts at December 31, 2018 and 2017.

Table 49 Forward Rates

Federal
Funds

December 31, 2018
Three-month
LIBOR

10-Year
Swap

Spot rates
12-month forward rates

2.50%
2.50

2.81%
2.64

Spot rates
12-month forward rates

December 31, 2017

1.50%
2.00

1.69%
2.14

2.71%
2.75

2.40%
2.48

Table 50 shows the pretax impact to forecasted net interest 
income over the next 12 months from December 31, 2018 and 
2017,  resulting  from  instantaneous  parallel  and  non-parallel 
shocks to the market-based forward curve. Periodically we evaluate 
the scenarios presented so that they are meaningful in the context 
of the current rate environment.

During 2018, the asset sensitivity of our balance sheet to rising 
rates declined primarily due  to  increases  in  long-end  rates. We 
continue to be asset sensitive to a parallel move in interest rates 
with the majority of that impact coming from the short end of the 
yield curve. Additionally, higher interest rates impact the fair value 
of debt securities and, accordingly, for debt securities classified 
as AFS, may adversely affect accumulated OCI and thus capital 
levels under the Basel 3 capital rules. Under instantaneous upward 
parallel shifts, the near-term adverse impact to Basel 3 capital is 
reduced over time by offsetting positive impacts to net interest 
income. For more information on Basel 3, see Capital Management 
– Regulatory Capital on page 59.

Table 50 Estimated Banking Book Net Interest Income 

Sensitivity to Curve Changes

(Dollars in millions)

Parallel Shifts
+100 bps 

instantaneous shift

-100 bps 

instantaneous shift

Flatteners

Short-end 

instantaneous change

Long-end 

instantaneous change

Steepeners
Short-end 

instantaneous change

Long-end 

instantaneous change

Short 
Rate 
(bps)

Long 
Rate 
(bps)

December 31

2018

2017

+100

+100

$

2,651

$

3,317

-100

-100

(4,109)

(5,183)

+100

—

1,977

2,182

—

-100

(1,616)

(2,765)

-100

—

(2,478)

(2,394)

—

+100

673

1,135

The sensitivity analysis in Table 50 assumes that we take no 
action in response to these rate shocks and does not assume any 
change in other macroeconomic variables normally correlated with 
changes in interest rates. As part of our ALM activities, we use 
securities,  certain  residential  mortgages,  and  interest  rate  and 
foreign exchange derivatives in managing interest rate sensitivity.
The behavior of our deposit portfolio in the baseline forecast 
and in alternate interest rate scenarios is a key assumption in our 
projected estimates of net interest income. The sensitivity analysis 
in Table 50 assumes no change in deposit portfolio size or mix 
from the baseline forecast in alternate rate environments. In higher 
rate scenarios, any customer activity resulting in the replacement 
of  low-cost  or  noninterest-bearing  deposits  with  higher  yielding 

Bank of America 2018     89 

 
 
 
 
 
deposits  or  market-based  funding  would  reduce  our  benefit  in 
those scenarios.

Interest Rate and Foreign Exchange Derivative 
Contracts
Interest rate and foreign exchange derivative contracts are utilized 
in our ALM activities and serve as an efficient tool to manage our 
interest  rate  and  foreign  exchange  risk.  We  use  derivatives  to 
hedge the variability in cash flows or changes in fair value on our 
balance  sheet  due  to  interest  rate  and  foreign  exchange 
components. For more information on our hedging activities, see 
Note 3 – Derivatives to the Consolidated Financial Statements.

Our interest rate contracts are generally non-leveraged generic 
interest rate and foreign exchange basis swaps, options, futures 
and  forwards.  In  addition,  we  use  foreign  exchange  contracts, 
including  cross-currency  interest  rate  swaps,  foreign  currency 
futures contracts, foreign currency forward contracts and options 
to  mitigate  the  foreign  exchange  risk  associated  with  foreign 
currency-denominated assets and liabilities.

Changes to the composition of our derivatives portfolio during 
2018 reflect actions taken for interest rate and foreign exchange 
rate risk management. The decisions to reposition our derivatives 
portfolio are based on the current assessment of economic and 
financial conditions including the interest rate and foreign currency 
environments,  balance  sheet  composition  and  trends,  and  the 
relative mix of our cash and derivative positions.

We  use  interest  rate  derivative  instruments  to  hedge  the 
variability in the cash flows of our assets and liabilities and other 
forecasted  transactions  (collectively  referred  to  as  cash  flow 

hedges). The net losses on both open and terminated cash flow 
hedge derivative instruments recorded in accumulated OCI were 
$1.3 billion, on a pretax basis, at both December 31, 2018 and 
2017.  These  net  losses  are  expected  to  be  reclassified  into 
earnings  in  the  same  period  as  the  hedged  cash  flows  affect 
earnings and will decrease income or increase expense on the 
respective hedged cash flows. Assuming no change in open cash 
flow derivative hedge positions and no changes in prices or interest 
rates beyond what is implied in forward yield curves at December 
31, 2018, the pretax net losses are expected to be reclassified 
into earnings as follows: 25 percent within the next year, 56 percent 
in years two through five and 11 percent in years six through 10, 
with the remaining eight percent thereafter. For more information 
on  derivatives  designated  as  cash  flow  hedges,  see  Note  3  – 
Derivatives to the Consolidated Financial Statements.

We hedge our net investment in non-U.S. operations determined 
to  have  functional  currencies  other  than  the  U.S.  dollar  using 
forward foreign exchange contracts that typically settle in less than 
180  days,  cross-currency  basis  swaps  and  foreign  exchange 
options.  We  recorded  net  after-tax  losses  on  derivatives  in 
accumulated OCI associated with net investment hedges which 
were offset by gains on our net investments in consolidated non-
U.S. entities at December 31, 2018.

Table 51 presents derivatives utilized in our ALM activities and 
shows the notional amount, fair value, weighted-average receive-
fixed and pay-fixed rates, expected maturity and average estimated 
durations of our open ALM derivatives at December 31, 2018 and 
2017.  These  amounts  do  not  include  derivative  hedges  on  our 
MSRs.

Table 51 Asset and Liability Management Interest Rate and Foreign Exchange Contracts

December 31, 2018
Expected Maturity

(Dollars in millions, average estimated duration in

years)

Fair
Value

Receive-fixed interest rate swaps (1)

$

2,128

Total

2019

2020

2021

2022

2023

Thereafter

Notional amount
Weighted-average fixed-rate
Pay-fixed interest rate swaps (1)

Notional amount
Weighted-average fixed-rate
Same-currency basis swaps (2)

Notional amount

  $ 198,914

$ 27,176

$ 16,347

$ 14,640

$ 19,866

$ 36,215

$ 84,670

2.66%

1.87%

2.68%

3.17%

2.56%

2.37%

2.97%

295

  $ 49,275

$

1,210

$

4,344

$

1,616

$

2.50%

2.07%

2.16%

2.22%

— $ 10,801
—%

2.59%

$ 31,304

2.55%

21

  $ 101,203

$

7,628

$ 15,097

$ 15,493

$

2,586

$

2,017

$ 58,382

Average
Estimated
Duration

5.17

6.30

Foreign exchange basis swaps (1, 3, 4)

(1,716)

Notional amount

Option products

Notional amount

Foreign exchange contracts (1, 4, 5)

Notional amount (6)

Net ALM contracts
For footnotes, see page 91.

2

82

$

812

106,742

13,946

21,448

19,241

10,239

6,260

35,608

587

572

(8,447)

(27,823)

—

13

—

—

15

—

4,196

2,741

2,448

9,978

90     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 51 Asset and Liability Management Interest Rate and Foreign Exchange Contracts (continued)

December 31, 2017
Expected Maturity

(Dollars in millions, average estimated duration in

years)

Fair
Value

Receive-fixed interest rate swaps (1)

$

2,330

Total

2018

2019

2020

2021

2022

Thereafter

Notional amount
Weighted-average fixed-rate
Pay-fixed interest rate swaps (1)

Notional amount
Weighted-average fixed-rate
Same-currency basis swaps (2)

Notional amount

  $176,390

$ 21,850

$ 27,176

$ 16,347

$ 6,498

$ 19,120

$ 85,399

2.42%

3.20%

1.87%

1.88%

2.99%

2.10%

2.52%

(37)

  $ 45,873

$ 11,555

$ 1,210

$ 4,344

$ 1,616

$

2.15%

1.73%

2.07%

2.16%

2.22%

— $ 27,148
—%

2.32%

(17)

  $ 38,622

$ 11,028

$ 6,789

$ 1,180

$ 2,807

$

955

$ 15,863

Average
Estimated
Duration

5.38

5.63

Foreign exchange basis swaps (1, 3, 4)

(1,616)

Notional amount

Option products

Notional amount

Foreign exchange contracts (1, 4, 5)

Notional amount (6)

Net ALM contracts

13

1,424

$

2,097

107,263

24,886

11,922

13,367

9,301

6,860

40,927

1,218

1,201

—

—

—

—

17

(11,783)

(28,689)

2,231

(24)

2,471

2,919

9,309

(1)  Does not include basis adjustments on either fixed-rate debt issued by the Corporation or AFS debt securities, which are hedged using derivatives designated as fair value hedging instruments, that 

substantially offset the fair values of these derivatives.

(2)  At December 31, 2018 and 2017, the notional amount of same-currency basis swaps included $101.2 billion and $38.6 billion in both foreign currency and U.S. dollar-denominated basis swaps in 

which both sides of the swap are in the same currency.

(3)  Foreign exchange basis swaps consisted of cross-currency variable interest rate swaps used separately or in conjunction with receive-fixed interest rate swaps.
(4)  Does not include foreign currency translation adjustments on certain non-U.S. debt issued by the Corporation that substantially offset the fair values of these derivatives.
(5)  The notional amount of foreign exchange contracts of $(8.4) billion at December 31, 2018 was comprised of $25.2 billion in foreign currency-denominated and cross-currency receive-fixed swaps, 
$(32.7) billion in net foreign currency forward rate contracts, $(1.8) billion in foreign currency-denominated pay-fixed swaps and $814 million in net foreign currency futures contracts. Foreign exchange 
contracts of $(11.8) billion at December 31, 2017 were comprised of $29.1 billion in foreign currency-denominated and cross-currency receive-fixed swaps, $(35.6) billion in net foreign currency 
forward rate contracts, $(6.2) billion in foreign currency-denominated pay-fixed swaps and $940 million in foreign currency futures contracts.

(6)  Reflects the net of long and short positions. Amounts shown as negative reflect a net short position.

Mortgage Banking Risk Management
We originate, fund and service mortgage loans, which subject us 
to  credit,  liquidity  and  interest  rate  risks,  among  others.  We 
determine whether loans will be held for investment or held for 
sale at the time of commitment and manage credit and liquidity 
risks by selling or securitizing a portion of the loans we originate.
Interest  rate  risk  and  market  risk  can  be  substantial  in  the 
mortgage business. Changes in interest rates and other market 
factors impact the volume of mortgage originations. Changes in 
interest  rates  also  impact  the  value  of  interest  rate  lock 
commitments (IRLCs) and the related residential first mortgage 
LHFS between the date of the IRLC and the date the loans are 
sold to the secondary market. An increase in mortgage interest 
rates  typically  leads  to  a  decrease  in  the  value  of  these 
instruments.  Conversely,  when  there  is  an  increase  in  interest 
rates,  the  value  of  the  MSRs  will  increase  driven  by  lower 
prepayment expectations. Because the interest rate risks of these 
two hedged items offset, we combine them into one overall hedged 
item with one combined economic hedge portfolio consisting of 
derivative contracts and securities.

During 2018 and 2017, we recorded gains of $244 million and 
$118 million related to the change in fair value of the MSRs, IRLCs 
and LHFS, net of gains and losses on the hedge portfolio. For more 
information on MSRs, see Note 20 – Fair Value Measurements to 
the Consolidated Financial Statements.

Compliance and Operational Risk Management
Compliance risk is the risk of legal or regulatory sanctions, material 
financial  loss  or  damage  to  the  reputation  of  the  Corporation 
arising  from  the  failure  of  the  Corporation  to  comply  with  the 
requirements of applicable laws, rules, regulations and our internal 
policies and procedures (collectively, applicable laws, rules and 
regulations).

Operational risk is the risk of loss resulting from inadequate 
or failed processes, people and systems or from external events. 
Operational risk may occur anywhere in the Corporation, including 
third-party business processes, and is not limited to operations 
functions. Effects may extend beyond financial losses and may 
result in reputational risk impacts. Operational risk includes legal 
risk. Additionally, operational risk is a component in the calculation 
of  total  risk-weighted  assets  used  in  the  Basel  3  capital 
calculation.  For  more  information  on  Basel  3  calculations,  see 
Capital Management on page 58. 

FLUs and control functions are first and foremost responsible 
for  managing  all  aspects  of  their  businesses,  including  their 
compliance and operational risk. FLUs and control functions are 
required to understand their business processes and related risks 
and controls, including the related regulatory requirements, and 
monitor and report on the effectiveness of the control environment. 
In order to actively monitor and assess the performance of their 
processes and controls, they must conduct comprehensive quality 
assurance activities and identify issues and risks to remediate 
control gaps and weaknesses. FLUs and control functions must 
also adhere to compliance and operational risk appetite limits to 
meet strategic, capital and financial planning objectives. Finally, 
FLUs  and  control  functions  are  responsible  for  the  proactive 
identification,  management  and  escalation  of  compliance  and 
operational risks across the Corporation.

Global Compliance and Operational Risk teams independently 
assess  compliance  and  operational  risk,  monitor  business 
activities and processes, evaluate FLUs and control functions for 
adherence  to  applicable  laws,  rules  and  regulations,  including 
identifying issues and risks, determining and developing tests to 
be  conducted  by  the  Enterprise  Independent  Testing  unit,  and 
reporting  on  the  state  of  the  control  environment.  Enterprise 
Independent Testing, an independent testing function within IRM, 
works with Global Compliance and Operational Risk, the FLUs and 

Bank of America 2018     91 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
control functions in the identification of testing needs and test 
design,  and  is  accountable  for  test  execution,  reporting  and 
analysis of results.

The Corporation’s approach to the management of compliance 
risk is described in the Global Compliance - Enterprise Policy, which 
outlines  the  requirements  of  the  Corporation’s  compliance  risk 
management program, and defines roles and responsibilities of 
FLUs,  IRM  and  Corporate  Audit,  the  three  lines  of  defense  in 
managing  compliance  risk.  The  requirements  work  together  to 
drive  a  comprehensive  risk-based  approach  for  the  proactive 
identification,  management  and  escalation  of  compliance  risks 
throughout  the  Corporation.  For  more  information  on  FLUs  and 
control functions, see Managing Risk on page 55.

The Corporation’s approach to operational risk management 
is outlined in the Operational Risk Management - Enterprise Policy 
which  establishes  the  requirements  of  the  Corporation’s 
operational  risk  management  program  and  specifies  the 
responsibilities and accountabilities of the first and second lines 
of  defense  for  managing  operational  risk  so  that  our  business 
processes are designed and executed effectively.

The Global Compliance Enterprise Policy and Operational Risk 
Management  -  Enterprise  Policy  also  set  the  requirements  for 
reporting compliance and operational risk information to executive 
management  as  well  as  the  Board  or  appropriate  Board-level 
committees  in  support  of  Global  Compliance  and  Operational 
Risk’s responsibilities for conducting independent oversight of our 
compliance and operational risk management activities. The Board 
provides oversight of compliance risk through its Audit Committee 
and the ERC, and operational risk through the ERC.

includes  cybersecurity.  Cybersecurity 

A  key  operational  risk  facing  the  Corporation  is  information 
security,  which 
risk 
represents,  among  other  things,  exposure  to  failures  or 
interruptions  of  service  or  breaches  of  security,  resulting  from 
malicious  technological  attacks  or  otherwise,  that  impact  the 
confidentiality, availability or integrity of our operations, systems 
or data, including sensitive corporate and customer information. 
The Corporation manages information security risk in accordance 
with internal policies which govern our comprehensive information 
security program designed to protect the Corporation by enabling 
preventative and detective measures to combat information and 
cybersecurity risks. The Board and the ERC provide cybersecurity 
and information security risk oversight for the Corporation and our 
Global  Information  Security  Team  manages  the  day-to-day 
implementation of our information security program. 

Reputational Risk Management
Reputational  risk  is  the  risk  that  negative  perceptions  of  the 
Corporation’s conduct or business practices may adversely impact 
its  profitability  or operations.  Reputational  risk may  result  from 
many of the Corporation’s activities, including those related to the 
management of our strategic, operational, compliance and credit 
risks.

risk 

reputational 

The  Corporation  manages 

through 
established  policies  and  controls  in  its  businesses  and  risk 
management processes to mitigate reputational risks in a timely 
manner  and  through  proactive  monitoring  and  identification  of 
potential reputational risk events. If reputational risk events occur, 
we focus on remediating the underlying issue and taking action to 
minimize damage to the Corporation’s reputation. The Corporation 
has processes and procedures in place to respond to events that 
give rise to reputational risk, including educating individuals and 
organizations that influence public opinion, implementing external 
communication strategies to mitigate the risk, and informing key 
stakeholders of potential reputational risks. 

92     Bank of America 2018

The  Corporation’s  organization  and  governance  structure 
provides  oversight  of  reputational  risks,  and  reputational  risk 
reporting is provided regularly and directly to management and the 
ERC,  which  provides  primary  oversight  of  reputational  risk.  In 
addition,  each  FLU  has  a  committee,  which 
includes 
representatives  from  Compliance,  Legal  and  Risk,  that  is 
responsible 
for  the  oversight  of  reputational  risk.  Such 
committees’  oversight  includes  providing  approval  for  business 
activities that present elevated levels of reputational risks.

Complex Accounting Estimates
Our  significant  accounting  principles,  as  described  in  Note  1  – 
Summary of Significant Accounting Principles to the Consolidated 
Financial  Statements,  are  essential  in  understanding  the 
Management's Discussion and Analysis of Financial Condition and 
Results of Operations (MD&A). Many of our significant accounting 
principles require complex judgments to estimate the values of 
assets and liabilities. We have procedures and processes in place 
to facilitate making these judgments.

The more judgmental estimates are summarized in the following 
discussion. We have identified and described the development of 
the  variables  most  important  in  the  estimation  processes  that 
involve  mathematical  models  to  derive  the  estimates.  In  many 
cases, there are numerous alternative judgments that could be 
used in the process of determining the inputs to the models. Where 
alternatives  exist,  we  have  used  the  factors  that  we  believe 
represent  the  most  reasonable  value  in  developing  the  inputs. 
Actual  performance  that  differs  from  our  estimates  of  the  key 
variables  could  materially  impact  our  results  of  operations. 
Separate  from  the  possible  future  impact  to  our  results  of 
operations from input and model variables, the value of our lending 
portfolio and market-sensitive assets and liabilities may change 
subsequent to the balance sheet date, often significantly, due to 
the nature and magnitude of future credit and market conditions. 
Such  credit  and  market  conditions  may  change  quickly  and  in 
unforeseen  ways  and  the  resulting  volatility  could  have  a 
significant,  negative  effect  on  future  operating  results.  These 
fluctuations would not be indicative of deficiencies in our models 
or inputs.

Allowance for Credit Losses
The allowance for credit losses, which includes the allowance for 
loan  and  lease  losses  and  the  reserve  for  unfunded  lending 
commitments,  represents  management’s  estimate  of  probable 
incurred credit losses in the Corporation’s loan and lease portfolio 
excluding those loans accounted for under the fair value option. 
The  allowance  for  credit  losses  includes  both  quantitative  and 
qualitative components. The qualitative component has a higher 
degree of management subjectivity, and includes factors such as 
concentrations,  economic  conditions  and  other  considerations. 
Our  process  for  determining  the  allowance  for  credit  losses  is 
discussed in Note 1 – Summary of Significant Accounting Principles
to the Consolidated Financial Statements. 

Our estimate for the allowance for loan and lease losses is 
sensitive  to  the  loss  rates  and  expected  cash  flows  from  our 
Consumer  Real  Estate  and  Credit  Card  and  Other  Consumer 
portfolio segments, as well as our U.S. small business commercial 
card portfolio within the Commercial portfolio segment. For each 
one-percent  increase  in  the  loss  rates  on  loans  collectively 
evaluated for impairment in our Consumer Real Estate portfolio 
segment,  excluding  PCI  loans,  coupled  with  a  one-percent 
decrease in the discounted cash flows on those loans individually 
evaluated  for  impairment  within  this  portfolio  segment,  the 
allowance for loan and lease losses at December 31, 2018 would 
have increased $24 million. We subject our PCI portfolio to stress 

scenarios to evaluate the potential impact given certain events. 
A one-percent decrease in the expected cash flows would result 
in a $41 million impairment of the portfolio. Within our Credit Card 
and Other Consumer portfolio segment and U.S. small business 
commercial card portfolio, for each one-percent increase in the 
loss rates on loans collectively evaluated for impairment coupled 
with a one-percent decrease in the expected cash flows on those 
loans individually evaluated for impairment, the allowance for loan 
and lease losses at December 31, 2018 would have increased 
$44 million.

Our allowance for loan and lease losses is sensitive to the risk 
ratings  assigned  to  loans  and  leases  within  the  Commercial 
portfolio segment (excluding the U.S. small business commercial 
card portfolio). Assuming a downgrade of one level in the internal 
risk ratings for commercial loans and leases, except loans and 
leases already classified as Substandard and Doubtful as defined 
by regulatory authorities, the allowance for loan and lease losses 
would have increased $2.5 billion at December 31, 2018.

The allowance for loan and lease losses as a percentage of 
total loans and leases at December 31, 2018 was 1.02 percent 
and these hypothetical increases in the allowance would raise the 
ratio to 1.30 percent.

These  sensitivity  analyses  do  not  represent  management’s 
expectations of the deterioration in risk ratings or the increases 
in loss rates but are provided as hypothetical scenarios to assess 
the  sensitivity  of  the  allowance  for  loan  and  lease  losses  to 
changes  in  key  inputs.  We  believe  the  risk  ratings  and  loss 
severities currently in use are appropriate and that the probability 
of the alternative scenarios outlined above occurring within a short 
period of time is remote.

The process of determining the level of the allowance for credit 
losses  requires  a  high  degree  of  judgment.  It  is  possible  that 
others, given the same information, may at any point in time reach 
different reasonable conclusions.

Fair Value of Financial Instruments
Under  applicable  accounting  standards,  we  are  required  to 
maximize the use of observable inputs and minimize the use of 
unobservable inputs in measuring fair value. We classify fair value 
measurements of financial instruments and MSRs based on the 
three-level fair value hierarchy in the accounting standards. 

The  fair  values  of  assets  and  liabilities  may  include 
adjustments,  such  as  market  liquidity  and  credit  quality,  where 
appropriate.  Valuations  of  products  using  models  or  other 
techniques are sensitive to assumptions used for the significant 
inputs.  Where  market  data  is  available,  the  inputs  used  for 
valuation reflect that information as of our valuation date. Inputs 
to  valuation  models  are  considered  unobservable  if  they  are 
supported  by  little  or  no  market  activity.  In  periods  of  extreme 
volatility,  lessened  liquidity  or  in  illiquid  markets,  there  may  be 
more variability in market pricing or a lack of market data to use 
in the valuation process. In keeping with the prudent application 
of estimates and management judgment in determining the fair 
value of assets and liabilities, we have in place various processes 
and controls that include: a model validation policy that requires 
review and approval of quantitative models used for deal pricing, 
financial  statement 
risk 
quantification;  a  trading  product  valuation  policy  that  requires 
verification of all traded product valuations; and a periodic review 
and substantiation of daily profit and loss reporting for all traded 
products.  Primarily  through  validation  controls,  we  utilize  both 
broker and pricing service inputs which can and do include both 
market-observable and internally-modeled values and/or valuation 
inputs.  Our  reliance  on  this  information  is  affected  by  our 
understanding of how the broker and/or pricing service develops 

value  determination  and 

fair 

its data with a higher degree of reliance applied to those that are 
more  directly  observable  and  lesser  reliance  applied  to  those 
developed through their own internal modeling. For example, broker 
quotes in less active markets may only be indicative and therefore 
less  reliable.  These  processes  and  controls  are  performed 
independently of the business. For additional information, see Note 
20 – Fair Value Measurements and Note 21 – Fair Value Option to 
the Consolidated Financial Statements. 

Level 3 Assets and Liabilities
Financial assets and liabilities, and MSRs, where values are based 
on  valuation  techniques  that  require  inputs  that  are  both 
unobservable  and  are  significant  to  the  overall  fair  value 
measurement  are  classified  as  Level  3  under  the  fair  value 
hierarchy established in applicable accounting standards. The fair 
value of these Level 3 financial assets and liabilities and MSRs 
is  determined  using  pricing  models,  discounted  cash  flow 
methodologies or similar techniques for which the determination 
of  fair  value  requires  significant  management  judgment  or 
estimation. 

Level 3 financial instruments may be hedged with derivatives 
classified as Level 1 or 2; therefore, gains or losses associated 
with Level 3 financial instruments may be offset by gains or losses 
associated with financial instruments classified in other levels of 
the fair value hierarchy. The Level 3 gains and losses recorded in 
earnings did not have a significant impact on our liquidity or capital. 
We conduct a review of our fair value hierarchy classifications on 
a quarterly basis. Transfers into or out of Level 3 are made if the 
significant inputs used in the financial models measuring the fair 
values  of  the  assets  and  liabilities  became  unobservable  or 
observable,  respectively,  in  the  current  marketplace.  For  more 
information on transfers into and out of Level 3 during 2018, 2017
and  2016,  see  Note  20  –  Fair  Value  Measurements  to  the 
Consolidated Financial Statements.

Accrued Income Taxes and Deferred Tax Assets
Accrued income taxes, reported as a component of either other 
assets  or  accrued  expenses  and  other  liabilities  on  the 
Consolidated Balance Sheet, represent the net amount of current 
income taxes we expect to pay to or receive from various taxing 
jurisdictions attributable to our operations to date. We currently 
file income tax returns in more than 100 jurisdictions and consider 
many factors, including statutory, judicial and regulatory guidance, 
in  estimating  the  appropriate  accrued  income  taxes  for  each 
jurisdiction.

Net  deferred  tax  assets,  reported  as  a  component  of  other 
assets  on  the  Consolidated  Balance  Sheet,  represent  the  net 
decrease in taxes expected to be paid in the future because of 
net operating loss (NOL) and tax credit carryforwards and because 
of future reversals of temporary differences in the bases of assets 
and liabilities as measured by tax laws and their bases as reported 
in the financial statements. NOL and tax credit carryforwards result 
in reductions to future tax liabilities, and many of these attributes 
can expire if not utilized within certain periods. We consider the 
need for valuation allowances to reduce net deferred tax assets 
to the amounts that we estimate are more likely than not to be 
realized.

Consistent with the applicable accounting guidance, we monitor 
relevant  tax  authorities  and  change  our  estimates  of  accrued 
income taxes and/or net deferred tax assets due to changes in 
income  tax  laws  and  their  interpretation  by  the  courts  and 
regulatory  authorities.  These  revisions  of  our  estimates,  which 
also  may  result  from  our  income  tax  planning  and  from  the 
resolution  of  income  tax  audit  matters,  may  be  material  to  our 
operating results for any given period.

Bank of America 2018     93 

See  Note  19  –  Income Taxes  to  the  Consolidated  Financial 
Statements for a table of significant tax attributes and additional 
information. For more information, see Item 1A. Risk Factors of 
our 2018 Annual Report on Form 10-K.

Goodwill and Intangible Assets
The nature of and accounting for goodwill and intangible assets 
are  discussed  in  Note  1  –  Summary  of  Significant  Accounting 
Principles, and Note 8 – Goodwill and Intangible Assets. Beginning 
with our annual goodwill impairment test as of June 30, 2018, we 
conducted  a  qualitative  assessment,  rather  than  a  quantitative 
assessment as previously performed, that is more fully described 
in  Note 1 – Summary of Significant Accounting Principles to  the 
Consolidated Financial Statements. 

We completed our annual goodwill impairment test as of June 
30,  2018  for  all  of  our  reporting  units  that  had  goodwill.  We 
performed that test by assessing qualitative factors to determine 
whether it is more likely than not that the fair value of each reporting 
unit is less than its respective carrying value. Factors considered 
in  the  qualitative  assessments  include,  among  other  things, 
macroeconomic conditions, industry and market considerations, 
financial performance of the respective reporting unit and other 
relevant entity- and reporting-unit specific considerations. If based 
on the results of the qualitative assessment, it is more likely than 
not that the fair value of a reporting unit is less than its carrying 
value, a quantitative assessment is performed.

Based on our qualitative assessments, we determined that for 
each reporting unit with goodwill, it was more likely than not that 
its  respective  fair  value  exceeded  its  carrying  value,  indicating 
there was no impairment. For more information regarding goodwill 
balances at June 30, 2018, see Note 8 – Goodwill and Intangible 
Assets to the Consolidated Financial Statements.

Representations and Warranties Liability
The methodology used to estimate the liability for obligations under 
representations and warranties related to transfers of residential 
mortgage loans is a function of the type of representations and 
warranties provided in the sales contracts and considers a variety 
of factors. These factors, which incorporate judgment, are subject 
to  change  based  on  our  specific  experience.  Our  experience  in 
negotiating settlements with trustees and other counterparties is 
an important input in determining our estimate of the liability. We 
also consider actual defaults, estimated future defaults, historical 
loss  experience,  estimated  home  prices  and  other  economic 
conditions. Changes to any one of these factors could impact the 
estimate of our liability.

The  representations  and  warranties  provision  may  vary 
significantly each period as the methodology used to estimate the 
expense continues to be refined. The estimate of the liability for 
representations and warranties is sensitive to future defaults, loss 
severity and the net repurchase rate. An assumed simultaneous 
increase or decrease of 10 percent in estimated future defaults, 
loss  severity  and  the  net  repurchase  rate  would  result  in  an 
increase  or  decrease  of  approximately  $200  million  in  the 
representations and warranties liability as of December 31, 2018. 
These sensitivities are hypothetical and are intended to provide 
an indication of the impact of a significant change in these key 
assumptions  on  the  representations  and  warranties  liability.  In 
reality, changes in one assumption may result in changes in other 
assumptions, which may or may not counteract the sensitivity.

For  more  information  on  representations  and  warranties 
exposure, see Note 12 – Commitments and Contingencies to the 
Consolidated Financial Statements.

94     Bank of America 2018

2017 Compared to 2016
The following discussion and analysis provide a comparison of our 
results of operations for 2017 and 2016. This discussion should 
be read in conjunction with the Consolidated Financial Statements 
and related Notes. 

Overview

Net Income
Net income was $18.2 billion, or $1.56 per diluted share in 2017
compared to $17.8 billion, or $1.49 per diluted share in 2016. 
The results for 2017 included a charge of $2.9 billion related to 
the Tax Act. The pretax results for 2017 compared to 2016 were 
driven by higher revenue, largely the result of an increase in net 
interest income, lower provision for credit losses and a decline in 
noninterest expense. 

Net Interest Income
Net interest income increased $3.6 billion to $44.7 billion in 2017
compared to 2016. Net interest yield on an FTE basis increased 
12 bps to 2.37 percent for 2017. These increases were primarily 
driven  by  the  benefits  from  higher  interest  rates  and  loan  and 
deposit  growth,  partially  offset  by  the  sale  of  the  non-U.S. 
consumer credit card business in the second quarter of 2017. 

Noninterest Income
Noninterest income increased $80 million to $42.7 billion in 2017
compared  to  2016.  The  following  highlights  the  significant 
changes.

Service charges increased $180 million primarily driven by the 
impact  of  pricing  strategies  and  higher  treasury  services 
related revenue. 
Investment  and  brokerage  services  income  increased  $487 
million primarily driven by the impact of AUM flows and higher 
market valuations, partially offset by the impact of changing 
market dynamics on transactional revenue and AUM pricing. 
Investment banking income increased $770 million primarily 
due to higher advisory fees and higher debt and equity issuance 
fees. 
Trading account profits increased $375 million primarily due 
to increased client financing activity in equities, partially offset 
by weaker performance across most fixed-income products. 
  Other  income  decreased  $1.8  billion  primarily  due  to  lower 
mortgage banking income, with declines in both MSR results 
and production. Included in 2017 was a $793 million pretax 
gain  recognized  in  connection  with  the  sale  of  the  non-U.S. 
consumer  credit  card  business  and  a  downward  valuation 
adjustment  of  $946  million  on  tax-advantaged  energy 
investments in connection with the Tax Act. 

Provision for Credit Losses
The provision for credit losses decreased $201 million to $3.4 
billion for 2017 compared to 2016 primarily due to reductions in 
energy exposures in the commercial portfolio and credit quality 
improvements  in  the  consumer  real  estate  portfolio.  This  was 
partially offset by portfolio seasoning and loan growth in the U.S. 
credit  card  portfolio  and  a  single-name  non-U.S.  commercial 
charge-off. 

Noninterest Expense
Noninterest expense decreased $340 million to $54.7 billion for 
2017 compared to 2016. The decrease was primarily due to lower 
operating  costs,  a  reduction  from  the  sale  of  the  non-U.S. 
consumer  credit  card  business  and  lower  litigation  expense, 
partially  offset  by  a  $316  million  impairment  charge  related  to 
certain data centers that were in the process of being sold and 

$145 million for the shared success discretionary year-end bonus 
awarded to certain employees. 

Income Tax Expense
Tax expense for 2017 included a charge of $1.9 billion reflecting 
the impact of the Tax Act. Other than the impact of the Tax Act, 
the  effective  tax  rate  for  2017  was  driven  by  our  recurring  tax 
preference  benefits  as  well  as  an  expense  recognized  in 
connection  with  the  sale  of  the  non-U.S.  consumer  credit  card 
business, largely offset by benefits related to the adoption of the 
new accounting standard for the tax impact associated with share-
based compensation, and the restructuring of certain subsidiaries. 
The  effective  tax  rate  for  2016  was  driven  by  our  recurring  tax 
preferences  and  net  tax  benefits  related  to  various  tax  audit 
matters, partially offset by a charge for the impact of U.K. tax law 
changes enacted in 2016.

Business Segment Operations

Consumer Banking
Net income for Consumer Banking increased $1.0 billion to $8.2 
billion in 2017 compared to 2016 primarily driven by higher net 
interest income, partially offset by higher provision for credit losses 
and  lower  mortgage  banking  income  which  is  included  in  other 
noninterest income. Net interest income increased $3.0 billion to 
$24.3 billion primarily due to the beneficial impact of an increase 
in  investable  assets  as  a  result  of  higher  deposits,  as  well  as 
pricing discipline and loan growth. Noninterest income decreased 
$227 million to $10.2 billion driven by lower mortgage banking 
income, partially offset by higher card income and service charges. 
The  provision  for  credit  losses  increased  $810  million  to  $3.5 
billion due to portfolio seasoning and loan growth in the U.S. credit 
card  portfolio.  Noninterest  expense  increased  $131  million  to 
$17.8 billion driven by higher personnel expense, including the 
shared success discretionary year-end bonus, and increased FDIC 
expense,  as  well  as  investments  in  digital  capabilities  and 
business growth. These increases were partially offset by improved 
operating efficiencies.

Global Wealth & Investment Management
Net  income  for  GWIM  increased $312  million  to  $3.1  billion  in 
2017 compared to 2016 due to higher revenue, partially offset by 
an increase in noninterest expense. Net interest income increased 
$414 million to $6.2 billion driven by higher short-term interest 
rates.  Noninterest  income,  which  primarily  includes  investment 
and brokerage services income, increased $526 million to $12.4 
billion. The increase in noninterest income was driven by the impact 
of AUM flows and higher market valuations, partially offset by the 
impact of changing market dynamics on transactional revenue and 
AUM  pricing.  Noninterest  expense  increased  $390  million  to 
$13.6 billion primarily driven by higher revenue-related incentive 
costs.

Global Banking
Net income for Global Banking increased $1.2 billion to $7.0 billion 
in  2017  compared  to  2016  driven  by  higher  revenue  and  lower

provision  for  credit  losses.  Revenue  increased  $1.6  billion  to 
$20.0 billion driven by higher net interest income and noninterest 
income. Net interest income increased $1.0 billion to $10.5 billion
due to loan and deposit-related growth, higher short-term rates on 
an increased deposit base and the impact of the allocation of ALM 
activities,  partially  offset  by  credit  spread  compression. 
Noninterest income increased $521 million to $9.5 billion largely 
due to higher investment banking fees. The provision for credit 
losses decreased $671 million to $212 million in 2017 primarily 
driven by reductions in energy exposures and continued portfolio 
improvement, partially offset by Global Banking’s portion of a 2017 
single-name non-U.S. commercial charge-off. Noninterest expense 
increased $110 million to $8.6 billion in 2017 primarily driven by 
higher investments in technology and higher deposit insurance, 
partially offset by lower litigation costs.

Global Markets
Net income for Global Markets decreased $524 million to $3.3 
billion  in  2017  compared  to  2016.  Net  DVA  losses  were  $428 
million compared to losses of $238 million in 2016. Excluding net 
DVA, net income decreased $405 million to $3.6 billion primarily 
driven  by  higher  noninterest  expense,  lower  sales  and  trading 
revenue and an increase in the provision for credit losses, partially 
offset  by  higher  investment  banking  fees.  Sales  and  trading 
revenue, excluding net DVA, decreased $423 million primarily due 
to weaker performance in rates products and emerging markets. 
The provision for credit losses increased $133 million to $164 
million in 2017, reflecting Global Markets’ portion of a single-name 
non-U.S. commercial charge-off. Noninterest expense increased 
$560  million  to  $10.7  billion  primarily  due  to  higher  litigation 
expense and continued investments in technology. 

All Other
The net loss for All Other increased $1.6 billion to a net loss of 
$3.3 billion, driven by a charge of $2.9 billion due to enactment 
of  the  Tax  Act.  The  pretax  loss  for  2017  compared  to  2016 
decreased $523 million reflecting lower noninterest expense and 
a larger benefit in the provision for credit losses, partially offset 
by a decline in revenue. Revenue declined $1.5 billion primarily 
due to lower mortgage banking income. All other noninterest loss 
decreased marginally and included a pretax gain of $793 million 
on the sale of the non-U.S. credit card business and a downward 
valuation adjustment of $946 million on tax-advantaged energy 
investments in connection with the Tax Act. 

The benefit in the provision for credit losses increased $461 
million to a benefit of $561 million primarily driven by continued 
runoff of the non-core portfolio, loan sale recoveries and the sale 
of the non-U.S. consumer credit card business. 

Noninterest  expense  decreased  $1.5  billion  to  $4.1  billion
driven by lower litigation expense, lower personnel expense and a 
decline in non-core mortgage servicing costs.

The income tax benefit was $1.0 billion in 2017 compared to 
a benefit of $3.1 billion in 2016. The decrease in the tax benefit 
was  driven  by  the  impacts  of  the  Tax  Act.  Both  periods  include 
income tax benefit adjustments to eliminate the FTE treatment of 
certain tax credits recorded in Global Banking.

Bank of America 2018     95 

Statistical Tables
Table of Contents

Table I – Outstanding Loans and Leases
Table II – Nonperforming Loans, Leases and Foreclosed Properties
Table III – Accruing Loans and Leases Past Due 90 Days or More
Table IV – Selected Loan Maturity Data
Table V – Allowance for Credit Losses
Table VI – Allocation of the Allowance for Credit Losses by Product Type

Table I Outstanding Loans and Leases

Page

96

97

97

98

98

99

(Dollars in millions)

Consumer

Residential mortgage
Home equity
U.S. credit card
Non-U.S. credit card
Direct/Indirect consumer (1)
Other consumer (2)

Total consumer loans excluding loans accounted for under the fair value option

Consumer loans accounted for under the fair value option (3)

Total consumer

Commercial

U.S. commercial
Non-U.S. commercial
Commercial real estate (4)
Commercial lease financing

U.S. small business commercial (5)

Total commercial loans excluding loans accounted for under the fair value option

Commercial loans accounted for under the fair value option (3)

Total commercial

Less: Loans of business held for sale (6)

Total loans and leases

2018

2017

208,557
48,286
98,338
—
91,166
202
446,549
682
447,231

299,277
98,776
60,845
22,534
481,432
14,565
495,997
3,667
499,664
—
946,895

$ 203,811
57,744
96,285
—
96,342
166
454,348
928
455,276

284,836
97,792
58,298
22,116
463,042
13,649
476,691
4,782
481,473
—
$ 936,749

$

$

December 31
2016

$ 191,797
66,443
92,278
9,214
95,962
626
456,320
1,051
457,371

270,372
89,397
57,355
22,375
439,499
12,993
452,492
6,034
458,526
(9,214)
$ 906,683

2015

2014

$ 187,911
75,948
89,602
9,975
90,149
713
454,298
1,871
456,169

252,771
91,549
57,199
21,352
422,871
12,876
435,747
5,067
440,814
—
$ 896,983

$ 216,197
85,725
91,879
10,465
81,386
841
486,493
2,077
488,570

220,293
80,083
47,682
19,579
367,637
13,293
380,930
6,604
387,534
—
$ 876,104

(1) 

Includes auto and specialty lending loans and leases of $50.1 billion, $52.4 billion, $50.7 billion, $43.9 billion and $38.7 billion, unsecured consumer lending loans of $383 million, $469 million, 
$585 million, $886 million and $1.5 billion, U.S. securities-based lending loans of $37.0 billion, $39.8 billion, $40.1 billion, $39.8 billion and $35.8 billion, non-U.S. consumer loans of $2.9 billion, 
$3.0 billion, $3.0 billion, $3.9 billion and $4.0 billion, student loans of $0, $0, $497 million, $564 million and $632 million, and other consumer loans of $746 million, $684 million, $1.1 billion, 
$1.0 billion and $761 million at December 31, 2018, 2017, 2016, 2015 and 2014, respectively.

(2)  Substantially all of other consumer at December 31, 2018 and 2017 is consumer overdrafts. Other consumer at December 31, 2016, 2015 and 2014 also includes consumer finance loans of $465 

million, $564 million and $676 million, respectively.

(3)  Consumer loans accounted for under the fair value option were residential mortgage loans of $336 million, $567 million, $710 million, $1.6 billion and $1.9 billion, and home equity loans of $346 
million, $361 million, $341 million, $250 million and $196 million at December 31, 2018, 2017, 2016, 2015 and 2014, respectively. Commercial loans accounted for under the fair value option 
were U.S. commercial loans of $2.5 billion, $2.6 billion, $2.9 billion, $2.3 billion and $1.9 billion, and non-U.S. commercial loans of $1.1 billion, $2.2 billion, $3.1 billion, $2.8 billion and $4.7 billion
at December 31, 2018, 2017, 2016, 2015 and 2014, respectively. 
Includes U.S. commercial real estate loans of $56.6 billion, $54.8 billion, $54.3 billion, $53.6 billion and $45.2 billion, and non-U.S. commercial real estate loans of $4.2 billion, $3.5 billion, $3.1 
billion, $3.5 billion and $2.5 billion at December 31, 2018, 2017, 2016, 2015 and 2014, respectively.
Includes card-related products.

(5) 

(4) 

(6)  Represents non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet.

96     Bank of America 2018

 
 
 
 
 
 
 
Table II Nonperforming Loans, Leases and Foreclosed Properties (1)

(Dollars in millions)

Consumer

Residential mortgage
Home equity
Direct/Indirect consumer
Other consumer

Total consumer (2)

Commercial

U.S. commercial
Non-U.S. commercial
Commercial real estate
Commercial lease financing

U.S. small business commercial

Total commercial (3)
Total nonperforming loans and leases

Foreclosed properties

2018

2017

December 31
2016

2015

2014

$

$

1,893
1,893
56
—
3,842

$

2,476
2,644
46
—
5,166

$

3,056
2,918
28
2
6,004

$

4,803
3,337
24
1
8,165

6,889
3,901
28
1
10,819

794
80
156
18
1,048
54
1,102
4,944
300
5,244

814
299
112
24
1,249
55
1,304
6,470
288
6,758

1,256
279
72
36
1,643
60
1,703
7,707
377
8,084

867
158
93
12
1,130
82
1,212
9,377
459
9,836

701
1
321
3
1,026
87
1,113
11,932
697
12,629

(2) 

Total nonperforming loans, leases and foreclosed properties

$
(1)  Balances do not include PCI loans even though the customer may be contractually past due. PCI loans were recorded at fair value upon acquisition and accrete interest income over the remaining 
life of the loan. In addition, balances do not include foreclosed properties insured by certain government-guaranteed loans, principally FHA-insured loans, that entered foreclosure of $488 million, 
$801 million, $1.2 billion, $1.4 billion and $1.1 billion at December 31, 2018, 2017, 2016, 2015 and 2014, respectively.
In 2018, $625 million in interest income was estimated to be contractually due on $3.8 billion of consumer loans and leases classified as nonperforming at December 31, 2018, as presented in 
the table above, plus $6.8 billion of TDRs classified as performing at December 31, 2018. Approximately $388 million of the estimated $625 million in contractual interest was received and included 
in interest income for 2018. 
In 2018, $119 million in interest income was estimated to be contractually due on $1.1 billion of commercial loans and leases classified as nonperforming at December 31, 2018, as presented in 
the table above, plus $1.3 billion of TDRs classified as performing at December 31, 2018. Approximately $84 million of the estimated $119 million in contractual interest was received and included 
in interest income for 2018.

$

$

$

$

(3) 

Table III  Accruing Loans and Leases Past Due 90 Days or More (1)

(Dollars in millions)

Consumer

Residential mortgage (2)
U.S. credit card
Non-U.S. credit card
Direct/Indirect consumer
Other consumer

Total consumer

Commercial

U.S. commercial 
Non-U.S. commercial
Commercial real estate
Commercial lease financing

U.S. small business commercial

Total commercial
Total accruing loans and leases past due 90 days or more

2018

2017

December 31
2016

2015

2014

$

$

1,884
994
—
38
—
2,916

197
—
4
29
230
84
314
3,230

$

$

3,230
900
—
40
—
4,170

144
3
4
19
170
75
245
4,415

$

$

4,793
782
66
34
4
5,679

106
5
7
19
137
71
208
5,887

$

$

7,150
789
76
39
3
8,057

113
1
3
15
132
61
193
8,250

$

$

11,407
866
95
64
1
12,433

110
—
3
40
153
67
220
12,653

(1)  Our policy is to classify consumer real estate-secured loans as nonperforming at 90 days past due, except the PCI loan portfolio, the fully-insured loan portfolio and loans accounted for under the 

fair value option.

(2)  Balances are fully-insured loans.

Bank of America 2018     97 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table IV Selected Loan Maturity Data (1, 2)

(Dollars in millions)

U.S. commercial
U.S. commercial real estate
Non-U.S. and other (3)

Total selected loans

Percent of total
Sensitivity of selected loans to changes in interest rates for loans due after one year:

Fixed interest rates
Floating or adjustable interest rates

Total

(1)  Loan maturities are based on the remaining maturities under contractual terms.
(2) 

Includes loans accounted for under the fair value option.

(3)  Loan maturities include non-U.S. commercial and commercial real estate loans.

Table V Allowance for Credit Losses

(Dollars in millions)

Allowance for loan and lease losses, January 1
Loans and leases charged off

Residential mortgage
Home equity
U.S. credit card
Non-U.S. credit card (1)
Direct/Indirect consumer
Other consumer

Total consumer charge-offs

U.S. commercial (2)
Non-U.S. commercial
Commercial real estate
Commercial lease financing

Total commercial charge-offs
Total loans and leases charged off

Recoveries of loans and leases previously charged off

Residential mortgage
Home equity
U.S. credit card
Non-U.S. credit card (1)
Direct/Indirect consumer
Other consumer

Total consumer recoveries

U.S. commercial (3)
Non-U.S. commercial
Commercial real estate
Commercial lease financing

Total commercial recoveries
Total recoveries of loans and leases previously charged off
Net charge-offs
Write-offs of PCI loans
Provision for loan and lease losses
Other (4)

Total allowance for loan and lease losses, December 31
Less: Allowance included in assets of business held for sale (5)

Allowance for loan and lease losses, December 31
Reserve for unfunded lending commitments, January 1
Provision for unfunded lending commitments
Other (4)

Reserve for unfunded lending commitments, December 31
Allowance for credit losses, December 31

Due in One
Year or Less

December 31, 2018

Due After One
Year Through
Five Years

Due After
Five Years

$

$

74,365
11,622
42,217
128,204

$

$

194,116
40,393
55,360
289,869

27%

61%

  $

  $

17,109
272,760
289,869

$

$

$

$

47,888
4,590
6,579
59,057

$

$

Total

316,369
56,605
104,156
477,130

12%

100%

27,664
31,393
59,057

2018

2017

2016

2015

2014

$

10,393

$

11,237

$

12,234

$

14,419

$

17,428

(207)
(483)
(3,345)
—
(495)
(197)
(4,727)
(575)
(82)
(10)
(8)
(675)
(5,402)

179
485
508
—
300
15
1,487
120
14
9
9
152
1,639
(3,763)
(273)
3,262
(18)
9,601
—
9,601
777
20
—
797
10,398

$

(188)
(582)
(2,968)
(103)
(491)
(212)
(4,544)
(589)
(446)
(24)
(16)
(1,075)
(5,619)

288
369
455
28
277
49
1,466
142
6
15
11
174
1,640
(3,979)
(207)
3,381
(39)
10,393
—
10,393
762
15
—
777
11,170

$

(403)
(752)
(2,691)
(238)
(392)
(232)
(4,708)
(567)
(133)
(10)
(30)
(740)
(5,448)

272
347
422
63
258
27
1,389
175
13
41
9
238
1,627
(3,821)
(340)
3,581
(174)
11,480
(243)
11,237
646
16
100
762
11,999

$

(866)
(975)
(2,738)
(275)
(383)
(224)
(5,461)
(536)
(59)
(30)
(19)
(644)
(6,105)

393
339
424
87
271
31
1,545
172
5
35
10
222
1,767
(4,338)
(808)
3,043
(82)
12,234
—
12,234
528
118
—
646
12,880

$

(855)
(1,364)
(3,068)
(357)
(456)
(268)
(6,368)
(584)
(35)
(29)
(10)
(658)
(7,026)

969
457
430
115
287
39
2,297
214
1
112
19
346
2,643
(4,383)
(810)
2,231
(47)
14,419
—
14,419
484
44
—
528
14,947

$

(1)  Represents net charge-offs related to the non-U.S. credit card loan portfolio, which was sold in 2017.
(2) 

Includes U.S. small business commercial charge-offs of $287 million, $258 million, $253 million, $282 million and $345 million in 2018, 2017, 2016, 2015 and 2014, respectively.
Includes U.S. small business commercial recoveries of $47 million, $43 million, $45 million, $57 million and $63 million in 2018, 2017, 2016, 2015 and 2014, respectively.

(3) 

(4)  Primarily represents the net impact of portfolio sales, consolidations and deconsolidations, foreign currency translation adjustments, transfers to held for sale and certain other reclassifications.
(5)  Represents allowance related to the non-U.S. credit card loan portfolio, which was sold in 2017.

98     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table V Allowance for Credit Losses (continued)

(Dollars in millions)

Loan and allowance ratios (6):

2018

2017

2016

2015

2014

Loans and leases outstanding at December 31 (7)
Allowance for loan and lease losses as a percentage of total loans and leases outstanding 

$ 942,546

$ 931,039

$ 908,812

$ 890,045

$ 867,422

at December 31 (7)

1.02%

1.12%

1.26%

1.37%

1.66%

Consumer allowance for loan and lease losses as a percentage of total consumer loans and 

leases outstanding at December 31 (8)

Commercial allowance for loan and lease losses as a percentage of total commercial loans 

and leases outstanding at December 31 (9)

Average loans and leases outstanding (7)
Net charge-offs as a percentage of average loans and leases outstanding (7, 10)
Net charge-offs and PCI write-offs as a percentage of average loans and leases 

outstanding (7)

Allowance for loan and lease losses as a percentage of total nonperforming loans and 

leases at December 31 (7)

Ratio of the allowance for loan and lease losses at December 31 to net charge-offs (10)
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs and PCI

write-offs

Amounts included in allowance for loan and lease losses for loans and leases that are 

1.08

0.97

1.18

1.05

1.36

1.16

1.63

1.11

2.05

1.16

$ 927,531

$ 911,988

$ 892,255

$ 869,065

$ 888,804

0.41%

0.44%

0.43%

0.50%

0.49%

0.44

194

2.55

2.38

0.46

161

2.61

2.48

0.47

149

3.00

2.76

0.59

130

2.82

2.38

0.58

121

3.29

2.78

excluded from nonperforming loans and leases at December 31 (11)

$

4,031

$

3,971

$

3,951

$

4,518

$

5,944

Allowance for loan and lease losses as a percentage of total nonperforming loans and 

leases, excluding the allowance for loan and lease losses for loans and leases that are 
excluded from nonperforming loans and leases at December 31 (7, 11)

113%

99%

98%

82%

71%

(6)  Loan and allowance ratios for 2016 include $243 million of non-U.S. credit card allowance for loan and lease losses and $9.2 billion of ending non-U.S. credit card loans, which were sold in 2017.
(7)  Outstanding loan and lease balances and ratios do not include loans accounted for under the fair value option of $4.3 billion, $5.7 billion, $7.1 billion, $6.9 billion and $8.7 billion at December 31, 
2018, 2017, 2016, 2015 and 2014, respectively. Average loans accounted for under the fair value option were $5.5 billion, $6.7 billion, $8.2 billion, $7.7 billion and $9.9 billion in 2018, 2017, 
2016, 2015 and 2014, respectively.

(8)  Excludes consumer loans accounted for under the fair value option of $682 million, $928 million, $1.1 billion, $1.9 billion and $2.1 billion at December 31, 2018, 2017, 2016, 2015 and 2014, 

respectively.

(9)  Excludes commercial loans accounted for under the fair value option of $3.7 billion, $4.8 billion, $6.0 billion, $5.1 billion and $6.6 billion at December 31, 2018, 2017, 2016, 2015 and 2014, 

respectively. 

(10)  Net charge-offs exclude $273 million, $207 million, $340 million, $808 million and $810 million of write-offs in the PCI loan portfolio in 2018, 2017, 2016, 2015 and 2014 respectively. For more 

information on PCI write-offs, see Consumer Portfolio Credit Risk Management – Purchased Credit-impaired Loan Portfolio on page 72.

(11)  Primarily includes amounts allocated to U.S. credit card and unsecured consumer lending portfolios in Consumer Banking and PCI loans and the non-U.S. credit card portfolio in All Other.

Table VI Allocation of the Allowance for Credit Losses by Product Type

(Dollars in millions)

Allowance for loan and lease losses

Residential mortgage
Home equity
U.S. credit card
Non-U.S. credit card
Direct/Indirect consumer
Other consumer

Total consumer
U.S. commercial (1)
Non-U.S. commercial
Commercial real estate
Commercial lease financing

Total commercial
Total allowance for loan and lease  

losses (2)

2018

2017

December 31
2016

2015

2014

Amount

Percent
of Total

Amount

Percent
of Total

Amount

Percent
of Total

Amount

Percent
of Total

Amount

Percent
of Total

$

422
506
3,597
—
248
29
4,802
3,010
677
958
154
4,799

4.40% $
5.27
37.47
—
2.58
0.30
50.02
31.35
7.05
9.98
1.60
49.98

701
1,019
3,368
—
264
31
5,383
3,113
803
935
159
5,010

6.74% $ 1,012
1,738
9.80
2,934
32.41
243
—
244
2.54
0.30
51
6,222
51.79
3,326
29.95
874
7.73
920
9.00
138
1.53
5,258
48.21

8.82% $ 1,500
2,414
2,927
274
223
47
7,385
2,964
754
967
164
4,849

15.14
25.56
2.12
2.13
0.44
54.21
28.97
7.61
8.01
1.20
45.79

12.26% $ 2,900
3,035
19.73
3,320
23.93
369
2.24
299
1.82
59
0.38
9,982
60.36
2,619
24.23
649
6.17
1,016
7.90
153
1.34
4,437
39.64

20.11%
21.05
23.03
2.56
2.07
0.41
69.23
18.16
4.50
7.05
1.06
30.77

9,601

100.00%

10,393

100.00%

11,480

100.00%

12,234

100.00%

14,419

100.00%

Less: Allowance included in assets of 

business held for sale (3)

Allowance for loan and lease losses
Reserve for unfunded lending commitments

Allowance for credit losses

—

9,601
797
$ 10,398

—

10,393
777
$ 11,170

(243)

11,237
762
  $ 11,999

—

12,234
646
$ 12,880

—

14,419
528
$ 14,947

(1) 

(2) 

Includes allowance for loan and lease losses for U.S. small business commercial loans of $474 million, $439 million, $416 million, $507 million and $536 million at December 31, 2018, 2017, 
2016, 2015 and 2014, respectively.
Includes $91 million, $289 million, $419 million, $804 million and $1.7 billion of valuation allowance presented with the allowance for loan and lease losses related to PCI loans at December 31, 
2018, 2017, 2016, 2015 and 2014, respectively.

(3)  Represents allowance for loan and lease losses related to the non-U.S. credit card loan portfolio, which was sold in 2017.

Bank of America 2018     99 

 
 
 
 
 
 
 
 
 
 
 
 
Financial Statements and Notes
Table of Contents

Consolidated Statement of Income
Consolidated Statement of Comprehensive Income
Consolidated Balance Sheet
Consolidated Statement of Changes in Shareholders’ Equity
Consolidated Statement of Cash Flows
Note 1 – Summary of Significant Accounting Principles
Note 2 – Noninterest Income
Note 3 – Derivatives
Note 4 – Securities
Note 5 – Outstanding Loans and Leases 
Note 6 – Allowance for Credit Losses
Note 7 – Securitizations and Other Variable Interest Entities
Note 8 – Goodwill and Intangible Assets
Note 9 – Deposits
Note 10 – Federal Funds Sold or Purchased, Securities Financing Agreements, Short-term Borrowings 

and Restricted Cash

Note 11 – Long-term Debt
Note 12 – Commitments and Contingencies
Note 13 – Shareholders’ Equity
Note 14 – Accumulated Other Comprehensive Income (Loss)
Note 15 – Earnings Per Common Share
Note 16 – Regulatory Requirements and Restrictions
Note 17 – Employee Benefit Plans
Note 18 – Stock-based Compensation Plans
Note 19 – Income Taxes
Note 20 – Fair Value Measurements
Note 21 – Fair Value Option
Note 22 – Fair Value of Financial Instruments
Note 23 – Business Segment Information
Note 24 – Parent Company Information
Note 25 – Performance by Geographical Area
Glossary
Acronyms

Page
103
103
104
105
106
107
115
116
123
126
137
138
142
143

143
146
147
153
155
156
156
158
163
163
165
175
177
178
181
182
183
184

100     Bank of America 2018

Report of Management on Internal Control Over Financial Reporting 

Bank of America Corporation and Subsidiaries

The management of Bank of America Corporation is responsible 
for  establishing  and  maintaining  adequate  internal  control  over 
financial reporting.

The Corporation’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 accounting 
principles generally accepted in the United States of America. The 
Corporation’s  internal  control  over  financial  reporting  includes 
those policies and procedures that (i) pertain to the maintenance 
of records that, in reasonable detail, accurately and fairly reflect 
the transactions and dispositions of the assets of the Corporation; 
(ii) provide reasonable assurance that transactions are recorded 
as  necessary  to  permit  preparation  of  financial  statements  in 
accordance with accounting principles generally accepted in the 
United States of America, and that receipts and expenditures of 
the  Corporation  are  being  made  only  in  accordance  with 
authorizations of management and directors of the Corporation; 
and  (iii)  provide  reasonable  assurance  regarding  prevention  or 
timely detection of unauthorized acquisition, use, or disposition 
of the Corporation’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.

Management assessed the effectiveness of the Corporation’s 
internal control over financial reporting as of December 31, 2018
based on the framework set forth by the Committee of Sponsoring 
Organizations of the Treadway Commission in Internal Control – 
Integrated  Framework  (2013).  Based  on  that  assessment, 
management  concluded  that,  as  of  December  31,  2018,  the 
Corporation’s internal control over financial reporting is effective.

The  Corporation’s  internal  control  over  financial  reporting              

as  of  December  31,  2018  has  been  audited  by 
PricewaterhouseCoopers, LLP, an independent registered public 
accounting  firm,  as  stated  in  their  accompanying  report  which 
expresses  an  unqualified  opinion  on  the  effectiveness  of  the 
Corporation’s  internal  control  over  financial  reporting  as  of 
December 31, 2018.

Brian T. Moynihan
Chairman, Chief Executive Officer and President

Paul M. Donofrio
Chief Financial Officer

Bank of America 2018     101 

Report of Independent Registered Public Accounting Firm

Bank of America Corporation and Subsidiaries

To the Board of Directors and Shareholders of Bank 
of America Corporation:

Opinions on the Financial Statements and Internal 
Control over Financial Reporting
We have audited the accompanying consolidated balance sheets 
of  Bank  of  America  Corporation  and  its  subsidiaries  as  of 
December  31,  2018  and  December  31,  2017,  and  the  related 
consolidated  statements  of  income,  comprehensive  income, 
changes in shareholders’ equity and cash flows for each of the 
three years in the period ended December 31, 2018, including the 
related notes (collectively referred to as the “consolidated financial 
statements”).  We  also  have  audited  the  Corporation’s  internal 
control over financial reporting as of December 31, 2018, based 
on criteria established in Internal Control - Integrated Framework 
(2013) issued by the Committee of Sponsoring Organizations of 
the Treadway Commission (COSO).

In our opinion, the consolidated financial statements referred 
to  above  present  fairly,  in  all  material  respects,  the  financial 
position  of  the  Corporation  as  of  December  31,  2018  and 
December 31, 2017, and the results of its operations and its cash 
flows for each of the three years in the period ended December 
31,  2018  in  conformity  with  accounting  principles  generally 
accepted in the United States of America. Also in our opinion, the 
Corporation maintained, in all material respects, effective internal 
control over financial reporting as of December 31, 2018, based 
on criteria established in Internal Control - Integrated Framework 
(2013) issued by the COSO.

is 

for 

responsible 

Basis for Opinions
The  Corporation’s  management 
these 
consolidated  financial  statements,  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 of Management on Internal 
Control Over Financial Reporting. Our responsibility is to express 
opinions on the Corporation’s consolidated financial statements 
and on the Corporation’s internal control over financial reporting 
based on our audits. We are a public accounting firm registered 
with  the  Public  Company  Accounting  Oversight  Board  (United 
States) (PCAOB) and are required to be independent with respect 
to the Corporation in accordance with the U.S. federal securities 
laws and the applicable rules and regulations of the Securities 
and Exchange Commission and the PCAOB.

misstatement of the consolidated 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 
consolidated  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 consolidated financial statements. Our audit 
of internal control over financial reporting included obtaining an 
understanding  of  internal  control  over  financial  reporting, 
assessing the risk that a material weakness exists, and testing 
and evaluating the design and operating effectiveness of internal 
control  based  on  the  assessed  risk.  Our  audits  also  included 
performing such other procedures as we considered necessary in 
the circumstances. We believe that our audits provide a reasonable 
basis for our opinions.

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 (i) pertain 
to the maintenance of records that, in reasonable detail, accurately 
and fairly reflect the transactions and dispositions of the assets 
of 
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  (iii) 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.

reasonable  assurance 

the  company; 

(ii) provide 

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.

We conducted our audits in accordance with the standards of 
the PCAOB. Those standards require that we plan and perform the 
audits  to  obtain  reasonable  assurance  about  whether  the 
consolidated 
free  of  material 
misstatement, whether due to error or fraud, and whether effective 
internal  control  over  financial  reporting  was  maintained  in  all 
material respects.

financial  statements  are 

Charlotte, North Carolina
February 26, 2019

We have served as the Corporation’s auditor since 1958.

Our audits of the consolidated financial statements included 
risks  of  material 

performing  procedures 

to  assess 

the 

102     Bank of America 2018

Bank of America Corporation and Subsidiaries

Consolidated Statement of Income

(In millions, except per share information)

Interest income

Loans and leases
Debt securities
Federal funds sold and securities borrowed or purchased under agreements to resell
Trading account assets
Other interest income

Total interest income

Interest expense

Deposits
Short-term borrowings
Trading account liabilities
Long-term debt

Total interest expense
Net interest income

Noninterest income

Card income
Service charges
Investment and brokerage services
Investment banking income
Trading account profits
Other income

Total noninterest income
Total revenue, net of interest expense

Provision for credit losses

Noninterest expense

Personnel
Occupancy
Equipment
Marketing
Professional fees
Data processing
Telecommunications
Other general operating

Total noninterest expense
Income before income taxes

Income tax expense
Net income

Preferred stock dividends

Net income applicable to common shareholders

Per common share information

Earnings
Diluted earnings

Average common shares issued and outstanding
Average diluted common shares issued and outstanding

Consolidated Statement of Comprehensive Income

(Dollars in millions)

Net income
Other comprehensive income (loss), net-of-tax:
Net change in debt and equity securities
Net change in debit valuation adjustments
Net change in derivatives
Employee benefit plan adjustments
Net change in foreign currency translation adjustments

Other comprehensive income (loss)

Comprehensive income

$

$

$

$

2018

2017

2016

$

$

$

$

40,811
11,724
3,176
4,811
6,247
66,769

4,495
5,839
1,358
7,645
19,337
47,432

6,051
7,767
14,160
5,327
8,540
1,970
43,815
91,247

3,282

31,880
4,066
1,705
1,674
1,699
3,222
699
8,436
53,381
34,584
6,437
28,147
1,451
26,696

2.64
2.61
10,096.5
10,236.9

$

$

$

$

36,221
10,471
2,390
4,474
4,023
57,579

1,931
3,538
1,204
6,239
12,912
44,667

5,902
7,818
13,836
6,011
7,277
1,841
42,685
87,352

3,396

31,931
4,009
1,692
1,746
1,888
3,139
699
9,639
54,743
29,213
10,981
18,232
1,614
16,618

1.63
1.56
10,195.6
10,778.4

33,228
9,167
1,118
4,423
3,121
51,057

1,015
2,350
1,018
5,578
9,961
41,096

5,851
7,638
13,349
5,241
6,902
3,624
42,605
83,701

3,597

32,018
4,038
1,804
1,703
1,971
3,007
746
9,796
55,083
25,021
7,199
17,822
1,682
16,140

1.57
1.49
10,284.1
11,046.8

2018

2017

2016

$

28,147

$

18,232

$

17,822

(3,953)
749
(53)
(405)
(254)
(3,916)
24,231

$

61
(293)
64
288
86
206
18,438

$

(1,345)
(156)
182
(524)
(87)
(1,930)
15,892

$

See accompanying Notes to Consolidated Financial Statements.

Bank of America 2018     103 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Bank of America Corporation and Subsidiaries

Consolidated Balance Sheet

(Dollars in millions)

Assets
Cash and due from banks
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks

Cash and cash equivalents

Time deposits placed and other short-term investments
Federal funds sold and securities borrowed or purchased under agreements to resell 
   (includes $56,399 and $52,906 measured at fair value)

Trading account assets (includes $119,363 and $106,274 pledged as collateral)
Derivative assets
Debt securities:

Carried at fair value
Held-to-maturity, at cost (fair value – $200,435 and $123,299)

Total debt securities

Loans and leases (includes $4,349 and $5,710 measured at fair value)
Allowance for loan and lease losses

Loans and leases, net of allowance

Premises and equipment, net
Goodwill
Loans held-for-sale (includes $2,942 and $2,156 measured at fair value)
Customer and other receivables
Other assets (includes $19,739 and $22,581 measured at fair value)

Total assets

Liabilities
Deposits in U.S. offices:
Noninterest-bearing
Interest-bearing (includes $492 and $449 measured at fair value)

Deposits in non-U.S. offices:

Noninterest-bearing
Interest-bearing
Total deposits

Federal funds purchased and securities loaned or sold under agreements to repurchase 
   (includes $28,875 and $36,182 measured at fair value)

Trading account liabilities
Derivative liabilities
Short-term borrowings (includes $1,648 and $1,494 measured at fair value)
Accrued expenses and other liabilities (includes $20,075 and $22,840 measured at fair value
   and $797 and $777 of reserve for unfunded lending commitments)

Long-term debt (includes $27,637 and $31,786 measured at fair value)

Total liabilities

Commitments and contingencies (Note 7 – Securitizations and Other Variable Interest Entities
   and Note 12 – Commitments and Contingencies)

Shareholders’ equity
Preferred stock, $0.01 par value; authorized – 100,000,000 shares; issued and outstanding – 3,843,140 and 3,837,683 shares
Common stock and additional paid-in capital, $0.01 par value; authorized – 12,800,000,000 shares;
   issued and outstanding – 9,669,286,370 and 10,287,302,431 shares

Retained earnings
Accumulated other comprehensive income (loss)

Total shareholders’ equity
Total liabilities and shareholders’ equity

Assets of consolidated variable interest entities included in total assets above (isolated to settle the liabilities of the variable interest entities)

Trading account assets
Loans and leases
Allowance for loan and lease losses

Loans and leases, net of allowance

All other assets

Total assets of consolidated variable interest entities

Liabilities of consolidated variable interest entities included in total liabilities above

Short-term borrowings

Long-term debt (includes $10,943 and $9,872 of non-recourse debt)

All other liabilities (includes $27 and $34 of non-recourse liabilities)

Total liabilities of consolidated variable interest entities

104     Bank of America 2018

See accompanying Notes to Consolidated Financial Statements.

December 31

2018

2017

$

$

$

29,063
148,341
177,404
7,494

261,131

214,348
43,725

238,101
203,652
441,753
946,895
(9,601)
937,294
9,906
68,951
10,367
65,814
116,320
2,354,507

412,587
891,636

14,060
63,193
1,381,476

29,480
127,954
157,434
11,153

212,747

209,358
37,762

315,117
125,013
440,130
936,749
(10,393)
926,356
9,247
68,951
11,430
61,623
135,043
2,281,234

430,650
796,576

14,024
68,295
1,309,545

186,988

176,865

68,220
37,891
20,189

165,078

229,340
2,089,182

81,187
34,300
32,666

152,123

227,402
2,014,088

22,326

22,323

118,896

136,314
(12,211)
265,325
2,354,507

5,798
43,850
(912)
42,938
337

49,073

742

10,944

30

$

$

$

$

138,089

113,816
(7,082)
267,146
2,281,234

6,521
48,929
(1,016)
47,913
1,721

56,155

312

9,873

37

11,716

$

10,222

$

$

$

$

$

$

$

$

 
 
 
 
 
 
 
 
 
Bank of America Corporation and Subsidiaries

Consolidated Statement of Changes in Shareholders’ Equity

(In millions)

Balance, December 31, 2015
Net income
Net change in debt and equity securities
Net change in debit valuation adjustments
Net change in derivatives
Employee benefit plan adjustments
Net change in foreign currency translation adjustments
Dividends declared:

Common
Preferred

Preferred
Stock

$

22,273

Common Stock and
Additional Paid-in Capital

Shares
10,380.3

Amount

$

151,042

$

Retained
Earnings

87,658
17,822

Accumulated
Other
Comprehensive
Income (Loss)

Total
Shareholders’
Equity

$

(5,358) $

(1,345)
(156)
182
(524)
(87)

Issuance of preferred stock
Common stock issued under employee plans, net, and related

2,947

$

25,220

5.1

1,108

(332.8)
10,052.6

$

(5,112)
147,038

$

tax effects

Common stock repurchased
Balance, December 31, 2016
Net income
Net change in debt and equity securities
Net change in debit valuation adjustments
Net change in derivatives
Employee benefit plan adjustments
Net change in foreign currency translation adjustments
Dividends declared:

Common
Preferred

700.0

43.3
(508.6)
10,287.3

$

2,933

932
(12,814)
138,089

Common stock issued in connection with exercise of warrants

and exchange of preferred stock

(2,897)

$

22,323

Common stock issued under employee plans, net, and other
Common stock repurchased
Balance, December 31, 2017
Cumulative adjustment for adoption of hedge accounting

standard

Adoption of accounting standard related to certain tax effects
stranded in accumulated other comprehensive income (loss)

Net income
Net change in debt and equity securities
Net change in debit valuation adjustments
Net change in derivatives
Employee benefit plan adjustments
Net change in foreign currency translation adjustments
Dividends declared:

Common
Preferred

Issuance of preferred stock
Redemption of preferred stock
Common stock issued under employee plans, net, and other
Common stock repurchased
Balance, December 31, 2018

4,515
(4,512)

$

22,326

58.2
(676.2)
9,669.3

$

901
(20,094)
118,896

(2,573)
(1,682)

101,225
18,232

$

(7,288) $

61
(293)
64
288
86

(4,027)
(1,578)

(36)

$

113,816

$

(7,082) $

(32)

57

(1,270)

(3,953)
749
(53)
(405)
(254)

1,270

28,147

(5,424)
(1,451)

(12)

$

136,314

$

(12,211) $

255,615
17,822
(1,345)
(156)
182
(524)
(87)

(2,573)
(1,682)
2,947

1,108

(5,112)
266,195
18,232
61
(293)
64
288
86

(4,027)
(1,578)

—

932
(12,814)
267,146

25

—

28,147
(3,953)
749
(53)
(405)
(254)

(5,424)
(1,451)
4,515
(4,512)
889
(20,094)
265,325

See accompanying Notes to Consolidated Financial Statements.

Bank of America 2018     105 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Bank of America Corporation and Subsidiaries

Consolidated Statement of Cash Flows

(Dollars in millions)
Operating activities
Net income
Adjustments to reconcile net income to net cash provided by operating activities:

Provision for credit losses
Gains on sales of debt securities
Depreciation and premises improvements amortization
Amortization of intangibles
Net amortization of premium/discount on debt securities
Deferred income taxes
Stock-based compensation

Loans held-for-sale:

Originations and purchases
Proceeds from sales and paydowns of loans originally classified as held for sale and instruments 

from related securitization activities

Net change in:

Trading and derivative instruments
Other assets
Accrued expenses and other liabilities

Other operating activities, net

Net cash provided by operating activities

Investing activities
Net change in:

Time deposits placed and other short-term investments
Federal funds sold and securities borrowed or purchased under agreements to resell

Debt securities carried at fair value:

Proceeds from sales
Proceeds from paydowns and maturities
Purchases

Held-to-maturity debt securities:

Proceeds from paydowns and maturities
Purchases

Loans and leases:

Proceeds from sales of loans originally classified as held for investment and instruments 

from related securitization activities

Purchases
Other changes in loans and leases, net

Other investing activities, net

Net cash used in investing activities

Financing activities
Net change in:
Deposits
Federal funds purchased and securities loaned or sold under agreements to repurchase
Short-term borrowings

Long-term debt:

Proceeds from issuance
Retirement
Preferred stock:

Proceeds from issuance
Redemption

Common stock repurchased
Cash dividends paid
Other financing activities, net

Net cash provided by financing activities

Effect of exchange rate changes on cash and cash equivalents
Net increase (decrease) in cash and cash equivalents

Cash and cash equivalents at January 1

Cash and cash equivalents at December 31

Supplemental cash flow disclosures
Interest paid
Income taxes paid, net

2018

2017

2016

$

28,147

$

18,232

$

17,822

3,282
(154)
1,525
538
1,824
3,041
1,729

3,396
(255)
1,482
621
2,251
8,175
1,649

3,597
(490)
1,511
730
3,134
5,793
1,367

(28,071)

(43,506)

(33,107)

28,972

40,548

32,588

(23,673)
11,920
13,010
(2,570)
39,520

3,659
(48,384)

5,117
78,513
(76,640)

18,789
(35,980)

21,365

(4,629)
(31,292)
(1,986)
(71,468)

71,931
10,070
(12,478)

64,278
(53,046)

4,515
(4,512)
(20,094)
(6,895)
(651)
53,118
(1,200)
19,970
157,434
177,404

19,087
2,470

$

$

(14,663)
(20,090)
4,673
7,351
9,864

(1,292)
(14,523)

73,353
93,874
(166,975)

16,653
(25,088)

11,996

(6,846)
(41,104)
8,411
(51,541)

48,611
7,024
8,538

53,486
(49,480)

—
—
(12,814)
(5,700)
(397)
49,268
2,105
9,696
147,738
157,434

12,852
3,235

$

$

(2,635)
(14,103)
(35)
1,105
17,277

(2,117)
(5,742)

71,547
108,592
(189,061)

18,677
(39,899)

18,787

(12,283)
(31,194)
408
(62,285)

63,675
(4,000)
(4,014)

35,537
(51,623)

2,947
—
(5,112)
(4,194)
(63)
33,153
240
(11,615)
159,353
147,738

10,510
1,043

$

$

106     Bank of America 2018

See accompanying Notes to Consolidated Financial Statements.

 
 
 
 
Bank of America Corporation and Subsidiaries
Notes to Consolidated Financial Statements

NOTE 1 Summary of Significant Accounting 
Principles
Bank  of  America  Corporation,  a  bank  holding  company  and  a 
financial holding company, provides a diverse range of financial 
services  and  products  throughout  the  U.S.  and  in  certain 
international markets. The term “the Corporation” as used herein 
may  refer  to  Bank  of  America  Corporation,  individually,  Bank  of 
America Corporation  and its  subsidiaries,  or certain  of  Bank  of 
America Corporation’s subsidiaries or affiliates.

Principles of Consolidation and Basis of Presentation
The Consolidated Financial Statements include the accounts of 
the  Corporation  and  its  majority-owned  subsidiaries  and  those 
variable  interest  entities  (VIEs)  where  the  Corporation  is  the 
primary beneficiary. Intercompany accounts and transactions have 
been eliminated. Results of operations of acquired companies are 
included from the dates of acquisition and for VIEs, from the dates 
that the Corporation became the primary beneficiary. Assets held 
in  an  agency  or  fiduciary  capacity  are  not  included  in  the 
Consolidated Financial Statements. The Corporation accounts for 
investments in companies for which it owns a voting interest and 
for which it has the ability to exercise significant influence over 
operating  and  financing  decisions  using  the  equity  method  of 
accounting. These investments are included in other assets. Equity 
method investments are subject to impairment testing, and the 
Corporation’s proportionate share of income or loss is included in 
other income.

The preparation of the Consolidated Financial Statements in 
conformity  with  accounting  principles  generally  accepted  in  the 
United States of America (GAAP) requires management to make 
estimates  and  assumptions  that  affect  reported  amounts  and 
disclosures.  Realized  results  could  materially  differ  from  those 
estimates and assumptions. Certain prior-period amounts have 
been reclassified to conform to current-period presentation.

New Accounting Standards
Effective January 1, 2018, the Corporation adopted the following 
new accounting standards on a prospective basis.
  Revenue  Recognition  –  The  new  accounting  standard 
addresses  the  recognition  of  revenue  from  contracts  with 
customers.  For  additional 
information,  see  Revenue 
Recognition  Accounting  Policies  in  this  Note,  Note  2  – 
Noninterest  Income  and  Note  23  –  Business  Segment 
Information.

  Hedge Accounting – The new accounting standard simplifies 
and expands the ability to apply hedge accounting to certain 
risk  management  activities.  For  additional  information,  see 
Note 3 – Derivatives.

  Recognition  and  Measurement  of  Financial  Assets  and 
Liabilities  –  The  new  accounting  standard  relates  to  the 
recognition  and  measurement  of  financial  instruments, 
including equity investments. For additional information, see 
Note  4  –  Securities  and  Note  22  –  Fair  Value  of  Financial 
Instruments.

  Tax Effects in Accumulated Other Comprehensive Income – The 
new  accounting  standard  addresses  certain  tax  effects 
stranded in accumulated other comprehensive income (OCI) 
related to the 2017  Tax Cuts  and  Job  Act  (the Tax  Act).  For 
additional  information,  see  Note  14  –  Accumulated  Other 
Comprehensive Income (Loss).

Effective  January  1,  2018,  the  Corporation  adopted  the 
following  new  accounting  standards  on  a  retrospective  basis, 
resulting  in  restatement  of  all  prior  periods  presented  in  the 
Consolidated  Statement  of  Income  and  the  Consolidated 
Statement of Cash Flows. The changes in presentation are not 
material to the individual line items affected.
  Presentation of Pension Costs – The new accounting standard 
requires separate presentation of the service cost component 
of pension expense from all other components of net pension 
benefit/cost in the Consolidated Statement of Income. As a 
result, the service cost component continues to be presented 
in personnel expense while other components of net pension 
benefit/cost (e.g., interest cost, actual return on plan assets, 
amortization of prior service cost) are now presented in other 
general operating expense. For additional information, see Note 
17 – Employee Benefit Plans.

  Classification  of  Cash  Flows  and  Restricted  Cash  –  The  new 
accounting  standards  address  the  classification  of  certain 
cash  receipts  and  cash  payments  in  the  statement  of  cash 
flows as well as the presentation and disclosure of restricted 
cash. For more information on restricted cash, see Note 10 – 
Federal  Funds  Sold  or  Purchased,  Securities  Financing 
Agreements, Short-term Borrowings and Restricted Cash.

Lease Accounting
On January 1, 2019, the Corporation adopted the new accounting 
standards that require lessees to recognize operating leases on 
the Consolidated Balance Sheet as right-of-use assets and lease 
liabilities  based  on  the  value  of  the  discounted  future  lease 
payments.  Lessor  accounting  is  largely  unchanged.  Expanded 
disclosures about the nature and terms of lease agreements will 
be required prospectively. The Corporation elected to apply certain 
transition elections which allow for the continued application of 
the previous determination of whether a contract that existed at 
transition  is  or  contains  a  lease,  the  associated  lease 
classification, and the recognition of leases on January 1, 2019 
through a cumulative-effect adjustment to retained earnings, with 
no  adjustment  to  comparative  prior  periods  presented.  Upon 
adoption, the Corporation recognized right-of-use assets and lease 
liabilities of $9.7 billion. Adoption of the standard did not have a 
significant effect on the Corporation’s regulatory capital measures.

Accounting Standards Issued and Not Yet Adopted

Accounting for Financial Instruments -- Credit Losses
The  Financial  Accounting  Standards  Board  issued  a  new 
accounting standard that will be effective for the Corporation on 
January 1, 2020. The standard replaces the existing measurement 
of the allowance for credit losses that is based on management’s 
best  estimate  of  probable  credit  losses  inherent  in  the 
Corporation’s lending activities with management’s best estimate 
of  lifetime  expected  credit  losses  inherent  in  the  Corporation’s 
financial  assets  that  are  recognized  at  amortized  cost.  The 
standard  will  also  expand  credit  quality  disclosures.  While  the 
standard changes the measurement of the allowance for credit 
losses,  it  does  not  change  the  Corporation’s  credit  risk  of  its 
lending  portfolios.  The  credit  loss  estimation  models  and 
processes  to  be  used  in  implementing  the  new  standard  have 
largely been designed and developed. The validation of the models 
and  testing  of  controls  are  in  process  and  expected  to  be 
completed  during  2019.  Currently,  the  impact  of  this  new 
accounting  standard  may  be  an  increase  in  the  Corporation’s 
allowance for credit losses at the date of adoption which would 
have  a  resulting  negative  adjustment  to  retained  earnings.  The 
ultimate impact will be dependent on the characteristics of the

Bank of America 2018     107 

Corporation’s  portfolio  at  adoption  date  as  well  as  the 
macroeconomic conditions and forecasts as of that date.

Significant Accounting Principles

Cash and Cash Equivalents
Cash and cash equivalents include cash on hand, cash items in 
the process of collection, cash segregated under federal and other 
brokerage  regulations,  and  amounts  due  from  correspondent 
banks,  the  Federal  Reserve  Bank  and  certain  non-U.S.  central 
banks. Certain cash balances are restricted as to withdrawal or 
usage  by  legal  binding  contractual  agreements  or  regulatory 
requirements. 

Securities Financing Agreements
Securities borrowed or purchased under agreements to resell and 
securities  loaned  or  sold  under  agreements  to  repurchase 
(securities  financing  agreements)  are  treated  as  collateralized 
financing transactions except in instances where the transaction 
is required to be accounted for as individual sale and purchase 
transactions.  Generally,  these  agreements  are  recorded  at 
acquisition or sale price plus accrued interest, except for certain 
securities financing agreements that the Corporation accounts for 
under the fair value option. Changes in the fair value of securities 
financing agreements that are accounted for under the fair value 
option are recorded in trading account profits in the Consolidated 
Statement of Income.

The Corporation’s policy is to monitor the market value of the 
principal  amount  loaned  under  resale  agreements  and  obtain 
collateral from or return collateral pledged to counterparties when 
appropriate.  Securities  financing  agreements  do  not  create 
material credit risk due to these collateral provisions; therefore, 
an allowance for loan losses is not necessary.

In transactions where the Corporation acts as the lender in a 
securities lending agreement and receives securities that can be 
pledged  or  sold  as  collateral,  it  recognizes  an  asset  on  the 
Consolidated  Balance  Sheet  at  fair  value,  representing  the 
securities received, and a liability, representing the obligation to 
return those securities.

Collateral
The Corporation accepts securities and loans as collateral that it 
is permitted by contract or practice to sell or repledge. At December 
31, 2018 and 2017, the fair value of this collateral was $599.0 
billion  and  $561.9  billion,  of  which  $508.6  billion  and  $476.1 
billion were sold or repledged. The primary source of this collateral 
is securities borrowed or purchased under agreements to resell. 
The Corporation also pledges company-owned securities and 
loans  as  collateral  in  transactions  that  include  repurchase 
agreements,  securities  loaned,  public  and  trust  deposits,  U.S. 
Treasury  tax  and  loan  notes,  and  short-term  borrowings.  This 
collateral, which in some cases can be sold or repledged by the 
counterparties to the transactions, is parenthetically disclosed on 
the Consolidated Balance Sheet.

In  certain  cases,  the  Corporation  has  transferred  assets  to 
consolidated  VIEs  where  those  restricted  assets  serve  as 
collateral for the interests issued by the VIEs. These assets are 
included  on  the  Consolidated  Balance  Sheet  in  Assets  of 
Consolidated VIEs.

In  addition,  the  Corporation  obtains  collateral  in  connection 
with  its  derivative  contracts.  Required  collateral  levels  vary 
depending on the credit risk rating and the type of counterparty. 
Generally, the Corporation accepts collateral in the form of cash, 
U.S. Treasury securities and other marketable securities. Based 
on  provisions  contained  in  master  netting  agreements,  the 

108     Bank of America 2018

Corporation  nets  cash  collateral  received  against  derivative 
assets.  The  Corporation  also  pledges  collateral  on  its  own 
derivative  positions  which  can  be  applied  against  derivative 
liabilities.

Trading Instruments
Financial instruments utilized in trading activities are carried at 
fair value. Fair value is generally based on quoted market prices 
for the same or similar assets and liabilities. If these market prices 
are not available, fair values are estimated based on dealer quotes, 
pricing  models,  discounted  cash  flow  methodologies,  or  similar 
techniques  where  the  determination  of  fair  value  may  require 
significant management judgment or estimation. Realized gains 
and  losses  are  recorded  on  a  trade-date  basis.  Realized  and 
unrealized  gains  and  losses  are  recognized  in  trading  account 
profits.

include  derivatives 

Derivatives and Hedging Activities
Derivatives are entered into on behalf of customers, for trading or 
to  support  risk  management  activities.  Derivatives  used  in  risk 
management  activities 
that  are  both 
designated  in  qualifying  accounting  hedge  relationships  and 
derivatives used to hedge market risks in relationships that are 
not  designated  in  qualifying  accounting  hedge  relationships 
(referred to as other risk management activities). The Corporation 
manages  interest  rate  and  foreign  currency  exchange  rate 
sensitivity  predominantly  through  the  use  of  derivatives. 
Derivatives utilized by the Corporation include swaps, futures and 
forward settlement contracts, and option contracts.

All derivatives are recorded on the Consolidated Balance Sheet 
at  fair  value,  taking  into  consideration  the  effects  of  legally 
enforceable master netting agreements that allow the Corporation 
to settle positive and negative positions and offset cash collateral 
held with the same counterparty on a net basis. For exchange-
traded contracts, fair value is based on quoted market prices in 
active or inactive markets or is derived from observable market- 
based  pricing  parameters,  similar  to  those  applied  to  over-the-
counter (OTC) derivatives. For non-exchange traded contracts, fair 
value is based on dealer quotes, pricing models, discounted cash 
flow  methodologies  or  similar  techniques 
for  which  the 
determination of fair value may require significant management 
judgment or estimation.

Valuations of derivative assets and liabilities reflect the value 
of the instrument including counterparty credit risk. These values 
also take into account the Corporation’s own credit standing.

Trading Derivatives and Other Risk Management Activities
Derivatives  held  for  trading  purposes  are  included  in  derivative 
assets or derivative liabilities on the Consolidated Balance Sheet 
with changes in fair value included in trading account profits.

Derivatives  used  for  other  risk  management  activities  are 
included in derivative assets or derivative liabilities. Derivatives 
used in other risk management activities have not been designated 
in qualifying accounting hedge relationships because they did not 
qualify or the risk that is being mitigated pertains to an item that 
is  reported  at  fair  value  through  earnings  so  that  the  effect  of 
measuring the derivative instrument and the asset or liability to 
which the risk exposure pertains will offset in the Consolidated 
Statement of Income to the extent effective. The changes in the 
fair  value  of  derivatives  that  serve  to  mitigate  certain  risks 
associated with mortgage servicing rights (MSRs), interest rate 
lock commitments (IRLCs) and first-lien mortgage loans held-for-
sale (LHFS) that are originated by the Corporation are recorded in 
other income. Changes in the fair value of derivatives that serve 
to mitigate interest rate risk and foreign currency risk are included 

in other income. Credit derivatives are also used by the Corporation 
to mitigate the risk associated with various credit exposures. The 
changes in the fair value of these derivatives are included in other 
income.

Derivatives Used For Hedge Accounting Purposes 
(Accounting Hedges)
For  accounting  hedges,  the  Corporation  formally  documents  at 
inception  all  relationships  between  hedging  instruments  and 
hedged  items,  as  well  as  the  risk  management  objectives  and 
strategies for undertaking various accounting hedges. Additionally, 
the Corporation primarily uses regression analysis at the inception 
of  a  hedge  and  for  each  reporting  period  thereafter  to  assess 
whether the derivative used in an accounting hedge transaction is 
expected to be and has been highly effective in offsetting changes 
in  the  fair  value  or  cash  flows  of  a  hedged  item  or  forecasted 
transaction. The Corporation discontinues hedge accounting when 
it  is  determined  that  a  derivative  is  not  expected  to  be  or  has 
ceased to be highly effective as a hedge, and then reflects changes 
in fair value of the derivative in earnings after termination of the 
hedge relationship.

Fair value hedges are used to protect against changes in the 
fair  value  of  the  Corporation’s  assets  and  liabilities  that  are 
attributable to interest rate or foreign exchange volatility. Changes 
in the fair value of derivatives designated as fair value hedges are 
recorded in earnings, together and in the same income statement 
line item with changes in the fair value of the related hedged item. 
If a derivative instrument in a fair value hedge is terminated or the 
hedge  designation  removed,  the  previous  adjustments  to  the 
carrying value of the hedged asset or liability are subsequently 
accounted for in the same manner as other components of the 
carrying value of that asset or liability. For interest-earning assets 
and interest-bearing liabilities, such adjustments are amortized to 
earnings over the remaining life of the respective asset or liability.
Cash flow hedges are used primarily to minimize the variability 
in cash flows of assets and liabilities or forecasted transactions 
caused  by  interest  rate  or  foreign  exchange  rate  fluctuations. 
Changes in the fair value of derivatives used in cash flow hedges 
are recorded in accumulated OCI and are reclassified into the line 
item in the income statement in which the hedged item is recorded 
in the same period the hedged item affects earnings. Components 
of a derivative that are excluded in assessing hedge effectiveness 
are  recorded  in  the  same  income  statement  line  item  as  the 
hedged item.

Net  investment  hedges  are  used  to  manage  the  foreign 
exchange rate sensitivity arising from a net investment in a foreign 
operation.  Changes  in  the  spot  prices  of  derivatives  that  are 
designated as net investment hedges of foreign operations are 
recorded  as  a  component  of  accumulated  OCI.  The  remaining 
components of these derivatives are excluded in assessing hedge 
effectiveness and are recorded in other income.

Securities
Debt securities are reported on the Consolidated Balance Sheet 
at their trade date. Their classification is dependent on the purpose 
for which the securities were acquired. Debt securities purchased 
for use in the Corporation’s trading activities are reported in trading 
account  assets  at  fair  value  with  unrealized  gains  and  losses 
included  in  trading  account  profits.  Substantially  all  other  debt 
securities  purchased  are  used  in  the  Corporation’s  asset  and 
liability  management  (ALM)  activities  and  are  reported  on  the 
Consolidated Balance Sheet as either debt securities carried at 
fair  value  or  as  held-to-maturity  (HTM)  debt  securities.  Debt 
securities carried at fair value are either available-for-sale (AFS) 

securities with unrealized gains and losses net-of-tax included in 
accumulated OCI or carried at fair value with unrealized gains and 
losses reported in other income. HTM debt securities, which are 
certain debt securities that management has the intent and ability 
to hold to maturity, are reported at amortized cost.

The Corporation regularly evaluates each AFS and HTM debt 
security  where  the  value  has  declined  below  amortized  cost  to 
assess whether the decline in fair value is other than temporary. 
In determining whether an impairment is other than temporary, the 
Corporation considers the severity and duration of the decline in 
fair value, the length of time expected for recovery, the financial 
condition of the issuer, and other qualitative factors, as well as 
whether the Corporation either plans to sell the security or it is 
more  likely  than  not  that  it  will  be  required  to  sell  the  security 
before recovery of the amortized cost. For AFS debt securities the 
Corporation intends to hold, an analysis is performed to determine 
how much  of the  decline  in fair  value  is  related  to  the issuer’s 
credit and how much is related to market factors (e.g., interest 
rates). If any of the decline in fair value is due to credit, an other-
than-temporary  impairment  (OTTI)  loss  is  recognized  in  the 
Consolidated Statement of Income for that amount. If any of the 
decline in fair value is related to market factors, that amount is 
recognized in accumulated OCI. In certain instances, the credit 
loss may exceed the total decline in fair value, in which case, the 
difference  is  due  to  market  factors  and  is  recognized  as  an 
unrealized gain in accumulated OCI. If the Corporation intends to 
sell or believes it is more likely than not that it will be required to 
sell the debt security, it is written down to fair value as an OTTI 
loss.

Interest on debt securities, including amortization of premiums 
and  accretion  of  discounts,  is  included  in  interest  income. 
Premiums  and  discounts  are  amortized  or  accreted  to  interest 
income at a constant effective yield over the contractual lives of 
the securities. Realized gains and losses from the sales of debt 
securities are determined using the specific identification method.
Equity securities with readily determinable fair values that are 
not  held  for  trading  purposes  are  carried  at  fair  value  with 
unrealized  gains  and  losses  included  in  other  income.  Equity 
securities that do not have readily determinable fair values are 
held at cost and evaluated for impairment. These securities are 
reported in other assets or time deposits placed and other short-
term investments.

Loans and Leases
Loans, with the exception of loans accounted for under the fair 
value option, are measured at historical cost and reported at their 
outstanding  principal  balances  net  of  any  unearned  income, 
charge-offs, unamortized deferred fees and costs on originated 
loans, and for purchased loans, net of any unamortized premiums 
or discounts. Loan origination fees and certain direct origination 
costs  are  deferred  and  recognized  as  adjustments  to  interest 
income  over  the  lives  of  the  related  loans.  Unearned  income, 
discounts and premiums are amortized to interest income using 
a level yield methodology. The Corporation elects to account for 
certain consumer and commercial loans under the fair value option 
with changes in fair value reported in other income.

Under applicable accounting guidance, for reporting purposes, 
the loan and lease portfolio is categorized by portfolio segment 
and,  within  each  portfolio  segment,  by  class  of  financing 
receivables. A portfolio segment is defined as the level at which 
an entity develops and documents a systematic methodology to 
determine the allowance for credit losses, and a class of financing 
receivables is defined as the level of disaggregation of portfolio 
segments  based  on  the  initial  measurement  attribute,  risk 

Bank of America 2018     109 

characteristics and methods for assessing risk. The Corporation’s 
three portfolio segments are Consumer Real Estate, Credit Card 
and  Other  Consumer,  and  Commercial.  The  classes  within  the 
Consumer Real Estate portfolio segment are residential mortgage 
and home equity. The classes within the Credit Card and Other 
Consumer portfolio segment are U.S. credit card, direct/indirect 
consumer and other consumer. The classes within the Commercial 
portfolio  segment  are  U.S.  commercial,  non-U.S.  commercial, 
commercial real estate, commercial lease financing and U.S. small 
business commercial.

Purchased Credit-impaired Loans
At acquisition, purchased credit-impaired (PCI) loans are recorded 
at fair value with no allowance for credit losses, and accounted 
for  individually  or  aggregated  in  pools  based  on  similar  risk 
characteristics. The expected cash flows in excess of the amount 
paid  for  the  loans  is  referred  to  as  the  accretable  yield  and  is 
recorded as interest income over the remaining estimated life of 
the loan or pool of loans. The excess of the contractual principal 
and  interest  over  the  expected  cash  flows  of  the  PCI  loans  is 
referred to as the nonaccretable difference. If, upon subsequent 
valuation,  the  Corporation  determines  it  is  probable  that  the 
present value of the expected cash flows has decreased, a charge 
to the provision for credit losses is recorded. If it is probable that 
there is a significant increase in the present value of expected 
cash flows, the allowance for credit losses is reduced or, if there 
is no remaining allowance for credit losses related to these PCI 
loans, the accretable yield is increased through a reclassification 
from nonaccretable difference, resulting in a prospective increase 
in  interest  income.  Reclassifications  to  or  from  nonaccretable 
difference can also occur for changes in the estimated lives of the 
PCI loans. If a loan within a PCI pool is sold, foreclosed, forgiven 
or the expectation of any future proceeds is remote, the loan is 
removed  from  the  pool  at  its  proportional  carrying  value.  If  the 
loan’s recovery value is less than its carrying value, the difference 
is first applied against the PCI pool’s nonaccretable difference and 
then against the allowance for credit losses.

Leases
The Corporation provides equipment financing to its customers 
through a variety of lease arrangements. Direct financing leases 
are carried at the aggregate of lease payments receivable plus 
estimated  residual  value  of  the  leased  property  less  unearned 
income. Leveraged leases, which are a form of financing leases, 
are  reported  net  of  non-recourse  debt.  Unearned  income  on 
leveraged  and  direct  financing  leases  is  accreted  to  interest 
income over the lease terms using methods that approximate the 
interest method.

Allowance for Credit Losses
The allowance for credit losses, which includes the allowance for 
loan  and  lease  losses  and  the  reserve  for  unfunded  lending 
commitments,  represents  management’s  estimate  of  probable 
incurred credit losses in the Corporation’s loan and lease portfolio 
excluding  loans  and  unfunded  lending  commitments  accounted 
for  under  the  fair  value  option.  The  allowance  for  credit  losses 
includes  both  quantitative  and  qualitative  components.  The 
qualitative  component  has  a  higher  degree  of  management 
subjectivity,  and  includes  factors  such  as  concentrations, 
economic conditions and other considerations. The allowance for 
loan and lease losses represents the estimated probable credit 
losses  on  funded  consumer  and  commercial  loans  and  leases 
while  the  reserve  for  unfunded  lending  commitments,  including 
standby  letters  of  credit  (SBLCs)  and  binding  unfunded  loan 
commitments,  represents  estimated  probable  credit  losses  on 

110     Bank of America 2018

these  unfunded  credit 
instruments  based  on  utilization 
assumptions.  Lending-related  credit  exposures  deemed  to  be 
uncollectible, excluding loans carried at fair value, are charged off 
against these accounts.

The  Corporation  performs  periodic  and  systematic  detailed 
reviews  of  its  lending  portfolios  to  identify  credit  risks  and  to 
assess the overall collectability of those portfolios. The allowance 
on  certain  homogeneous  consumer  loan  portfolios,  which 
generally  consist  of  consumer  real  estate  loans  within  the 
Consumer  Real  Estate  portfolio  segment  and  credit  card  loans 
within the Credit Card and Other Consumer portfolio segment, is 
based on aggregated portfolio segment evaluations generally by 
product type. Loss forecast models are utilized for these portfolios 
which consider a variety of factors including, but not limited to, 
historical  loss  experience,  estimated  defaults  or  foreclosures 
based on portfolio trends, delinquencies, bankruptcies, economic 
conditions, credit scores and the amount of loss in the event of 
default.

For consumer loans secured by residential real estate, using 
statistical modeling methodologies, the Corporation estimates the 
number  of  loans  that  will  default  based  on  the  individual  loan 
attributes  aggregated  into  pools  of  homogeneous  loans  with 
similar attributes. The attributes that are most significant to the 
probability of default and are used to estimate defaults include 
refreshed loan-to-value (LTV) or, in the case of a subordinated lien, 
refreshed  combined  LTV  (CLTV),  borrower  credit  score,  months 
since origination (referred to as vintage) and geography, all of which 
are further broken down by present collection status (whether the 
loan is current, delinquent, in default or in bankruptcy). The severity 
or loss given default is estimated based on the refreshed LTV for 
first-lien mortgages or CLTV for subordinated liens. The estimates 
are based on the Corporation’s historical experience with the loan 
portfolio,  adjusted  to  reflect  an  assessment  of  environmental 
factors not yet reflected in the historical data underlying the loss 
estimates,  such  as  changes  in  real  estate  values,  local  and 
national  economies,  underwriting  standards  and  the  regulatory 
environment. The probability of default models also incorporate 
recent experience with modification programs including re-defaults 
subsequent  to  modification,  a  loan’s  default  history  prior  to 
modification  and  the  change  in  borrower  payments  post-
modification. On home equity loans where the Corporation holds 
only  a  second-lien  position  and  foreclosure  is  not  the  best 
alternative, the loss severity is estimated at 100 percent.

The allowance on certain commercial loans (except business 
card and certain small business loans) is calculated using loss 
rates delineated by risk rating and product type. Factors considered 
when  assessing  loss  rates  include  the  value  of  the  underlying 
collateral, if applicable, the industry of the obligor, and the obligor’s 
liquidity and other financial indicators along with certain qualitative 
factors. These statistical models are updated regularly for changes 
in economic and business conditions. Included in the analysis of 
consumer  and  commercial  loan  portfolios  are  qualitative 
estimates which are maintained to cover uncertainties that affect 
the Corporation’s estimate of probable losses including domestic 
and global economic uncertainty and large single-name defaults.
For  individually  impaired  loans,  which  include  nonperforming 
commercial loans as well as consumer and commercial loans and 
(TDR), 
leases  modified 
management measures impairment primarily based on the present 
value  of  payments  expected  to  be  received,  discounted  at  the 
loans’  original  effective  contractual  interest  rates.  Credit  card 
loans are discounted at the portfolio average contractual annual 
percentage  rate,  excluding  promotionally  priced  loans,  in  effect 
prior  to  restructuring.  Impaired  loans  and  TDRs  may  also  be 

in  a  troubled  debt  restructuring 

measured based on observable market prices, or for loans that 
are solely dependent on the collateral for repayment, the estimated 
fair  value  of  the  collateral  less  costs  to  sell.  If  the  recorded 
investment  in  impaired  loans  exceeds  this  amount,  a  specific 
allowance  is  established  as  part  of  the  allowance  for  loan  and 
lease losses unless these are secured consumer loans that are 
solely dependent on collateral for repayment, in which case the 
amount that exceeds the fair value of the collateral is charged off.
Generally, the Corporation initially estimates the fair value of 
the collateral securing these consumer real estate-secured loans 
using an automated valuation model (AVM). An AVM is a tool that 
estimates  the  value  of  a  property  by  reference  to  market  data 
including sales of comparable properties and price trends specific 
to the Metropolitan Statistical Area in which the property being 
valued is located. In the event that an AVM value is not available, 
the  Corporation  utilizes  publicized  indices  or  if  these  methods 
provide less reliable valuations, the Corporation uses appraisals 
or broker price opinions to estimate the fair value of the collateral. 
While  there  is  inherent  imprecision  in  these  valuations,  the 
Corporation believes that they are representative of the portfolio 
in the aggregate.

In  addition  to  the  allowance  for  loan  and  lease  losses,  the 
Corporation also estimates probable losses related to unfunded 
lending  commitments,  such  as  letters  of  credit,  financial 
guarantees and binding unfunded loan commitments. Unfunded 
lending  commitments  are  subject  to  individual  reviews  and  are 
analyzed  and  segregated  by  risk  according  to the  Corporation’s 
internal risk rating scale. These risk classifications, in conjunction 
with  an  analysis  of  historical  loss  experience,  utilization 
assumptions,  current  economic  conditions,  performance  trends 
within the portfolio and any other pertinent information, result in 
the estimation of the reserve for unfunded lending commitments.
The allowance for credit losses related to the loan and lease 
portfolio is reported separately on the Consolidated Balance Sheet 
whereas  the  reserve  for  unfunded  lending  commitments  is 
reported on the Consolidated Balance Sheet in accrued expenses 
and other liabilities. The provision for credit losses related to the 
loan and lease portfolio and unfunded lending commitments is 
reported in the Consolidated Statement of Income.

Nonperforming Loans and Leases, Charge-offs and 
Delinquencies
Nonperforming  loans  and  leases  generally  include  loans  and 
leases  that  have  been  placed  on  nonaccrual  status.  Loans 
accounted for under the fair value option, PCI loans and LHFS are 
not reported as nonperforming.

In accordance with the Corporation’s policies, consumer real 
estate-secured loans, including residential mortgages and home 
equity  loans,  are  generally  placed  on  nonaccrual  status  and 
classified as nonperforming at 90 days past due unless repayment 
of the loan is insured by the Federal Housing Administration (FHA) 
or through individually insured long-term standby agreements with 
Fannie  Mae  (FNMA)  or  Freddie  Mac  (FHLMC)  (the  fully-insured 
portfolio). Residential mortgage loans in the fully-insured portfolio 
are  not  placed  on  nonaccrual  status  and,  therefore,  are  not 
reported  as  nonperforming.  Junior-lien  home  equity  loans  are 
placed on nonaccrual status and classified as nonperforming when 
the underlying first-lien mortgage loan becomes 90 days past due 
even if the junior-lien loan is current. The outstanding balance of 
real  estate-secured  loans  that  is  in  excess  of  the  estimated 
property value less costs to sell is charged off no later than the 
end of the month in which the loan becomes 180 days past due 
unless the loan is fully insured, or for loans in bankruptcy, within 

60  days  of  receipt  of  notification  of  filing,  with  the  remaining 
balance classified as nonperforming.

Consumer loans secured by personal property, credit card loans 
and other unsecured consumer loans are not placed on nonaccrual 
status  prior  to  charge-off  and,  therefore,  are  not  reported  as 
nonperforming loans, except for certain secured consumer loans, 
including  those  that  have  been  modified  in  a  TDR.  Personal 
property-secured loans (including auto loans) are charged off to 
collateral value no later than the end of the month in which the 
account becomes 120 days past due, or upon repossession of an 
auto  or,  for  loans  in  bankruptcy,  within  60  days  of  receipt  of 
notification of filing. Credit card and other unsecured customer 
loans are charged off no later than the end of the month in which 
the  account  becomes  180  days  past  due,  within  60  days  after 
receipt of notification of death or bankruptcy, or upon confirmation 
of fraud.

Commercial loans and leases, excluding business card loans, 
that are past due 90 days or more as to principal or interest, or 
where reasonable doubt exists as to timely collection, including 
loans  that  are  individually  identified  as  being  impaired,  are 
generally  placed  on  nonaccrual  status  and  classified  as 
nonperforming  unless  well-secured  and  in  the  process  of 
collection.

Business card loans are charged off in the same manner as 
consumer  credit  card  loans.  These  loans  are  not  placed  on 
nonaccrual  status  prior  to  charge-off  and,  therefore,  are  not 
reported  as  nonperforming  loans.  Other  commercial  loans  and 
leases  are  generally  charged  off  when  all  or  a  portion  of  the 
principal amount is determined to be uncollectible.

The entire balance of a consumer loan or commercial loan or 
lease is contractually delinquent if the minimum payment is not 
received  by  the  specified  due  date  on  the  customer’s  billing 
statement. Interest and fees continue to accrue on past due loans 
and leases until the date the loan is placed on nonaccrual status, 
if applicable. Accrued interest receivable is reversed when loans 
and leases are placed on nonaccrual status. Interest collections 
on  nonaccruing  loans  and  leases  for  which  the  ultimate 
collectability  of  principal  is  uncertain  are  applied  as  principal 
reductions;  otherwise,  such  collections  are  credited  to  income 
when received. Loans and leases may be restored to accrual status 
when all principal and interest is current and full repayment of the 
remaining contractual principal and interest is expected.

PCI loans are recorded at fair value at the acquisition date. 
Although  the  PCI  loans  may  be  contractually  delinquent,  the 
Corporation does not classify these loans as nonperforming as 
the loans were written down to fair value at the acquisition date 
and the accretable yield is recognized in interest income over the 
remaining  life  of  the  loan.  In  addition,  reported  net  charge-offs 
exclude write-offs on PCI loans as the fair value already considers 
the estimated credit losses.

Troubled Debt Restructurings
Consumer and commercial loans and leases whose contractual 
terms have been restructured in a manner that grants a concession 
to a borrower experiencing financial difficulties are classified as 
TDRs. Concessions could include a reduction in the interest rate 
to a rate that is below market on the loan, payment extensions, 
forgiveness of principal, forbearance or other actions designed to 
maximize collections. Loans that are carried at fair value, LHFS 
and PCI loans are not classified as TDRs.

Loans and leases whose contractual terms have been modified 
in a TDR and are current at the time of restructuring may remain 
on accrual status if there is demonstrated performance prior to 
the restructuring and payment in full under the restructured terms 

Bank of America 2018     111 

is expected. Otherwise, the loans are placed on nonaccrual status 
and reported as nonperforming, except for fully-insured consumer 
real estate loans, until there is sustained repayment performance 
for a reasonable period, generally six months. If accruing TDRs 
cease  to perform  in  accordance with  their  modified contractual 
terms,  they  are  placed  on  nonaccrual  status  and  reported  as 
nonperforming TDRs.

Secured consumer loans that have been discharged in Chapter 
7 bankruptcy and have not been reaffirmed by the borrower are 
classified as TDRs at the time of discharge. Such loans are placed 
on nonaccrual status and written down to the estimated collateral 
value less costs to sell no later than at the time of discharge. If 
these  loans  are  contractually  current,  interest  collections  are 
generally recorded in interest income on a cash basis. Consumer 
real estate-secured loans for which a binding offer to restructure 
has been extended are also classified as TDRs. Credit card and 
other unsecured consumer loans that have been renegotiated in 
a TDR generally remain on accrual status until the loan is either 
paid in full or charged off, which occurs no later than the end of 
the month in which the loan becomes 180 days past due or, for 
loans that have been placed on a fixed payment plan, 120 days 
past due.

A  loan  that  had  previously  been  modified  in  a  TDR  and  is 
subsequently refinanced under current underwriting standards at 
a market rate with no concessionary terms is accounted for as a 
new loan and is no longer reported as a TDR.

Loans Held-for-sale
Loans  that  are  intended  to  be  sold  in  the  foreseeable  future, 
including residential mortgages, loan syndications, and to a lesser 
degree, commercial real estate, consumer finance and other loans, 
are reported as LHFS and are carried at the lower of aggregate 
cost  or  fair  value.  The  Corporation  accounts  for  certain  LHFS, 
including residential mortgage LHFS, under the fair value option. 
Loan  origination  costs  related  to  LHFS  that  the  Corporation 
accounts  for  under  the  fair  value  option  are  recognized  in 
noninterest  expense  when  incurred.  Loan  origination  costs  for 
LHFS carried at the lower of cost or fair value are capitalized as 
part of the carrying value of the loans and recognized as a reduction 
of noninterest income upon the sale of such loans. LHFS that are 
on  nonaccrual  status  and  are  reported  as  nonperforming,  as 
defined  in  the  policy  herein,  are  reported  separately  from 
nonperforming loans and leases.

Premises and Equipment
Premises  and  equipment  are  carried  at  cost  less  accumulated 
depreciation and amortization. Depreciation and amortization are 
recognized  using  the  straight-line  method  over  the  estimated 
useful lives of the assets. Estimated lives range up to 40 years 
for buildings, up to 12 years for furniture and equipment, and the 
shorter  of  lease  term  or  estimated  useful  life  for  leasehold 
improvements.

Goodwill and Intangible Assets
Goodwill is the purchase premium after adjusting for the fair value 
of net assets acquired. Goodwill is not amortized but is reviewed 
for potential impairment on an annual basis, or when events or 
circumstances indicate a potential impairment, at the reporting 
unit level. A reporting unit is a business segment or one level below 
a business segment. 

The Corporation assesses the fair value of each reporting unit 
against  its  carrying  value,  including  goodwill,  as  measured  by 
allocated equity. For purposes of goodwill impairment testing, the 
Corporation  utilizes  allocated  equity  as  a  proxy  for  the  carrying 
value of its reporting units. Allocated equity in the reporting units 

112     Bank of America 2018

is comprised of allocated capital plus capital for the portion of 
goodwill and intangibles specifically assigned to the reporting unit. 
In performing its goodwill impairment testing, the Corporation 
first assesses qualitative factors to determine whether it is more 
likely than not that the fair value of a reporting unit is less than 
its carrying value. Qualitative factors include, among other things, 
macroeconomic conditions, industry and market considerations, 
financial performance of the respective reporting unit and other 
relevant entity- and reporting-unit specific considerations. 

If the Corporation concludes it is more likely than not that the 
fair  value  of  a  reporting  unit  is  less  than  its  carrying  value,  a 
quantitative  assessment  is  performed.  If  the  fair  value  of  the 
reporting unit exceeds its carrying value, goodwill of the reporting 
unit is considered not impaired; however, if the carrying value of 
the  reporting  unit  exceeds  its  fair  value,  an  additional  step  is 
performed to measure potential impairment.

This step involves calculating an implied fair value of goodwill 
which  is  the  excess  of  the  fair  value  of  the  reporting  unit,  as 
determined in the first step, over the aggregate fair values of the 
assets, liabilities and identifiable intangibles as if the reporting 
unit was being acquired in a business combination. If the implied 
fair value of goodwill exceeds the goodwill assigned to the reporting 
unit, there is no impairment. If the goodwill assigned to a reporting 
unit  exceeds  the  implied  fair  value  of  goodwill,  an  impairment 
charge is recorded for the excess. An impairment loss recognized 
cannot exceed the amount of goodwill assigned to a reporting unit. 
An impairment loss establishes a new basis in the goodwill, and 
subsequent  reversals  of  goodwill  impairment  losses  are  not 
permitted under applicable accounting guidance.

For intangible assets subject to amortization, an impairment 
loss is recognized if the carrying value of the intangible asset is 
not recoverable and exceeds fair value. The carrying value of the 
intangible asset is considered not recoverable if it exceeds the 
sum of the undiscounted cash flows expected to result from the 
use  of  the  asset.  Intangible  assets  deemed  to  have  indefinite 
useful lives are not subject to amortization. An impairment loss 
is recognized if the carrying value of the intangible asset with an 
indefinite life exceeds its fair value.

Variable Interest Entities
A  VIE  is  an  entity  that  lacks  equity  investors  or  whose  equity 
investors do not have a controlling financial interest in the entity 
through their equity investments. The Corporation consolidates a 
VIE if it has both the power to direct the activities of the VIE that 
most significantly impact the VIE’s economic performance and an 
obligation to absorb losses or the right to receive benefits that 
could potentially be significant to the VIE. On a quarterly basis, 
the  Corporation  reassesses  its  involvement  with  the  VIE  and 
evaluates the impact of changes in governing documents and its 
financial interests in the VIE. The consolidation status of the VIEs 
with which the Corporation is involved may change as a result of 
such reassessments.

The  Corporation  primarily  uses  VIEs  for  its  securitization 
activities, in which the Corporation transfers whole loans or debt 
securities into a trust or other vehicle. When the Corporation is 
the servicer of whole loans held in a securitization trust, including 
non-agency residential mortgages, home equity loans, credit cards, 
and other loans, the Corporation has the power to direct the most 
significant activities of the trust. The Corporation generally does 
not have the power to direct the most significant activities of a 
residential mortgage agency trust except in certain circumstances 
in  which  the  Corporation  holds  substantially  all  of  the  issued 
securities and has the unilateral right to liquidate the trust. The 
power  to  direct  the  most  significant  activities  of  a  commercial 

mortgage  securitization  trust  is  typically  held  by  the  special 
servicer  or  by  the  party  holding  specific  subordinate  securities 
which  embody  certain  controlling  rights.  The  Corporation 
consolidates a whole-loan securitization trust if it has the power 
to direct the most significant activities and also holds securities 
issued by the trust or has other contractual arrangements, other 
than  standard  representations  and  warranties,  that  could 
potentially be significant to the trust.

The Corporation may also transfer trading account securities 
and AFS securities into municipal bond or resecuritization trusts. 
The Corporation consolidates a municipal bond or resecuritization 
trust if it has control over the ongoing activities of the trust such 
as the remarketing of the trust’s liabilities or, if there are no ongoing 
activities, sole discretion over the design of the trust, including 
the identification of securities to be transferred in and the structure 
of  securities  to  be  issued,  and  also  retains  securities  or  has 
liquidity or other commitments that could potentially be significant 
to  the  trust.  The  Corporation  does  not  consolidate  a  municipal 
bond or resecuritization trust if one or a limited number of third-
party investors share responsibility for the design of the trust or 
have  control  over  the  significant  activities  of  the  trust  through 
liquidation or other substantive rights.

Other VIEs used by the Corporation include collateralized debt 
obligations  (CDOs),  investment  vehicles  created  on  behalf  of 
customers and other investment vehicles. The Corporation does 
not routinely serve as collateral manager for CDOs and, therefore, 
does not typically have the power to direct the activities that most 
significantly impact the economic performance of a CDO. However, 
following an event of default, if the Corporation is a majority holder 
of senior securities issued by a CDO and acquires the power to 
manage its assets, the Corporation consolidates the CDO.

The Corporation consolidates a customer or other investment 
vehicle  if  it  has  control  over  the  initial  design  of  the  vehicle  or 
manages the assets in the vehicle and also absorbs potentially 
significant gains or losses through an investment in the vehicle, 
derivative contracts or other arrangements. The Corporation does 
not consolidate an investment vehicle if a single investor controlled 
the  initial  design  of  the  vehicle  or  manages  the  assets  in  the 
vehicles or if the Corporation does not have a variable interest 
that could potentially be significant to the vehicle.

Retained interests in securitized assets are initially recorded 
at  fair  value.  In  addition,  the  Corporation  may  invest  in  debt 
securities issued by unconsolidated VIEs. Fair values of these debt 
securities, which are classified as trading account assets, debt 
securities  carried  at  fair  value  or  HTM  securities,  are  based 
primarily on quoted market prices in active or inactive markets. 
Generally, quoted market prices for retained residual interests are 
not  available;  therefore,  the  Corporation  estimates  fair  values 
based on the present value of the associated expected future cash 
flows.

Fair Value
The  Corporation  measures  the  fair  values  of  its  assets  and 
liabilities,  where  applicable,  in  accordance  with  accounting 
guidance that requires an entity to base fair value on exit price. 
Under this guidance, an entity is required to maximize the use of 
observable inputs and minimize the use of unobservable inputs 
in  measuring  fair  value.  A  hierarchy  is  established  which 
categorizes fair value measurements into three levels based on 
the inputs to the valuation technique with the highest priority given 
to  unadjusted  quoted  prices  in  active  markets  and  the  lowest 
priority given to unobservable inputs. The Corporation categorizes 
its fair value measurements of financial instruments based on this 
three-level hierarchy.

Level 1  Unadjusted quoted prices in active markets for identical 
assets or liabilities. Level 1 assets and liabilities include 
debt and equity securities and derivative contracts that 
are  traded  in  an  active  exchange  market,  as  well  as 
certain U.S. Treasury securities that are highly liquid and 
are actively traded in OTC markets.

than  exchange-traded 

Level 2  Observable  inputs  other  than  Level  1  prices,  such  as 
quoted  prices  for  similar  assets  or  liabilities,  quoted 
prices in markets that are not active, or other inputs that 
are  observable  or  can  be  corroborated  by  observable 
market data for substantially the full term of the assets 
or liabilities. Level 2 assets and liabilities include debt 
securities  with  quoted  prices  that  are  traded  less 
frequently 
instruments  and 
derivative contracts where fair value is determined using 
a pricing model with inputs that are observable in the 
market or can be derived principally from or corroborated 
by  observable  market  data.  This  category  generally 
includes U.S. government and agency mortgage-backed 
(MBS) and asset-backed securities (ABS), corporate debt 
securities, derivative contracts, certain loans and LHFS.
Level 3  Unobservable inputs that are supported by little or no 
market activity and that are significant to the overall fair 
value  of  the  assets  or  liabilities.  Level  3  assets  and 
liabilities  include  financial  instruments  for  which  the 
determination  of 
requires  significant 
management judgment or estimation. The fair value for 
such assets and liabilities is generally determined using 
pricing models, discounted cash flow methodologies or 
similar techniques that incorporate the assumptions a 
market  participant  would  use  in  pricing  the  asset  or 
liability.  This  category  generally  includes  retained 
residual  interests  in  securitizations,  consumer  MSRs, 
certain  ABS,  highly  structured,  complex  or  long-dated 
derivative contracts, certain loans and LHFS, IRLCs and 
certain  CDOs  where  independent  pricing  information 
cannot  be  obtained  for  a  significant  portion  of  the 
underlying assets.

fair  value 

Income Taxes
There are two components of income tax expense: current and 
deferred. Current income tax expense reflects taxes to be paid or 
refunded  for  the  current  period.  Deferred  income  tax  expense 
results from changes in deferred tax assets and liabilities between 
periods. These gross deferred tax assets and liabilities represent 
decreases or increases in taxes expected to be paid in the future 
because of future reversals of temporary differences in the bases 
of assets and liabilities as measured by tax laws and their bases 
as reported in the financial statements. Deferred tax assets are 
also  recognized  for  tax  attributes  such  as  net  operating  loss 
carryforwards and tax credit carryforwards. Valuation allowances 
are  recorded  to  reduce  deferred  tax  assets  to  the  amounts 
management concludes are more likely than not to be realized.

Income tax benefits are recognized and measured based upon 
a two-step model: first, a tax position must be more likely than not 
to be sustained based solely on its technical merits in order to be 
recognized, and second, the benefit is measured as the largest 
dollar amount of that position that is more likely than not to be 
sustained upon settlement. The difference between the benefit 
recognized and the tax benefit claimed on a tax return is referred 
to as an unrecognized tax benefit. The Corporation records income 
tax-related interest and penalties, if applicable, within income tax 
expense.

Bank of America 2018     113 

Revenue Recognition
The following summarizes the Corporation’s revenue recognition 
accounting policies for certain noninterest income activities.

the  corresponding  payment  network’s 

Card Income
Card income includes annual, late and over-limit fees as well as 
fees  earned  from  interchange,  cash  advances  and  other 
miscellaneous transactions and is presented net of direct costs. 
Interchange fees are recognized upon settlement of the credit and 
debit card payment transactions and are generally determined on 
a percentage basis for credit cards and fixed rates for debit cards 
based  on 
rates. 
Substantially all card fees are recognized at the transaction date, 
except for certain time-based fees such as annual fees, which are 
recognized over 12 months. Fees charged to cardholders that are 
estimated to be uncollectible are reserved in the allowance for 
loan and lease losses. Included in direct cost are rewards and 
credit  card  partner  payments.  Rewards  paid  to  cardholders  are 
related to points earned by the cardholder that can be redeemed 
for a broad range of rewards including cash, travel and gift cards. 
The  points  to  be  redeemed  are  estimated  based  on  past 
redemption  behavior,  card  product  type,  account  transaction 
activity  and  other  historical  card  performance.  The  liability  is 
reduced as the points are redeemed. The Corporation also makes 
payments  to  credit  card  partners.  The  payments  are  based  on 
revenue-sharing  agreements  that  are  generally  driven  by 
cardholder transactions and partner sales volumes. As part of the 
revenue-sharing agreements, the credit card partner provides the 
Corporation exclusive rights to market to the credit card partner’s 
members or customers on behalf of the Corporation.

Service Charges
Service charges include deposit and lending-related fees. Deposit-
related fees consist of fees earned on consumer and commercial 
deposit  activities  and  are  generally  recognized  when  the 
transactions occur or as the service is performed. Consumer fees 
are  earned  on  consumer  deposit  accounts 
for  account 
maintenance and various transaction-based services, such as ATM 
transactions,  wire  transfer  activities,  check  and  money  order 
processing  and 
transactions. 
Commercial deposit-related fees are from the Corporation’s Global 
Transaction Services business and consist of commercial deposit 
and 
including  account 
maintenance and other services, such as payroll, sweep account 
and  other  cash  management  services.  Lending-related  fees 
generally represent transactional fees earned from certain loan 
commitments, financial guarantees and SBLCs.

treasury  management  services, 

funds/overdraft 

insufficient 

Investment and Brokerage Services
Investment and brokerage services consist of asset management 
and brokerage fees. Asset management fees are earned from the 
management of client assets under advisory agreements or the 
full discretion of the Corporation’s financial advisors (collectively 
referred  to  as  assets  under  management  (AUM)).  Asset 
management fees are earned as a percentage of the client’s AUM 
and generally range from 50 basis points (bps) to 150 bps of the 
AUM.  In  cases  where  a  third  party  is  used  to  obtain  a  client’s 
investment allocation, the fee remitted to the third party is recorded 
net and is not reflected in the transaction price, as the Corporation 
is an agent for those services.

Brokerage fees include income earned from transaction-based 
services that are performed as part of investment management 
services and are based on a fixed price per unit or as a percentage 
of  the  total  transaction  amount.  Brokerage  fees  also  include 
distribution fees and sales commissions that are primarily in the 

114     Bank of America 2018

Global Wealth & Investment Management (GWIM) segment and are 
earned  over  time.  In  addition,  primarily  in  the  Global  Markets 
segment,  brokerage  fees  are  earned  when  the  Corporation  fills 
customer orders to buy or sell various financial products or when 
it acknowledges, affirms, settles and clears transactions and/or 
submits  trade  information  to  the  appropriate  clearing  broker. 
Certain customers pay brokerage, clearing and/or exchange fees 
imposed by relevant regulatory bodies or exchanges in order to 
execute or clear trades. These fees are recorded net and are not 
reflected in the transaction price, as the Corporation is an agent 
for those services.

Investment Banking Income
Investment  banking  income  includes  underwriting  income  and 
financial advisory services income. Underwriting consists of fees 
earned for the placement of a customer’s debt or equity securities. 
The  revenue  is  generally  earned  based  on  a  percentage  of  the 
fixed number of shares or principal placed. Once the number of 
shares or notes is determined and the service is completed, the 
underwriting fees are recognized. The Corporation incurs certain 
out-of-pocket expenses, such as legal costs, in performing these 
services. These expenses are recovered through the revenue the 
Corporation earns from the customer and are included in operating 
expenses. Syndication fees represent fees earned as the agent 
or  lead  lender  responsible  for  structuring,  arranging  and 
administering a loan syndication.

Financial advisory services consist of fees earned for assisting 
customers with transactions related to mergers and acquisitions 
and financial restructurings. Revenue varies depending on the size 
and  number  of  services  performed  for  each  contract  and  is 
generally contingent on successful execution of the transaction. 
Revenue is typically recognized once the transaction is completed 
and all services have been rendered. Additionally, the Corporation 
may  earn  a  fixed  fee  in  merger  and  acquisition  transactions  to 
provide  a  fairness  opinion,  with  the  fees  recognized  when  the 
opinion is delivered to the customer.

Other Revenue Measurement and Recognition Policies
The Corporation did not disclose the value of any open performance 
obligations at December 31, 2018, as its contracts with customers 
generally have a fixed term that is less than one year, an open 
term  with  a  cancellation  period  that  is  less  than  one  year,  or 
provisions that allow the Corporation to recognize revenue at the 
amount it has the right to invoice.

Earnings Per Common Share
Earnings  per  common  share  (EPS)  is  computed  by  dividing  net 
income  allocated  to  common  shareholders  by  the  weighted-
average common shares outstanding, excluding unvested common 
shares subject to repurchase or cancellation. Net income allocated 
to  common  shareholders  is  net  income  adjusted  for  preferred 
stock  dividends  including  dividends  declared,  accretion  of 
discounts on preferred stock including accelerated accretion when 
preferred stock is repaid early, and cumulative dividends related 
to the current dividend period that have not been declared as of 
period  end,  less  income  allocated  to  participating  securities. 
Diluted EPS is computed by dividing income allocated to common 
shareholders plus dividends on dilutive convertible preferred stock 
and preferred stock that can be tendered to exercise warrants, by 
the weighted-average common shares outstanding plus amounts 
representing  the  dilutive  effect  of  stock  options  outstanding, 
restricted  stock,  restricted  stock  units  (RSUs),  outstanding 
warrants  and  the  dilution  resulting  from  the  conversion  of 
convertible preferred stock, if applicable.

Foreign Currency Translation
Assets,  liabilities  and  operations  of  foreign  branches  and 
subsidiaries are recorded based on the functional currency of each 
entity. When the functional currency of a foreign operation is the 
local currency, the assets, liabilities and operations are translated, 
for  consolidation  purposes,  from  the  local  currency  to  the  U.S. 
dollar  reporting  currency  at  period-end  rates  for  assets  and 

liabilities and generally at average rates for results of operations. 
The  resulting  unrealized  gains  and  losses  are  reported  as  a 
component  of  accumulated  OCI,  net-of-tax.  When  the  foreign 
entity’s  functional  currency  is  the  U.S.  dollar,  the  resulting 
remeasurement gains or losses on foreign currency-denominated 
assets or liabilities are included in earnings.

NOTE 2 Noninterest Income
The table below presents the Corporation’s noninterest income disaggregated by revenue source for 2018, 2017 and 2016. For more 
information, see Note 1 – Summary of Significant Accounting Principles. For a disaggregation of noninterest income by business segment 
and All Other, see Note 23 – Business Segment Information. 

(Dollars in millions)

Card income

Interchange fees (1)
Other card income

Total card income

Service charges

Deposit-related fees
Lending-related fees

Total service charges

Investment and brokerage services

Asset management fees
Brokerage fees

Total investment and brokerage services

Investment banking income

Underwriting income
Syndication fees
Financial advisory services

Total investment banking income

Trading account profits
Other income

Total noninterest income

2018

2017

2016

$

$

4,093
1,958
6,051

6,667
1,100
7,767

10,189
3,971
14,160

2,722
1,347
1,258
5,327
8,540
1,970
43,815

$

$

3,942
1,960
5,902

6,708
1,110
7,818

9,310
4,526
13,836

2,821
1,499
1,691
6,011
7,277
1,841
42,685

$

$

3,960
1,891
5,851

6,545
1,093
7,638

8,328
5,021
13,349

2,585
1,388
1,268
5,241
6,902
3,624
42,605

(1)  During 2018, 2017 and 2016, gross interchange fees were $9.5 billion, $8.8 billion and $8.2 billion and are presented net of $5.4 billion, $4.8 billion and $4.2 billion, respectively, of expenses for 

rewards and partner payments.

Bank of America 2018     115 

NOTE 3 Derivatives

Derivative Balances
Derivatives are entered into on behalf of customers, for trading or 
to  support  risk  management  activities.  Derivatives  used  in  risk 
management activities include derivatives that may or may not be 
designated 
relationships. 
Derivatives that are not designated in qualifying hedge accounting 
relationships are referred to as other risk management derivatives. 
For more information on the Corporation’s derivatives and hedging 

in  qualifying  hedge  accounting 

activities,  see  Note  1  –  Summary  of  Significant  Accounting 
Principles.  The  following  tables  present  derivative  instruments 
included on the Consolidated Balance Sheet in derivative assets 
and  liabilities  at  December  31,  2018  and  2017.  Balances  are 
presented on a gross basis, prior to the application of counterparty 
and cash collateral netting. Total derivative assets and liabilities 
are adjusted on an aggregate basis to take into consideration the 
effects of legally enforceable master netting agreements and have 
been reduced by cash collateral received or paid.

Gross Derivative Assets

Gross Derivative Liabilities

December 31, 2018

Trading and
Other Risk
Management
Derivatives

Qualifying
Accounting
Hedges

Contract/
Notional (1)

Total

Trading and
Other Risk
Management
Derivatives

Qualifying
Accounting
Hedges

(Dollars in billions)

Interest rate contracts

Swaps
Futures and forwards
Written options
Purchased options

Foreign exchange contracts

Swaps
Spot, futures and forwards
Written options
Purchased options

Equity contracts

Swaps
Futures and forwards
Written options
Purchased options
Commodity contracts

Swaps
Futures and forwards
Written options
Purchased options
Credit derivatives (2, 3)

Purchased credit derivatives:

Credit default swaps
Total return swaps/options

Written credit derivatives:
Credit default swaps
Total return swaps/options

Gross derivative assets/liabilities

Less: Legally enforceable master netting agreements
Less: Cash collateral received/paid

Total derivative assets/liabilities

$

$ 15,977.9
3,656.6
1,584.9
1,614.0

$

141.0
4.7
—
30.8

38.8
39.8
—
4.6

7.7
2.1
—
36.0

2.7
3.2
—
1.7

5.3
0.4

1,704.8
4,276.0
256.7
240.4

253.6
100.0
597.1
549.4

43.1
51.7
27.5
23.4

408.1
84.5

371.9
87.3

3.2
—
—
—

1.4
0.4
—
—

—
—
—
—

—
—
—
—

—
—

$

$

144.2
4.7
—
30.8

$

138.9
5.0
28.6
—

40.2
40.2
—
4.6

7.7
2.1
—
36.0

2.7
3.2
—
1.7

5.3
0.4

42.2
39.3
5.0
—

8.4
0.3
27.5
—

4.5
0.5
2.2
—

4.9
1.0

2.0
—
—
—

2.3
0.3
—
—

—
—
—
—

—
—
—
—

—
—

Total

$

140.9
5.0
28.6
—

44.5
39.6
5.0
—

8.4
0.3
27.5
—

4.5
0.5
2.2
—

4.9
1.0

4.4
0.6
323.8

$

$

—
—
5.0

$

  $

$

4.4
0.6
328.8
(252.7)
(32.4)
43.7

4.3
0.6
313.2

$

—
—
4.6

$

  $

4.3
0.6
317.8
(252.7)
(27.2)
37.9

(1)  Represents the total contract/notional amount of derivative assets and liabilities outstanding.
(2)  The net derivative liability and notional amount of written credit derivatives for which the Corporation held purchased credit derivatives with identical underlying referenced names were $185 million

and $342.8 billion at December 31, 2018. 

(3)  Derivative assets and liabilities for credit default swaps (CDS) reflect a central clearing counterparty’s amendments to legally re-characterize daily cash variation margin from collateral, which secures 

an outstanding exposure, to settlement, which discharges an outstanding exposure, effective in 2018.

116     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(Dollars in billions)

Interest rate contracts

Swaps
Futures and forwards
Written options
Purchased options

Foreign exchange contracts

Swaps
Spot, futures and forwards
Written options
Purchased options

Equity contracts

Swaps
Futures and forwards
Written options
Purchased options
Commodity contracts

Swaps
Futures and forwards
Written options
Purchased options
Credit derivatives (2)

Purchased credit derivatives:

Credit default swaps
Total return swaps/options

Written credit derivatives:
Credit default swaps
Total return swaps/options

Gross Derivative Assets

Gross Derivative Liabilities

December 31, 2017

Trading and
Other Risk
Management
Derivatives

Qualifying
Accounting
Hedges

Contract/
Notional (1)

Total

Trading and
Other Risk
Management
Derivatives

Qualifying
Accounting
Hedges

$

$ 15,416.4
4,332.4
1,170.5
1,184.5

$

175.1
0.5
—
37.6

$

$

178.0
0.5
—
37.6

$

172.5
0.5
35.5
—

2.9
—
—
—

2.2
0.7
—
—

—
—
—
—

—
—
—
—

—
—

37.8
39.8
—
4.6

4.8
1.5
—
24.7

1.8
3.5
—
1.4

4.1
0.1

35.6
39.1
—
4.6

4.8
1.5
—
24.7

1.8
3.5
—
1.4

4.1
0.1

2,011.1
3,543.3
291.8
271.9

265.6
106.9
480.8
428.2

46.1
47.1
21.7
22.9

470.9
54.1

448.2
55.2

Total

$

174.2
0.5
35.5
—

38.8
39.9
5.1
—

4.4
0.9
23.9
—

4.6
0.6
1.4
—

11.1
1.3

1.7
—
—
—

2.7
0.8
—
—

—
—
—
—

—
—
—
—

—
—

—
—
5.2

$

  $

3.6
0.2
346.0
(279.2)
(32.5)
34.3

36.1
39.1
5.1
—

4.4
0.9
23.9
—

4.6
0.6
1.4
—

11.1
1.3

3.6
0.2
340.8

$

Gross derivative assets/liabilities

  $

Less: Legally enforceable master netting agreements
Less: Cash collateral received/paid

Total derivative assets/liabilities

10.6
0.8
345.8

$

—
—
5.8

$

  $

10.6
0.8
351.6
(279.2)
(34.6)
37.8

$

(1)  Represents the total contract/notional amount of derivative assets and liabilities outstanding.
(2)  The net derivative asset and notional amount of written credit derivatives for which the Corporation held purchased credit derivatives with identical underlying referenced names were $6.4 billion and 

$435.1 billion at December 31, 2017.

Offsetting of Derivatives
The Corporation enters into International Swaps and Derivatives 
Association,  Inc.  (ISDA)  master  netting  agreements  or  similar 
agreements with substantially all of the Corporation’s derivative 
counterparties. Where legally enforceable, these master netting 
agreements give the Corporation, in the event of default by the 
counterparty, the right to liquidate securities held as collateral and 
to offset receivables and payables with the same counterparty. 
For purposes of the Consolidated Balance Sheet, the Corporation 
offsets derivative assets and liabilities and cash collateral held 
with the same counterparty where it has such a legally enforceable 
master netting agreement.

The following table presents derivative instruments included 
in derivative assets and liabilities on the Consolidated Balance 

Sheet  at  December  31,  2018  and  2017  by  primary  risk  (e.g., 
interest rate risk) and the platform, where applicable, on which 
these  derivatives  are  transacted.  Balances  are  presented  on  a 
gross  basis,  prior  to  the  application  of  counterparty  and  cash 
collateral netting. Total gross derivative assets and liabilities are 
adjusted  on  an  aggregate  basis  to  take  into  consideration  the 
effects  of  legally  enforceable  master  netting  agreements  which 
include  reducing  the  balance  for  counterparty  netting  and  cash 
collateral received or paid.

For  more  information  on  offsetting  of  securities  financing 
agreements,  see  Note  10  –  Federal  Funds  Sold  or  Purchased, 
Securities  Financing  Agreements,  Short-term  Borrowings  and 
Restricted Cash.

Bank of America 2018     117 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Offsetting of Derivatives (1)

(Dollars in billions)

Interest rate contracts
Over-the-counter
Over-the-counter cleared
Foreign exchange contracts

Over-the-counter
Over-the-counter cleared

Equity contracts

Over-the-counter
Exchange-traded
Commodity contracts
Over-the-counter
Exchange-traded

Credit derivatives
Over-the-counter
Over-the-counter cleared

Total gross derivative assets/liabilities, before netting

Over-the-counter
Exchange-traded
Over-the-counter cleared

Less: Legally enforceable master netting agreements and cash collateral received/paid

Over-the-counter
Exchange-traded
Over-the-counter cleared

Derivative assets/liabilities, after netting

Other gross derivative assets/liabilities (2)

Total derivative assets/liabilities

Less: Financial instruments collateral (3)

Derivative 
Assets

Derivative
Liabilities

Derivative 
Assets

Derivative
Liabilities

December 31, 2018

December 31, 2017

$

$

174.2
4.8

$

169.4
4.0

$

211.7
1.9

206.0
1.8

82.5
0.9

24.6
16.1

3.5
1.0

7.7
2.5

292.5
17.1
8.2

86.3
0.9

14.6
15.1

4.5
0.9

8.2
2.3

283.0
16.0
7.2

78.7
0.9

18.3
9.1

2.9
0.7

9.1
6.1

320.7
9.8
8.9

80.8
0.7

16.2
8.5

4.4
0.8

9.6
6.0

317.0
9.3
8.5

(264.4)
(13.5)
(7.2)
32.7
11.0
43.7
(16.3)
27.4

(259.2)
(13.5)
(7.2)
26.3
11.6
37.9
(8.6)
29.3

(296.9)
(8.6)
(8.3)
25.6
12.2
37.8
(11.2)
26.6

(294.6)
(8.6)
(8.5)
23.1
11.2
34.3
(10.4)
23.9

Total net derivative assets/liabilities
(1)  OTC derivatives include bilateral transactions between the Corporation and a particular counterparty. OTC-cleared derivatives include bilateral transactions between the Corporation and a counterparty 

$

$

$

$

where the transaction is cleared through a clearinghouse. Exchange-traded derivatives include listed options transacted on an exchange.

(2)  Consists of derivatives entered into under master netting agreements where the enforceability of these agreements is uncertain under bankruptcy laws in some countries or industries. 
(3)  Amounts are limited to the derivative asset/liability balance and, accordingly, do not include excess collateral received/pledged. Financial instruments collateral includes securities collateral received 
or pledged and cash securities held and posted at third-party custodians that are not offset on the Consolidated Balance Sheet but shown as a reduction to derive net derivative assets and liabilities.

ALM and Risk Management Derivatives
The Corporation’s ALM and risk management activities include the 
use  of  derivatives  to  mitigate  risk  to  the  Corporation  including 
derivatives  designated 
in  qualifying  hedge  accounting 
relationships  and  derivatives  used  in  other  risk  management 
activities. Interest rate, foreign exchange, equity, commodity and 
credit  contracts  are  utilized  in  the  Corporation’s  ALM  and  risk 
management activities.

The  Corporation  maintains  an  overall  interest  rate  risk 
management strategy that incorporates the use of interest rate 
contracts, which are generally non-leveraged generic interest rate 
and  basis  swaps,  options,  futures  and  forwards,  to  minimize 
significant  fluctuations  in  earnings  caused  by  interest  rate 
volatility.  The  Corporation’s  goal  is  to  manage  interest  rate 
sensitivity and volatility so that movements in interest rates do 
not significantly adversely affect earnings or capital. As a result 
of interest rate fluctuations, hedged fixed-rate assets and liabilities 
appreciate  or  depreciate  in  fair  value.  Gains  or  losses  on  the 
derivative  instruments  that  are  linked  to  the  hedged  fixed-rate 
assets  and  liabilities  are  expected  to  substantially  offset  this 
unrealized appreciation or depreciation.

Market risk, including interest rate risk, can be substantial in 
the mortgage business. Market risk in the mortgage business is 
the  risk  that  values  of  mortgage  assets  or  revenues  will  be 
adversely  affected  by  changes  in  market  conditions  such  as 
interest  rate  movements.  To  mitigate  the  interest  rate  risk  in 
mortgage  banking  production  income,  the  Corporation  utilizes 
forward loan sale commitments and other derivative instruments, 
including  purchased  options,  and  certain  debt  securities.  The 

118     Bank of America 2018

Corporation also utilizes derivatives such as interest rate options, 
interest rate swaps, forward settlement contracts and eurodollar 
futures  to  hedge  certain  market  risks  of  MSRs.  For  more 
information on MSRs, see Note 20 – Fair Value Measurements.

The Corporation uses foreign exchange contracts to manage 
the foreign exchange risk associated with certain foreign currency-
denominated assets and liabilities, as well as the Corporation’s 
investments in non-U.S. subsidiaries. Foreign exchange contracts, 
which include spot and forward contracts, represent agreements 
to exchange the currency of one country for the currency of another 
country  at  an  agreed-upon  price  on  an  agreed-upon  settlement 
date. Exposure to loss on these contracts will increase or decrease 
over their respective lives as currency exchange and interest rates 
fluctuate. 

The Corporation purchases credit derivatives to manage credit 
risk  related  to  certain  funded  and  unfunded  credit  exposures. 
Credit derivatives include CDS, total return swaps and swaptions. 
These derivatives are recorded on the Consolidated Balance Sheet 
at fair value with changes in fair value recorded in other income.

Derivatives Designated as Accounting Hedges
The Corporation uses various types of interest rate and foreign 
exchange derivative contracts to protect against changes in the 
fair value of its assets and liabilities due to fluctuations in interest 
rates and exchange rates (fair value hedges). The Corporation also 
uses these types of contracts to protect against changes in the 
cash  flows  of  its  assets  and  liabilities,  and  other  forecasted 
transactions (cash flow hedges). The Corporation hedges its net 
investment  in  consolidated  non-U.S.  operations  determined  to 
have functional currencies other than the U.S. dollar using forward 

 
 
 
 
exchange  contracts  and  cross-currency  basis  swaps,  and  by 
issuing  foreign  currency-denominated  debt  (net  investment 
hedges). 

Fair Value Hedges
The  table  below  summarizes  information  related  to  fair  value 
hedges for 2018, 2017 and 2016.

Gains and Losses on Derivatives Designated as Fair Value Hedges

(Dollars in millions)

2018

Derivative
2017

2016

2018

Hedged Item
2017

2016

Interest rate risk on long-term debt (1)
Interest rate and foreign currency risk on long-term debt (2)
Interest rate risk on available-for-sale securities (3)

646
944
(286)
1,304
(1)  Amounts are recorded in interest expense in the Consolidated Statement of Income. In 2017 and 2016, amounts representing hedge ineffectiveness were losses of $492 million and $842 million.
In 2018, 2017 and 2016, the derivative amount includes losses of $992 million, gains of $2.2 billion and losses of $910 million, respectively, in other income and losses of $116 million, $365 
(2) 
million and $30 million, respectively, in interest expense. Line item totals are in the Consolidated Statement of Income.

(1,537) $
1,811
(67)
207

(1,488) $
(941)
227
(2,202) $

(1,538) $
(1,187)
(52)
(2,777) $

1,429
1,079
50
2,558

1,045
(1,767)
35

(687) $

Total

$

$

$

$

$

$

(3)  Amounts are recorded in interest income in the Consolidated Statement of Income.

The table below summarizes the carrying value of hedged assets and liabilities that are designated and qualifying in fair value 
hedging relationships along with the cumulative amount of fair value hedging adjustments included in the carrying value that have been 
recorded in the current hedging relationships. These fair value hedging adjustments are open basis adjustments that are not subject 
to amortization as long as the hedging relationship remains designated.

Designated Fair Value Hedged Assets (Liabilities)

(Dollars in millions)

Long-term debt
Available-for-sale debt securities
(1)  For assets, increase (decrease) to carrying value and for liabilities, (increase) decrease to carrying value.

December 31, 2018

Carrying Value

Cumulative Fair Value 
Adjustments (1)

$

(138,682) $
981

(2,117)
(29)

At December 31, 2018, the cumulative fair value adjustments 
remaining  on  long-term  debt  and  AFS  debt  securities  from 
discontinued hedging relationships were a decrease to the related 
liability and related asset of $1.6 billion and $29 million, which 
are being amortized over the remaining contractual life of the de-
designated hedged items.

Cash Flow and Net Investment Hedges
The following table summarizes certain information related to cash 
flow hedges and net investment hedges for 2018, 2017 and 2016. 

Of  the  $1.0  billion  after-tax  net  loss  ($1.3  billion  pretax)  on 
derivatives  in  accumulated  OCI  at  December  31,  2018,  $253 
million after-tax ($332 million pretax) is expected to be reclassified 
into earnings in the next 12 months. These net losses reclassified 
into earnings are expected to primarily reduce net interest income 
related to the respective hedged items. For terminated cash flow 
hedges, the time period over which the majority of the forecasted 
transactions are hedged is approximately 4 years, with a maximum 
length of time for certain forecasted transactions of 17 years.

Gains and Losses on Derivatives Designated as Cash Flow and Net Investment Hedges

(Dollars in millions, amounts pretax)

Cash flow hedges

Interest rate risk on variable-rate assets (1)
Price risk on certain restricted stock awards (2)

Total

Net investment hedges

Gains (Losses) Recognized in
Accumulated OCI on Derivatives

Gains (Losses) in Income
Reclassified from Accumulated OCI

2018

2017

2016

2018

2017

2016

$

$

(159) $
4
(155) $

(109) $

59
(50) $

(340) $
41
(299) $

(165) $

27

(138) $

(327) $
148
(179) $

(553)
(32)
(585)

Foreign exchange risk (3) 

(1,588) $
(1)  Amounts reclassified from accumulated OCI are recorded in interest income in the Consolidated Statement of Income.
(2)  Amounts reclassified from accumulated OCI are recorded in personnel expense in the Consolidated Statement of Income.
(3)  Amounts reclassified from accumulated OCI are recorded in other income in the Consolidated Statement of Income. Amounts excluded from effectiveness testing and recognized in other income 

1,782

1,636

$

$

$

3

989

411

$

$

were gains of $47 million, $120 million and $325 million in 2018, 2017 and 2016, respectively.

Bank of America 2018     119 

 
 
Other Risk Management Derivatives
Other risk management derivatives are used by the Corporation 
to reduce certain risk exposures by economically hedging various 
assets and liabilities. The gains and losses on these derivatives 
are recognized in other income. The table below presents gains 
(losses) on these derivatives for 2018, 2017 and 2016. These 
gains (losses) are largely offset by the income or expense that is 
recorded on the hedged item.

Gains and Losses on Other Risk Management Derivatives

(Dollars in millions)

2018

2017

2016

Interest rate risk on mortgage 

activities (1)

Credit risk on loans
Interest rate and foreign currency 

risk on ALM activities (2)

$

(107) $

8

$

9

1,010

(6)

(36)

461

(107)

(754)

(1)  Primarily related to hedges of interest rate risk on MSRs and IRLCs to originate mortgage loans 
that will be held for sale. The net gains on IRLCs, which are not included in the table but are 
considered derivative instruments, were $47 million, $220 million and $533 million for 2018, 
2017 and 2016, respectively.

(2)  Primarily related to hedges of debt securities carried at fair value and hedges of foreign currency-

denominated debt.

Transfers of Financial Assets with Risk Retained 
through Derivatives
The  Corporation  enters  into  certain  transactions  involving  the 
transfer of financial assets that are accounted for as sales where 
substantially  all  of  the  economic  exposure  to  the  transferred 
financial assets is retained through derivatives (e.g., interest rate 
and/or credit), but the Corporation does not retain control over 
the assets transferred. As of December 31, 2018 and 2017, the 
Corporation had transferred $5.8 billion and $6.0 billion of non-
U.S.  government-guaranteed  MBS  to  a  third-party  trust  and 
retained  economic  exposure  to  the  transferred  assets  through 
derivative  contracts.  In  connection  with  these  transfers,  the 
Corporation received gross cash proceeds of $5.8 billion and $6.0 
billion at the transfer dates. At December 31, 2018 and 2017, 
the fair value of the transferred securities was $5.5 billion and 
$6.1 billion. 

Sales and Trading Revenue
The Corporation enters into trading derivatives to facilitate client 
transactions and to manage risk exposures arising from trading 
account  assets  and  liabilities.  It  is  the  Corporation’s  policy  to 
include these derivative instruments in its trading activities which 
include  derivatives  and  non-derivative  cash  instruments.  The 
resulting  risk  from  these  derivatives  is  managed  on  a  portfolio 
basis  as  part  of  the  Corporation’s  Global  Markets  business 
segment. The related sales and trading revenue generated within 
Global Markets is recorded in various income statement line items 
including trading account profits and net interest income as well 
as other revenue categories.

Sales and trading revenue includes changes in the fair value 
and realized gains and losses on the sales of trading and other 
assets, net interest income, and fees primarily from commissions 
on equity securities. Revenue is generated by the difference in the 
client price for an instrument and the price at which the trading 
desk  can  execute  the  trade  in  the  dealer  market.  For  equity 
securities,  commissions  related  to  purchases  and  sales  are 
recorded in the “Other” column in the Sales and Trading Revenue 
table. Changes in the fair value of these securities are included 
in trading account profits. For debt securities, revenue, with the 
exception  of  interest  associated  with  the  debt  securities,  is 
typically included in trading account profits. Unlike commissions 
for equity securities, the initial revenue related to broker-dealer 
services for debt securities is typically included in the pricing of 

120     Bank of America 2018

the instrument  rather  than being  charged  through  separate  fee 
arrangements.  Therefore,  this  revenue  is  recorded  in  trading 
account  profits  as  part  of  the  initial  mark  to  fair  value.  For 
derivatives, the majority of revenue is included in trading account 
profits. In transactions where the Corporation acts as agent, which 
include exchange-traded futures and options, fees are recorded in 
other income.

The  table  below,  which  includes  both  derivatives  and  non-
derivative  cash  instruments,  identifies  the  amounts  in  the 
respective  income  statement  line  items  attributable  to  the 
Corporation’s  sales  and  trading  revenue  in  Global  Markets, 
categorized  by  primary  risk,  for  2018,  2017  and  2016.  The 
difference between total trading account profits in the following 
table  and  in  the  Consolidated  Statement  of  Income  represents 
trading activities in business segments other than Global Markets. 
This table includes debit valuation adjustment (DVA) and funding 
valuation adjustment (FVA) gains (losses). Global Markets results 
in Note 23 – Business Segment Information are presented on a 
fully  taxable-equivalent  (FTE)  basis.  The  table  below  is  not 
presented on an FTE basis.

Sales and Trading Revenue

(Dollars in millions)

Interest rate risk
Foreign exchange risk
Equity risk
Credit risk
Other risk

Total sales and trading

revenue

Interest rate risk
Foreign exchange risk
Equity risk
Credit risk
Other risk

Total sales and trading

revenue

Interest rate risk
Foreign exchange risk
Equity risk
Credit risk
Other risk

Total sales and trading

revenue

Trading
Account
Profits

Net 
Interest
Income

Other (1)

Total

$

$

$

$

$

$

1,180
1,503
3,994
1,063
189

2018

$

1,292
(7)
(781)
1,853
64

$

220
6
1,619
552
66

2,692
1,502
4,832
3,468
319

7,929

$

2,421

$

2,463

$

12,813

$

712
1,417
2,689
1,685
203

2017

$

1,560
(1)
(517)
1,937
45

$

249
7
1,903
576
76

2,521
1,423
4,075
4,198
324

6,706

$

3,024

$

2,811

$ 12,541

$

1,189
1,360
1,917
1,674
407

2016

$

2,002
(10)
28
1,956
(7)

$

145
5
2,074
424
39

3,336
1,355
4,019
4,054
439

$

6,547

$

3,969

$

2,687

$ 13,203

(1)  Represents amounts in investment and brokerage services and other income that are recorded 
in Global Markets and included in the definition of sales and trading revenue. Includes investment 
and brokerage services revenue of $1.7 billion, $2.0 billion and $2.1 billion for 2018, 2017 
and 2016, respectively.

Credit Derivatives
The Corporation enters into credit derivatives primarily to facilitate 
client transactions and to manage credit risk exposures. Credit 
derivatives  derive  value  based  on  an  underlying  third-party 
referenced obligation or a portfolio of referenced obligations and 
generally require the Corporation, as the seller of credit protection, 
to make payments to a buyer upon the occurrence of a predefined 
credit event. Such credit events generally include bankruptcy of 
the referenced credit entity and failure to pay under the obligation, 
as well as acceleration of indebtedness and payment repudiation 
or  moratorium.  For  credit  derivatives  based  on  a  portfolio  of 
referenced credits or credit indices, the Corporation may not be 
required to make payment until a specified amount of loss has 
occurred and/or may only be required to make payment up to a 
specified amount. 

Credit  derivatives  are  classified  as  investment  and  non-
investment  grade  based  on  the  credit  quality  of  the  underlying 
referenced obligation. The Corporation considers ratings of BBB- 
or higher as investment grade. Non-investment grade includes non-
rated  credit  derivative  instruments.  The  Corporation  discloses 

internal categorizations of investment grade and non-investment 
grade consistent with how risk is managed for these instruments.
Credit  derivative  instruments  where  the  Corporation  is  the 
seller of credit protection and their expiration at December 31, 
2018 and 2017 are summarized in the following table.

Credit Derivative Instruments

(Dollars in millions)
Credit default swaps:
Investment grade
Non-investment grade

Total

Total return swaps/options:

Investment grade
Non-investment grade

Total
Total credit derivatives

Credit-related notes:
Investment grade
Non-investment grade

Total credit-related notes

Credit default swaps:
Investment grade
Non-investment grade

Total

Total return swaps/options:

Investment grade
Non-investment grade

Total
Total credit derivatives

Credit default swaps:
Investment grade
Non-investment grade

Total

Total return swaps/options:

Investment grade
Non-investment grade

Total
Total credit derivatives

Credit-related notes:
Investment grade
Non-investment grade

Total credit-related notes

Credit default swaps:
Investment grade
Non-investment grade

Total

Total return swaps/options:

Investment grade
Non-investment grade

Total
Total credit derivatives

$

$

$

$

$

$

$

$

$

$

$

$

Less than
One Year

One to
Three Years

Three to
Five Years
December 31, 2018
Carrying Value

Over Five
Years

Total

2
132
134

105
472
577
711

$

$

— $
1
1

$

53,758
24,297
78,055

60,042
24,524
84,566
162,621

4
203
207

30
150
180
387

$

$

$

$

— $
12
12

$

44
636
680

—
21
21
701

$

$

436
914
1,350

—
—
—
1,350

$

$

$

— $
1
1
$
Maximum Payout/Notional

4
1
5

$

95,699
33,881
129,580

822
1,649
2,471
132,051

$

$

95,274
34,530
129,804

59
39
98
129,902

December 31, 2017
Carrying Value

3
453
456

—
—
—
456

$

$

61
484
545

—
—
—
545

$

$

$

$

$

— $
4
4
$
Maximum Payout/Notional

7
34
41

$

61,388
39,312
100,700

37,394
13,751
51,145
151,845

$

$

115,480
49,843
165,323

2,581
514
3,095
168,418

$

$

107,081
39,098
146,179

—
143
143
146,322

$

$

488
1,691
2,179

—
—
—
2,179

532
1,500
2,032

20,054
14,426
34,480

72
70
142
34,622

245
2,133
2,378

—
3
3
2,381

689
1,548
2,237

21,579
14,420
35,999

143
697
840
36,839

$

$

$

$

$

$

$

$

$

$

$

$

970
3,373
4,343

105
493
598
4,941

536
1,503
2,039

264,785
107,134
371,919

60,995
26,282
87,277
459,196

313
3,273
3,586

30
153
183
3,769

696
1,598
2,294

305,528
142,673
448,201

40,118
15,105
55,223
503,424

The notional amount represents the maximum amount payable 
by  the  Corporation  for  most  credit  derivatives.  However,  the 
Corporation  does  not  monitor  its  exposure  to  credit  derivatives 
based solely on the notional amount because this measure does 
not take into consideration the probability of occurrence. As such, 
the notional amount is not a reliable indicator of the Corporation’s 
exposure to these contracts. Instead, a risk framework is used to 
define risk tolerances and establish limits so that certain credit 
risk-related losses occur within acceptable, predefined limits.

Credit-related notes in the table above include investments in 
securities issued by CDO, collateralized loan obligation (CLO) and 
credit-linked  note  vehicles.  These  instruments  are  primarily 
classified  as  trading  securities.  The  carrying  value  of  these 
instruments equals the Corporation’s maximum exposure to loss. 
The  Corporation  is  not  obligated  to  make  any  payments  to  the 
entities under the terms of the securities owned.

Credit-related Contingent Features and Collateral
The Corporation executes the majority of its derivative contracts 
in the OTC market with large, international financial institutions, 
including broker-dealers and, to a lesser degree, with a variety of 
non-financial  companies. A significant  majority of  the  derivative 
transactions  are  executed  on  a  daily  margin  basis.  Therefore, 
events  such  as  a  credit  rating  downgrade  (depending  on  the 
ultimate rating level) or a breach of credit covenants would typically 
require  an  increase  in  the  amount  of  collateral  required  of  the 
counterparty, where applicable, and/or allow the Corporation to 
take additional protective measures such as early termination of 
all  trades.  Further,  as  previously  discussed  on  page  117,  the 
Corporation  enters  into  legally  enforceable  master  netting 
agreements which reduce risk by permitting closeout and netting 
of transactions with the same counterparty upon the occurrence 
of certain events.

Bank of America 2018     121 

A  majority  of  the  Corporation’s  derivative  contracts  contain 
credit risk-related contingent features, primarily in the form of ISDA 
master netting agreements and credit support documentation that 
enhance the creditworthiness of these instruments compared to 
other  obligations  of  the  respective  counterparty  with  whom  the 
Corporation has transacted. These contingent features may be for 
the benefit of the Corporation as well as its counterparties with 
respect to changes in the Corporation’s creditworthiness and the 
mark-to-market  exposure  under  the  derivative  transactions.  At 
December 31,  2018  and 2017,  the  Corporation  held  cash  and 
securities collateral of $81.6 billion and $77.2 billion, and posted 
cash and securities collateral of $56.5 billion and $59.2 billion in 
the  normal  course  of  business  under  derivative  agreements, 
excluding cross-product margining agreements where clients are 
permitted to margin on a net basis for both derivative and secured 
financing arrangements.

In connection with certain OTC derivative contracts and other 
trading agreements, the Corporation can be required to provide 
additional  collateral  or  to  terminate  transactions  with  certain 
counterparties  in  the  event  of  a  downgrade  of  the  senior  debt 
ratings of the Corporation or certain subsidiaries. The amount of 
additional  collateral  required  depends  on  the  contract  and  is 
usually a fixed incremental amount and/or the market value of the 
exposure. 

At December 31, 2018, the amount of collateral, calculated 
based  on  the  terms  of  the  contracts,  that  the  Corporation  and 
certain subsidiaries could be required to post to counterparties 
but had not yet posted to counterparties was $1.8 billion, including 
$1.0 billion for Bank of America, National Association (Bank of 
America, N.A. or BANA). 

Some  counterparties  are  currently  able  to  unilaterally 
terminate  certain  contracts,  or  the  Corporation  or  certain 
subsidiaries may be required to take other action such as find a 
suitable  replacement  or  obtain  a  guarantee.  At  December  31, 
2018 and 2017, the liability recorded for these derivative contracts 
was not significant.

The table below presents the amount of additional collateral 
that would have been contractually required by derivative contracts 
and other trading agreements at December 31, 2018 if the rating 
agencies had downgraded their long-term senior debt ratings for 
the Corporation or certain subsidiaries by one incremental notch 
and by an additional second incremental notch.

Additional Collateral Required to be Posted Upon
Downgrade at December 31, 2018

(Dollars in millions)

One 
incremental 
notch

Second
incremental 
notch

Bank of America Corporation
Bank of America, N.A. and subsidiaries (1)

$

$

619
209

347
268

(1) 

Included in Bank of America Corporation collateral requirements in this table.

The following table presents the derivative liabilities that would 
be  subject  to  unilateral  termination  by  counterparties  and  the 
amounts of collateral that would have been contractually required 
at December 31, 2018 if the long-term senior debt ratings for the 
Corporation  or  certain  subsidiaries  had  been  lower  by  one 
incremental notch and by an additional second incremental notch.

122     Bank of America 2018

Derivative Liabilities Subject to Unilateral Termination
Upon Downgrade at December 31, 2018

(Dollars in millions)

Derivative liabilities
Collateral posted

One 
incremental 
notch

Second
incremental 
notch

$

$

13
1

581
305

Valuation Adjustments on Derivatives
The  Corporation  records  credit  risk  valuation  adjustments  on 
derivatives  in  order  to  properly  reflect  the  credit  quality  of  the 
counterparties  and  its  own  credit  quality.  The  Corporation 
calculates  valuation  adjustments  on  derivatives  based  on  a 
modeled expected exposure that incorporates current market risk 
factors.  The  exposure  also  takes  into  consideration  credit 
mitigants  such  as  enforceable  master  netting  agreements  and 
collateral.  CDS  spread  data  is  used  to  estimate  the  default 
probabilities  and  severities  that  are  applied  to  the  exposures. 
Where  no  observable  credit  default  data  is  available  for 
counterparties,  the  Corporation  uses  proxies  and  other  market 
data to estimate default probabilities and severity.

Valuation adjustments on derivatives are affected by changes 
in  market  spreads,  non-credit  related  market  factors  such  as 
interest  rate  and  currency  changes  that  affect  the  expected 
exposure,  and  other 
in  collateral 
arrangements and partial payments. Credit spreads and non-credit 
factors can move independently. For example, for an interest rate 
swap,  changes  in  interest  rates  may  increase  the  expected 
exposure, which would increase the counterparty credit valuation 
adjustment (CVA). Independently, counterparty credit spreads may 
tighten, which would result in an offsetting decrease to CVA. 

like  changes 

factors 

The  Corporation  enters  into  risk  management  activities  to 
offset market driven exposures. The Corporation often hedges the 
counterparty spread risk in CVA with CDS. The Corporation hedges 
other market risks in both CVA and DVA primarily with currency and 
interest rate swaps. In certain instances, the net-of-hedge amounts 
in the table below move in the same direction as the gross amount 
or  may  move  in  the  opposite  direction.  This  movement  is  a 
consequence of the complex interaction of the risks being hedged, 
resulting in limitations in the ability to perfectly hedge all of the 
market exposures at all times.

The table below presents CVA, DVA and FVA gains (losses) on 
derivatives,  which  are  recorded  in  trading  account  profits,  on  a 
gross and net of hedge basis for 2018, 2017 and 2016. CVA gains 
reduce the cumulative CVA thereby increasing the derivative assets 
balance.  DVA  gains  increase  the  cumulative  DVA  thereby 
decreasing the derivative liabilities balance. CVA and DVA losses 
have the opposite impact. FVA gains related to derivative assets 
reduce the cumulative FVA thereby increasing the derivative assets 
balance.  FVA  gains  related  to  derivative  liabilities  increase  the 
cumulative  FVA  thereby  decreasing  the  derivative  liabilities 
balance. FVA losses have the opposite impact.

Valuation Adjustments on Derivatives (1) 

Gains (Losses)
(Dollars in millions)
Derivative assets (CVA)
Derivative assets/
liabilities (FVA)

Gross

Net

Gross

Net

Gross

Net

2018
77 $ 187

2017
$ 330 $ 98

$

2016

$ 374

$ 214

(15)

14

160

178

186

102

(141)
Derivative liabilities (DVA)
(1)  At December 31, 2018, 2017 and 2016, cumulative CVA reduced the derivative assets balance 
by  $600  million,  $677  million  and  $1.0  billion,  cumulative  FVA  reduced  the  net  derivatives 
balance  by  $151  million,  $136  million  and  $296  million,  and  cumulative  DVA  reduced  the 
derivative liabilities balance by $432 million, $450 million and $774 million, respectively.

(281)

(324)

24

(19)

(55)

NOTE 4 Securities
The table below presents the amortized cost, gross unrealized gains and losses, and fair value of AFS debt securities, other debt 
securities carried at fair value and HTM debt securities at December 31, 2018 and 2017. 

Debt Securities

(Dollars in millions)

Available-for-sale debt securities
Mortgage-backed securities:

Agency
Agency-collateralized mortgage obligations
Commercial
Non-agency residential (1)

Total mortgage-backed securities

U.S. Treasury and agency securities
Non-U.S. securities
Other taxable securities, substantially all asset-backed securities

Total taxable securities

Tax-exempt securities

Total available-for-sale debt securities

Other debt securities carried at fair value

Total debt securities carried at fair value

Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities (2)

Total debt securities (3, 4)

Available-for-sale debt securities
Mortgage-backed securities:

Amortized
Cost

Gross
Unrealized
Gains

Gross
Unrealized
Losses

December 31, 2018

Fair 
Value

$ 125,116
5,621
14,469
1,792
146,998
56,239
9,307
4,387
216,931
17,349
234,280
8,595
242,875
203,652
$ 446,527

$

$

138
19
11
136
304
62
5
29
400
99
499
172
671
747
1,418

$

$

(3,428) $ 121,826
(110)
5,530
(402)
14,078
1,917
(11)
(3,951)
143,351
(1,378)
54,923
(6)
9,306
(6)
4,410
(5,341)
211,990
17,376
(72)
(5,413)
229,366
8,735
(32)
(5,445)
238,101
(3,964)
200,435
(9,409) $ 438,536

December 31, 2017

$

$

Total taxable securities

Agency
Agency-collateralized mortgage obligations
Commercial
Non-agency residential (1)

Total mortgage-backed securities
U.S. Treasury and agency securities
Non-U.S. securities
Other taxable securities, substantially all asset-backed securities

(1,696) $ 192,929
6,804
(81)
13,684
(208)
2,669
(8)
216,086
(1,993)
53,523
(1,018)
6,677
(1)
5,770
(2)
282,056
(3,014)
20,575
(104)
302,631
(3,118)
12,486
(39)
315,117
(3,157)
(1,825)
123,299
(4,982) $ 438,416
Available-for-sale marketable equity securities (5)
25
(1)  At December 31, 2018 and 2017, the underlying collateral type included approximately 68 percent and 62 percent prime, 4 percent and 13 percent Alt-A, and 28 percent and 25 percent subprime.
(2)  During 2018, the Corporation transferred AFS debt securities with an amortized cost of $64.5 billion to held to maturity.
(3) 

$ 194,119
6,846
13,864
2,410
217,239
54,523
6,669
5,699
284,130
20,541
304,671
12,273
316,944
125,013
$ 441,957
27
$

506
39
28
267
840
18
9
73
940
138
1,078
252
1,330
111
1,441

Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities

Other debt securities carried at fair value

Total debt securities carried at fair value

Total available-for-sale debt securities

Includes securities pledged as collateral of $40.6 billion and $35.8 billion at December 31, 2018 and 2017.

Total debt securities (3, 4)

Tax-exempt securities

$
— $

(2) $

$
$

(4)  The Corporation had debt securities from FNMA and FHLMC that each exceeded 10 percent of shareholders’ equity, with an amortized cost of $161.2 billion and $52.2 billion, and a fair value of 
$158.5 billion and $51.4 billion at December 31, 2018, and an amortized cost of $163.6 billion and $50.3 billion, and a fair value of $162.1 billion and $50.0 billion at December 31, 2017.

(5)  Classified in other assets on the Consolidated Balance Sheet.

At December 31, 2018, the accumulated net unrealized loss 
on  AFS  debt  securities  included  in  accumulated  OCI  was  $3.7 
billion, net of the related income tax benefit of $1.2 billion. The 
Corporation had nonperforming AFS debt securities of $11 million 
and $99 million at December 31, 2018 and 2017.

Effective  January  1,  2018,  the  Corporation  adopted  an 
accounting standard applicable to equity securities. For additional 
information,  see  Note  1  –  Summary  of  Significant  Accounting 
Principles.  At  December  31,  2018,  the  Corporation  held  equity 
securities  at  an  aggregate  fair  value  of  $893  million  and  other 
equity securities, as valued under the measurement alternative, 

at cost of $219 million, both of which are included in other assets. 
At December 31, 2018, the Corporation also held equity securities 
at fair value of $1.2 billion included in time deposits placed and 
other short-term investments.

The  following  table  presents  the  components  of  other  debt 
securities carried at fair value where the changes in fair value are 
reported  in  other  income.  In  2018,  the  Corporation  recorded 
unrealized mark-to-market net losses of $73 million and realized 
net gains of $140 million, and unrealized mark-to-market net gains
of $243 million and realized net losses of $49 million in 2017. 
These amounts exclude hedge results. 

Bank of America 2018     123 

 
 
 
 
 
Other Debt Securities Carried at Fair Value

(Dollars in millions)

Mortgage-backed securities
U.S. Treasury and agency securities
Non-U.S. securities (1)
Other taxable securities, substantially all

asset-backed securities

$

December 31

2018

2017

$

1,606
1,282
5,844

3

2,769
—
9,488

229

(Dollars in millions)

Gross gains
Gross losses

Total

$

8,735

$

12,486

(1)  These  securities  are  primarily  used  to  satisfy  certain  international  regulatory  liquidity 

requirements.

Net gains on sales of AFS debt securities

Income tax expense attributable to realized
net gains on sales of AFS debt securities

The  gross  realized  gains  and  losses  on  sales  of  AFS  debt 
securities for 2018, 2017 and 2016 are presented in the table 
below.

Gains and Losses on Sales of AFS Debt Securities

2018

2017

2016

$

$

$

169
(15)
154

37

$

$

$

352
(97)
255

97

$

$

$

520
(30)
490

186

The table below presents the fair value and the associated gross unrealized losses on AFS debt securities and whether these 

securities have had gross unrealized losses for less than 12 months or for 12 months or longer at December 31, 2018 and 2017.

Temporarily Impaired and Other-than-temporarily Impaired AFS Debt Securities

(Dollars in millions)

Temporarily impaired AFS debt securities

Mortgage-backed securities:

Agency
Agency-collateralized mortgage obligations
Commercial
Non-agency residential

Total mortgage-backed securities

U.S. Treasury and agency securities
Non-U.S. securities
Other taxable securities, substantially all asset-backed securities

Total taxable securities

Tax-exempt securities

Total temporarily impaired AFS debt securities
Other-than-temporarily impaired AFS debt securities (1)
Non-agency residential mortgage-backed securities

Total temporarily impaired and other-than-temporarily impaired 

Less than Twelve Months

Twelve Months or Longer

Total

Fair 
Value

Gross
Unrealized
Losses

Fair 
Value

Gross
Unrealized
Losses

Fair 
Value

Gross
Unrealized
Losses

December 31, 2018

$

$

14,771
3
1,344
106
16,224
288
773
183
17,468
232
17,700

$

(49) $
—
(8)
(8)
(65)
(1)
(5)
(1)
(72)
(2)
(74)

99,211
4,452
11,991
49
115,703
51,374
21
185
167,283
2,148
169,431

$

(3,379) $
(110)
(394)
(3)
(3,886)
(1,377)
(1)
(5)
(5,269)
(70)
(5,339)

113,982
4,455
13,335
155
131,927
51,662
794
368
184,751
2,380
187,131

(3,428)
(110)
(402)
(11)
(3,951)
(1,378)
(6)
(6)
(5,341)
(72)
(5,413)

131

—

3

—

134

—

AFS debt securities

$

17,831

$

(74) $

169,434

$

(5,339) $

187,265

$

(5,413)

Temporarily impaired AFS debt securities

Mortgage-backed securities:

Agency
Agency-collateralized mortgage obligations
Commercial
Non-agency residential

Total mortgage-backed securities

U.S. Treasury and agency securities
Non-U.S. securities
Other taxable securities, substantially all asset-backed securities

Total taxable securities

Tax-exempt securities

Total temporarily impaired AFS debt securities
Other-than-temporarily impaired AFS debt securities (1)
Non-agency residential mortgage-backed securities

Total temporarily impaired and other-than-temporarily impaired 

December 31, 2017

$

73,535
2,743
5,575
335
82,188
27,537
772
—
110,497
1,090
111,587

$

(352) $

(29)
(50)
(7)
(438)
(251)
(1)
—
(690)
(2)
(692)

$

72,612
1,684
4,586
—
78,882
24,035
—
92
103,009
7,100
110,109

$

(1,344) $ 146,147
4,427
10,161
335
161,070
51,572
772
92
213,506
8,190
221,696

(52)
(158)
—
(1,554)
(767)
—
(2)
(2,323)
(102)
(2,425)

(1,696)
(81)
(208)
(7)
(1,992)
(1,018)
(1)
(2)
(3,013)
(104)
(3,117)

58

(1)

—

—

58

(1)

AFS debt securities

$ 111,645

$

(693) $ 110,109

$

(2,425) $ 221,754

$

(3,118)

(1) 

Includes other than temporarily impaired AFS debt securities on which an OTTI loss, primarily related to changes in interest rates, remains in accumulated OCI.

124     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In 2018, 2017 and 2016, the Corporation had $33 million, 
$41  million  and  $19  million,  respectively,  of  credit-related  OTTI 
losses  on  AFS  debt  securities  which  were  recognized  in  other 
income. The amount of noncredit-related OTTI losses recognized 
in OCI was not significant for all periods presented.

The cumulative OTTI credit losses recognized in income on AFS 
debt securities that the Corporation does not intend to sell were 
$120  million,  $274  million  and  $253  million  at  December  31, 
2018, 2017 and 2016, respectively. 

The Corporation estimates the portion of a loss on a security 
that is attributable to credit using a discounted cash flow model 
and estimates the expected cash flows of the underlying collateral 
using  internal  credit,  interest  rate  and  prepayment  risk  models 
that  incorporate  management’s  best  estimate  of  current  key 
assumptions such as default rates, loss severity and prepayment 
rates. Assumptions used for the underlying loans that support the 
MBS can vary widely from loan to loan and are influenced by such 
factors as loan interest rate, geographic location of the borrower, 
borrower  characteristics  and  collateral  type.  Based  on  these 
assumptions, the Corporation then determines how the underlying 
collateral cash flows will be distributed to each MBS issued from 
the  applicable  special  purpose  entity.  Expected  principal  and 
interest  cash  flows  on  an  impaired  AFS  debt  security  are 
discounted using the effective yield of each individual impaired 
AFS debt security.

Significant assumptions used in estimating the expected cash 
flows  for  measuring  credit  losses  on  non-agency  residential 
mortgage-backed securities (RMBS) were as follows at December 
31, 2018.

Significant Assumptions

Range (1)

Weighted
average

10th 
Percentile (2)

90th 
Percentile (2)

Prepayment speed
Loss severity
Life default rate
(1)  Represents the range of inputs/assumptions based upon the underlying collateral.
(2)  The value of a variable below which the indicated percentile of observations will fall.

12.9%
19.8
16.9

3.3%
8.5
1.4

21.5%
36.4
64.4

Annual constant prepayment speed and loss severity rates are 
projected  considering  collateral  characteristics  such  as  LTV, 
creditworthiness  of  borrowers  as  measured  using  Fair  Isaac 
Corporation  (FICO)  scores,  and  geographic  concentrations.  The 
weighted-average severity by collateral type was 16.0 percent for 
prime, 16.6 percent for Alt-A and 25.6 percent for subprime at 
December 31, 2018. Default rates are projected by considering 
collateral  characteristics  including,  but  not  limited to,  LTV,  FICO 
and geographic concentration. Weighted-average life default rates 
by collateral type were 14.7 percent for prime, 16.6 percent for 
Alt-A and 19.1 percent for subprime at December 31, 2018. 

The remaining contractual maturity distribution and yields of 
the  Corporation’s  debt  securities  carried  at  fair  value  and  HTM 
debt securities at December 31, 2018 are summarized in the table 
below. Actual duration and yields may differ as prepayments on 
the  loans  underlying  the  mortgages  or  other  ABS  are  passed 
through to the Corporation.

Maturities of Debt Securities Carried at Fair Value and Held-to-maturity Debt Securities

Due in One
Year or Less

Due after One Year
through Five Years

Due after Five Years
through Ten Years

Due after 
Ten Years

Total

Amount

Yield (1)

Amount

Yield (1)

Amount

Yield (1)

Amount

Yield (1)

Amount

Yield (1)

—% $

2.42% $

1,245

2.39% $123,757

3.34% $125,116

3.33%

—

2.36

—

2.36

1.48

1.88

3.54

1.66
2.59

1.81

3.93

30

10,976

14

12,265

23,159

21

688

36,133
6,162

$ 42,295

$

1,475

2.50

2.53

—

2.51

2.36

4.43

3.48

2.43
2.44

2.43

2.89

(Dollars in millions)
Amortized cost of debt securities carried at fair value

Mortgage-backed securities:

Agency

Agency-collateralized mortgage obligations

Commercial

Non-agency residential

Total mortgage-backed securities

U.S. Treasury and agency securities

Non-U.S. securities

Other taxable securities, substantially all asset-backed

securities

Total taxable securities

Tax-exempt securities

Total amortized cost of debt securities carried at

fair value

Amortized cost of HTM debt securities (2)

Debt securities carried at fair value

Mortgage-backed securities:

Agency
Agency-collateralized mortgage obligations
Commercial
Non-agency residential

Total mortgage-backed securities

U.S. Treasury and agency securities
Non-U.S. securities

Other taxable securities, substantially all asset-backed

securities

Total taxable securities

Tax-exempt securities

Total debt securities carried at fair value

Fair value of HTM debt securities (2)

$

—

—

198

—

198

670

14,318

1,591

16,777
938

$ 17,715

$

657

$

—
—
198
—
198
669
14,315

1,585

16,767

936
$ 17,703

$

657

—

1.78

—

1.78

0.78

1.30

3.34

1.48
2.59

1.54

5.78

114

—

2,467

—

2,581
33,659

682

2,022

38,944

7,526

$ 46,470

$

18

—
2,425
—
2,539
32,694
692

2,043

37,968

7,537
$ 45,505

$

18

$

114

$

1,219
29
10,656
24
11,928
22,821
19

698

35,466

6,184
$ 41,650

$

1,429

3.17

2.52

9.84

3.39

1.83

1.37

3.49

2.85
2.53

2.83

3.24

5,591

828

3,268

133,444

21

121

86

133,672
2,723

$ 136,395

$ 201,502

$120,493
5,501
799
3,499
130,292
21
124

87

130,524

2,719
$ 133,243

$ 198,331

3.17

2.96

9.88

3.49

2.57

6.57

5.59

3.49
2.55

3.47

3.23

5,621
14,469

3,282

148,488
57,509

15,142

4,387

225,526
17,349

$ 242,875

$ 203,652

$121,826
5,530
14,078

3,523
144,957
56,205
15,150

4,413

220,725
17,376
$ 238,101

$ 200,435

(1)  The weighted average yield is computed based on a constant effective interest rate over the contractual life of each security. The average yield considers the contractual coupon and the amortization 

of premiums and accretion of discounts, excluding the effect of related hedging derivatives.

(2)  Substantially all U.S. agency MBS.

Bank of America 2018     125 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTE 5 Outstanding Loans and Leases
The following tables present total outstanding loans and leases and an aging analysis for the Consumer Real Estate, Credit Card and 
Other Consumer, and Commercial portfolio segments, by class of financing receivables, at December 31, 2018 and 2017.

Total
Outstandings

$ 193,695
40,010

14,862
8,276

98,338
91,166
202
446,549

682

447,231

299,277
98,776
60,845
22,534
14,565
495,997

(Dollars in millions)

Consumer real estate

Core portfolio

Residential mortgage
Home equity
Non-core portfolio

Residential mortgage
Home equity

Credit card and other consumer

U.S. credit card
Direct/Indirect consumer (5)
Other consumer (6)
Total consumer

Consumer loans accounted for under the 

fair value option (7)

30-59 Days 
Past Due (1)

60-89 Days 
Past Due (1)

$

1,188
200

$

624
119

577
317
—
3,025

249
85

268
60

418
90
—
1,170

90 Days or
More
Past Due (2)

Total Past
Due 30 
Days
or More

Total 
Current or 
Less Than 
30 Days 
Past Due (3)

Loans
Accounted
for Under
the Fair
Value Option

Purchased
Credit-
impaired (4)

December 31, 2018

$

$

793
387

2,230
672

$ 191,465
39,338

2,012
287

994
40
—
4,513

2,904
466

1,989
447
—
8,708

8,158
6,965

$

3,800
845

96,349
90,719
202
433,196

4,645

  $

682

682

Total consumer loans and leases

3,025

1,170

4,513

8,708

433,196

4,645

Commercial

U.S. commercial
Non-U.S. commercial
Commercial real estate (8)
Commercial lease financing
U.S. small business commercial

Total commercial

Commercial loans accounted for under 

the fair value option (7)

594
1
29
124
83
831

232
49
16
114
54
465

573
—
14
37
96
720

1,399
50
59
275
233
2,016

297,878
98,726
60,786
22,259
14,332
493,981

Total commercial loans and leases
Total loans and leases (9)

831
3,856

$

465
1,635

$

720
5,233

2,016
10,724

$

493,981
$ 927,177

$

$

4,645

$

3,667

3,667
4,349

3,667

499,664
$ 946,895

100.00%
Percentage of outstandings
(1)  Consumer real estate loans 30-59 days past due includes fully-insured loans of $637 million and nonperforming loans of $217 million. Consumer real estate loans 60-89 days past due includes 

97.92%

0.41%

0.55%

0.17%

1.13%

0.46%

0.49%

fully-insured loans of $269 million and nonperforming loans of $146 million.

(2)  Consumer real estate includes fully-insured loans of $1.9 billion.
(3)  Consumer real estate includes $1.8 billion and direct/indirect consumer includes $53 million of nonperforming loans.
(4)  PCI loan amounts are shown gross of the valuation allowance.
(5)  Total outstandings includes auto and specialty lending loans and leases of $50.1 billion, unsecured consumer lending loans of $383 million, U.S. securities-based lending loans of $37.0 billion, 

non-U.S. consumer loans of $2.9 billion and other consumer loans of $746 million.

(6)  Substantially all of other consumer is consumer overdrafts.
(7)  Consumer loans accounted for under the fair value option includes residential mortgage loans of $336 million and home equity loans of $346 million. Commercial loans accounted for under the fair 
value option includes U.S. commercial loans of $2.5 billion and non-U.S. commercial loans of $1.1 billion. For additional information, see Note 20 – Fair Value Measurements and Note 21 – Fair Value 
Option. 

(8)  Total outstandings includes U.S. commercial real estate loans of $56.6 billion and non-U.S. commercial real estate loans of $4.2 billion.
(9)  Total outstandings includes loans and leases pledged as collateral of $36.7 billion. The Corporation also pledged $166.1 billion of loans with no related outstanding borrowings to secure potential 

borrowing capacity with the Federal Reserve Bank and Federal Home Loan Bank (FHLB). 

126     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
$

928

928

27,193
13,499

96,285
96,342
166
454,348

928

455,276

284,836
97,792
58,298
22,116
13,649
476,691

4,782

4,782
5,710

4,782

481,473
$ 936,749

30-59 Days
Past Due (1)

60-89 Days 
Past Due (1)

90 Days or
More
Past Due (2)

Total Past
Due 30
Days
or More

Total 
Current or
Less Than 
30 Days
Past Due (3)

Loans
Accounted 
for Under
the Fair 
Value Option

Purchased
Credit-
impaired (4)

Total
Outstandings

December 31, 2017

$

2,603
796

$ 174,015
43,449

  $ 176,618
44,245

$

$

$

1,242
215

1,028
224

542
330
—
3,581

321
108

468
121

405
104
—
1,527

1,040
473

3,535
572

900
44
—
6,564

5,031
917

1,847
478
—
11,672

14,161
9,866

$

8,001
2,716

94,438
95,864
166
431,959

10,717

(Dollars in millions)

Consumer real estate

Core portfolio

Residential mortgage
Home equity
Non-core portfolio

Residential mortgage
Home equity

Credit card and other consumer

U.S. credit card
Direct/Indirect consumer (5)
Other consumer (6)
Total consumer

Consumer loans accounted for under the 

fair value option (7)

Total consumer loans and leases

3,581

1,527

6,564

11,672

431,959

10,717

Commercial

U.S. commercial
Non-U.S. commercial
Commercial real estate (8)
Commercial lease financing
U.S. small business commercial

Total commercial

Commercial loans accounted for under 

the fair value option (7)

547
52
48
110
95
852

244
1
10
68
45
368

425
3
29
26
88
571

1,216
56
87
204
228
1,791

283,620
97,736
58,211
21,912
13,421
474,900

Total commercial loans and leases
Total loans and leases (9)

852
4,433

$

368
1,895

$

571
7,135

1,791
13,463

$

474,900
$ 906,859

$

$

10,717

$

Percentage of outstandings
100.00%
(1)  Consumer real estate loans 30-59 days past due includes fully-insured loans of $850 million and nonperforming loans of $253 million. Consumer real estate loans 60-89 days past due includes 

96.81%

0.48%

0.76%

1.14%

0.61%

1.44%

0.20%

fully-insured loans of $386 million and nonperforming loans of $195 million.

(2)  Consumer real estate includes fully-insured loans of $3.2 billion.
(3)  Consumer real estate includes $2.3 billion and direct/indirect consumer includes $43 million of nonperforming loans.
(4)  PCI loan amounts are shown gross of the valuation allowance.
(5)  Total outstandings includes auto and specialty lending loans and leases of $52.4 billion, unsecured consumer lending loans of $469 million, U.S. securities-based lending loans of $39.8 billion, 

non-U.S. consumer loans of $3.0 billion and other consumer loans of $684 million.

(6)  Substantially all of other consumer is consumer overdrafts.
(7)  Consumer loans accounted for under the fair value option includes residential mortgage loans of $567 million and home equity loans of $361 million. Commercial loans accounted for under the fair 
value option includes U.S. commercial loans of $2.6 billion and non-U.S. commercial loans of $2.2 billion. For additional information, see Note 20 – Fair Value Measurements and Note 21 – Fair Value 
Option.

(8)  Total outstandings includes U.S. commercial real estate loans of $54.8 billion and non-U.S. commercial real estate loans of $3.5 billion.
(9)  Total outstandings includes loans and leases pledged as collateral of $40.1 billion. The Corporation also pledged $160.3 billion of loans with no related outstanding borrowings to secure potential 

borrowing capacity with the Federal Reserve Bank and FHLB.

The  Corporation  categorizes  consumer  real  estate  loans  as 
core  and  non-core  based  on  loan  and  customer  characteristics 
such  as  origination  date,  product  type,  LTV,  FICO  score  and 
delinquency  status  consistent  with  its  current  consumer  and 
mortgage servicing strategy. Generally, loans that were originated 
after  January  1,  2010,  qualified  under  government-sponsored 
enterprise  (GSE)  underwriting  guidelines,  or  otherwise  met  the 
Corporation’s  underwriting  guidelines  in  place  in  2015  are 
characterized  as  core  loans.  All  other  loans  are  generally 
characterized as non-core loans and represent runoff portfolios. 
The Corporation has entered into long-term credit protection 
agreements with FNMA and FHLMC on loans totaling $6.1 billion 
and $6.3 billion at December 31, 2018 and 2017, providing full 
credit  protection  on  residential  mortgage  loans  that  become 
severely delinquent. All of these loans are individually insured and 
therefore the Corporation does not record an allowance for credit 
losses related to these loans.

During 2018, the Corporation sold $11.6 billion of consumer 
real estate loans compared to $4.0 billion in 2017. In addition to 
recurring loan sales, the 2018 amount includes sales of loans, 
primarily non-core, with a carrying value of $9.6 billion and related 
gains of $731 million recorded in other income in the Consolidated 
Statement of Income. 

Nonperforming Loans and Leases
The  Corporation  classifies  junior-lien  home  equity  loans  as 
nonperforming when the first-lien loan becomes 90 days past due 
even if the junior-lien loan is performing. At December 31, 2018 
and 2017, $221 million and $330 million of such junior-lien home 
equity loans were included in nonperforming loans. 

The  Corporation  classifies  consumer  real  estate  loans  that 
have been discharged in Chapter 7 bankruptcy and not reaffirmed 
by  the  borrower  as  TDRs,  irrespective  of  payment  history  or 
delinquency status, even if the repayment terms for the loan have 
not been otherwise modified. The Corporation continues to have 
a  lien  on  the  underlying  collateral.  At  December  31,  2018, 
nonperforming loans discharged in Chapter 7 bankruptcy with no 
change in repayment terms were $185 million of which $98 million
were current on their contractual payments, while $70 million were 
90  days  or  more  past  due.  Of  the  contractually  current 
nonperforming loans,  63 percent were discharged  in Chapter 7 
bankruptcy over 12 months ago, and 55 percent were discharged 
24 months or more ago. 

Bank of America 2018     127 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
During  2018,  the  Corporation  sold  nonperforming  and  PCI 
consumer real estate loans with a carrying value of $5.3 billion, 
including  $4.4  billion  of  PCI  loans,  compared  to  $1.3  billion, 
including $803 million of PCI loans, in 2017. 

The  table  below  presents  the  Corporation’s  nonperforming 
loans  and  leases  including  nonperforming  TDRs,  and  loans 

accruing past due 90 days or more at December 31, 2018 and 
2017.  Nonperforming  LHFS  are  excluded  from  nonperforming 
loans and leases as they are recorded at either fair value or the 
lower of cost or fair value. For more information on the criteria for 
classification  as  nonperforming,  see  Note  1  –  Summary  of 
Significant Accounting Principles.

Credit Quality

(Dollars in millions)

Consumer real estate

Core portfolio

Residential mortgage (1)
Home equity
Non-core portfolio

Residential mortgage (1)
Home equity

Credit card and other consumer

U.S. credit card
Direct/Indirect consumer
Total consumer

Commercial

Nonperforming Loans 
and Leases

Accruing Past Due
90 Days or More

2018

2017

2018

2017

December 31

$

$

1,010
955

$

1,087
1,079

$

274
—

883
938

n/a
56
3,842

1,389
1,565

n/a
46
5,166

1,610
—

994
38
2,916

417
—

2,813
—

900
40
4,170

U.S. commercial
Non-U.S. commercial
Commercial real estate
Commercial lease financing
U.S. small business commercial

144
3
4
19
75
245
4,415
(1)  Residential mortgage loans in the core and non-core portfolios accruing past due 90 days or more are fully-insured loans. At December 31, 2018 and 2017, residential mortgage includes $1.4 billion
and $2.2 billion of loans on which interest has been curtailed by the FHA and therefore are no longer accruing interest, although principal is still insured, and $498 million and $1.0 billion of loans 
on which interest is still accruing.

814
299
112
24
55
1,304
6,470

Total commercial
Total loans and leases

197
—
4
29
84
314
3,230

794
80
156
18
54
1,102
4,944

$

$

$

$

n/a = not applicable

Credit Quality Indicators
The Corporation monitors credit quality within its Consumer Real 
Estate, Credit Card and Other Consumer, and Commercial portfolio 
segments  based  on  primary  credit  quality  indicators.  For  more 
information on the portfolio segments, see Note 1 – Summary of 
Significant Accounting Principles. Within the Consumer Real Estate 
portfolio  segment,  the  primary  credit  quality  indicators  are 
refreshed LTV and refreshed FICO score. Refreshed LTV measures 
the carrying value of the loan as a percentage of the value of the 
property securing the loan, refreshed quarterly. Home equity loans 
are evaluated using CLTV which measures the carrying value of 
the Corporation’s loan and available line of credit combined with 
any outstanding senior liens against the property as a percentage 
of the value of the property securing the loan, refreshed quarterly. 
FICO score measures the creditworthiness of the borrower based 
on  the  financial  obligations  of  the  borrower  and  the  borrower’s 
credit history. FICO scores are typically refreshed quarterly or more 

frequently. Certain borrowers (e.g., borrowers that have had debts 
discharged in a bankruptcy proceeding) may not have their FICO 
scores  updated.  FICO  scores  are  also  a  primary  credit  quality 
indicator for the Credit Card and Other Consumer portfolio segment 
and  the  business  card  portfolio  within  U.S.  small  business 
commercial. Within the Commercial portfolio segment, loans are 
evaluated  using  the  internal  classifications  of  pass  rated  or 
reservable criticized as the primary credit quality indicators. The 
term reservable criticized refers to those commercial loans that 
are  internally  classified  or  listed  by  the  Corporation  as  Special 
Mention,  Substandard  or  Doubtful,  which  are  asset  quality 
categories defined by regulatory authorities. These assets have 
an elevated level of risk and may have a high probability of default 
or  total  loss.  Pass  rated  refers  to  all  loans  not  considered 
reservable  criticized.  In  addition  to  these  primary  credit  quality 
indicators, the Corporation uses other credit quality indicators for 
certain types of loans.

128     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
The following tables present certain credit quality indicators for the Corporation’s Consumer Real Estate, Credit Card and Other 

Consumer, and Commercial portfolio segments, by class of financing receivables, at December 31, 2018 and 2017.

Consumer Real Estate – Credit Quality Indicators (1) 

(Dollars in millions)

Refreshed LTV (3)

Less than or equal to 90 percent
Greater than 90 percent but less than or equal to 100 percent
Greater than 100 percent

Fully-insured loans (4)

Total consumer real estate

Refreshed FICO score

Less than 620
Greater than or equal to 620 and less than 680
Greater than or equal to 680 and less than 740
Greater than or equal to 740

Fully-insured loans (4)

Total consumer real estate

Core 
Residential
Mortgage (2)

Non-core 
Residential
Mortgage (2)

Residential 
Mortgage 
PCI 

Core Home 
Equity (2)

Non-core 
Home 
Equity (2)

Home 
Equity PCI

December 31, 2018

$

$

$

$

173,911
2,349
817
16,618
193,695

2,125
4,538
23,841
146,573
16,618
193,695

$

$

$

$

6,861
340
349
3,512
11,062

1,264
1,068
1,841
3,377
3,512
11,062

$

$

$

$

$

$

3,411
193
196

3,800

710
651
1,201
1,238

$

$

$

39,246
354
410

40,010

1,064
2,008
7,008
29,930

$

$

$

5,870
603
958

7,431

1,325
1,575
1,968
2,563

$

3,800

$

40,010

$

7,431

$

608
112
125

845

178
145
220
302

845

(1)  Excludes $682 million of loans accounted for under the fair value option.
(2)  Excludes PCI loans. 
(3)  Refreshed LTV percentages for PCI loans are calculated using the carrying value net of the related valuation allowance.
(4)  Credit quality indicators are not reported for fully-insured loans as principal repayment is insured.

Credit Card and Other Consumer – Credit Quality Indicators

(Dollars in millions)

Refreshed FICO score

Less than 620
Greater than or equal to 620 and less than 680
Greater than or equal to 680 and less than 740
Greater than or equal to 740
Other internal credit metrics (1, 2)

Total credit card and other consumer

U.S. Credit
Card

Direct/Indirect
Consumer

Other
Consumer

December 31, 2018

$

$

5,016
12,415
35,781
45,126

$

98,338

$

1,719
3,124
8,921
36,709
40,693
91,166

$
$

202
202

(1)  Other internal credit metrics may include delinquency status, geography or other factors.
(2)  Direct/indirect consumer includes $39.9 billion of securities-based lending which is overcollateralized and therefore has minimal credit risk.

Commercial – Credit Quality Indicators (1)

(Dollars in millions)

Risk ratings
Pass rated
Reservable criticized
Refreshed FICO score (3)

Less than 620
Greater than or equal to 620 and less than 680
Greater than or equal to 680 and less than 740
Greater than or equal to 740
Other internal credit metrics (3, 4)

Total commercial

U.S.
Commercial

Non-U.S.
Commercial

Commercial
Real Estate

December 31, 2018

Commercial
Lease
Financing

U.S. Small
Business
Commercial (2)

$

291,918
7,359

$

97,916
860

$

59,910
935

$

22,168
366

$

$

299,277

$

98,776

$

60,845

$

22,534

$

389
29

264
684
2,072
4,254
6,873
14,565

(1)  Excludes $3.7 billion of loans accounted for under the fair value option.
(2)  U.S. small business commercial includes $731 million of criticized business card and small business loans which are evaluated using refreshed FICO scores or internal credit metrics, including 

delinquency status, rather than risk ratings. At December 31, 2018, 99 percent of the balances where internal credit metrics are used was current or less than 30 days past due.

(3)  Refreshed FICO score and other internal credit metrics are applicable only to the U.S. small business commercial portfolio.
(4)  Other internal credit metrics may include delinquency status, application scores, geography or other factors.

Bank of America 2018     129 

 
 
 
 
 
 
 
 
 
 
 
 
 
Consumer Real Estate – Credit Quality Indicators (1)

(Dollars in millions)

Refreshed LTV (3)

Less than or equal to 90 percent
Greater than 90 percent but less than or equal to 100 percent
Greater than 100 percent

Fully-insured loans (4)

Total consumer real estate

Refreshed FICO score

Less than 620
Greater than or equal to 620 and less than 680
Greater than or equal to 680 and less than 740
Greater than or equal to 740

Fully-insured loans (4)

Total consumer real estate

Core 
Residential
Mortgage (2)

Non-core 
Residential
Mortgage (2)

Residential 
Mortgage 
PCI 

Core Home 
Equity (2)

Non-core 
Home 
Equity (2)

Home 
Equity PCI

December 31, 2017

$

$

$

$

153,669
3,082
1,322
18,545
176,618

2,234
4,531
22,934
128,374
18,545
176,618

$

$

$

$

12,135
850
1,011
5,196
19,192

2,390
2,086
3,519
6,001
5,196
19,192

$

$

$

$

$

$

6,872
559
570

8,001

1,941
1,657
2,396
2,007

$

$

$

43,048
549
648

44,245

1,169
2,371
8,115
32,590

$

$

$

7,944
1,053
1,786

10,783

2,098
2,393
2,723
3,569

1,781
412
523

2,716

452
466
786
1,012

$

8,001

$

44,245

$

10,783

$

2,716

(1)  Excludes $928 million of loans accounted for under the fair value option.
(2)  Excludes PCI loans.
(3)  Refreshed LTV percentages for PCI loans are calculated using the carrying value net of the related valuation allowance.
(4)  Credit quality indicators are not reported for fully-insured loans as principal repayment is insured.

Credit Card and Other Consumer – Credit Quality Indicators

(Dollars in millions)

Refreshed FICO score

Less than 620
Greater than or equal to 620 and less than 680
Greater than or equal to 680 and less than 740
Greater than or equal to 740
Other internal credit metrics (1, 2)

Total credit card and other consumer

U.S. Credit
Card

Direct/Indirect
Consumer

Other
Consumer

December 31, 2017

$

$

4,730
12,422
35,656
43,477

$

96,285

$

2,005
4,064
10,371
36,445
43,457
96,342

$
$

166
166

(1)  Other internal credit metrics may include delinquency status, geography or other factors.
(2)  Direct/indirect consumer includes $42.8 billion of securities-based lending which is overcollateralized and therefore has minimal credit risk. 

Commercial – Credit Quality Indicators (1)

(Dollars in millions)

Risk ratings
Pass rated
Reservable criticized
Refreshed FICO score (3)

Less than 620
Greater than or equal to 620 and less than 680
Greater than or equal to 680 and less than 740
Greater than or equal to 740
Other internal credit metrics (3, 4)

Total commercial

U.S.
Commercial

Non-U.S.
Commercial

Commercial
Real Estate

December 31, 2017

Commercial
Lease
Financing

U.S. Small
Business
Commercial (2)

$

275,904
8,932

$

96,199
1,593

$

57,732
566

$

21,535
581

$

$

284,836

$

97,792

$

58,298

$

22,116

$

322
50

223
625
1,875
3,713
6,841
13,649

(1)  Excludes $4.8 billion of loans accounted for under the fair value option.
(2)  U.S. small business commercial includes $709 million of criticized business card and small business loans which are evaluated using refreshed FICO scores or internal credit metrics, including 

delinquency status, rather than risk ratings. At December 31, 2017, 98 percent of the balances where internal credit metrics are used was current or less than 30 days past due.

(3)  Refreshed FICO score and other internal credit metrics are applicable only to the U.S. small business commercial portfolio.
(4)  Other internal credit metrics may include delinquency status, application scores, geography or other factors.

130     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Impaired Loans and Troubled Debt Restructurings
A loan is considered impaired when, based on current information, 
it  is  probable  that  the  Corporation  will  be  unable  to  collect  all 
amounts due from the borrower in accordance with the contractual 
terms of the loan. For more information, see Note 1 – Summary 
of Significant Accounting Principles.

Consumer Real Estate
Impaired consumer real estate loans within the Consumer Real 
Estate portfolio segment consist entirely of TDRs. Excluding PCI 
loans, most modifications of consumer real estate loans meet the 
definition of TDRs when a binding offer is extended to a borrower. 
Modifications  of  consumer  real  estate  loans  are  done  in 
accordance  with  government  programs  or  the  Corporation’s 
proprietary programs. These modifications are considered to be 
TDRs if concessions have been granted to borrowers experiencing 
financial  difficulties.  Concessions  may  include  reductions  in 
interest rates, capitalization of past due amounts, principal and/
or  interest  forbearance,  payment  extensions,  principal  and/or 
interest forgiveness, or combinations thereof.

Prior  to  permanently  modifying  a  loan,  the  Corporation  may 
enter  into  trial  modifications  with  certain  borrowers  under  both 
government and proprietary programs. Trial modifications generally 
represent a three- to four-month period during which the borrower 
makes monthly payments under the anticipated modified payment 
terms.  Upon  successful  completion  of  the  trial  period,  the 
Corporation and the borrower enter into a permanent modification. 
Binding trial modifications are classified as TDRs when the trial 
offer is made and continue to be classified as TDRs regardless of 
whether the borrower enters into a permanent modification.

Consumer  real  estate  loans  that  have  been  discharged  in 
Chapter 7 bankruptcy with no change in repayment terms and not 
reaffirmed by the borrower of $858 million were included in TDRs 
at December 31, 2018, of which $185 million were classified as 
nonperforming and $344 million were loans fully insured by the 
FHA.  For  more  information  on  loans  discharged  in  Chapter  7 
bankruptcy, see Nonperforming Loans and Leases in this Note.

Consumer real estate TDRs are measured primarily based on 
the net present value of the estimated cash flows discounted at 
the loan’s original effective interest rate. If the carrying value of a 
TDR exceeds this amount, a specific allowance is recorded as a 
component  of  the  allowance  for  loan  and  lease  losses. 

Alternatively, consumer real estate TDRs that are considered to 
be dependent solely on the collateral for repayment (e.g., due to 
the  lack  of  income  verification)  are  measured  based  on  the 
estimated fair value of the collateral and a charge-off is recorded 
if  the  carrying  value  exceeds  the  fair  value  of  the  collateral. 
Consumer real estate loans that reached 180 days past due prior 
to modification had been charged off to their net realizable value, 
less costs to sell, before they were modified as TDRs in accordance 
with established policy. Therefore, modifications of consumer real 
estate loans that are 180 or more days past due as TDRs do not 
have an impact on the allowance for loan and lease losses nor 
are  additional  charge-offs  required  at  the  time  of  modification. 
Subsequent declines in the fair value of the collateral after a loan 
has reached 180 days past due are recorded as charge-offs. Fully-
insured loans are protected against principal loss, and therefore, 
the Corporation does not record an allowance for loan and lease 
losses on the outstanding principal balance, even after they have 
been modified in a TDR.

At December 31, 2018 and 2017, remaining commitments to 
lend additional funds to debtors whose terms have been modified 
in a consumer real estate TDR were not significant. Consumer real 
estate foreclosed properties totaled $244 million and $236 million
at December 31, 2018 and 2017. The carrying value of consumer 
real estate loans, including fully-insured and PCI loans, for which 
formal foreclosure proceedings were in process at December 31, 
2018 was $2.5 billion. During 2018 and 2017, the Corporation 
reclassified $670 million and $815 million of consumer real estate 
loans  to  foreclosed  properties  or,  for  properties  acquired  upon 
foreclosure  of  certain  government-guaranteed  loans  (principally 
FHA-insured  loans),  to  other  assets.  The  reclassifications 
represent non-cash investing activities and, accordingly, are not 
reflected in the Consolidated Statement of Cash Flows.

The  following  table  provides  the  unpaid  principal  balance, 
carrying value and related allowance at December 31, 2018 and 
2017,  and  the  average  carrying  value  and  interest  income 
recognized  in  2018,  2017  and  2016  for  impaired  loans  in  the 
Corporation’s Consumer Real Estate portfolio segment. Certain 
impaired  consumer  real  estate  loans  do  not  have  a  related 
allowance  as  the  current  valuation  of  these  impaired  loans 
exceeded the carrying value, which is net of previously recorded 
charge-offs.

Bank of America 2018     131 

Impaired Loans – Consumer Real Estate

(Dollars in millions)

With no recorded allowance

Residential mortgage
Home equity

With an allowance recorded

Residential mortgage
Home equity

Total (1)

Residential mortgage
Home equity

With no recorded allowance

Residential mortgage
Home equity

With an allowance recorded

Residential mortgage
Home equity

Total (1)

Residential mortgage
Home equity

Unpaid
Principal
Balance

Carrying
Value

Related
Allowance

Unpaid
Principal
Balance

Carrying
Value

Related
Allowance

December 31, 2018

December 31, 2017

$

$

$

$

$

$

$

$

$

5,396
2,948

1,977
812

7,373
3,760

4,268
1,599

1,929
760

6,197
2,359

Average
Carrying
Value

Interest
Income
Recognized (2)

2018

$

$

$

5,424
1,894

2,409
861

7,833
2,755

207
105

91
25

298
130

$

$

$

$

$

$

— $
—

$

$

114
144

114
144

8,856
3,622

2,908
972

11,764
4,594

Average
Carrying
Value

Interest
Income
Recognized (2)

2017

7,737
1,997

3,414
858

11,151
2,855

$

$

$

311
109

123
24

434
133

$

$

$

$

$

$

$

$

$

6,870
1,956

2,828
900

9,698
2,856

—
—

174
174

174
174

Average
Carrying
Value

Interest
Income
Recognized (2)

2016

10,178
1,906

5,067
852

15,245
2,758

$

$

$

360
90

167
24

527
114

(1)  During 2018, previously impaired consumer real estate loans with a carrying value of $2.3 billion were sold.
(2) 

Interest income recognized includes interest accrued and collected on the outstanding balances of accruing impaired loans as well as interest cash collections on nonaccruing impaired loans for 
which the principal is considered collectible.

The table below presents the December 31, 2018, 2017 and 2016 unpaid principal balance, carrying value, and average pre- and 
post-modification interest rates on consumer real estate loans that were modified in TDRs during 2018, 2017 and 2016. The following 
Consumer Real Estate portfolio segment tables include loans that were initially classified as TDRs during the period and also loans 
that had previously been classified as TDRs and were modified again during the period.

Consumer Real Estate – TDRs Entered into During 2018, 2017 and 2016

(Dollars in millions)

Residential mortgage
Home equity

Total

Residential mortgage
Home equity

Total

Residential mortgage
Home equity

Total

Unpaid
Principal
Balance

Carrying
Value

Pre-
Modification
Interest Rate

Post-
Modification 
Interest Rate (1)

774
489
1,263

824
764
1,588

1,130
849
1,979

$

$

$

$

$

$

December 31, 2018

641
358
999

December 31, 2017

712
590
1,302

December 31, 2016

1,017
649
1,666

4.33%
4.46
4.38

4.43%
4.22
4.33

4.73%
3.95
4.40

$

$

$

$

$

$

4.21%
3.74
4.03

4.16%
3.49
3.83

4.16%
2.72
3.54

(1)  The post-modification interest rate reflects the interest rate applicable only to permanently completed modifications, which exclude loans that are in a trial modification period.

132     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The table below presents the December 31, 2018, 2017 and 2016 carrying value for consumer real estate loans that were modified 

in a TDR during 2018, 2017 and 2016, by type of modification.

Consumer Real Estate – Modification Programs

(Dollars in millions)

Modifications under government programs

Contractual interest rate reduction
Principal and/or interest forbearance
Other modifications (1)

Total modifications under government programs

Modifications under proprietary programs

Contractual interest rate reduction
Capitalization of past due amounts
Principal and/or interest forbearance
Other modifications (1)

Total modifications under proprietary programs

Trial modifications
Loans discharged in Chapter 7 bankruptcy (2)

Total modifications

TDRs Entered into During
2017

2018

2016

$

$

19
—
42
61

209
96
51
167
523
285
130
999

$

$

$

59
4
22
85

281
63
38
55
437
569
211
1,302

$

151
13
23
187

235
40
72
75
422
831
226
1,666

(1) 

(2) 

Includes other modifications such as term or payment extensions and repayment plans. During 2018, this included $198 million of modifications that met the definition of a TDR related to the 2017 
hurricanes. These modifications had been written down to their net realizable value less costs to sell or were fully insured as of December 31, 2018.
Includes loans discharged in Chapter 7 bankruptcy with no change in repayment terms that are classified as TDRs.

The table below presents the carrying value of consumer real estate loans that entered into payment default during 2018, 2017
and 2016 that were modified in a TDR during the 12 months preceding payment default. A payment default for consumer real estate 
TDRs is recognized when a borrower has missed three monthly payments (not necessarily consecutively) since modification.

Consumer Real Estate – TDRs Entering Payment Default that were Modified During the Preceding 12 Months

(Dollars in millions)

Modifications under government programs
Modifications under proprietary programs
Loans discharged in Chapter 7 bankruptcy (1)
Trial modifications (2)
Total modifications
Includes loans discharged in Chapter 7 bankruptcy with no change in repayment terms that are classified as TDRs.
Includes trial modification offers to which the customer did not respond.

(1) 

(2) 

2018

2017

2016

39
158
64
107
368

$

$

81
138
116
391
726

$

$

262
196
158
824
1,440

$

$

Credit Card and Other Consumer
Impaired loans within the Credit Card and Other Consumer portfolio 
segment consist entirely of loans that have been modified in TDRs. 
The Corporation seeks to assist customers that are experiencing 
financial difficulty by modifying loans while ensuring compliance 
with federal and local laws and guidelines. Credit card and other 
consumer  loan  modifications  generally  involve  reducing  the 
interest  rate  on  the  account,  placing  the  customer  on  a  fixed 
payment  plan  not  exceeding  60  months  and  canceling  the 
customer’s  available  line  of  credit,  all  of  which  are  considered 
TDRs.  The  Corporation  makes  loan  modifications  directly  with 
borrowers for debt held only by the Corporation (internal programs). 
Additionally,  the  Corporation  makes  loan  modifications  for 

borrowers  working  with  third-party  renegotiation  agencies  that 
provide solutions to customers’ entire unsecured debt structures 
(external  programs).  The  Corporation  classifies  other  secured 
consumer  loans  that  have  been  discharged  in  Chapter  7 
bankruptcy as TDRs which are written down to collateral value and 
placed on nonaccrual status no later than the time of discharge. 
For  more  information  on  the  regulatory  guidance  on  loans 
discharged in Chapter 7 bankruptcy, see Nonperforming Loans and 
Leases in this Note. 

The table below provides the unpaid principal balance, carrying 
value and related allowance at December 31, 2018 and 2017, 
and the average carrying value for 2018, 2017 and 2016 on TDRs 
within the Credit Card and Other Consumer portfolio segment.

Bank of America 2018     133 

Impaired Loans – Credit Card and Other Consumer

(Dollars in millions)

With no recorded allowance
Direct/Indirect consumer
With an allowance recorded

U.S. credit card
Non-U.S. credit card (3)
Direct/Indirect consumer

Total

U.S. credit card
Non-U.S. credit card (3)
Direct/Indirect consumer
Includes accrued interest and fees.

(1) 

Unpaid
Principal
Balance

Carrying
Value (1)

Related
Allowance

Unpaid
Principal
Balance

Carrying
Value (1)

Related
Allowance

Average Carrying Value (2)

December 31, 2018

December 31, 2017

2018

2017

2016

$

$

$

$

$

$

72

522
n/a
—

522
n/a
72

$

$

$

33

533
n/a
—

533
n/a
33

— $

58

$

$

154
n/a
—

154
n/a
—

454
n/a
1

454
n/a
59

$

$

$

$

$

$

28

461
n/a
1

461
n/a
29

— $

30

$

$

125
n/a
—

125
n/a
—

491
n/a
1

491
n/a
31

$

$

$

$

$

$

21

464
47
2

464
47
23

20

556
111
10

556
111
30

(2)  The related interest income recognized, which included interest accrued and collected on the outstanding balances of accruing impaired loans as well as interest cash collections on nonaccruing 

impaired loans for which the principal was considered collectible, was not significant in 2018, 2017 and 2016. 
In 2017, the Corporation sold its non-U.S. consumer credit card business.

(3) 

n/a = not applicable

The table below provides information on the Corporation’s primary modification programs for the Credit Card and Other Consumer 

TDR portfolio at December 31, 2018 and 2017.

Credit Card and Other Consumer – TDRs by Program Type at December 31

(Dollars in millions)

Internal programs
External programs
Other

Total

Percent of balances current or less than 30 days past due

U.S. Credit Card

2018

2017

Direct/Indirect Consumer
2018
2017

Total TDRs by Program Type

2018

2017

$

$

$

$

259
273
1
533

85%

$

$

203
257
1
461

87%

— $
—
33
33
81%

$

$

$

1
—
28
29
88%

$

$

259
273
34
566

85%

204
257
29
490

87%

The table below provides information on the Corporation’s Credit Card and Other Consumer TDR portfolio including the December 
31, 2018, 2017 and 2016 unpaid principal balance, carrying value, and average pre- and post-modification interest rates of loans that 
were modified in TDRs during 2018, 2017 and 2016.

Credit Card and Other Consumer – TDRs Entered into During 2018, 2017 and 2016

Unpaid
Principal
Balance

Carrying 
Value (1)

Pre-
Modification
Interest Rate

Post-
Modification
Interest Rate

$

$

$

$

$

$

278
42
320

203
37
240

163
66
21
250

$

$

$

$

$

$

December 31, 2018

292
23
315

19.49%
5.10
18.45

December 31, 2017

213
22
235

18.47%
4.81
17.17

December 31, 2016

172
75
13
260

17.54%
23.99
3.44
18.73

5.24%
4.95
5.22

5.32%
4.30
5.22

5.47%
0.52
3.29
3.93

(Dollars in millions)

U.S. credit card
Direct/Indirect consumer

Total

U.S. credit card
Direct/Indirect consumer

Total

U.S. credit card
Non-U.S. credit card
Direct/Indirect consumer

Total
Includes accrued interest and fees.

(1) 

134     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Credit  card  and  other  consumer  loans  are  deemed  to  be  in 
payment default during the quarter in which a borrower misses the 
second of two consecutive payments. Payment defaults are one 
of the factors considered when projecting future cash flows in the 
calculation of the allowance for loan and lease losses for impaired 
credit  card  and  other  consumer  loans.  Based  on  historical 
experience, the Corporation estimates that 13 percent of new U.S. 
credit card TDRs and 14 percent of new direct/indirect consumer 
TDRs  may  be  in  payment  default  within  12  months  after 
modification. 

Commercial Loans
Impaired commercial loans include nonperforming loans and TDRs 
(both  performing  and  nonperforming).  Modifications  of  loans  to 
commercial borrowers that are experiencing financial difficulty are 
designed to reduce the Corporation’s loss exposure while providing 
the  borrower  with  an  opportunity  to  work  through  financial 
difficulties,  often  to  avoid  foreclosure  or  bankruptcy.  Each 
modification is unique and reflects the individual circumstances 
of the borrower. Modifications that result in a TDR may include 
extensions of maturity at a concessionary (below market) rate of 
interest,  payment  forbearances  or  other  actions  designed  to 
benefit  the  customer  while  mitigating  the  Corporation’s  risk 
exposure.  Reductions  in  interest  rates  are  rare.  Instead,  the 
interest rates are typically increased, although the increased rate 
may   not   represent   a   market   rate   of   interest.   Infrequently, 

concessions may also include principal forgiveness in connection 
with  foreclosure,  short  sale  or  other  settlement  agreements 
leading to termination or sale of the loan.

At the time of restructuring, the loans are remeasured to reflect 
the  impact,  if  any,  on  projected  cash  flows  resulting  from  the 
modified terms. If there was no forgiveness of principal and the 
interest rate was not decreased, the modification may have little 
or no impact on the allowance established for the loan. If a portion 
of  the  loan  is  deemed  to  be  uncollectible,  a  charge-off  may  be 
recorded  at  the  time  of  restructuring.  Alternatively,  a  charge-off 
may have already been recorded in a previous period such that no 
charge-off  is  required  at  the  time  of  modification.  For  more 
information  on  modifications  for  the  U.S.  small  business 
commercial portfolio, see Credit Card and Other Consumer in this 
Note.

At December 31, 2018 and 2017, remaining commitments to 
lend additional funds to debtors whose terms have been modified 
in a commercial loan TDR were $297 million and $205 million.

The table below provides information on impaired loans in the 
Commercial loan portfolio segment including the unpaid principal 
balance, carrying value and related allowance at December 31, 
2018 and 2017, and the average carrying value for 2018, 2017
and  2016.  Certain  impaired  commercial  loans  do  not  have  a 
related allowance because the valuation of these impaired loans 
exceeded the carrying value, which is net of previously recorded 
charge-offs.

Impaired Loans – Commercial

(Dollars in millions)

With no recorded allowance

U.S. commercial
Non-U.S. commercial
Commercial real estate
Commercial lease financing

With an allowance recorded

U.S. commercial
Non-U.S. commercial
Commercial real estate
Commercial lease financing
U.S. small business commercial (2)

Total

U.S. commercial
Non-U.S. commercial
Commercial real estate
Commercial lease financing
U.S. small business commercial (2)

Unpaid
Principal
Balance

Carrying
Value

Related
Allowance

Unpaid
Principal
Balance

Carrying
Value

Related
Allowance

Average Carrying Value (1)

December 31, 2018

December 31, 2017

2018

2017

2016

$

$

$

$

$

$

638
93
—
—

1,437
155
247
71
83

2,075
248
247
71
83

$

$

$

616
93
—
—

1,270
149
162
71
72

1,886
242
162
71
72

— $
—
—
—

$

$

121
30
16
—
29

121
30
16
—
29

$

$

$

576
14
83
—

1,393
528
133
20
84

1,969
542
216
20
84

$

$

$

571
11
80
—

1,109
507
41
18
70

1,680
518
121
18
70

— $
—
—
—

$

$

98
58
4
3
27

98
58
4
3
27

$

$

$

655
43
44
3

1,162
327
46
42
73

1,817
370
90
45
73

$

$

$

772
46
69
—

1,260
463
73
8
73

2,032
509
142
8
73

787
34
67
—

1,569
409
92
2
87

2,356
443
159
2
87

(1)  The related interest income recognized, which included interest accrued and collected on the outstanding balances of accruing impaired loans as well as interest cash collections on nonaccruing 

impaired loans for which the principal was considered collectible, was not significant in 2018, 2017 and 2016. 
Includes U.S. small business commercial renegotiated TDR loans and related allowance.

(2) 

Bank of America 2018     135 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
million for U.S. commercial and $3 million, $19 million and $34 
million for commercial real estate at December 31, 2018, 2017
and 2016, respectively.

includes 

the  Countrywide 

Purchased Credit-impaired Loans 
The table below shows activity for the accretable yield on PCI loans, 
which 
Financial  Corporation 
(Countrywide) portfolio and loans repurchased in connection with 
the 2013 settlement with FNMA. The amount of accretable yield 
is affected by changes in credit outlooks, including metrics such 
as default rates and loss severities, prepayment speeds, which 
can  change  the  amount  and  period  of  time  over  which  interest 
payments are expected to be received, and the interest rates on 
variable  rate  loans.  The  reclassifications  from  nonaccretable 
difference during 2018 and 2017 were primarily due to an increase 
in  the  expected  principal  and  interest  cash  flows  due  to  lower 
default estimates and the rising interest rate environment.

Rollforward of Accretable Yield

(Dollars in millions)

Accretable yield, January 1, 2017

Accretion
Disposals/transfers
Reclassifications from nonaccretable difference

Accretable yield, December 31, 2017

Accretion
Disposals/transfers
Reclassifications from nonaccretable difference

Accretable yield, December 31, 2018

$

$

3,805
(601)
(634)
219
2,789
(457)
(1,456)
368
1,244

During 2018 and 2017, the Corporation sold PCI loans with a 
carrying  value  of  $4.4  billion  and  $803  million.  For  more 
information  on  PCI  loans,  see  Note  1  –  Summary  of  Significant 
Accounting  Principles  and  for  the  carrying  value  and  valuation 
allowance for PCI loans, see Note 6 – Allowance for Credit Losses.

Loans Held-for-sale
The Corporation had LHFS of $10.4 billion and $11.4 billion at 
December 31, 2018 and 2017. Cash and non-cash proceeds from 
sales and paydowns of loans originally classified as LHFS were 
$29.2 billion, $41.3 billion and $32.6 billion for 2018, 2017 and 
2016, respectively. Cash used for originations and purchases of 
LHFS  totaled  $28.1  billion,  $43.5  billion  and  $33.1  billion  for 
2018, 2017 and 2016, respectively.

The table below presents the December 31, 2018, 2017 and 
2016 unpaid principal balance and carrying value of commercial 
loans that were modified as TDRs during 2018, 2017 and 2016. 
The  table  below  includes  loans  that  were  initially  classified  as 
TDRs during the period and also loans that had previously been 
classified as TDRs and were modified again during the period.

Commercial – TDRs Entered into During 2018, 2017 and
2016

(Dollars in millions)

U.S. commercial
Non-U.S. commercial
Commercial real estate
Commercial lease financing
U.S. small business commercial (1)

Total

U.S. commercial
Non-U.S. commercial
Commercial real estate
Commercial lease financing
U.S. small business commercial (1)

Total

Unpaid
Principal
Balance

Carrying
Value

December 31, 2018

1,154
166
115
68
9
1,512

$

$

1,098
165
115
68
8
1,454

December 31, 2017

1,033
105
35
20
13
1,206

$

$

922
105
24
17
13
1,081

December 31, 2016

$

$

$

$

$

U.S. commercial
Non-U.S. commercial
Commercial real estate
Commercial lease financing
U.S. small business commercial (1)

1,482
253
77
4
1
1,817
(1)  U.S. small business commercial TDRs are comprised of renegotiated small business card loans.

1,556
255
77
6
1
1,895

Total

$

$

$

A commercial TDR is generally deemed to be in payment default 
when the loan is 90 days or more past due, including delinquencies 
that  were  not  resolved  as  part  of  the  modification.  U.S.  small 
business commercial TDRs are deemed to be in payment default 
during the quarter in which a borrower misses the second of two 
consecutive payments. Payment defaults are one of the factors 
considered  when  projecting  future  cash  flows,  along  with 
observable market prices or fair value of collateral when measuring 
the allowance for loan and lease losses. TDRs that were in payment 
default had a carrying value of $150 million, $64 million and $140 

136     Bank of America 2018

NOTE 6 Allowance for Credit Losses
The table below summarizes the changes in the allowance for credit losses by portfolio segment for 2018, 2017 and 2016.

Consumer 
Real Estate (1)

Credit Card and
Other Consumer

Commercial

Total

(Dollars in millions)

Allowance for loan and lease losses, January 1

Loans and leases charged off
Recoveries of loans and leases previously charged off

Net charge-offs

Write-offs of PCI loans (2)
Provision for loan and lease losses
Other (3)

Allowance for loan and lease losses, December 31
Reserve for unfunded lending commitments, January 1

Provision for unfunded lending commitments

Reserve for unfunded lending commitments, December 31
Allowance for credit losses, December 31

Allowance for loan and lease losses, January 1

Loans and leases charged off
Recoveries of loans and leases previously charged off

Net charge-offs

Write-offs of PCI loans (2)
Provision for loan and lease losses
Other (3)

Allowance for loan and lease losses, December 31
Reserve for unfunded lending commitments, January 1

Provision for unfunded lending commitments

Reserve for unfunded lending commitments, December 31
Allowance for credit losses, December 31

Allowance for loan and lease losses, January 1

Loans and leases charged off
Recoveries of loans and leases previously charged off

Net charge-offs

Write-offs of PCI loans (2)
Provision for loan and lease losses
Other (3)

Total allowance for loan and lease losses, December 31
Less: Allowance included in assets of business held for sale (4)

Allowance for loan and lease losses, December 31
Reserve for unfunded lending commitments, January 1

Provision for unfunded lending commitments
Other (3)

Reserve for unfunded lending commitments, December 31
Allowance for credit losses, December 31

$

$

$

$

$

$

1,720
(690)
664
(26)
(273)
(492)
(1)
928
—
—
—
928

2,750
(770)
657
(113)
(207)
(710)
—
1,720
—
—
—
1,720

3,914
(1,155)
619
(536)
(340)
(258)
(30)
2,750
—
2,750
—
—
—
—
2,750

$

$

$

$

$

$

2018
$

$

2017
$

$

2016
$

3,663
(4,037)
823
(3,214)
—
3,441
(16)
3,874
—
—
—
3,874

3,229
(3,774)
809
(2,965)
—
3,437
(38)
3,663
—
—
—
3,663

3,471
(3,553)
770
(2,783)
—
2,826
(42)
3,472
(243)
3,229
—
—
—
—
3,229

$

5,010
(675)
152
(523)
—
313
(1)
4,799
777
20
797
5,596

5,258
(1,075)
174
(901)
—
654
(1)
5,010
762
15
777
5,787

4,849
(740)
238
(502)
—
1,013
(102)
5,258
—
5,258
646
16
100
762
6,020

$

$

$

$

$

$

10,393
(5,402)
1,639
(3,763)
(273)
3,262
(18)
9,601
777
20
797
10,398

11,237
(5,619)
1,640
(3,979)
(207)
3,381
(39)
10,393
762
15
777
11,170

12,234
(5,448)
1,627
(3,821)
(340)
3,581
(174)
11,480
(243)
11,237
646
16
100
762
11,999

(1) 

(2) 

Includes valuation allowance associated with the PCI loan portfolio.
Includes write-offs associated with the sale of PCI loans of $167 million, $87 million and $60 million in 2018, 2017 and 2016, respectively. 

(3)  Primarily represents the net impact of portfolio sales, consolidations and deconsolidations, foreign currency translation adjustments, transfers to held for sale and certain other reclassifications.
(4)  Represents allowance for loan and lease losses related to the non-U.S. consumer credit card loan portfolio, which was sold in 2017.

Bank of America 2018     137 

The table below presents the allowance and the carrying value of outstanding loans and leases by portfolio segment at December 

31, 2018 and 2017.

Allowance and Carrying Value by Portfolio Segment

(Dollars in millions)

Impaired loans and troubled debt restructurings (1)

Allowance for loan and lease losses
Carrying value (2)
Allowance as a percentage of carrying value

Loans collectively evaluated for impairment

Allowance for loan and lease losses
Carrying value (2, 3)
Allowance as a percentage of carrying value (3)

Purchased credit-impaired loans

Valuation allowance
Carrying value gross of valuation allowance
Valuation allowance as a percentage of carrying value

Total

Allowance for loan and lease losses
Carrying value (2, 3)
Allowance as a percentage of carrying value (3)

Impaired loans and troubled debt restructurings (1)

Allowance for loan and lease losses
Carrying value (2)
Allowance as a percentage of carrying value

Loans collectively evaluated for impairment

Allowance for loan and lease losses
Carrying value (2, 3)
Allowance as a percentage of carrying value (3)

Purchased credit-impaired loans

Valuation allowance
Carrying value gross of valuation allowance
Valuation allowance as a percentage of carrying value

Total

Consumer
Real Estate

Credit Card and
Other Consumer

Commercial

Total

December 31, 2018

$

$

$

$

$

$

$

$

$

$

$

$

258
8,556

3.02%

579
243,642

0.24%

91
4,645

1.96%

928
256,843

0.36%

348
12,554

2.77%

1,083
238,284

0.45%

289
10,717

2.70%

$

$

154
566
27.21%

3,720
189,140

1.97%

n/a
n/a
n/a

196
2,433

8.06%

4,603
493,564

0.93%

n/a
n/a
n/a

3,874
189,706

$

2.04%

4,799
495,997

0.97%

December 31, 2017

$

$

125
490
25.51%

3,538
192,303

1.84%

n/a
n/a
n/a

190
2,407

7.89%

4,820
474,284

1.02%

n/a
n/a
n/a

$

$

$

$

$

$

$

608
11,555

5.26%

8,902
926,346

0.96%

91
4,645

1.96%

9,601
942,546

1.02%

663
15,451

4.29%

9,441
904,871

1.04%

289
10,717

2.70%

Allowance for loan and lease losses
Carrying value (2, 3)
Allowance as a percentage of carrying value (3)
1.12%
Impaired loans include nonperforming commercial loans and all TDRs, including both commercial and consumer TDRs. Impaired loans exclude nonperforming consumer loans unless they are TDRs, 
and all consumer and commercial loans accounted for under the fair value option.

5,010
476,691

1,720
261,555

10,393
931,039

3,663
192,793

1.05%

1.90%

0.66%

$

$

$

$

(1) 

(2)  Amounts are presented gross of the allowance for loan and lease losses.
(3)  Outstanding loan and lease balances and ratios do not include loans accounted for under the fair value option of $4.3 billion and $5.7 billion at December 31, 2018 and 2017.
n/a = not applicable

NOTE 7 Securitizations and Other Variable 
Interest Entities 
The Corporation utilizes VIEs in the ordinary course of business 
to  support  its  own  and  its  customers’  financing  and  investing 
needs.  The  Corporation  routinely  securitizes  loans  and  debt 
securities using VIEs as a source of funding for the Corporation 
and as a means of transferring the economic risk of the loans or 
debt securities to third parties. The assets are transferred into a 
trust or other securitization vehicle such that the assets are legally 
isolated from the creditors of the Corporation and are not available 
to satisfy its obligations. These assets can only be used to settle 
obligations  of  the  trust  or  other  securitization  vehicle.  The 
Corporation also administers, structures or invests in other VIEs 
including CDOs, investment vehicles and other entities. For more 
information  on  the  Corporation’s  use  of  VIEs,  see  Note  1  – 
Summary of Significant Accounting Principles.

The tables in this Note present the assets and liabilities of 
consolidated and unconsolidated VIEs at December 31, 2018 and 
2017  in  situations  where  the  Corporation  has  continuing 
involvement  with  transferred  assets  or  if  the  Corporation 
otherwise  has  a  variable  interest  in  the  VIE.  The  tables  also 
present the Corporation’s maximum loss exposure at December 
31,  2018  and  2017  resulting  from  its  involvement  with 
consolidated  VIEs  and  unconsolidated  VIEs  in  which  the 
Corporation holds a variable interest. The Corporation’s maximum 
loss exposure is based on the unlikely event that all of the assets 
in the VIEs become worthless and incorporates not only potential 
losses  associated  with  assets  recorded  on  the  Consolidated 
Balance  Sheet  but  also  potential  losses  associated  with  off-
balance  sheet  commitments,  such  as  unfunded  liquidity 
commitments  and  other  contractual  arrangements.  The 
Corporation’s maximum loss exposure does not include losses 
previously recognized through write-downs of assets.

138     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Corporation invests in ABS issued by third-party VIEs with 
which it has no other form of involvement and enters into certain 
commercial lending arrangements that may also incorporate the 
use of VIEs, for example to hold collateral. These securities and 
loans are included in Note 4 – Securities or Note 5 – Outstanding 
Loans and Leases. In addition, the Corporation has used VIEs such 
as trust preferred securities trusts in connection with its funding 
activities.  In  2018,  the  Corporation  redeemed  trust  preferred 
securities with a total carrying value of $3.1 billion resulting in 
the  extinguishment  of  the  related  junior  subordinated  notes 
issued  by  the  Corporation.  In  connection  therewith,  the 
Corporation recorded a charge to other income of $729 million 
primarily  due  to  the  difference  between  the  carrying  and 
redemption values of the trust preferred securities, the majority 
of which relates to the discount on the junior subordinated notes 
resulting from prior acquisitions. For more information on trust 
preferred securities, see Note 11 – Long-term Debt. These VIEs, 
which  are  generally  not  consolidated  by  the  Corporation,  as 
applicable, are not included in the tables herein.

The  Corporation  did  not  provide  financial  support  to 
consolidated  or  unconsolidated  VIEs  during  2018,  2017  and 
2016 that it was not previously contractually required to provide, 
nor does it intend to do so.

The Corporation had liquidity commitments, including written 
put  options  and  collateral  value  guarantees,  with  certain 

unconsolidated  VIEs  of  $218  million  and  $442  million  at 
December 31, 2018 and 2017.

First-lien Mortgage Securitizations
As  part  of  its  mortgage  banking  activities,  the  Corporation 
securitizes a portion of the first-lien residential mortgage loans it 
originates or purchases from third parties, generally in the form 
of RMBS guaranteed by government-sponsored enterprises, FNMA 
and FHLMC (collectively the GSEs), or the Government National 
Mortgage Association (GNMA) primarily in the case of FHA-insured 
and  U.S.  Department  of  Veterans  Affairs  (VA)-guaranteed 
mortgage loans. Securitization usually occurs in conjunction with 
or shortly after origination or purchase, and the Corporation may 
also securitize loans held in its residential mortgage portfolio. In 
addition,  the  Corporation  may,  from  time  to  time,  securitize 
commercial  mortgages  it  originates  or  purchases  from  other 
entities. The Corporation typically services the loans it securitizes. 
Further,  the  Corporation  may  retain  beneficial  interests  in  the 
securitization trusts including senior and subordinate securities 
and equity tranches issued by the trusts. Except as described in 
Note 12 – Commitments and Contingencies, the Corporation does 
not  provide  guarantees  or  recourse  to  the  securitization  trusts 
other than standard representations and warranties.

The table below summarizes select information related to first-

lien mortgage securitizations for 2018, 2017 and 2016.

First-lien Mortgage Securitizations

(Dollars in millions)

Residential Mortgage - Agency
2017

2018

2016

2018

Commercial Mortgage
2017

2016

Cash proceeds from new securitizations (1)
Gains on securitizations (2)
Repurchases from securitization trusts (3)
(1)  The Corporation transfers residential mortgage loans to securitizations sponsored by the GSEs or GNMA in the normal course of business and receives RMBS in exchange which may then be sold 

14,467
158
2,713

24,201
370
3,611

5,641
91
—

3,887
38
—

6,713
101
—

5,369
62
1,485

$

$

$

$

$

$

into the market to third-party investors for cash proceeds.

(2)  A majority of the first-lien residential mortgage loans securitized are initially classified as LHFS and accounted for under the fair value option. Gains recognized on these LHFS prior to securitization, 

which totaled $71 million, $243 million and $487 million, net of hedges, during 2018, 2017 and 2016, respectively, are not included in the table above.

(3)  The Corporation may have the option to repurchase delinquent loans out of securitization trusts, which reduces the amount of servicing advances it is required to make. The Corporation may also 

repurchase loans from securitization trusts to perform modifications. Repurchased loans include FHA-insured mortgages collateralizing GNMA securities.

In addition to cash proceeds as reported in the table above, 
the  Corporation  received  securities  with  an  initial  fair  value  of 
$711 million, $1.9 billion and $4.2 billion in connection with first-
in  2018,  2017  and  2016, 
lien  mortgage  securitizations 
respectively. Substantially all of these securities are classified as 
Level 2 assets within the fair value hierarchy. 

The Corporation recognizes consumer MSRs from the sale or 
securitization of consumer real estate loans. The unpaid principal 
balance  of  loans  serviced  for  investors,  including  residential 
mortgage  and  home  equity  loans,  totaled  $226.6  billion  and 
$277.6 billion at December 31, 2018 and 2017. Servicing fee 
and  ancillary  fee  income  on  serviced  loans  was  $710  million,  
$893  million  and  $1.2  billion  in  2018,  2017  and  2016, 
respectively.  Servicing  advances  on  serviced  loans,  including 
loans  serviced  for  others  and  loans  held  for  investment,  were 
$3.3 billion and $4.5 billion at December 31, 2018 and 2017. 
For  more  information  on  MSRs,  see  Note  20  –  Fair  Value 
Measurements.

There  were  no  significant  deconsolidations  of  agency 
residential  mortgage  securitizations  in  2018  or  2017.  During 
2016,  the  Corporation  deconsolidated  agency  residential 
mortgage securitization vehicles with total assets of $3.8 billion
and total liabilities of $628 million following the sale of retained 
interests to third parties, after which the Corporation no longer 
had the unilateral ability to liquidate the vehicles. Of the balances 
deconsolidated in 2016, $706 million of assets and $628 million
of liabilities represent non-cash investing and financing activities 
and, accordingly, are not reflected on the Consolidated Statement 
of Cash Flows. A gain on sale of $125 million in 2016 related to 
the  deconsolidation  was  recorded  in  other  income  in  the 
Consolidated Statement of Income.

The following table summarizes select information related to 
first-lien mortgage securitization trusts in which the Corporation 
held a variable interest at December 31, 2018 and 2017.

Bank of America 2018     139 

First-lien Mortgage VIEs

(Dollars in millions)
Unconsolidated VIEs
Maximum loss exposure (1)
On-balance sheet assets

Senior securities:

Trading account assets
Debt securities carried at fair

value

Residential Mortgage

Agency

Prime

Non-agency
Subprime
December 31

Alt-A

Commercial Mortgage

2018

2017

2018

2017

2018

2017

2018

2017

2018

2017

$ 16,011 $ 19,110

$

448 $

689

$

1,897 $

2,643

$

217 $

403

$

767 $

585

$

460 $

716

$

30 $

6

$

36 $

10

$

90 $

50

$

97 $

108

9,381

15,036

246

477

1,470

2,221

125

351

—

—

Held-to-maturity securities

All other assets

Total retained positions

Principal balance outstanding (2)

6,170
—

3,348
10
$ 16,011 $ 19,110
$ 187,512 $ 232,761

$
$

—
3
279 $

—
5
488
8,954 $ 10,549

$
$

—
—
37
38
1,543 $
2,269
8,719 $ 10,254

—
2
217 $

—
2
$
403
$ 23,467 $ 28,129

528
40
665 $

274
88
$
470
$ 43,593 $ 26,504

Consolidated VIEs
Maximum loss exposure (1)
On-balance sheet assets
Trading account assets
Loans and leases, net
All other assets
Total assets
Total liabilities

$ 13,296 $ 14,502

$

7 $

571

$

— $

— $

— $

— $

76 $

—

$

1,318 $

—
—
—
—
—
(1)  Maximum loss exposure includes obligations under loss-sharing reinsurance and other arrangements for non-agency residential mortgage and commercial mortgage securitizations, but excludes 
the reserve for representations and warranties obligations and corporate guarantees and also excludes servicing advances and other servicing rights and obligations. For additional information, 
see Note 12 – Commitments and Contingencies and Note 20 – Fair Value Measurements.

232
14,030
240
$ 13,319 $ 14,502
26 $
$
3

150 $
—
—
150 $
143 $

— $
—
—
— $
— $

— $
—
—
— $
— $

76 $
—
—
76 $
— $

— $
—
—
— $
— $

— $
—
—
— $
— $

571
—
—
571

11,858
143

$
— $

$
$

$

$

(2)  Principal balance outstanding includes loans where the Corporation was the transferor to securitization VIEs with which it has continuing involvement, which may include servicing the loans.

Other Asset-backed Securitizations
The table below summarizes select information related to home equity, credit card and other asset-backed VIEs in which the Corporation 
held a variable interest at December 31, 2018 and 2017.

Home Equity Loan, Credit Card and Other Asset-backed VIEs

(Dollars in millions)
Unconsolidated VIEs
Maximum loss exposure
On-balance sheet assets
Senior securities (4):

Trading account assets
Debt securities carried at fair value
Held-to-maturity securities

All other assets (4)

Total retained positions

Total assets of VIEs (5)

Consolidated VIEs
Maximum loss exposure
On-balance sheet assets
Trading account assets
Loans and leases
Allowance for loan and lease losses
All other assets
Total assets

On-balance sheet liabilities
Short-term borrowings
Long-term debt
All other liabilities
Total liabilities

$

$

$
$

$

$

$

$

$

Home Equity (1)

Credit Card (2, 3)

Resecuritization Trusts

Municipal Bond Trusts

December 31

2018

2017

2018

2017

2018

2017

2018

2017

908 $

1,522

$

— $

— $

7,647 $

8,204

$

2,150 $

1,631

— $
27
—
—
27 $
1,813 $

— $
36
—
—
36
2,432

$
$

— $
—
—
—
— $
— $

— $
—
—
—
— $
— $

1,419 $
1,337
4,891
—
7,647 $
16,949 $

869
1,661
5,644
30
8,204
19,281

85 $

112

$

18,800 $

24,337

$

128 $

628

— $

133
(5)
4
132 $

— $
55
—
55 $

— $

177
(9)
6
174

$

— $
76
—
76

$

— $

29,906
(901)
136
29,141 $

— $

10,321
20
10,341 $

— $

32,554
(988)
1,385
32,951

$

— $

8,598
16
8,614

$

366 $
—
—
—
366 $

— $

238
—
238 $

1,557
—
—
—
1,557

— $

929
—
929

$

$

$
$

$

$

$

26 $
—
—
—
26 $
2,829 $

33
—
—
—
33
2,287

1,540 $

1,453

1,553 $
—
—
1
1,554 $

742 $
12
—
754 $

1,452
—
—
1
1,453

312
—
—
312

(1)  For unconsolidated home equity loan VIEs, the maximum loss exposure includes outstanding trust certificates issued by trusts in rapid amortization, net of recorded reserves. For both consolidated 
and unconsolidated home equity loan VIEs, the maximum loss exposure excludes the reserve for representations and warranties obligations and corporate guarantees. For additional information, 
see Note 12 – Commitments and Contingencies.

(2)  At December 31, 2018 and 2017, loans and leases in the consolidated credit card trust included $11.0 billion and $15.6 billion of seller’s interest.
(3)  At December 31, 2018 and 2017, all other assets in the consolidated credit card trust included certain short-term investments and unbilled accrued interest and fees.
(4)  All other assets includes subordinate securities. The retained senior and subordinate securities were valued using quoted market prices or observable market inputs (Level 2 of the fair value 

hierarchy).

(5)  Total assets of VIEs includes loans the Corporation transferred with which it has continuing involvement, which may include servicing the loan.

140     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Home Equity Loans
The Corporation retains interests in home equity  securitization 
trusts, primarily senior securities, to which it transferred home 
equity  loans.  In  addition,  the  Corporation  may  be  obligated  to 
provide  subordinate  funding  to  the  trusts  during  a  rapid 
amortization event. This obligation is included in the maximum 
loss exposure in the table above. The charges that will ultimately 
be recorded as a result of the rapid amortization events depend 
on the undrawn portion of the home equity lines of credit (HELOCs), 
performance of the loans, the amount of subsequent draws and 
the timing of related cash flows. 

Credit Card Securitizations
The Corporation securitizes originated and purchased credit card 
loans.  The  Corporation’s  continuing  involvement  with  the 
securitization trust includes servicing the receivables, retaining 
an  undivided  interest  (seller’s  interest)  in  the  receivables,  and 
holding certain retained interests including subordinate interests 
in accrued interest and fees on the securitized receivables and 
cash reserve accounts.

During  2018,  2017  and  2016,  new  senior  debt  securities 
issued to third-party investors from the credit card securitization 
trust were $4.0 billion, $3.1 billion and $750 million, respectively.
At  December  31,  2018  and  2017,  the  Corporation  held 
subordinate  securities  issued  by  the  credit  card  securitization 
trust with a notional principal amount of $7.7 billion and $7.4 
billion. These securities serve as a form of credit enhancement 
to the senior debt securities and have a stated interest rate of 
zero  percent.  During  2018,  2017  and  2016,  the  credit  card 
securitization trust issued $650 million, $500 million and $121 
million, respectively, of these subordinate securities.

Resecuritization Trusts
The  Corporation  transfers  securities,  typically  MBS, 
into 
resecuritization  VIEs  at  the  request  of  customers  seeking 

securities  with  specific  characteristics.  Generally,  there  are  no 
significant ongoing activities performed in a resecuritization trust, 
and no single investor has the unilateral ability to liquidate the 
trust.

The Corporation resecuritized $22.8 billion, $25.1 billion and 
$23.4 billion of securities in 2018, 2017 and 2016, respectively. 
Securities transferred into resecuritization VIEs were measured 
at fair value with changes in fair value recorded in trading account 
profits prior to the resecuritization and no gain or loss on sale 
was  recorded.  During  2018,  2017  and  2016,  resecuritization 
proceeds  included  securities  with  an  initial  fair  value  of  $4.1 
billion, $3.3 billion and $3.3 billion, respectively. Substantially all 
of the other securities received as resecuritization proceeds were 
classified as trading securities and were categorized as Level 2 
within the fair value hierarchy.

Municipal Bond Trusts
The  Corporation  administers  municipal  bond  trusts  that  hold 
highly-rated,  long-term,  fixed-rate  municipal  bonds.  The  trusts 
obtain  financing  by  issuing  floating-rate  trust  certificates  that 
reprice  on  a  weekly  or  other  short-term  basis  to  third-party 
investors.

The  Corporation’s  liquidity  commitments  to  unconsolidated 
municipal bond trusts, including those for which the Corporation 
was transferor, totaled $2.1 billion and $1.6 billion at December 
31, 2018 and 2017. The weighted-average remaining life of bonds 
held in the trusts at December 31, 2018 was 7.3 years. There 
were no material write-downs or downgrades of assets or issuers 
during 2018, 2017 and 2016.

Other Variable Interest Entities
The table below summarizes select information related to other 
VIEs in which the Corporation held a variable interest at December 
31, 2018 and 2017.

Other VIEs

(Dollars in millions)

Maximum loss exposure
On-balance sheet assets
Trading account assets
Debt securities carried at fair value
Loans and leases
Allowance for loan and lease losses
All other assets

Total

On-balance sheet liabilities

Long-term debt
All other liabilities

Total

Total assets of VIEs

Consolidated

Unconsolidated

Total

Consolidated

Unconsolidated

Total

$

$

$

$

$
$

4,177

2,335
—
1,949
(2)
53
4,335

152
7
159
4,335

$

$

$

$

$
$

2018

24,498

860
84
3,940
(30)
18,885
23,739

$

$

$

— $

4,231
4,231
94,746

$
$

December 31

28,675

3,195
84
5,889
(32)
18,938
28,074

152
4,238
4,390
99,081

$

$

$

$

$
$

4,660

2,709
—
2,152
(3)
89
4,947

270
18
288
4,947

$

$

$

$

$
$

2017

19,785

346
160
3,596
(32)
15,216
19,286

$

$

$

— $

3,417
3,417
69,746

$
$

24,445

3,055
160
5,748
(35)
15,305
24,233

270
3,435
3,705
74,693

Customer VIEs
Customer VIEs include credit-linked, equity-linked and commodity-
linked note VIEs, repackaging VIEs and asset acquisition VIEs, 
which are typically created on behalf of customers who wish to 
obtain market or credit exposure to  a  specific  company,  index, 
commodity or financial instrument.

The  Corporation’s  maximum  loss  exposure  to  consolidated 
and  unconsolidated  customer VIEs totaled  $2.1 billion and $2.3 
billion at December 31, 2018 and 2017, including the notional 
amount of derivatives to which the Corporation is a counterparty, 

net  of  losses  previously  recorded,  and  the  Corporation’s 
investment, if any, in securities issued by the VIEs. 

Collateralized Debt Obligation VIEs
The  Corporation  receives  fees  for  structuring  CDO  VIEs,  which 
hold  diversified  pools  of  fixed-income  securities,  typically 
corporate debt or ABS, which the CDO VIEs fund by issuing multiple 
tranches  of  debt  and  equity  securities.  CDOs  are  generally 
managed  by  third-party  portfolio  managers.  The  Corporation 
typically transfers assets to these CDOs, holds securities issued 
by the CDOs and may be a derivative counterparty to the CDOs. 
The Corporation’s maximum loss exposure to consolidated and 

Bank of America 2018     141 

 
 
 
 
 
 
 
 
 
 
 
 
 
unconsolidated CDOs totaled $421 million and $358 million at 
December 31, 2018 and 2017.

Investment VIEs
The Corporation sponsors, invests in or provides financing, which 
may  be  in  connection  with  the  sale  of  assets,  to  a  variety  of 
investment VIEs that hold loans, real estate, debt securities or 
other  financial  instruments  and  are  designed  to  provide  the 
desired  investment  profile  to  investors  or  the  Corporation.  At 
December 31, 2018 and 2017, the Corporation’s consolidated 
investment  VIEs  had  total  assets  of  $270  million  and  $249 
million. The Corporation also held investments in unconsolidated 
VIEs  with  total  assets  of  $37.7  billion  and  $20.3  billion  at 
December 31, 2018 and 2017. The Corporation’s maximum loss 
exposure associated with both consolidated and unconsolidated 
investment VIEs totaled $7.2 billion and $5.7 billion at December 
31,  2018  and  2017  comprised  primarily  of  on-balance  sheet 
assets less non-recourse liabilities.

Leveraged Lease Trusts
The Corporation’s net investment in consolidated leveraged lease 
trusts totaled $1.8 billion and $2.0 billion at December 31, 2018 
and 2017. The trusts hold long-lived equipment such as rail cars, 
power  generation  and  distribution  equipment,  and  commercial 
aircraft.  The  Corporation  structures  the  trusts  and  holds  a 
significant residual interest. The net investment represents the 
Corporation’s maximum loss exposure to the trusts in the unlikely 
event that the leveraged lease investments become worthless. 
Debt issued by the leveraged lease trusts is non-recourse to the 
Corporation.

NOTE 8 Goodwill and Intangible Assets

The  Corporation’s 

Tax Credit VIEs
The  Corporation  holds  investments  in  unconsolidated  limited 
partnerships and similar entities that construct, own and operate 
affordable housing, wind and solar projects. An unrelated third 
party is typically the general partner or managing member and 
has  control  over  the  significant  activities  of  the  VIE.  The 
Corporation  earns  a  return  primarily  through  the  receipt  of  tax 
credits  allocated  to  the  projects.  The  maximum  loss  exposure 
included  in  the  Other  VIEs  table  was  $17.0  billion  and  $13.8 
billion at December 31, 2018 and 2017. The Corporation’s risk 
of loss is generally mitigated by policies requiring that the project 
qualify for the expected tax credits prior to making its investment.
in  affordable  housing 
investments 
partnerships,  which  are  reported  in  other  assets  on  the 
Consolidated Balance Sheet, totaled $8.9 billion and $8.0 billion, 
including unfunded commitments to provide capital contributions 
of $3.8 billion and $3.1 billion at December 31, 2018 and 2017. 
The unfunded commitments are expected to be paid over the next 
five  years.  During  2018,  2017  and  2016,  the  Corporation 
recognized tax credits and other tax benefits from investments in 
affordable housing partnerships of $981 million, $1.0 billion and 
$1.1 billion and reported pretax losses in other income of $798 
million, $766 million and $789 million, respectively. Tax credits 
are recognized as part of the Corporation’s annual effective tax 
rate used to determine tax expense in a given quarter. Accordingly, 
the portion of a year’s expected tax benefits recognized in any 
given quarter may differ from 25 percent. The Corporation may 
from time to time be asked to invest additional amounts to support 
troubled  affordable  housing  project.  Such  additional 
a 
investments have not been and are not expected to be significant.

Goodwill
The table below presents goodwill balances by reporting unit and All Other at December 31, 2018 and 2017. The reporting units 
utilized for goodwill impairment testing are the operating segments or one level below. 

Goodwill

(Dollars in millions)

Deposits
Consumer Lending
Consumer Banking
U.S. Trust
Merrill Lynch Global Wealth Management
Global Wealth & Investment Management
Global Commercial Banking
Global Corporate and Investment Banking
Business Banking
Global Banking
Global Markets
All Other

Total goodwill

December 31

2018

2017

18,414
11,709
30,123
2,917
6,760
9,677
16,146
6,231
1,546
23,923
5,182
46
68,951

$

$

18,414
11,709
30,123
2,917
6,760
9,677
16,146
6,231
1,546
23,923
5,182
46
68,951

$

$

During 2018, the Corporation completed its annual goodwill impairment test as of June 30, 2018 using qualitative assessments 
for all applicable reporting units. Based on the results of the annual goodwill impairment test, the Corporation determined there was 
no impairment. For more information on the use of qualitative assessments, see Note 1 – Summary of Significant Accounting Principles.

142     Bank of America 2018

Intangible Assets
The table below presents the gross and net carrying values and accumulated amortization for intangible assets at December 31, 
2018 and 2017.

Intangible Assets (1, 2)

(Dollars in millions)

Purchased credit card and affinity relationships
Core deposit and other intangibles (3)
Customer relationships
Total intangible assets

Gross
Carrying Value

Accumulated
Amortization

Net
Carrying Value

Gross
Carrying Value

Accumulated
Amortization

Net
Carrying Value

December 31, 2018

5,919
3,835
—
9,754

$

$

5,759
2,221
—
7,980

$

$

$

$

160
1,614
—
1,774

$

$

December 31, 2017

5,919
3,835
3,886
13,640

$

$

5,604
2,140
3,584
11,328

$

$

315
1,695
302
2,312

(1)  Excludes fully amortized intangible assets.
(2)  At December 31, 2018 and 2017, none of the intangible assets were impaired.
(3) 

Includes $1.6 billion at both December 31, 2018 and 2017 of intangible assets associated with trade names that have an indefinite life and, accordingly, are not amortized.

Amortization of intangibles expense was $538 million, $621 million and $730 million for 2018, 2017 and 2016, respectively. The 
Corporation estimates aggregate amortization expense will be $105 million for 2019, $55 million for 2020 and none for the years 
thereafter.

NOTE 9 Deposits
The table below presents information about the Corporation’s time deposits of $100 thousand or more at December 31, 2018 and 
2017. The Corporation also had aggregate time deposits of $16.4 billion and $17.0 billion in denominations that met or exceeded 
the Federal Deposit Insurance Corporation (FDIC) insurance limit at December 31, 2018 and 2017. 

Time Deposits of $100 Thousand or More

(Dollars in millions)

December 31, 2018

December 31
2017

Three Months
or Less

Over Three
Months to
Twelve Months

Thereafter

Total

Total

U.S. certificates of deposit and other time deposits
Non-U.S. certificates of deposit and other time deposits

$

14,441
7,317

$

11,855
2,655

$

$

3,209
820

29,505
10,792

$

25,192
15,472

The scheduled contractual maturities for total time deposits at December 31, 2018 are presented in the table below.

Contractual Maturities of Total Time Deposits

(Dollars in millions)

Due in 2019
Due in 2020
Due in 2021
Due in 2022
Due in 2023
Thereafter

Total time deposits

U.S.

Non-U.S.

Total

$

$

43,452
4,580
725
560
270
570
50,157

$

$

10,030
164
8
11
632
37
10,882

$

$

53,482
4,744
733
571
902
607
61,039

NOTE 10 Federal Funds Sold or Purchased, Securities Financing Agreements, Short-term Borrowings 
and Restricted Cash
The  table  below  presents  federal  funds  sold  or  purchased,  securities  financing  agreements  (which  include  securities  borrowed  or 
purchased under agreements to resell and securities loaned or sold under agreements to repurchase) and short-term borrowings. The 
Corporation elects to account for certain securities financing agreements and short-term borrowings under the fair value option. For 
more information on the fair value option, see Note 21 – Fair Value Option.

(Dollars in millions)

Federal funds sold and securities borrowed or purchased under agreements to resell

Average during year
Maximum month-end balance during year

Federal funds purchased and securities loaned or sold under agreements to repurchase

Average during year
Maximum month-end balance during year

Short-term borrowings
Average during year
Maximum month-end balance during year

n/a = not applicable

Amount

Rate

Amount

Rate

2018

2017

$

$

251,328
279,350

193,681
201,089

36,021
52,480

1.26% $

n/a

222,818
237,064

1.80% $

n/a

199,501
218,017

2.69
n/a

37,337
46,202

0.81%
n/a

1.30%
n/a

2.48
n/a

Bank of America 2018     143 

Bank of America, N.A. maintains a global program to offer up 
to a maximum of $75 billion outstanding at any one time, of bank 
notes with fixed or floating rates and maturities of at least seven 
days from the date of issue. Short-term bank notes outstanding 
under  this  program  totaled  $12.1  billion  and  $14.2  billion  at 
December  31,  2018  and  2017.  These  short-term  bank  notes, 
along with FHLB advances, U.S. Treasury tax and loan notes, and 
term  federal  funds  purchased,  are  included  in  short-term 
borrowings on the Consolidated Balance Sheet.

Offsetting of Securities Financing Agreements
The  Corporation  enters  into  securities  financing  agreements  to 
accommodate  customers  (also  referred  to  as  “matched-book 
transactions”), obtain securities to cover short positions, and to 
finance inventory positions. Substantially all of the Corporation’s 
securities  financing  activities  are  transacted  under  legally 
enforceable master repurchase agreements or legally enforceable 
master securities lending agreements that give the Corporation, 

in the event of default by the counterparty, the right to liquidate 
securities held and to offset receivables and payables with the 
same counterparty. The Corporation offsets securities financing 
transactions  with  the  same  counterparty  on  the  Consolidated 
Balance  Sheet  where  it  has  such  a  legally  enforceable  master 
netting agreement and the transactions have the same maturity 
date.

The Securities Financing Agreements table presents securities 
financing agreements included on the Consolidated Balance Sheet 
in federal funds sold and securities borrowed or purchased under 
agreements  to  resell,  and  in  federal  funds  purchased  and 
securities  loaned  or  sold  under  agreements  to  repurchase  at 
December 31, 2018 and 2017. Balances are presented on a gross 
basis, prior to the application of counterparty netting. Gross assets 
and  liabilities  are  adjusted  on  an  aggregate  basis  to  take  into 
consideration  the  effects  of  legally  enforceable  master  netting 
agreements. For more information on the offsetting of derivatives, 
see Note 3 – Derivatives.

Securities Financing Agreements

(Dollars in millions)

December 31, 2018

Securities borrowed or purchased under agreements to resell (3)
Securities loaned or sold under agreements to repurchase
Other (4)
Total

$
$

$

366,274
293,853
19,906
313,759

$
$

$

(106,865) $
(106,865) $

—

(106,865) $

259,409
186,988
19,906
206,894

$
$

$

(240,790) $
(176,740) $
(19,906)
(196,646) $

18,619
10,248
—
10,248

Gross Assets/
Liabilities (1)

Amounts Offset

Net Balance
Sheet Amount

Financial 
Instruments (2)

Net Assets/
Liabilities

December 31, 2017

Securities borrowed or purchased under agreements to resell (3)
Securities loaned or sold under agreements to repurchase
Other (4)
Total
Includes activity where uncertainty exists as to the enforceability of certain master netting agreements under bankruptcy laws in some countries or industries.
Includes securities collateral received or pledged under repurchase or securities lending agreements where there is a legally enforceable master netting agreement. These amounts are not offset 
on the Consolidated Balance Sheet, but are shown as a reduction to derive a net asset or liability. Securities collateral received or pledged where the legal enforceability of the master netting 
agreements is uncertain is excluded from the table.

212,747
176,857
22,711
199,568

348,472
312,582
22,711
335,293

47,027
30,652
—
30,652

(165,720) $
(146,205) $

(135,725) $
(135,725) $

(168,916) $

(135,725) $

(22,711)

$
$

$
$

$
$

—

$

$

$

(1) 

(2) 

(3)  Excludes repurchase activity of $11.5 billion and $10.2 billion reported in loans and leases on the Consolidated Balance Sheet at December 31, 2018 and 2017.
(4)  Balance is reported in accrued expenses and other liabilities on the Consolidated Balance Sheet and relates to transactions where the Corporation acts as the lender in a securities lending agreement 
and receives securities that can be pledged as collateral or sold. In these transactions, the Corporation recognizes an asset at fair value, representing the securities received, and a liability, representing 
the obligation to return those securities.

Repurchase Agreements and Securities Loaned 
Transactions Accounted for as Secured Borrowings
The following tables present securities sold under agreements to 
repurchase and securities loaned by remaining contractual term 
to maturity and class of collateral pledged. Included in “Other” are 
transactions  where  the  Corporation  acts  as  the  lender  in  a 

securities lending agreement and receives securities that can be 
pledged as collateral or sold. Certain agreements contain a right 
to substitute collateral and/or terminate the agreement prior to 
maturity at the option of the Corporation or the counterparty. Such 
agreements are included in the table below based on the remaining 
contractual term to maturity.

Remaining Contractual Maturity

(Dollars in millions)

Securities sold under agreements to repurchase
Securities loaned
Other

Total

Securities sold under agreements to repurchase
Securities loaned
Other

Total

(1)  No agreements have maturities greater than three years.

144     Bank of America 2018

Overnight and
Continuous

30 Days or Less

After 30 Days
Through 90 Days

Greater than 
90 Days (1)

Total

$

$

$

$

139,017
7,753
19,906
166,676

125,956
9,853
22,711
158,520

$

$

$

$

81,917
4,197
—
86,114

79,913
5,658
—
85,571

December 31, 2018
34,204
$
1,783
—
35,987

$

December 31, 2017
46,091
$
2,043
—
48,134

$

$

$

$

$

21,476
3,506
—
24,982

38,935
4,133
—
43,068

$

$

$

$

276,614
17,239
19,906
313,759

290,895
21,687
22,711
335,293

Class of Collateral Pledged

(Dollars in millions)

U.S. government and agency securities
Corporate securities, trading loans and other
Equity securities
Non-U.S. sovereign debt
Mortgage trading loans and ABS

Total

U.S. government and agency securities
Corporate securities, trading loans and other
Equity securities
Non-U.S. sovereign debt
Mortgage trading loans and ABS

Total

Securities Sold
Under Agreements
to Repurchase

Securities
Loaned

Other

Total

$

$

$

$

164,664
11,400
14,090
81,329
5,131
276,614

158,299
12,787
23,975
90,857
4,977
290,895

$

$

$

$

December 31, 2018
— $

— $

2,163
10,869
4,207
—
17,239

$

December 31, 2017
— $

2,669
13,523
5,495
—
21,687

$

287
19,572
47
—
19,906

409
624
21,628
50
—
22,711

$

$

$

164,664
13,850
44,531
85,583
5,131
313,759

158,708
16,080
59,126
96,402
4,977
335,293

Under repurchase agreements, the Corporation is required to 
post collateral with a market value equal to or in excess of the 
principal amount borrowed. For securities loaned transactions, the 
Corporation receives collateral in the form of cash, letters of credit 
or other securities. To determine whether the market value of the 
underlying  collateral  remains  sufficient,  collateral  is  generally 
valued  daily,  and  the  Corporation  may  be  required  to  deposit 
additional  collateral  or  may  receive  or  return  collateral  pledged 
when appropriate. Repurchase agreements and securities loaned 
transactions  are  generally  either  overnight,  continuous  (i.e.,  no 
stated term) or short-term. The Corporation manages liquidity risks 
related  to  these  agreements  by  sourcing  funding  from  a  diverse

group of counterparties, providing a range of securities collateral 
and pursuing longer durations, when appropriate.

Restricted Cash
At December 31, 2018 and 2017, the Corporation held restricted 
cash  included  within  cash  and  cash  equivalents  on  the 
Consolidated Balance Sheet of $22.6 billion and $18.8 billion, 
predominantly related to cash held on deposit with the Federal 
Reserve  Bank  and  non-U.S.  central  banks  to  meet  reserve 
requirements and cash segregated in compliance with securities 
regulations.

Bank of America 2018     145 

NOTE 11 Long-term Debt
Long-term debt consists of borrowings having an original maturity of one year or more. The table below presents the balance of long-
term debt at December 31, 2018 and 2017, and the related contractual rates and maturity dates as of December 31, 2018.

(Dollars in millions)

Notes issued by Bank of America Corporation
Senior notes:

Fixed
Floating

Senior structured notes (1)
Subordinated notes:

Fixed
Floating

Junior subordinated notes (2):

Fixed
Floating

Total notes issued by Bank of America Corporation

Notes issued by Bank of America, N.A.
Senior notes:

Fixed
Floating

Subordinated notes
Advances from Federal Home Loan Banks:

Fixed
Floating

Securitizations and other BANA VIEs (3)
Other

Total notes issued by Bank of America, N.A.

Other debt
Structured liabilities
Nonbank VIEs (3)
Other

Total other debt
Total long-term debt

Weighted-
average Rate

Interest Rates

Maturity Dates

2018

2017

December 31

3.39 %
2.09

0.39 - 8.40 %
0.06 - 7.26

2019 - 2049
2019 - 2044

$

$

120,548
25,574
13,768

4.91
2.16

6.71
3.54

2.96
6.00

5.10
2.49

2.94 - 8.57
1.14 - 3.55

6.45 - 8.05
3.54

2019 - 2045
2019 - 2026

2027 - 2066
2056

2.90 - 2.96
6.00

0.01 - 7.72
2.24 - 2.80

2020 - 2041
2036

2019 - 2034
2019 - 2020

20,843
1,742

732
1
183,208

—
1,770
1,617

130
14,751
10,326
442
29,036

16,478
618
—
17,096
229,340

$

$

119,548
21,048
15,460

22,004
4,058

3,282
553
185,953

4,686
1,033
1,679

146
5,000
8,641
433
21,618

18,574
1,232
25
19,831
227,402

(1) 

(2) 

Includes total loss-absorbing capacity compliant debt.
Includes amounts related to trust preferred securities. For additional information, see Trust Preferred Securities in this Note.

(3)  Represents the total long-term debt included in the liabilities of consolidated VIEs on the Consolidated Balance Sheet.

Bank  of  America  Corporation  and  Bank  of  America,  N.A. 
maintain various U.S. and non-U.S. debt programs to offer both 
senior and subordinated notes. The notes may be denominated 
in U.S. dollars or foreign currencies. At December 31, 2018 and 
2017, the amount of foreign currency-denominated debt translated 
into U.S. dollars included in total long-term debt was $48.6 billion 
and  $51.8  billion.  Foreign  currency  contracts  may  be  used  to 
convert  certain  foreign  currency-denominated  debt  into  U.S. 
dollars.

At December 31, 2018, long-term debt of consolidated VIEs in 
the table above included debt from credit card and all other VIEs 
of  $10.3  billion  and  $623  million.  Long-term  debt  of  VIEs  is 
collateralized by the assets of the VIEs. For additional information, 
see Note 7 – Securitizations and Other Variable Interest Entities.

The weighted-average effective interest rates for total long-term 
debt (excluding senior structured notes), total fixed-rate debt and 
total floating-rate debt were 3.29 percent, 3.66 percent and 2.26 
percent, respectively, at December 31, 2018, and 3.44 percent, 
3.87  percent  and  1.49  percent,  respectively,  at  December  31, 
2017. The Corporation’s ALM activities maintain an overall interest 
rate  risk  management  strategy  that  incorporates  the  use  of 
interest rate contracts to manage fluctuations in earnings that are 
caused  by  interest  rate  volatility.  The  Corporation’s  goal  is  to 
manage  interest  rate  sensitivity  so  that  movements  in  interest 
rates do not significantly  adversely affect earnings  and capital. 
The weighted-average rates are the contractual interest rates on 
the debt and do not reflect the impacts of derivative transactions.

146     Bank of America 2018

Debt outstanding of $3.8 billion at December 31, 2018 was 
issued  by  BofA  Finance  LLC,  a  100  percent  owned  finance 
subsidiary of Bank of America Corporation, the parent company, 
and is fully and unconditionally guaranteed by the parent company.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        

During  2018,  the  Corporation  had  total  long-term  debt 
maturities  and  redemptions  in  the  aggregate  of  $53.3  billion
consisting of $29.8 billion for Bank of America Corporation, $11.2 
billion for Bank of America, N.A. and $12.3 billion of other debt. 
During 2017, the Corporation had total long-term debt maturities 
and redemptions in the aggregate of $48.8 billion consisting of 
$29.1 billion for Bank of America Corporation, $13.3 billion for 
Bank of America, N.A. and $6.4 billion of other debt.

The  following  table  shows  the  carrying  value  for  aggregate 
annual contractual maturities of long-term debt as of December 
31, 2018. Included in the table are certain structured notes issued 
by the Corporation that contain provisions whereby the borrowings 
are redeemable at the option of the holder (put options) at specified 
dates  prior  to  maturity.  Other  structured  notes  have  coupon  or 
repayment  terms  linked  to  the  performance  of  debt  or  equity 
securities, indices, currencies or commodities, and the maturity 
may be accelerated based on the value of a referenced index or 
security. In both cases, the Corporation or a subsidiary may be 
required to settle the obligation for cash or other securities prior 
to the contractual maturity date. These borrowings are reflected 
in the table as maturing at their contractual maturity date.

 
 
 
 
 
 
 
 
 
 
Long-term Debt by Maturity

(Dollars in millions)

Bank of America Corporation

Senior notes
Senior structured notes
Subordinated notes
Junior subordinated notes

Total Bank of America Corporation

Bank of America, N.A.

Senior notes
Subordinated notes
Advances from Federal Home Loan Banks
Securitizations and other Bank VIEs (1)
Other

Total Bank of America, N.A.

Other debt

Structured liabilities
Nonbank VIEs (1)

Total other debt
Total long-term debt

2019

2020

2021

2022

2023

Thereafter

Total

$

$

14,831
1,337
1,501
—
17,669

—
—
11,762
3,200
224
15,186

5,085
35
5,120
37,975

$

$

10,308
875
—
—
11,183

1,750
—
3,010
3,100
83
7,943

15,883
482
346
—
16,711

—
—
2
4,022
—
4,024

$

$

14,882
1,914
364
—
17,160

$

22,570
323
—
—
22,893

—
—
3
—
2
5

—
—
1
—
133
134

$

67,648
8,837
20,374
733
97,592

20
1,617
103
4
—
1,744

146,122
13,768
22,585
733
183,208

1,770
1,617
14,881
10,326
442
29,036

2,712
—
2,712
21,838

$

1,112
—
1,112
21,847

$

558
—
558
17,723

$

830
23
853
23,880

$

6,181
560
6,741
106,077

$

16,478
618
17,096
229,340

$

(1)   Represents the total long-term debt included in the liabilities of consolidated VIEs on the Consolidated Balance Sheet.

Trust Preferred Securities
Trust preferred securities (Trust Securities) are primarily issued by 
trust companies (the Trusts) that are not consolidated. These Trust 
Securities  are  mandatorily 
redeemable  preferred  security 
obligations of the Trusts. The sole assets of the Trusts generally 
are  junior  subordinated  deferrable  interest  notes  of  the 
Corporation or its subsidiaries (the Notes). The Trusts generally 
are 100 percent owned finance subsidiaries of the Corporation.

Periodic  cash  payments  and  payments  upon  liquidation  or 
redemption with respect to Trust Securities are guaranteed by the 
Corporation or its subsidiaries to the extent of funds held by the 
Trusts  (the  Preferred  Securities  Guarantee).  The  Preferred 
Securities Guarantee, when taken together with the Corporation’s 
other  obligations  including  its  obligations  under  the  Notes, 
generally will constitute a full and unconditional guarantee, on a 
subordinated basis, by the Corporation of payments due on the 
Trust Securities.

During 2018, the Corporation redeemed Trust Securities of 11 
Trusts with a carrying value of $3.1 billion. At December 31, 2018, 
the  Corporation  had  one 
junior 
subordinated note held in trust.

floating-rate 

remaining 

NOTE 12 Commitments and Contingencies
In the normal course of business, the Corporation enters into a 
number of off-balance sheet commitments. These commitments 
expose the Corporation to varying degrees of credit and market 
risk and are subject to the same credit and market risk limitation 
reviews  as  those  instruments  recorded  on  the  Consolidated 
Balance Sheet. 

Credit Extension Commitments
The Corporation enters into commitments to extend credit such 
as loan commitments, SBLCs and commercial letters of credit to 
meet the financing needs of its customers. The following table 
includes the notional amount of unfunded legally binding lending 
commitments  net  of  amounts  distributed  (i.e.,  syndicated  or 
participated)  to  other  financial  institutions.  The  distributed 
amounts were $10.7 billion and $11.0 billion at December 31, 
2018  and  2017.  At  December  31,  2018,  the  carrying  value  of 
these commitments, excluding commitments accounted for under 
the fair value option, was $813 million, including deferred revenue 
of $16 million and a reserve for unfunded lending commitments 
of $797 million. At December 31, 2017, the comparable amounts 
were $793 million, $16 million and $777 million, respectively. The 
carrying  value  of  these  commitments  is  classified  in  accrued 
expenses and other liabilities on the Consolidated Balance Sheet.
Legally binding commitments to extend credit generally have 
specified rates and maturities. Certain of these commitments have 
adverse  change  clauses  that  help  to  protect  the  Corporation 
against deterioration in the borrower’s ability to pay. 

The  table  below  also  includes  the  notional  amount  of 
commitments  of  $3.1  billion  and  $4.8  billion  at  December  31, 
2018 and 2017 that are accounted for under the fair value option. 
However, the following table excludes cumulative net fair value of 
$169 million and $120 million at December 31, 2018 and 2017
on these commitments, which is classified in accrued expenses 
and  other  liabilities.  For  more  information  regarding  the 
Corporation’s loan commitments accounted for under the fair value 
option, see Note 21 – Fair Value Option.

Bank of America 2018     147 

Credit Extension Commitments

(Dollars in millions)

Notional amount of credit extension commitments

Loan commitments
Home equity lines of credit
Standby letters of credit and financial guarantees (1)
Letters of credit (2)

Legally binding commitments

Credit card lines (3)

Total credit extension commitments

Notional amount of credit extension commitments

Loan commitments
Home equity lines of credit
Standby letters of credit and financial guarantees (1)
Letters of credit

Legally binding commitments

Credit card lines (3)

Total credit extension commitments

$

$

$

$

Expire in One
Year or Less

Expire After One
Year Through
Three Years

Expire After Three 
Years Through 
Five Years

December 31, 2018

Expire After 
Five Years

Total

84,910
2,578
22,571
1,168
111,227
371,658
482,885

85,804
6,172
19,976
1,291
113,243
362,030
475,273

$

$

$

$

142,271
2,249
9,702
84
154,306
—
154,306

$

$

155,298
3,530
2,457
69
161,354
—
161,354

December 31, 2017

140,942
4,457
11,261
117
156,777
—
156,777

$

$

147,043
2,288
3,420
129
152,880
—
152,880

$

$

$

$

22,683
34,702
1,074
57
58,516
—
58,516

21,342
31,250
1,144
87
53,823
—
53,823

$

$

$

$

405,162
43,059
35,804
1,378
485,403
371,658
857,061

395,131
44,167
35,801
1,624
476,723
362,030
838,753

(1)   The notional amounts of SBLCs and financial guarantees classified as investment grade and non-investment grade based on the credit quality of the underlying reference name within the instrument 
were $28.3 billion and $7.1 billion at December 31, 2018, and $27.3 billion and $8.1 billion at December 31, 2017. Amounts in the table include consumer SBLCs of $372 million and $421 million
at December 31, 2018 and 2017.

(2)   At December 31, 2018, included letters of credit of $422 million related to certain liquidity commitments of VIEs. For additional information, see Note 7 – Securitizations and Other Variable Interest 

Entities.

(3)  Includes business card unused lines of credit. 

Other Commitments
At  December  31,  2018  and  2017,  the  Corporation  had 
commitments to purchase loans (e.g., residential mortgage and 
commercial real estate) of $329 million and $344 million, which 
upon  settlement  will  be  included  in  loans  or  LHFS,  and 
commitments to purchase commercial loans of $463 million and 
$994 million, which upon settlement will be included in trading 
account assets.

At  December  31,  2018  and  2017,  the  Corporation  had 
commitments to purchase commodities, primarily liquefied natural 
gas, of $1.3 billion and $1.5 billion, which upon settlement will 
be included in trading account assets. 

At  December  31,  2018  and  2017,  the  Corporation  had 
commitments to enter into resale and forward-dated resale and 
securities borrowing agreements of $59.7 billion and $56.8 billion, 
and  commitments  to  enter  into  forward-dated  repurchase  and 
securities lending agreements of $21.2 billion and $34.3 billion. 
These commitments expire primarily within the next 12 months.

At both December 31, 2018 and 2017, the Corporation had a 
commitment to originate or purchase up to $3.0 billion, on a rolling 
12-month basis, of auto loans and leases from a strategic partner. 
This commitment extends through November 2022 and can be 
terminated with 12 months prior notice. 

The Corporation is a party to operating leases for certain of its 
premises and equipment. Commitments under these leases are 
approximately $2.4 billion, $2.2 billion, $2.0 billion, $1.7 billion 
and $1.3 billion for 2019 and the years through 2023, respectively, 
and $6.2 billion in the aggregate for all years thereafter.

Other Guarantees

Bank-owned Life Insurance Book Value Protection
The Corporation sells products that offer book value protection to 
insurance  carriers  who  offer  group  life  insurance  policies  to 
corporations, primarily banks. At December 31, 2018 and 2017, 
the notional amount of these guarantees totaled $9.8 billion and 

148     Bank of America 2018

$10.4 billion. At December 31, 2018 and 2017, the Corporation’s 
maximum  exposure  related  to  these  guarantees  totaled  $1.5 
billion  and  $1.6  billion,  with  estimated  maturity  dates  between 
2033 and 2039. 

Indemnifications
In the ordinary course of business, the Corporation enters into 
various  agreements  that  contain  indemnifications,  such  as  tax 
indemnifications, whereupon payment may become due if certain 
external  events  occur,  such  as  a  change  in  tax  law.  The 
indemnification clauses are often standard contractual terms and 
were entered into in the normal course of business based on an 
assessment  that  the  risk  of  loss  would  be  remote.  These 
agreements  typically  contain  an  early  termination  clause  that 
permits the Corporation to exit the agreement upon these events. 
The  maximum  potential  future  payment  under  indemnification 
agreements is difficult to assess for several reasons, including 
the occurrence of an external event, the inability to predict future 
changes in tax and other laws, the difficulty in determining how 
such  laws  would  apply  to  parties  in  contracts,  the  absence  of 
exposure limits contained in standard contract language and the 
timing of any early termination clauses. Historically, any payments 
made  under  these  guarantees  have  been  de  minimis.  The 
Corporation  has  assessed  the  probability  of  making  such 
payments in the future as remote.

Merchant Services
In  accordance  with  credit  and  debit  card  association  rules,  the 
Corporation sponsors merchant processing servicers that process 
credit and debit card transactions on behalf of various merchants. 
If the merchant processor fails to meet its obligation to reimburse 
the cardholder for disputed transactions, then the Corporation, as 
the sponsor, could be held liable for the disputed amount. In 2018 
and 2017, the sponsored entities processed and settled $874.3 
billion and $812.2 billion of transactions and recorded losses of 
$31 million and $28 million. A significant portion of this activity 
was processed by a joint venture in which the Corporation holds 

 
 
 
 
 
 
 
 
 
 
 
a 49 percent ownership. The carrying value of the Corporation’s 
investment in the merchant services joint venture was $2.8 billion 
and $2.9 billion at December 31, 2018 and 2017, and is recorded 
in other assets on the Consolidated Balance Sheet and in All Other.
At  December  31,  2018  and  2017,  the  maximum  potential 
exposure for sponsored transactions totaled $348.1 billion and 
$346.4  billion.  However,  the  Corporation  believes  that  the 
maximum potential exposure is not representative of the actual 
potential  loss  exposure  and  does  not  expect  to  make  material 
payments in connection with these guarantees.

Exchange and Clearing House Member Guarantees
The Corporation is a member of various securities and derivative 
exchanges  and  clearinghouses,  both  in  the  U.S.  and  other 
countries. As a member, the Corporation may be required to pay 
a  pro-rata  share  of  the  losses  incurred  by  some  of  these 
organizations as a result of another member default and under 
other loss scenarios. The Corporation’s potential obligations may 
be  limited  to  its  membership  interests  in  such  exchanges  and 
clearinghouses, to the amount (or multiple) of the Corporation’s 
contribution to the guarantee fund or, in limited instances, to the 
full  pro-rata  share  of  the  residual  losses  after  applying  the 
guarantee fund. The Corporation’s maximum potential exposure 
under  these  membership  agreements  is  difficult  to  estimate; 
however, the Corporation has assessed the probability of making 
any such payments as remote. 

Prime Brokerage and Securities Clearing Services 
In connection with its prime brokerage and clearing businesses, 
the  Corporation  performs  securities  clearance  and  settlement 
services with other brokerage firms and clearinghouses on behalf 
of its clients. Under these arrangements, the Corporation stands 
ready to meet the obligations of its clients with respect to securities 
transactions.  The  Corporation’s  obligations  in  this  respect  are 
secured by the assets in the clients’ accounts and the accounts 
of their customers as well as by any proceeds received from the 
transactions cleared and settled by the firm on behalf of clients 
or their customers. The Corporation’s maximum potential exposure 
under these arrangements is difficult to estimate; however, the 
potential for the Corporation to incur material losses pursuant to 
these arrangements is remote.

Other Guarantees
The Corporation has entered into additional guarantee agreements 
and commitments, including sold risk participation swaps, liquidity 
facilities, 
lease-end  obligation  agreements,  partial  credit 
guarantees on certain leases, real estate joint venture guarantees, 
divested business commitments and sold put options that require 
gross settlement. The maximum potential future payment under 
these  agreements  was  approximately  $5.9  billion  at  both 
December 31, 2018 and 2017. The estimated maturity dates of 
these obligations extend up to 2040. The Corporation has made 
no  material  payments  under  these  guarantees.  For  more 
information  on  maximum  potential  future  payments  under  VIE-
related liquidity commitments at December 31, 2018, see Note 7 
– Securitizations and Other Variable Interest Entities. 

In the normal course of business, the Corporation periodically 
guarantees  the  obligations  of  its  affiliates  in  a  variety  of 
transactions  including  ISDA-related  transactions  and  non-ISDA 
related  transactions  such  as  commodities  trading,  repurchase 
agreements, prime brokerage agreements and other transactions.

Payment Protection Insurance 
On June 1, 2017, the Corporation sold its non-U.S. consumer credit 
card business. Included in the calculation of the gain on sale, the 

Corporation recorded an obligation to indemnify the purchaser for 
substantially  all  payment  protection  insurance  exposure  above 
reserves assumed by the purchaser.

Representations  and  Warranties  Obligations  and 
Corporate Guarantees
The Corporation securitizes first-lien residential mortgage loans 
generally in the form of RMBS guaranteed by the GSEs or by GNMA 
in  the  case  of  FHA-insured,  VA-guaranteed  and  Rural  Housing 
Service-guaranteed mortgage loans, and sells pools of first-lien 
residential mortgage loans in the form of whole loans. In addition, 
in  prior  years,  legacy  companies  and  certain  subsidiaries  sold 
pools of first-lien residential mortgage loans and home equity loans 
as private-label securitizations or in the form of whole loans. In 
connection with these transactions, the Corporation or certain of 
its subsidiaries or legacy companies make and have made various 
representations 
these 
representations and warranties have resulted in and may continue 
to result in the requirement to repurchase mortgage loans or to 
otherwise make whole or provide indemnification or other remedies 
to sponsors, investors, securitization trusts, guarantors, insurers 
or other parties (collectively, repurchases).

and  warranties.  Breaches 

of 

Unresolved Repurchase Claims
Unresolved  representations  and  warranties  repurchase  claims 
represent  the  notional  amount  of  repurchase  claims  made  by 
counterparties, typically the outstanding principal balance or the 
unpaid principal balance at the time of default. In the case of first-
lien mortgages, the claim amount is often significantly greater than 
the expected loss amount due to the benefit of collateral and, in 
some  cases,  mortgage  insurance  or  mortgage  guarantee 
payments.  Claims 
remain 
outstanding until the underlying loan is repurchased, the claim is 
rescinded  by  the  counterparty,  the  Corporation  determines  that 
the  applicable  statute  of 
limitations  has  expired,  or 
representations  and  warranties  claims  with  respect  to  the 
applicable trust are settled, and fully and finally released. 

from  a  counterparty 

received 

The  notional  amount  of  unresolved  repurchase  claims  at 
December 31, 2018 and 2017 was $14.4 billion and $17.6 billion. 
This balance included $6.2 billion and $6.9 billion of claims related 
to loans in specific private-label securitization groups or tranches 
where the Corporation owns substantially all of the outstanding 
securities or will otherwise realize the benefit of any repurchase 
claims paid. The balance also includes $1.5 billion of repurchase 
claims related to a single monoline insurer and is the subject of 
litigation.

During  2018,  the  Corporation  received  $283  million  in  new 
repurchase  claims,  including  $201  million  in  claims  that  were 
deemed  time-barred.  During  2018,  $3.5  billion  in  claims  were 
resolved, including $2.2 billion of claims that were deemed time-
barred and $1.1 billion related to settlements. Although the pace 
of  new  claims  has  declined,  it  is  possible  the  Corporation  will 
receive additional claims or file requests in the future. 

Reserve and Related Provision
The reserve for representations and warranties obligations and 
corporate guarantees at December 31, 2018 and 2017 was $2.0 
billion and $1.9 billion and is included in accrued expenses and 
other liabilities on the Consolidated Balance Sheet and the related 
provision  is  included  in  other  income  in  the  Consolidated 
Statement of Income. The representations and warranties reserve 
represents the Corporation’s best estimate of probable incurred 
losses.  This  reserve  considers  a  number  of  provisional 
settlements with sponsors, investors and trustees, some of which 

Bank of America 2018     149 

are subject to trustee approval processes, which may include court 
proceedings. Future representations and warranties losses may 
occur  in  excess  of  the  amounts  recorded  for  these  exposures; 
however,  the  Corporation  does  not  expect  such  amounts  to  be 
material. Future provisions for representations and warranties may 
be significantly impacted if actual experiences are different from 
the  Corporation’s  assumptions  in  predictive  models.  The 
Corporation has combined the range of reasonably possible losses 
that are in excess of the representations and warranties reserve 
with  the  litigation  range  of  possible  loss  in  excess  of  litigation 
reserves, as discussed in Litigation and Regulatory Matters in this 
Note.  This  is  consistent  with  the  reduction  in  outstanding 
representations and warranties exposure in comparison to prior 
periods resulting from the resolution of prior matters along with 
changes in the Corporation’s business model.  

The  reserve  for  representations  and  warranties  exposures 
does not consider certain losses related to servicing, including 
foreclosure and related costs, fraud, indemnity, or claims (including 
for  RMBS)  related  to  securities  law  or  monoline  insurance 
litigation. Losses with respect to one or more of these matters 
could  be  material  to  the  Corporation’s  results  of  operations  or 
liquidity for any particular reporting period. 

Litigation and Regulatory Matters
In  the  ordinary  course  of  business,  the  Corporation  and  its 
subsidiaries are routinely defendants in or parties to many pending 
and  threatened  legal,  regulatory  and  governmental  actions  and 
proceedings.  In  view  of  the  inherent  difficulty  of  predicting  the 
outcome of such matters, particularly where the claimants seek 
very large or indeterminate damages or where the matters present 
novel  legal  theories  or  involve  a  large  number  of  parties,  the 
Corporation generally cannot predict the eventual outcome of the 
pending matters, timing of the ultimate resolution of these matters, 
or eventual loss, fines or penalties related to each pending matter.
In  accordance  with  applicable  accounting  guidance,  the 
Corporation establishes an accrued liability when those matters 
present loss contingencies that are both probable and estimable. 
In such cases, there may be an exposure to loss in excess of any 
amounts  accrued.  As  a  matter  develops,  the  Corporation,  in 
conjunction  with  any  outside  counsel  handling  the  matter, 
evaluates on an ongoing basis whether such matter presents a 
loss contingency that is probable and estimable. Once the loss 
contingency is deemed to be both probable and estimable, the 
Corporation  will  establish  an  accrued  liability  and  record  a 
litigation-related  expense.  The 
corresponding  amount  of 
Corporation  continues  to  monitor  the  matter 
further 
developments that could affect the amount of the accrued liability 
that  has  been  previously  established.  Excluding  expenses  of 
internal  and  external  legal  service  providers,  litigation-related 
expense of $469 million and $753 million was recognized in 2018 
and 2017.

for 

For a limited number of the matters disclosed in this Note for 
which a loss, whether in excess of a related accrued liability or 
where there is no accrued liability, is reasonably possible in future 
periods, the Corporation is able to estimate a range of possible 
loss. In determining whether it is possible to estimate a range of 
possible loss, the Corporation reviews and evaluates its matters 
on  an  ongoing  basis,  in  conjunction  with  any  outside  counsel 
handling the matter, in light of potentially relevant factual and legal 
developments. With respect to the matters disclosed in this Note, 
in cases in which the Corporation possesses sufficient appropriate 
information to estimate a range of possible loss, that estimate is 
aggregated and disclosed below. There may be other disclosed 
matters for which a loss is probable or reasonably possible but 

150     Bank of America 2018

such an estimate of the range of possible loss may not be possible. 
For such matters disclosed in this Note, where an estimate of the 
range of possible loss is possible, as well as for representations 
and warranties exposures, management currently estimates the 
aggregate range of reasonably possible loss for these exposures 
is $0 to $1.9 billion in excess of the accrued liability, if any. This 
estimated range of possible loss is based upon currently available 
information and is subject to significant judgment and a variety of 
assumptions and known and unknown uncertainties. The matters 
underlying the estimated range will change from time to time, and 
actual  results  may  vary  significantly  from  the  current  estimate. 
Therefore, this estimated range of possible loss represents what 
the Corporation believes to be an estimate of possible loss only 
for certain matters meeting these criteria. It does not represent 
the Corporation’s maximum loss exposure. 

Information  is  provided  below  regarding  the  nature  of  the 
litigation contingencies and, where specified, the amount of the 
claim associated with these loss contingencies. Based on current 
knowledge, management does not believe that loss contingencies 
arising  from  pending  matters,  including  the  matters  described 
herein,  will  have  a  material  adverse  effect  on  the  consolidated 
financial position or liquidity of the Corporation. However, in light 
of the inherent uncertainties involved in these matters, some of 
which are beyond the Corporation’s control, 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  the  Corporation’s  results  of  operations  or  liquidity  for  any 
particular reporting period.

Ambac Bond Insurance Litigation
Ambac  Assurance  Corporation  and  the  Segregated  Account  of 
Ambac Assurance Corporation (together, Ambac) have filed four 
separate  lawsuits  against  the  Corporation  and  its  subsidiaries 
relating  to  bond  insurance  policies  Ambac  provided  on  certain 
securitized pools of HELOCs, first-lien subprime home equity loans, 
fixed-rate second-lien mortgage loans and negative amortization 
pay  option  adjustable-rate  mortgage  loans.  Ambac  alleges  that 
they  have  paid  or  will  pay  claims  as  a  result  of  defaults  in  the 
underlying loans and asserts that the defendants misrepresented 
the characteristics of the underlying loans and/or breached certain 
contractual 
the 
underwriting and servicing of the loans. In those actions where 
the Corporation is named as a defendant, Ambac contends the 
Corporation is liable on various successor and vicarious liability 
theories.

representations  and  warranties 

regarding 

Ambac v. Countrywide I
The Corporation, Countrywide and other Countrywide entities are 
named as defendants in an action filed on September 28, 2010 
in New York Supreme Court. Ambac asserts claims for fraudulent 
inducement as well as breach of contract and seeks damages in 
excess of $2.2 billion, plus punitive damages.

judgment 

rulings.  Ambac  appealed 

On May 16, 2017, the First Department issued its decisions 
on the parties’ cross-appeals of the trial court’s October 22, 2015 
summary 
the  First 
Department’s rulings requiring Ambac to prove all of the elements 
of its fraudulent inducement claim, including justifiable reliance 
and loss causation; restricting Ambac’s sole remedy for its breach 
of contract claims to the repurchase protocol of cure, repurchase 
or  substitution  of  any  materially  defective  loan;  and  dismissing 
Ambac’s claim for reimbursements of attorneys’ fees. On June 27, 
2018, the New York Court of Appeals affirmed the First Department 
rulings that Ambac appealed.

Ambac v. Countrywide II
On  December  30,  2014,  Ambac  filed  a  complaint  in  New  York 
Supreme Court against the same defendants, claiming fraudulent 
inducement  against  Countrywide,  and  successor  and  vicarious 
liability against the Corporation. Ambac seeks damages in excess 
of $600 million, plus punitive damages. On December 19, 2016, 
the Court granted in part and denied in part Countrywide’s motion 
to dismiss the complaint.

Ambac v. Countrywide IV
On July 21, 2015, Ambac filed an action in New York Supreme 
Court  against  Countrywide  asserting  the  same  claims  for 
fraudulent inducement that Ambac asserted in the now-dismissed 
Ambac v. Countrywide III. The complaint seeks damages in excess 
of $350 million, plus punitive damages.

Ambac v. First Franklin
On  April  16,  2012,  Ambac  filed  an  action  against  BANA,  First 
Franklin and various Merrill Lynch entities, including Merrill Lynch, 
Pierce,  Fenner  &  Smith  Incorporated  (MLPF&S),  in  New  York 
Supreme Court relating to guaranty insurance Ambac provided on 
a  First  Franklin  securitization  sponsored  by  Merrill  Lynch.  The 
complaint alleges fraudulent inducement and breach of contract, 
including breach of contract claims against BANA based upon its 
servicing  of  the  loans  in  the  securitization.  Ambac  seeks  as 
damages hundreds of millions of dollars that Ambac alleges it has 
paid or will pay in claims.

Deposit Insurance Assessment
On January 9, 2017, the FDIC filed suit against BANA in U.S. District 
Court for the District of Columbia alleging failure to pay a December 
15, 2016 invoice for additional deposit insurance assessments 
and interest in the amount of $542 million for the quarters ending 
June 30, 2013 through December 31, 2014. On April 7, 2017, the 
FDIC amended its complaint to add a claim for additional deposit 
insurance  and  interest  in  the  amount  of  $583  million  for  the 
quarters ending March 31, 2012 through March 31, 2013. The 
FDIC asserts these claims based on BANA’s alleged underreporting 
of  counterparty  exposures  that  resulted  in  underpayment  of 
assessments for those quarters. BANA disagrees with the FDIC’s 
interpretation of the regulations as they existed during the relevant 
time  period  and  is  defending  itself  against  the  FDIC’s  claims. 
Pending final resolution, BANA has pledged security satisfactory 
to  the  FDIC  related  to  the  disputed  additional  assessment 
amounts. 

On March 27, 2018, the U.S. District Court for the District of 
Columbia denied BANA’s partial motion to dismiss certain of the 
FDIC’s claims.

Interchange and Related Litigation
In  2005,  a  group  of  merchants  filed  a  series  of  putative  class 
actions  and  individual  actions  directed  at  interchange  fees 
associated with Visa and MasterCard payment card transactions. 
These actions, which were consolidated in the U.S. District Court 
for the Eastern District of New York under the caption In re Payment 
Card Interchange Fee and Merchant Discount Anti-Trust Litigation 
(Interchange),  named  Visa,  MasterCard  and  several  banks  and 
bank holding companies, including the Corporation, as defendants. 
Plaintiffs  alleged  that  defendants  conspired  to  fix  the  level  of 
default  interchange  rates  and  that  certain  rules  of  Visa  and 
MasterCard  were  unreasonable  restraints  of  trade.  Plaintiffs 
sought compensatory and treble damages and injunctive relief.

On October 19, 2012, defendants reached a settlement with 
respect to the putative class actions that the U.S. Court of Appeals 
for the Second Circuit rejected. In 2018, defendants reached a 

settlement with the representatives of the putative Rule 23(b)(3) 
damages  class  to  contribute  an  additional  $900  million  to  the 
approximately $5.3 billion held in escrow from the prior settlement. 
The  Corporation’s  additional  contribution  is  not  material  to  the 
Corporation. The District Court granted preliminary approval of the 
settlement  with  the  putative  Rule  23(b)(3)  damages  class  in 
January 2019.

In  addition,  the  putative  Rule  23(b)(2)  class  action  seeking 
injunctive relief is pending, and a number of individual merchant 
actions  continue  against  the  defendants,  including  one  against 
the Corporation. As a result of various loss-sharing agreements, 
however,  the  Corporation  remains  liable  for  a  portion  of  any 
settlement or judgment in individual suits where it is not named 
as a defendant.

LIBOR, Other Reference Rates, Foreign Exchange (FX) and 
Bond Trading Matters
Government  authorities  in  the  U.S.  and  various  international 
jurisdictions continue to conduct investigations, to make inquiries 
of,  and  to  pursue  proceedings  against,  the  Corporation  and  its 
subsidiaries  regarding  FX  and  other  reference  rates  as  well  as 
government,  sovereign,  supranational  and  agency  bonds  in 
connection  with  conduct  and  systems  and  controls.  The 
Corporation is cooperating with these inquiries and investigations 
and responding to the proceedings. 

Foreign Exchange (FX) 
The Corporation, BANA and MLPF&S were named as defendants 
along with other FX market participants in a putative class action 
filed in the U.S. District Court for the Southern District of New York, 
in which plaintiffs allege that they sustained losses as a result of 
the  defendants’  alleged  conspiracy  to  manipulate  the  prices  of 
OTC FX transactions and FX transactions on an exchange. Plaintiffs 
assert antitrust claims and claims for violations of the Commodity 
Exchange Act (CEA) and seek compensatory and treble damages, 
as well as declaratory and injunctive relief. On October 1, 2015, 
the Corporation, BANA and MLPF&S executed a final settlement 
agreement,  in  which  they  agreed  to  pay  participating  class 
members  $187.5  million  to  settle  the  litigation.  In  2018,  the 
District Court granted final approval to the settlement.

LIBOR
The Corporation, BANA and certain Merrill Lynch entities have been 
named  as  defendants  along  with  most  of  the  other  London 
InterBank  Offered  Rate  (LIBOR)  panel  banks  in  a  number  of 
individual  and  putative  class  actions  by  persons  alleging  they 
sustained losses on U.S. dollar LIBOR-based financial instruments 
as a result of collusion or manipulation by defendants regarding 
the setting of U.S. dollar LIBOR. Plaintiffs assert a variety of claims, 
including  antitrust,  CEA,  Racketeer  Influenced  and  Corrupt 
Organizations (RICO), Securities Exchange Act of 1934, common 
law fraud and breach of contract claims, and seek compensatory, 
treble and punitive damages, and injunctive relief. All cases naming 
the Corporation and its affiliates relating to U.S. dollar LIBOR are 
pending in the U.S. District Court for the Southern District of New 
York.

The  District  Court  has  dismissed  all  RICO  claims,  and 
dismissed all manipulation claims based on alleged trader conduct 
against  Bank  of  America  entities.  The  District  Court  has  also 
substantially limited the scope of antitrust, CEA and various other 
claims, including by dismissing in their entirety certain individual 
and putative class plaintiffs’ antitrust claims for lack of standing 
and/or personal jurisdiction. Plaintiffs whose antitrust claims were 
dismissed by the District Court are pursuing appeals in the Second 
Circuit. Certain  individual  and  putative  class  actions  remain 

Bank of America 2018     151 

pending in the District Court against the Corporation, BANA and 
certain Merrill Lynch entities.

On February 28, 2018, the District Court denied certification 
of  proposed  classes  of  lending  institutions  and  persons  that 
transacted in eurodollar futures, and the U.S. Court of Appeals for 
the Second Circuit subsequently denied petitions filed by those 
plaintiffs  for  interlocutory  appeals  of  those  rulings.  Also  on 
February  28,  2018,  the  District  Court  granted  certification  of  a 
class  of  persons  that  purchased  OTC  swaps  and  notes  that 
referenced U.S. dollar LIBOR from one of the U.S. dollar LIBOR 
panel banks, limited to claims under Section 1 of the Sherman 
Act. The U.S. Court of Appeals for the Second Circuit subsequently 
denied a petition filed by the defendants for interlocutory appeal 
of that ruling.

Mortgage Appraisal Litigation
The Corporation and certain subsidiaries are named as defendants 
in two putative class action lawsuits filed in U.S. District Court for 
the Central District of California (Waldrup and Williams, et al.). In 
November  2016,  the  actions  were  consolidated  for  pre-trial 
purposes.  Plaintiffs  allege  that  in  fulfilling  orders  made  by 
Countrywide for residential mortgage appraisal services, a former 
Countrywide  subsidiary,  LandSafe  Appraisal  Services,  Inc., 
arranged for and completed appraisals that were not in compliance 
with  applicable  laws  and  appraisal  standards.  Plaintiffs  seek, 
among other forms of relief, compensatory and treble damages.

On  February  8,  2018,  the  District  Court  granted  plaintiffs’ 
motion for class certification. On May 22, 2018, the U.S. Court of 
Appeals  for  the  Ninth  Circuit  denied  Defendants’  petition  for 
permission to file an interlocutory appeal of the District Court’s 
ruling granting class certification.

Mortgage-backed Securities Litigation 
The Corporation and its affiliates, Countrywide entities and their 
affiliates, and Merrill Lynch entities and their affiliates have been 
named as defendants in cases relating to their various roles in 
MBS offerings and, in certain instances, have received claims for 
contractual indemnification related to the MBS securities actions. 
these  cases  generally  sought  unspecified 
Plaintiffs 

in 

compensatory and/or rescissory damages, unspecified costs and 
legal fees and generally alleged false and misleading statements. 
The  indemnification  claims  include  claims  from  underwriters  of 
MBS that were issued by these entities, and from underwriters 
and issuers of MBS backed by loans originated by these entities.

Mortgage Repurchase Litigation

U.S. Bank - Harborview Repurchase Litigation
On August 29, 2011, U.S. Bank, National Association (U.S. Bank), 
as trustee for the HarborView Mortgage Loan Trust 2005-10 (the 
Trust), a mortgage pool backed by loans originated by Countrywide 
Home Loans, Inc. (CHL), filed a complaint in New York Supreme 
Court against the Corporation and various subsidiaries alleging 
breaches  of  representations  and  warranties.  This  litigation  has 
been  stayed  since  March  23,  2017,  pending  finalization  of  the 
settlement discussed below.

On December 5, 2016, the defendants and certain certificate-
holders in the Trust agreed to settle the litigation in an amount 
not  material  to  the  Corporation,  subject  to  acceptance  by  U.S. 
Bank. 

U.S. Bank - SURF/OWNIT Repurchase Litigation
On August 29, 2014 and September 2, 2014, U.S. Bank, as trustee 
for  seven  securitization  trusts  (the  Trusts),  served  seven 
summonses  with  notice  commencing  actions  against  various 
subsidiaries of the Corporation in New York Supreme Court. The 
summonses  advance  breach  of  contract  claims  alleging  that 
defendants breached representations and warranties related to 
loans  securitized  in  the  Trusts.  The  summonses  allege  that 
defendants failed to repurchase breaching mortgage loans from 
the Trusts, and seek specific performance of defendants’ alleged 
obligation to repurchase breaching loans, declaratory judgment, 
compensatory, rescissory and other damages, and indemnity. 

U.S. Bank has served complaints regarding six of the seven 
Trusts. In 2018, for those six Trusts, the defendants and certain 
certificate-holders  agreed  to  settle  the  respective  litigations  in 
amounts not material to the Corporation, subject to acceptance 
by U.S. Bank. 

152     Bank of America 2018

NOTE 13 Shareholders’ Equity

Common Stock

Declared Quarterly Cash Dividends on Common Stock (1)

Declaration Date

Record Date

Payment Date

Dividend
Per Share

January 30, 2019
October 24, 2018
July 26, 2018
April 25, 2018
January 31, 2018
(1) 

March 1, 2019
December 7, 2018
September 7, 2018
June 1, 2018
March 2, 2018
In 2018, and through February 26, 2019.

$

March 29, 2019
December 28, 2018
September 28, 2018
June 29, 2018
March 30, 2018

0.15
0.15
0.15
0.12
0.12

The  cash  dividends  paid  per  share  of  common  stock  were 
$0.54, $0.39 and $0.25 for 2018, 2017 and 2016, respectively.
The following table summarizes common stock repurchases 

during 2018, 2017 and 2016.

Common Stock Repurchase Summary

(in millions)
Total share repurchases, including CCAR

capital plan repurchases

2018

2017

2016

676

509

333

Purchase price of shares repurchased and 

retired (1)

CCAR capital plan repurchases
Other authorized repurchases
   Total shares repurchased

$ 16,754
3,340
$ 20,094

$ 9,347
3,467
$12,814

$ 4,312
800
$ 5,112

(1)  Represents reductions to shareholders’ equity due to common stock repurchases.

On June 28, 2018, following the non-objection of the Board of 
Governors of the Federal Reserve System (Federal Reserve) to the 
Corporation’s 2018 Comprehensive Capital Analysis and Review 
(CCAR) capital plan, the Board of Directors (Board) authorized the 
repurchase of approximately $20.6 billion in common stock from 
July 1, 2018 through June 30, 2019, which includes approximately 
$600 million in repurchases to offset shares awarded under equity-
based compensation plans during the same period. The common 
stock repurchase authorization includes both common stock and 
warrants.

During  2018,  the  Corporation  repurchased  $20.1  billion  of 
common stock in connection with the 2018 and 2017 CCAR capital 
plans  and  pursuant  to  a  December  5,  2017  authorization  to 
repurchase an additional $5.0 billion in common stock.

At  December  31,  2018,  the  Corporation  had  warrants 
outstanding and exercisable to purchase 121 million shares of 
common  stock.  These  warrants,  substantially  all  of  which  were 
exercised on or before the expiration date of January 16, 2019, 
were  originally  issued  in  connection  with  a  preferred  stock 
issuance to the U.S. Department of the Treasury in 2009 and were 
listed on the New York Stock Exchange.

On August 24, 2017, the holders of the Corporation’s Series 
T 6% Non-cumulative preferred stock (Series T) exercised warrants 
to acquire 700 million shares of the Corporation’s common stock. 
The  carrying  value  of  the  preferred  stock  was  $2.9  billion  and, 
upon conversion, was recorded as additional paid-in capital. For 
more information, see Note 15 – Earnings Per Common Share.

In  connection  with  employee  stock  plans,  in  2018,  the 
Corporation issued 75 million shares of its common stock and, to 

satisfy tax withholding obligations, repurchased 29 million shares 
of its common stock. At December 31, 2018, the Corporation had 
reserved 781 million unissued shares of common stock for future 
issuances under employee stock plans, common stock warrants, 
convertible notes and preferred stock.

Preferred Stock
The cash dividends declared on preferred stock were $1.5 billion, 
$1.6  billion  and  $1.7  billion  for  2018,  2017  and  2016, 
respectively. 

On March 15, 2018, the Corporation issued 94,000 shares of 
5.875%  Fixed-to-Floating  Rate  Non-Cumulative  Preferred  Stock, 
Series  FF  for  $2.35  billion.  On  May  16,  2018,  the  Corporation 
issued  54,000  shares  of  6.000%  Fixed  Rate  Non-Cumulative 
Preferred Stock, Series GG for $1.35 billion. On July 24, 2018, 
the Corporation issued 34,160 shares of 5.875% Non-Cumulative 
Preferred Stock, Series HH for $854 million. 

In  2018,  the  Corporation  fully  redeemed  Series  D,  Series  I, 
Series K, Series M and Series 3 preferred stock for a total of $4.5 
billion.

All series of preferred stock in the Preferred Stock Summary 
table have a par value of $0.01 per share, are not subject to the 
operation of a sinking fund, have no participation rights, and with 
the exception of the Series L Preferred Stock, are not convertible. 
The holders of the Series B Preferred Stock and Series 1 through 
5 Preferred Stock have general voting rights and vote together with 
the common stock. The holders of the other series included in the 
table  have  no  general  voting  rights.  All  outstanding  series  of 
preferred  stock  of  the  Corporation  have  preference  over  the 
Corporation’s  common  stock  with  respect  to  the  payment  of 
dividends and distribution of the Corporation’s assets in the event 
of a liquidation or dissolution. With the exception of the Series B, 
F, G and T Preferred Stock, if any dividend payable on these series 
is in arrears for three or more semi-annual or six  or more quarterly 
dividend periods, as applicable (whether consecutive or not), the 
holders of these series and any other class or series of preferred 
stock ranking equally as to payment of dividends and upon which 
equivalent voting rights have been conferred and are exercisable 
(voting as a single class) will be entitled to vote for the election 
of two additional directors. These voting rights terminate when the 
Corporation has paid in full dividends on these series for at least 
two semi-annual or four quarterly dividend periods, as applicable, 
following the dividend arrearage.

The  7.25%  Non-Cumulative  Perpetual  Convertible  Preferred 
Stock,  Series  L  (Series  L  Preferred  Stock)  does  not  have  early 
redemption/call rights. Each share of the Series L Preferred Stock 
may be converted at any time, at the option of the holder, into 20
shares  of  the Corporation’s  common  stock  plus  cash  in  lieu  of 
fractional shares. The Corporation may cause some or all of the 
Series L Preferred Stock, at its option, at any time or from time to 
time, to be converted into shares of common stock at the then-
applicable conversion rate if, for 20  trading days during any period 
of 30  consecutive trading days, the closing price of common stock 
exceeds 130 percent of the then-applicable conversion price of 
the Series L Preferred Stock. If a conversion of Series L Preferred 
Stock occurs at the option of the holder, subsequent to a dividend 
record date but prior to the dividend payment date, the Corporation 
will still pay any accrued dividends payable.

The  table  on  the  following  page  presents  a  summary  of 

perpetual preferred stock outstanding at December 31, 2018.

Bank of America 2018     153 

Preferred Stock Summary

(Dollars in millions, except as noted)

Series

Description

Initial
Issuance
Date

Total
Shares
Outstanding

Liquidation
Preference
per Share
(in dollars)

Carrying
Value

Per Annum
Dividend Rate

Dividend per 
Share
(in dollars)

Annual
Dividend

Redemption Period (1)

Series B

Series E (2)

Series F 

Series G

Series L

7% Cumulative
Redeemable

June
1997

Floating Rate Non-
Cumulative

November
2006

Floating Rate Non-
Cumulative

Adjustable Rate Non-
Cumulative

7.25% Non-
Cumulative Perpetual
Convertible

Series T

6% Non-cumulative

Series U (4)

Fixed-to-Floating Rate 
Non-Cumulative

March
2012

March
2012

January
2008

September
2011

May
2013

June
2014

Series V (4)

Series W (2)

Series X (4)

Series Y (2)

Fixed-to-Floating Rate 
Non-Cumulative

6.625% Non-
Cumulative

September 
2014

Fixed-to-Floating Rate 
Non-Cumulative

September 
2014

6.500% Non-
Cumulative

January      
2015

7,110

$

100

$

1

7.00% $

7.00

$

12,691

25,000

317

3-mo. LIBOR + 35 bps (3)

1.01

1,409

100,000

141

3-mo. LIBOR + 40 bps (3)

4,055.56

4,926

100,000

493

3-mo. LIBOR + 40 bps (3)

4,055.56

—

13

6

20

n/a

On or after
November 15, 2011

On or after
March 15, 2012

On or after
March 15, 2012

3,080,182

1,000

3,080

7.25%

72.50

223

n/a

354

100,000

35

6.00%

6,000.00

2

After May 7, 2019

40,000

25,000

1,000

60,000

25,000

1,500

5.2% to, but excluding, 
6/1/23; 3-mo. LIBOR + 
313.5 bps thereafter

5.125% to, but excluding,
6/17/19; 3-mo. LIBOR +
338.7 bps thereafter

52.00

51.25

44,000

25,000

1,100

6.625%

1.66

52

77

73

80,000

25,000

2,000

6.250% to, but excluding,
9/5/24; 3-mo. LIBOR +
370.5 bps thereafter

62.50

125

44,000

25,000

1,100

6.500%

1.63

6.500% to, but excluding,
10/23/24; 3-mo. LIBOR +
417.4 bps thereafter

6.100% to, but excluding,
3/17/25; 3-mo. LIBOR +
389.8 bps thereafter

Series Z (4)

Fixed-to-Floating Rate 
Non-Cumulative

October      
2014

56,000

25,000

1,400

65.00

Series AA (4)

Series CC (2)

Series DD (4)

Series EE (2)

Series FF (4)

Series GG (2)

Series HH (2)

Series 1 (5)

Series 2 (5)

Series 4 (5)

Series 5 (5)

Fixed-to-Floating Rate 
Non-Cumulative

6.200% Non-
Cumulative

March       
2015

January      
2016

Fixed-to-Floating Rate 
Non-Cumulative

6.000% Non-
Cumulative

March      
2016

April         
2016

76,000

25,000

1,900

61.00

116

44,000

25,000

1,100

6.200%

1.55

40,000

25,000

1,000

6.300% to, but excluding,
3/10/26; 3-mo. LIBOR +
455.3 bps thereafter

63.00

36,000

25,000

900

6.000%

1.50

Fixed-to-Floating Rate 
Non-Cumulative

March      
2018

94,000

25,000

2,350

5.875% to, but excluding, 
3/15/28; 3-mo. LIBOR + 
293.1 bps thereafter

6.000% Non-
Cumulative

5.875% Non-
Cumulative

May
2018

July
2018

Floating Rate Non-
Cumulative

November
2004

Floating Rate Non-
Cumulative

March
2005

Floating Rate Non-
Cumulative

November
2005

Floating Rate Non-
Cumulative

March
2007

54,000

25,000

1,350

34,160

25,000

854

6.000%

5.875%

3,275

30,000

98

3-mo. LIBOR + 75 bps (6)

9,967

30,000

299

3-mo. LIBOR + 65 bps (6)

7,010

30,000

210

3-mo. LIBOR + 75 bps (3)

14,056

30,000

3-mo. LIBOR + 50 bps (3)

422

(324)

29.38

0.75

0.73

0.76

0.76

1.01

1.01

Issuance costs and certain adjustments

Total

3,843,140

$

22,326

(1)  The Corporation may redeem series of preferred stock on or after the redemption date, in whole or in part, at its option, at the liquidation preference plus declared and unpaid dividends. Series B 

and Series L Preferred Stock do not have early redemption/call rights.

(2)  Ownership is held in the form of depositary shares, each representing a 1/1,000th interest in a share of preferred stock, paying a quarterly cash dividend, if and when declared.
(3)  Subject to 4.00% minimum rate per annum.
(4)  Ownership is held in the form of depositary shares, each representing a 1/25th interest in a share of preferred stock, paying a semi-annual cash dividend, if and when declared, until the first 

redemption date at which time, it adjusts to a quarterly cash dividend, if and when declared, thereafter.

(5)  Ownership is held in the form of depositary shares, each representing a 1/1,200th interest in a share of preferred stock, paying a quarterly cash dividend, if and when declared.
(6)  Subject to 3.00% minimum rate per annum.
n/a = not applicable

154     Bank of America 2018

On or after
June 1, 2023

On or after
June 17, 2019

On or after
September 9, 2019

On or after
September 5, 2024

On or after
January 27, 2020

On or after
October 23, 2024

On or after
March 17, 2025

On or after
January 29, 2021

On or after
March 10, 2026

On or after
April 25, 2021

On or after
March 15, 2028

On or after
May 16, 2023

On or after
July 24, 2023

On or after
November 28, 2009

On or after
November 28, 2009

On or after
November 28, 2010

On or after
May 21, 2012

72

91

68

63

54

69

41

25

3

9

9

17

 
 
 
 
 
NOTE 14 Accumulated Other Comprehensive Income (Loss)
The table below presents the changes in accumulated OCI after-tax for 2016, 2017 and 2018. 

(Dollars in millions)

Debt and 
Equity Securities 

Debit Valuation
Adjustments

Derivatives

Employee
Benefit Plans

Foreign
Currency

Total

$

$

Net change

Net change

Balance, December 31, 2015

Balance, December 31, 2017

Balance, December 31, 2016

(5,358)
(1,930)
(7,288)
206
(7,082)
(1,270)
57
(3,916)
(12,211)
Balance, December 31, 2018
(1)  Effective January 1, 2018, the Corporation adopted the accounting standard on tax effects in accumulated OCI related to the Tax Act. Accordingly, certain tax effects were reclassified from accumulated 

Accounting change related to certain tax effects (1)
Cumulative adjustment for hedge accounting change (2)
Net change

78
(1,345)
(1,267) $
61
(1,206) $
(393)
—
(3,953)
(5,552) $

(2,956) $
(524)
(3,480) $
288
(3,192) $
(707)
—
(405)
(4,304) $

(611) $
(156)
(767) $
(293)
(1,060) $
(220)
—
749
(531) $

(831) $
(189)
57
(53)
(1,016) $

(793) $
239
—
(254)
(808) $

(1,077) $
182
(895) $

(792) $
(87)
(879) $

64

86

$

$

$

OCI to retained earnings. For additional information, see Note 1 – Summary of Significant Accounting Principles.

(2)  Reflects the Corporation’s adoption of the new hedge accounting standard. For additional information, see Note 1 – Summary of Significant Accounting Principles.

The table below presents the net change in fair value recorded in accumulated OCI, net realized gains and losses reclassified into 

earnings and other changes for each component of OCI pre- and after-tax for 2018, 2017 and 2016.

Changes in OCI Components Pre- and After-tax

(Dollars in millions)

Debt and equity securities:
Net increase (decrease) in fair value
Net realized (gains) reclassified into earnings (1)

Net change

Debit valuation adjustments:
Net increase (decrease) in fair value
Net realized losses reclassified into earnings (1)

Net change

Derivatives:
Net (decrease) in fair value
Reclassifications into earnings:

Net interest income
Personnel expense

Net realized losses reclassified into earnings

Net change
Employee benefit plans:
Net increase (decrease) in fair value
Net actuarial losses and other reclassified into earnings (2)
Settlements, curtailments and other

Net change
Foreign currency:
Net (decrease) in fair value
Net realized (gains) losses reclassified into earnings (1)

Pretax

Tax 
effect

2018

After-
tax

Pretax

Tax 
effect

2017

After-
tax

Pretax

Tax
effect

2016

After-
tax

$ (5,189) $ 1,329
30
1,359

(123)
(5,312)

$ (3,860) $
(93)
(3,953)

952
26
978

(224)
(5)
(229)

728
21
749

$

240
(304)
(64)

(490)
42
(448)

14
111
125

171
(16)
155

$

254
(193)
61

$ (1,694) $
(471)
(2,165)

641
179
820

$ (1,053)
(292)
(1,345)

(319)
26
(293)

(271)
17
(254)

104
(6)
98

(167)
11
(156)

(232)

74

(158)

(50)

1

(49)

(299)

113

(186)

165
(27)
138
(94)

(703)
171
11
(521)

(40)
7
(33)
41

164
(46)
(2)
116

125
(20)
105
(53)

(539)
125
9
(405)

327
(148)
179
129

223
179
3
405

(122)
56
(66)
(65)

(55)
(61)
(1)
(117)

205
(92)
113
64

168
118
2
288

553
32
585
286

(921)
97
15
(809)

(205)
(12)
(217)
(104)

329
(36)
(8)
285

348
20
368
182

(592)
61
7
(524)

(195)
98
(97)
$ (5,106) $ 1,190
(1)  Reclassifications of pretax debt and equity securities, DVA and foreign currency (gains) losses are recorded in other income in the Consolidated Statement of Income.
(2)  Reclassifications of pretax employee benefit plan costs are recorded in other general operating expense in the Consolidated Statement of Income.

430
701
1,131
$ (3,916) $ (1,023) $ 1,229

514
—
514
$ (2,428) $

Total other comprehensive income (loss)

(439)
(606)
(1,045)

(9)
95
86
206

(203)
(51)
(254)

(8)
(149)
(157)

Net change

$

(601)
—
(601)
498

(87)
—
(87)
$ (1,930)

Bank of America 2018     155 

NOTE 15 Earnings Per Common Share
The calculation of EPS and diluted EPS for 2018, 2017 and 2016 is presented below. For more information on the calculation of EPS, 
see Note 1 – Summary of Significant Accounting Principles. 

(In millions, except per share information)

Earnings per common share
Net income
Preferred stock dividends

Net income applicable to common shareholders
Average common shares issued and outstanding
Earnings per common share

Diluted earnings per common share
Net income applicable to common shareholders
Add preferred stock dividends due to assumed conversions (1)

Net income allocated to common shareholders
Average common shares issued and outstanding
Dilutive potential common shares (2)

Total diluted average common shares issued and outstanding

Diluted earnings per common share
(1)  Represents the Series T dividends under the “if-converted” method prior to conversion.
(2) 

Includes incremental dilutive shares from RSUs, restricted stock and warrants.

The Corporation previously issued warrants to purchase 700 
million shares of the Corporation’s common stock to the holders 
of the Series T 6% Non-cumulative preferred stock (Series T) at 
an exercise price of $7.142857 per share. On August 24, 2017, 
the Series T holders exercised the warrants and acquired the 700 
million shares of the Corporation’s common stock using the Series 
T preferred stock as consideration for the exercise price, which 
increased  common  shares  outstanding,  but  had  no  effect  on 
diluted earnings per share as this conversion was included in the 
Corporation’s  diluted  earnings  per  share  calculation  under  the 
applicable  accounting  guidance.  For  2016,  the  average  dilutive 
impact of the 700 million potential common shares was included 
in the diluted share count under the “if-converted” method. 

For 2018, 2017 and 2016, 62 million average dilutive potential 
common shares associated with the Series L preferred stock were 
not included in the diluted share count because the result would 
have been antidilutive under the “if-converted” method. For 2018, 
2017 and 2016, average options to purchase 4 million, 21 million 
and  45  million  shares  of  common  stock,  respectively,  were 
outstanding but not included in the computation of EPS because 
the result would have been antidilutive under the treasury stock 
method.  For 2017 and 2016, average warrants to purchase 122 
million shares of common stock were outstanding but not included 
in the computation of EPS because the result would have been 
antidilutive  under  the  treasury  stock  method.  These  warrants 
expired on October 29, 2018. For 2018, 2017 and 2016, average 
warrants  to  purchase  136  million,  143  million  and  150  million 
shares of common stock, respectively, were included in the diluted 
EPS calculation under the treasury stock method. Substantially all 
of  the  outstanding  warrants  were  exercised  on  or  before  the 
expiration date of January 16, 2019. 

2018

2017

2016

$

$

$

$

$

$

28,147
(1,451)
26,696
10,096.5
2.64

26,696
—
26,696
10,096.5
140.4
10,236.9
2.61

$

$

$

$

$

$

18,232
(1,614)
16,618
10,195.6
1.63

16,618
186
16,804
10,195.6
582.8
10,778.4
1.56

$

$

$

$

$

$

17,822
(1,682)
16,140
10,284.1
1.57

16,140
300
16,440
10,284.1
762.7
11,046.8
1.49

NOTE 16 Regulatory Requirements and 
Restrictions
The  Federal  Reserve,  Office  of  the  Comptroller  of  the  Currency 
(OCC)  and  FDIC  (collectively,  U.S.  banking  regulators)  jointly 
establish regulatory capital adequacy guidelines, including Basel 
3, for U.S. banking organizations. As a financial holding company, 
the Corporation is subject to capital adequacy rules issued by the 
Federal  Reserve.  The  Corporation’s  banking  entity  affiliates  are 
subject to capital adequacy rules issued by the OCC.

The Corporation and its primary banking entity affiliate, BANA, 
are Advanced approaches institutions under Basel 3. As Advanced 
approaches  institutions,  the  Corporation  and  its  banking  entity 
affiliates are required to report regulatory risk-based capital ratios 
and  risk-weighted  assets  under  both  the  Standardized  and 
Advanced approaches. The approach that yields the lower ratio is 
used  to  assess  capital  adequacy,  including  under  the  Prompt 
Corrective  Action  (PCA)  framework.  At  December  31,  2018, 
Common equity tier 1 and Tier 1 capital ratios were lower under 
the  Standardized  approach  whereas  the  Advanced  approaches 
yielded a lower result for the Total capital ratio. All three ratios 
were lower under the Advanced approaches method at December 
31, 2017.

Effective  January  1,  2018,  the  Corporation  is  required  to 
maintain a minimum supplementary leverage ratio (SLR) of 3.0 
percent  plus  a  leverage  buffer  of  2.0  percent  in  order  to  avoid 
certain  restrictions  on  capital  distributions  and  discretionary 
bonus payments. The Corporation’s insured depository institution 
subsidiaries are required to maintain a minimum 6.0 percent SLR 
to be considered well capitalized under the PCA framework.

The  following  table  presents  capital  ratios  and  related 
information  in  accordance  with  Basel  3  Standardized  and 
Advanced approaches as measured at December 31, 2018 and 
2017 for the Corporation and BANA. 

156     Bank of America 2018

 
 
 
 
Regulatory Capital under Basel 3 (1)

(Dollars in millions, except as noted)

Risk-based capital metrics:

Common equity tier 1 capital
Tier 1 capital
Total capital (4)
Risk-weighted assets (in billions)
Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio

Leverage-based metrics:

Adjusted quarterly average assets (in billions) (5)
Tier 1 leverage ratio

SLR leverage exposure (in billions)
SLR

Risk-based capital metrics:

Common equity tier 1 capital
Tier 1 capital
Total capital (4)
Risk-weighted assets (in billions)
Common equity tier 1 capital ratio
Tier 1 capital ratio
Total capital ratio

Leverage-based metrics:

Adjusted quarterly average assets (in billions) (5)
Tier 1 leverage ratio

Bank of America Corporation

Bank of America, N.A.

Standardized
Approach

Advanced
Approaches

Regulatory 
Minimum (2)

Standardized
Approach

Advanced
Approaches

Regulatory 
Minimum (3)

$ 167,272
189,038
221,304
1,437

$ 167,272
189,038
212,878
1,409

11.6%
13.2
15.4

$

2,258

8.4%

$

$

11.9%
13.4
15.1

2,258

8.4%

2,791

6.8%

December 31, 2018

$ 149,824
149,824
161,760
1,195

8.25%
9.75
11.75

12.5%
12.5
13.5

$

1,719

8.7%

4.0

5.0

December 31, 2017

$ 149,824
149,824
153,627
959
15.6%
15.6
16.0

$

$

1,719

8.7%

2,112

7.1%

6.5%
8.0
10.0

5.0

6.0

$ 171,063
191,496
227,427
1,434

$ 171,063
191,496
218,529
1,449

$ 150,552
150,552
163,243
1,201

$ 150,552
150,552
154,675
1,007

11.9%
13.4
15.9

11.8%
13.2
15.1

7.25%
8.75
10.75

12.5%
12.5
13.6

14.9%
14.9
15.4

6.5%
8.0
10.0

$

2,224

$

2,224

$

1,672

$

1,672

8.6%

8.6%

4.0

9.0%

9.0%

5.0

(1)  Regulatory capital metrics at December 31, 2017 reflect Basel 3 transition provisions for regulatory capital adjustments and deductions, which were fully phased-in as of January 1, 2018.
(2)  The December 31, 2018 and 2017 amounts include a transition capital conservation buffer of 1.875 percent and 1.25 percent and a transition global systemically important bank surcharge of 

1.875 percent and 1.5 percent. The countercyclical capital buffer for both periods is zero.

(3)  Percent required to meet guidelines to be considered “well capitalized” under the PCA framework.
(4)  Total capital under the Advanced approaches differs from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.
(5)  Reflects adjusted average total assets for the three months ended December 31, 2018 and 2017.

The  capital  adequacy  rules  issued  by  the  U.S.  banking 
regulators require institutions to meet the established minimums 
outlined  in  the  table  above.  Failure  to  meet  the  minimum 
requirements  can  lead  to  certain  mandatory  and  discretionary 
actions by regulators that could have a material adverse impact 
on the Corporation’s financial position. At December 31, 2018 and 
2017, the Corporation and its banking entity affiliates were “well 
capitalized.”

Other Regulatory Matters
The Federal Reserve requires the Corporation’s bank subsidiaries 
to maintain reserve requirements based on a percentage of certain 
deposit liabilities. The average daily reserve balance requirements, 
in excess of vault cash, maintained by the Corporation with the 
Federal Reserve Bank were $11.4 billion and $8.9 billion for 2018 
and 2017. At December 31, 2018 and 2017, the Corporation had 
cash and cash equivalents in the amount of $5.8 billion and $4.1 
billion, and securities with a fair value of $16.6 billion and $17.3 
billion  that  were  segregated  in  compliance  with  securities 
regulations. Cash held on deposit with the Federal Reserve Bank 
to  meet  reserve  requirements  and  cash  and  cash  equivalents 
segregated  in  compliance  with  securities  regulations  are 
components  of  restricted  cash.  For  additional  information,  see 
Note 10 – Federal Funds Sold or Purchased, Securities Financing 
Agreements,  Short-term  Borrowings  and  Restricted  Cash.  In 

addition, at December 31, 2018 and 2017, the Corporation had 
cash  deposited  with  clearing  organizations  of  $8.1  billion  and 
$11.9  billion  primarily  recorded  in  other  assets  on  the 
Consolidated Balance Sheet.

Bank Subsidiary Distributions
The  primary  sources  of  funds  for  cash  distributions  by  the 
Corporation to its shareholders are capital distributions received 
from its bank subsidiaries, BANA and Bank of America California, 
N.A. In 2018, the Corporation received dividends of $26.1 billion
from BANA and $320 million from Bank of America California, N.A. 
In addition, Bank of America California, N.A. returned capital of 
$1.4 billion to the Corporation in 2018. 

The amount of dividends that a subsidiary bank may declare 
in a calendar year without OCC approval is the subsidiary bank’s 
net profits for that year combined with its retained net profits for 
the preceding two years. Retained net profits, as defined by the 
OCC,  consist  of  net  income  less  dividends  declared  during  the 
period.  In  2019,  BANA  can  declare  and  pay  dividends  of 
approximately $3.1 billion to the Corporation plus an additional 
amount equal to its retained net profits for 2019 up to the date 
of any such dividend declaration. Bank of America California, N.A. 
can pay dividends of $40 million in 2019 plus an additional amount 
equal to its retained net profits for 2019 up to the date of any 
such dividend declaration.

Bank of America 2018     157 

 
 
 
 
 
 
 
 
 
NOTE 17 Employee Benefit Plans

Pension and Postretirement Plans
The  Corporation  sponsors  a  qualified  noncontributory  trusteed 
pension plan (Qualified Pension Plan), a number of noncontributory 
nonqualified  pension  plans,  and  postretirement  health  and  life 
plans  that  cover  eligible  employees.  Non-U.S.  pension  plans 
sponsored by the Corporation vary based on the country and local 
practices.

The Qualified Pension Plan has a balance guarantee feature 
for  account  balances  with  participant-selected  investments, 
applied at the time a benefit payment is made from the plan that 
effectively provides principal protection for participant balances 
transferred and certain compensation credits. The Corporation is 
responsible for funding any shortfall on the guarantee feature.

Benefits earned under the Qualified Pension Plan have been 
frozen.  Thereafter,  the  cash  balance  accounts  continue  to  earn 
investment credits or interest credits in accordance with the terms 
of the plan document.

The Corporation has an annuity contract that guarantees the 
payment of benefits vested under a terminated U.S. pension plan 
(Other  Pension  Plan).  The  Corporation,  under  a  supplemental 
agreement,  may  be  responsible  for,  or  benefit  from  actual 
experience  and  investment  performance  of  the  annuity  assets. 
The  Corporation  made  no  contribution  under  this  agreement  in 
2018 or 2017. Contributions may be required in the future under 
this agreement.

The Corporation’s noncontributory, nonqualified pension plans 
are unfunded and provide supplemental defined pension benefits 
to certain eligible employees.

Pension and Postretirement Plans (1)

In  addition  to  retirement  pension  benefits,  certain  benefits-
eligible employees may become eligible to continue participation 
as retirees in health care and/or life insurance plans sponsored 
by  the  Corporation.  These  plans  are  referred  to  as  the 
Postretirement  Health  and  Life  Plans.  During  2017,  the 
Corporation  established  and  funded  a  Voluntary  Employees’ 
Beneficiary Association trust in the amount of $300 million for the 
Postretirement Health and Life Plans.

The Pension and Postretirement Plans table summarizes the 
changes in the fair value of plan assets, changes in the projected 
benefit  obligation  (PBO),  the  funded  status  of  both  the 
accumulated  benefit  obligation  (ABO)  and  the  PBO,  and  the 
weighted-average  assumptions  used  to  determine  benefit 
obligations  for  the  pension  plans  and  postretirement  plans  at 
December 31, 2018 and 2017. The estimate of the Corporation’s 
PBO  associated  with  these  plans  considers  various  actuarial 
assumptions,  including  assumptions  for  mortality  rates  and 
discount rates. The discount rate assumptions are derived from 
a cash flow matching technique that utilizes rates that are based 
on Aa-rated corporate bonds with cash flows that match estimated 
benefit  payments  of  each  of  the  plans.  The  increases  in  the 
weighted-average discount rates in 2018 resulted in decreases to 
the PBO of approximately $1.3 billion at December 31, 2018. The 
decreases in the weighted-average discount rates in 2017 resulted 
in increases to the PBO of approximately $1.1 billion at December 
31, 2017. Significant gains and losses related to changes in the 
PBO for 2018 and 2017 primarily resulted from changes in the 
discount rate. 

(Dollars in millions)
Fair value, January 1

Actual return on plan assets
Company contributions
Plan participant contributions
Settlements and curtailments
Benefits paid
Federal subsidy on benefits paid
Foreign currency exchange rate changes

Fair value, December 31

Change in projected benefit obligation
Projected benefit obligation, January 1

Service cost
Interest cost
Plan participant contributions
Plan amendments
Settlements and curtailments
Actuarial loss (gain)
Benefits paid
Federal subsidy on benefits paid
Foreign currency exchange rate changes

Projected benefit obligation, December 31
Amounts recognized on Consolidated Balance Sheet

Other assets
Accrued expenses and other liabilities

Net amount recognized, December 31

Funded status, December 31

Accumulated benefit obligation
Overfunded (unfunded) status of ABO
Provision for future salaries
Projected benefit obligation

Weighted-average assumptions, December 31

Discount rate
Rate of compensation increase
Interest-crediting rate

Qualified
Pension Plan

Non-U.S.
Pension Plans

Nonqualified and Other
Pension Plans

Postretirement
Health and Life Plans

2018

2017

2018

2017

2018

2017

2018

2017

$

$

$

$

$

$

$

19,708
(550)
—
—
—
(980)
n/a
n/a
18,178

15,706
—
563
—
—
—
(1,145)
(980)
n/a
n/a
14,144

4,034
—
4,034

14,144
4,034
—
14,144

$

$

$

$

$

$

$

$

$

$

$

$

$

$

18,239
2,285
—
—
—
(816)
 n/a
 n/a
19,708

14,982
—
606
—
—
—
934
(816)
 n/a
 n/a
15,706

4,002
—
4,002

15,706
4,002
—
15,706

$

$

$

$

$

$

$

2,943
(181)
22
1
(107)
(52)
n/a
(165)
2,461

2,814
19
65
1
13
(107)
(29)
(52)
n/a
(135)
2,589

316
(444)
(128)

2,542
(81)
47
2,589

$

$

$

$

$

$

$

2,789
118
23
1
(190)
(54)
 n/a
256
2,943

2,763
24
72
1
—
(200)
(26)
(54)
 n/a
234
2,814

610
(481)
129

2,731
212
83
2,814

$

$

$

$

$

$

$

2,724
8
91
—
—
(239)
n/a
n/a
2,584

3,047
1
105
—
—
—
(135)
(239)
n/a
n/a
2,779

754
(949)
(195)

2,778
(194)
1
2,779

4.32%
n/a
5.18

3.68%
 n/a
5.08

2.60%
4.49
1.47

2.39%
4.31
1.49

4.26%
4.00
4.50

$

$

$

$

$

$

$

2,744
128
98
—
—
(246)
 n/a
 n/a
2,724

3,047
1
117
—
—
—
128
(246)
 n/a
 n/a
3,047

730
(1,053)
(323)

3,046
(322)
1
3,047

3.58%
4.00
4.53

300
5
43
115
—
(214)
3
n/a
252

1,056
6
36
115
—
—
(73)
(214)
3
(1)
928

$

$

$

$

— $

$

$

(676)
(676)

n/a
n/a
n/a
928

4.25%
n/a
n/a

—
—
393
125
—
(230)
12
 n/a
300

1,125
6
43
125
(19)
—
(7)
(230)
12
1
1,056

—
(756)
(756)

n/a
n/a
n/a
1,056

3.58%
n/a
n/a

(1)  The measurement date for the Qualified Pension Plan, Non-U.S. Pension Plans, Nonqualified and Other Pension Plans, and Postretirement Health and Life Plans was December 31 of each year 

reported.

n/a = not applicable

158     Bank of America 2018

The Corporation’s estimate of its contributions to be made to 
the Non-U.S. Pension Plans, Nonqualified and Other Pension Plans, 
and Postretirement Health and Life Plans in 2019 is $21 million, 
$91 million and $15 million, respectively. The Corporation does 
not expect to make a contribution to the Qualified Pension Plan in 
2019. It is the policy of the Corporation to fund no less than the 

minimum funding amount required by the Employee Retirement 
Income Security Act of 1974 (ERISA). 

Pension Plans with ABO and PBO in excess of plan assets as 
of December 31, 2018 and 2017 are presented in the table below. 
For these plans, funding strategies vary due to legal requirements 
and local practices.

Plans with ABO and PBO in Excess of Plan Assets

(Dollars in millions)

PBO
ABO
Fair value of plan assets

Components of Net Periodic Benefit Cost

(Dollars in millions)

Components of net periodic benefit cost (income)

Service cost
Interest cost
Expected return on plan assets
Amortization of net actuarial loss
Other

Net periodic benefit cost (income)

Weighted-average assumptions used to determine net cost for years ended December 31

Discount rate
Expected return on plan assets
Rate of compensation increase

(Dollars in millions)

Components of net periodic benefit cost (income)

Service cost
Interest cost
Expected return on plan assets
Amortization of net actuarial loss (gain)
Other

Net periodic benefit cost (income)

Weighted-average assumptions used to determine net cost for years ended December 31

Discount rate
Expected return on plan assets
Rate of compensation increase

n/a = not applicable

Non-U.S.
Pension Plans

Nonqualified
and Other
Pension Plans

2018

2017

2018

2017

$

$

615
605
173

$

671
644
191

$

950
949
1

1,054
1,053
1

Qualified Pension Plan
2017

2016

2018

Non-U.S. Pension Plans
2017

2016

2018

$

— $

— $

— $

563
(1,136)
147
—
(426)

$

606
(1,068)
154
—
(308)

$

634
(1,038)
139
—
(265)

$

$

3.68%
6.00
n/a

4.16%
6.00
n/a

4.51%
6.00
n/a

$

$

19
65
(126)
10
12
(20)

2.39%
4.37
4.31

$

$

24
72
(136)
8
(7)
(39)

2.56%
4.73
4.51

25
86
(123)
6
2
(4)

3.59%
4.84
4.67

Nonqualified and
Other Pension Plans

Postretirement Health
and Life Plans

2018

2017

2016

2018

2017

2016

$

$

$

$

1
105
(84)
43
—
65

3.58%
3.19
4.00

1
117
(95)
34
—
57

4.01%
3.50
4.00

$

— $

$

127
(101)
25
3
54

4.34%
3.66
4.00

$

6
36
(6)
(27)
(3)
6

$

$

6
43
—
(21)
4
32

$

$

7
47
—
(81)
4
(23)

3.58%
2.00
n/a

3.99%
 n/a
 n/a

4.32%
 n/a
 n/a

The  asset  valuation  method  used  to  calculate  the  expected 
return on plan assets component of net periodic benefit cost for 
the Qualified Pension Plan recognizes 60 percent of the prior year’s 
market gains or losses at the next measurement date with the 
remaining  40  percent  spread  equally  over  the  subsequent  four 
years.

Gains and losses for all benefit plans except postretirement 
health  care  are  recognized  in  accordance  with  the  standard 
amortization provisions of the applicable accounting guidance. Net 
periodic postretirement health and life expense was determined 
using  the  “projected  unit  credit”  actuarial  method.  For  the 
Postretirement  Health  and  Life  Plans,  50  percent  of  the 
unrecognized gain or loss at the beginning of the fiscal year (or at 
subsequent remeasurement) is recognized on a level basis during 
the year.

Assumed health care cost trend rates affect the postretirement 
benefit obligation and benefit cost reported for the Postretirement 
Health and Life Plans. The assumed health care cost trend rate 
used  to  measure  the  expected  cost  of  benefits  covered  by  the 
Postretirement Health and Life Plans is 6.50 percent for 2019, 
reducing in steps to 5.00 percent in 2023 and later years.

The Corporation’s net periodic benefit cost (income) recognized 
for the plans is sensitive to the discount rate and expected return 
on plan assets. For the Qualified Pension Plan, Non-U.S. Pension 
Plans, Nonqualified and Other Pension Plans, and Postretirement 
Health  and  Life  Plans,  a  25  bp  decline  in  discount  rates  and 
expected return on assets would not have a significant impact on 
the net periodic benefit cost for 2018.

Bank of America 2018     159 

 
 
 
 
 
 
 
 
 
 
 
 
 
Pretax Amounts included in Accumulated OCI

(Dollars in millions)

Net actuarial loss (gain)
Prior service cost (credits)

Amounts recognized in accumulated OCI

Pretax Amounts Recognized in OCI

(Dollars in millions)

Current year actuarial loss (gain)
Amortization of actuarial gain (loss) and 

prior service cost

Current year prior service cost (credit)

Amounts recognized in OCI

Qualified
Pension Plan

Non-U.S.
Pension Plans

Nonqualified
and Other
Pension Plans

Postretirement
Health and
Life Plans

Total

2018
$ 4,386
—
$ 4,386

2017
$ 3,992
—
$ 3,992

2018

$

$

454
18
472

2017
$ 196
4
$ 200

2018

$

$

912
—
912

2017
$ 1,014
—
$ 1,014

2018

2017

2018

$

$

(75) $
(9)
(84) $

(30) $ 5,677
9
(11)
(41) $ 5,686

2017
$ 5,172
(7)
$ 5,165

Qualified
Pension Plan

Non-U.S.
Pension Plans

Nonqualified
and Other
Pension Plans

Postretirement
Health and
Life Plans

Total

2018

$

541

2017
$ (283) $

2018

2017

2018

2017

2018

2017

2018

270

$

(12) $

(59) $

95

$

(73) $

(7) $

679

2017
$ (207)

(147)

(154)

—
394

—
$ (437) $

$

(11)

13
272

(8)

(43)

—
(20) $ (102) $

—

$

(34)

—
61

$

30

—
(43) $

21

(23)

(9) $

(171)

(175)

13
521

(23)
$ (405)

Plan Assets
The Qualified Pension Plan has been established as a retirement 
vehicle  for  participants,  and  trusts  have  been  established  to 
secure benefits promised under the Qualified Pension Plan. The 
Corporation’s  policy  is  to  invest  the  trust  assets  in  a  prudent 
manner  for  the  exclusive  purpose  of  providing  benefits  to 
participants and defraying reasonable expenses of administration. 
The  Corporation’s  investment  strategy  is  designed  to  provide  a 
total return that, over the long term, increases the ratio of assets 
to liabilities. The strategy attempts to maximize the investment 
return  on  assets  at  a  level  of  risk  deemed  appropriate  by  the 
Corporation  while  complying  with  ERISA  and  any  applicable 
regulations  and  laws.  The  investment  strategy  utilizes  asset 
allocation  as  a  principal  determinant  for  establishing  the  risk/
return  profile  of  the  assets.  Asset  allocation  ranges  are 
established, periodically reviewed and adjusted as funding levels 
and liability characteristics change. Active and passive investment 
managers are employed to help enhance the risk/return profile of 
the assets. An additional aspect of the investment strategy used 
to  minimize  risk  (part  of  the  asset  allocation  plan)  includes 
matching  the  exposure  of  participant-selected 
investment 
measures. 

The  assets  of  the  Non-U.S.  Pension  Plans  are  primarily 
attributable to a U.K. pension plan. This U.K. pension plan’s assets 
are invested prudently so that the benefits promised to members 
are provided with consideration given to the nature and the duration 

of the plan’s liabilities. The selected asset allocation strategy is 
designed to achieve a higher return than the lowest risk strategy.
The expected rate of return on plan assets assumption was 
developed through analysis of historical market returns, historical 
asset class volatility and correlations, current market conditions, 
anticipated future asset allocations, the funds’ past experience, 
and expectations on potential future market returns. The expected 
return  on  plan  assets  assumption  is  determined  using  the 
calculated market-related value for the Qualified Pension Plan and 
the Other Pension Plan and the fair value for the Non-U.S. Pension 
Plans  and  Postretirement  Health  and  Life  Plans.  The  expected 
return on plan assets assumption represents a long-term average 
view of the performance of the assets in the Qualified Pension 
Plan,  the  Non-U.S.  Pension  Plans,  the  Other  Pension  Plan,  and 
Postretirement Health and Life Plans, a return that may or may not 
be achieved during any one calendar year. The Other Pension Plan 
is invested solely in an annuity contract which is primarily invested 
in fixed-income securities structured such that asset maturities 
match the duration of the plan’s obligations.

The  target  allocations  for  2019  by  asset  category  for  the 
Qualified Pension Plan, Non-U.S. Pension Plans, and Nonqualified 
and  Other  Pension  Plans  are  presented  in  the  following  table. 
Equity securities for the Qualified Pension Plan include common 
stock  of  the  Corporation  in  the  amounts  of  $221  million  (1.22 
percent of total plan assets) and $261 million (1.33 percent of 
total plan assets) at December 31, 2018 and 2017.

2019 Target Allocation

Asset Category

Equity securities
Debt securities
Real estate
Other

160     Bank of America 2018

Percentage

Qualified
Pension Plan

Non-U.S.
Pension Plans

Nonqualified
and Other
Pension Plans

20-50
45-75
0-10
0-5

5-35
40-80
0-15
5-30

0-5
95-100
0-5
0-5

 
Fair Value Measurements
For more information on fair value measurements, including descriptions of Level 1, 2 and 3 of the fair value hierarchy and the valuation 
methods employed by the Corporation, see Note 1 – Summary of Significant Accounting Principles and Note 20 – Fair Value Measurements. 
Combined plan investment assets measured at fair value by level and in total at December 31, 2018 and 2017 are summarized in the 
Fair Value Measurements table.

Fair Value Measurements

(Dollars in millions)

Cash and short-term investments

Money market and interest-bearing cash
Cash and cash equivalent commingled/mutual funds

Fixed income

U.S. government and agency securities
Corporate debt securities
Asset-backed securities
Non-U.S. debt securities
Fixed income commingled/mutual funds

Equity

Common and preferred equity securities
Equity commingled/mutual funds
Public real estate investment trusts

Real estate

Private real estate
Real estate commingled/mutual funds

Limited partnerships
Other investments (1)

Total plan investment assets, at fair value

Cash and short-term investments

Money market and interest-bearing cash
Cash and cash equivalent commingled/mutual funds

Fixed income

U.S. government and agency securities
Corporate debt securities
Asset-backed securities
Non-U.S. debt securities
Fixed income commingled/mutual funds

Equity

Common and preferred equity securities
Equity commingled/mutual funds
Public real estate investment trusts

Real estate

Private real estate
Real estate commingled/mutual funds

Limited partnerships
Other investments (1)

Total plan investment assets, at fair value

Level 1

Level 2

Level 3

Total

December 31, 2018

$

$

1,530
—

— $

644

— $
—

3,637
—
—
539
933

4,414
288
104

—
—
—
93
11,538

2,190
—

3,331
—
—
693
775

5,833
271
138

$

$

805
2,852
2,119
961
1,177

—
1,275
—

9
—
—
—
—

—
—
—

—
13
158
364
10,368

$

5
885
82
588
1,569

$

December 31, 2017

— $

1,004

854
2,417
1,832
898
1,676

—
1,753
—

— $
—

9
—
—
—
—

—
—
—

—
—
—
101
13,332

$

—
13
155
649
11,251

$

93
831
85
74
1,092

$

$

$

$

1,530
644

4,451
2,852
2,119
1,500
2,110

4,414
1,563
104

5
898
240
1,045
23,475

2,190
1,004

4,194
2,417
1,832
1,591
2,451

5,833
2,024
138

93
844
240
824
25,675

(1)  Other investments include commodity and balanced funds of $305 million and $451 million, insurance annuity contracts of $562 million and $50 million and other various investments of $178 

million and $323 million at December 31, 2018 and 2017.

Bank of America 2018     161 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Level 3 Fair Value Measurements table presents a reconciliation of all plan investment assets measured at fair value using 

significant unobservable inputs (Level 3) during 2018, 2017 and 2016.

Level 3 Fair Value Measurements

(Dollars in millions)

Fixed income

U.S. government and agency securities

Real estate

Private real estate
Real estate commingled/mutual funds

Limited partnerships
Other investments

Total

Fixed income

U.S. government and agency securities

Real estate

Private real estate
Real estate commingled/mutual funds

Limited partnerships
Other investments

Total

Fixed income

U.S. government and agency securities

Real estate

Private real estate
Real estate commingled/mutual funds

Limited partnerships
Other investments

Total

Balance
January 1

Actual Return on
Plan Assets Still
Held at the
Reporting Date

Purchases, Sales
and Settlements

Balance
December 31

$

$

$

$

$

$

9

$

93
831
85
74
1,092

$

10

$

150
748
38
83
1,029

$

11

$

144
731
49
102
1,037

$

2018

— $

(7)
52
(12)
—
33

$

2017

— $

8
63
14
5
90

$

2016

— $

1
21
(2)
4
24

$

— $

(81)
2
9
514
444

$

(1) $

(65)
20
33
(14)
(27) $

(1) $

5
(4)
(9)
(23)
(32) $

9

5
885
82
588
1,569

9

93
831
85
74
1,092

10

150
748
38
83
1,029

Projected Benefit Payments
Benefit payments projected to be made from the Qualified Pension Plan, Non-U.S. Pension Plans, Nonqualified and Other Pension Plans, 
and Postretirement Health and Life Plans are presented in the table below.

Projected Benefit Payments

(Dollars in millions)

Qualified
Pension Plan (1)

Non-U.S.
Pension Plans (2)

Nonqualified
and Other
Pension Plans (2)

Postretirement 
Health and 
Life Plans (3)

2019
2020
2021
2022
2023
2024 - 2028
(1)  Benefit payments expected to be made from the plan’s assets.
(2)  Benefit payments expected to be made from a combination of the plans’ and the Corporation’s assets.
(3)  Benefit payments (net of retiree contributions) expected to be made from a combination of the plans’ and the Corporation’s assets.

905
932
920
925
915
4,451

$

$

$

98
103
110
119
125
671

$

241
244
239
234
228
1,046

85
82
79
77
74
323

Defined Contribution Plans
The  Corporation  maintains  qualified  and  non-qualified  defined 
contribution retirement plans. The Corporation recorded expense 
of $1.0 billion in each of 2018, 2017, and 2016 related to the 
qualified defined contribution plans. At December 31, 2018 and 
2017,  212  million  and  218  million  shares  of  the  Corporation’s 

common stock were held by these plans. Payments to the plans 
for dividends on common stock were $115 million, $86 million
and $60 million in 2018, 2017 and 2016, respectively.

Certain  non-U.S.  employees  are  covered  under  defined 
contribution  pension  plans  that  are  separately  administered  in 
accordance with local laws.

162     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTE 18 Stock-based Compensation Plans
The  Corporation  administers  a  number  of  equity  compensation 
plans, with awards being granted predominantly from the Bank of 
America Key Employee Equity Plan (KEEP). Under this plan, 450 
million shares of the Corporation’s common stock are authorized 
to be used for grants of awards.

During 2018 and 2017, the Corporation granted 71 million and 
85 million RSU awards to certain employees under the KEEP. The 
RSUs were authorized to settle predominantly in shares of common 
stock of the Corporation. Certain RSUs will be settled in cash or 
contain settlement provisions that subject these awards to variable 
accounting  whereby  compensation  expense  is  adjusted  to  fair 
value based on changes in the share price of the Corporation’s 
common stock up to the settlement date. Of the RSUs granted in 
2018 and 2017, 63 million and 85 million will vest in one-third 
increments on each of the first three anniversaries of the grant 
date provided that the employee remains continuously employed 
with the Corporation during that time, and will be expensed ratably 
over  the  vesting  period,  net  of  estimated  forfeitures,  for  non-
retirement eligible employees based on the grant-date fair value 
of the shares. Additionally, eight million of the RSUs granted in 
2018 will vest in one-fourth increments on each of the first four 
anniversaries of the grant date provided that the employee remains 
continuously employed with the Corporation during that time, and 
will be expensed ratably over the vesting period, net of estimated 
forfeitures, based on the grant-date fair value of the shares. Awards 
granted in years prior to 2016 were predominantly cash settled. 
Effective  October  1,  2017,  the  Corporation  changed  its 
accounting  method 
for  determining  when  stock-based 
compensation awards granted to retirement-eligible employees are 
deemed authorized, changing from the grant date to the beginning 
of  the  year  preceding  the  grant  date  when  the  incentive  award 
plans are generally approved. As a result, the estimated value of 
the awards is expensed ratably over the year preceding the grant 
date. The compensation cost for all periods prior to this change 
presented herein has been restated. 

The compensation cost for the stock-based plans was $1.8 
billion, $2.2 billion and $2.2 billion and the related income tax 
benefit was $433 million, $829 million and $835 million for 2018, 
2017 and 2016, respectively.

Restricted Stock/Units
The table below presents the status at December 31, 2018 of the 
share-settled restricted stock/units and changes during 2018.

Stock-settled Restricted Stock/Units

Outstanding at January 1, 2018
Granted
Vested
Canceled

Outstanding at December 31, 2018

Shares/Units

179,273,243
68,899,627
(74,357,624)
(8,194,000)
165,621,246

Weighted-
average Grant 
Date Fair Value

$

17.53
30.53
16.31
22.84
23.22

The table below presents the status at December 31, 2018 of 
the cash-settled RSUs granted under the KEEP and changes during 
2018.

Cash-settled Restricted Units

Outstanding at January 1, 2018
Granted
Vested
Canceled

Outstanding at December 31, 2018

Units

42,209,626
2,195,025
(41,434,793)
(360,736)
2,609,122

At December 31, 2018, there was an estimated $1.1 billion of 
total  unrecognized  compensation  cost  related  to  certain  share-
based  compensation  awards  that  is  expected  to  be  recognized 
over a period of up to four years, with a weighted-average period 
of 1.9 years. The total fair value of restricted stock vested in 2018, 
2017 and 2016 was $2.3 billion, $1.3 billion and $358 million, 
respectively. In 2018, 2017 and 2016, the amount of cash paid 
to settle equity-based awards for all equity compensation plans 
was $1.3 billion, $1.9 billion and $1.7 billion, respectively.

Stock Options
Of the 16.6 million stock options with a weighted-average exercise 
price of $43.44 outstanding at January 1, 2018, 2.1 million and 
14.5 million were exercised and forfeited during 2018 at weighted-
average  exercise  prices  of  $30.71  and  $45.29.  There  were  no
outstanding stock options at December 31, 2018.

NOTE 19 Income Taxes
The components of income tax expense for 2018, 2017 and 2016 are presented in the table below. 

Income Tax Expense

(Dollars in millions)

Current income tax expense

U.S. federal
U.S. state and local
Non-U.S. 

Total current expense
Deferred income tax expense

U.S. federal
U.S. state and local
Non-U.S. 

Total deferred expense
Total income tax expense

2018

2017

2016

$

$

816
1,377
1,203
3,396

2,579
240
222
3,041
6,437

$

$

1,310
557
939
2,806

7,238
835
102
8,175
10,981

$

$

302
120
984
1,406

5,416
(279)
656
5,793
7,199

Bank of America 2018     163 

 
 
 
 
 
 
Total  income  tax  expense  does  not  reflect  the  tax  effects  of 
items that are included in OCI each period. For more information, 
see Note 14 – Accumulated Other Comprehensive Income (Loss). 
Other tax effects included in OCI each period resulted in a benefit 
of $1.2 billion, $1.2 billion and $498 million in 2018, 2017 and 
2016,  respectively.  In  addition,  prior  to  2017,  total  income  tax 
expense  did  not  reflect  tax  effects  associated  with  the 
Corporation’s  employee  stock  plans  which  decreased  common 
stock and additional paid-in capital $41 million in 2016.

Income tax expense for 2018, 2017 and 2016 varied from the 
amount  computed  by  applying  the  statutory  income  tax  rate  to 
income before income taxes. The Corporation’s federal statutory 
tax rate was 21 percent for 2018 and 35 percent for 2017 and 
2016.  A  reconciliation  of  the  expected  U.S.  federal  income  tax 
expense, calculated by applying the federal statutory tax rate, to 
the Corporation’s actual income tax expense, and the effective tax 
rates for 2018, 2017 and 2016 are presented in the table below. 

On December 22, 2017, the President signed into law the Tax 
Act  which  made  significant  changes  to  federal  income  tax  law 
including,  among  other  things,  reducing  the  statutory  corporate 
income tax rate to 21 percent from 35 percent and changing the 
taxation  of  the  Corporation’s  non-U.S.  business  activities.  The 
impact on net income in 2017 was $2.9 billion, driven by $2.3 
billion  in  income  tax  expense,  largely  from  a  lower  valuation  of 
certain U.S. deferred tax assets and liabilities. The change in the 
statutory tax rate also impacted the Corporation’s tax-advantaged 
energy investments, resulting in a downward valuation adjustment 
of $946 million recorded in other income and a related income 
tax benefit of $347 million, which when netted against the $2.3 
billion, resulted in a net impact on income tax expense of $1.9 
billion. The Corporation has completed its analysis and accounting 
under Staff Accounting Bulletin No. 118 for the effects of the Tax 
Act.

Reconciliation of Income Tax Expense

(Dollars in millions)

Expected U.S. federal income tax expense
Increase (decrease) in taxes resulting from:
State tax expense, net of federal benefit
Affordable housing/energy/other credits
Tax-exempt income, including dividends
Share-based compensation
Nondeductible expenses
Changes in prior-period UTBs, including interest
Rate differential on non-US earnings
Tax law changes (1)
Other

Total income tax expense

(1)  Amounts for 2016 are for non-U.S. tax law changes.

Amount

Percent

Amount

Percent

Amount

Percent

2018

2017

2016

$

7,263

21.0% $ 10,225

35.0% $

8,757

35.0%

1,367
(1,888)
(413)
(257)
302
144
98
—
(179)
6,437

$

4.0
881
(5.5)
(1,406)
(1.2)
(672)
(0.7)
(236)
0.9
97
0.4
133
0.3
(272)
—
2,281
(0.6)
(50)
18.6% $ 10,981

3.0
(4.8)
(2.3)
(0.8)
0.3
0.5
(0.9)
7.8
(0.2)
37.6% $

420
(1,203)
(562)
—
180
(328)
(307)
348
(106)
7,199

1.7
(4.8)
(2.2)
—
0.7
(1.3)
(1.2)
1.4
(0.5)
28.8%

The reconciliation of the beginning unrecognized tax benefits (UTB) balance to the ending balance is presented in the following 

table.

Reconciliation of the Change in Unrecognized Tax Benefits

(Dollars in millions)

Balance, January 1

Increases related to positions taken during the current year
Increases related to positions taken during prior years 
Decreases related to positions taken during prior years
Settlements
Expiration of statute of limitations

Balance, December 31

At December 31, 2018, 2017 and 2016, the balance of the 
Corporation’s  UTBs  which  would,  if  recognized,  affect  the 
Corporation’s effective tax rate was $1.6 billion, $1.2 billion and 
$0.6 billion, respectively. Included in the UTB balance are some 
items the recognition of which would not affect the effective tax 
rate, such as the tax effect of certain temporary differences, the 
portion of gross state UTBs that would be offset by the tax benefit 
of the associated federal deduction and the portion of gross non-
U.S.  UTBs  that  would  be  offset  by  tax  reductions  in  other 
jurisdictions.

The Corporation files income tax returns in more than 100 state 
and  non-U.S.  jurisdictions  each  year.  The  IRS  and  other  tax 
authorities in countries and states in which the Corporation has 
significant business operations examine tax returns periodically 
table 
(continuously 

jurisdictions).  The 

in  some 

following 

164     Bank of America 2018

2018

2017

2016

$

$

1,773
395
406
(371)
(6)
—
2,197

$

$

875
292
750
(122)
(17)
(5)
1,773

$

$

1,095
104
1,318
(1,091)
(503)
(48)
875

summarizes the status of examinations by major jurisdiction for 
the Corporation and various subsidiaries at December 31, 2018.

Tax Examination Status

Years under
Examination (1)

Status at
December 31
2018

United States
United States
New York
United Kingdom
(1)  All tax years subsequent to the years shown remain subject to examination.

2012 – 2013
2014 – 2016
2015
2017

IRS Appeals
Field examination
Field examination
To begin in 2019

It is reasonably possible that the UTB balance may decrease 
by  as  much  as  $1.2  billion  during  the  next  12  months,  since 

 
resolved  items  will  be  removed  from  the  balance  whether  their 
resolution results in payment or recognition.

The Corporation recognized interest expense of $43 million, $1 
million and $56 million in 2018, 2017 and 2016, respectively. At 
December  31,  2018  and  2017,  the  Corporation’s  accrual  for 
interest and penalties that related to income taxes, net of taxes 
and remittances, was $218 million and $185 million.

Significant components of the Corporation’s net deferred tax 
assets  and  liabilities  at  December  31,  2018  and  2017  are 
presented in the following table.

Deferred Tax Assets and Liabilities

(Dollars in millions)

Deferred tax assets

Net operating loss carryforwards
Allowance for credit losses
Accrued expenses
Available-for-sale securities
Security, loan and debt valuations
Employee compensation and retirement benefits
Credit carryforwards
Other

Gross deferred tax assets

Valuation allowance

Total deferred tax assets, net of valuation

allowance

Deferred tax liabilities

Equipment lease financing
Fixed assets
Tax credit investments
Other

Gross deferred tax liabilities
Net deferred tax assets, net of valuation

allowance

December 31

2018

2017

$

$

7,993
2,400
1,875
1,854
1,818
1,564
623
1,037
19,164
(1,569)

8,506
2,598
2,021
510
2,939
1,705
1,793
1,034
21,106
(1,644)

17,595

19,462

2,684
1,104
940
2,126
6,854

2,492
840
734
2,771
6,837

$

10,741

$ 12,625

The  table  below  summarizes  the  deferred  tax  assets  and 
related valuation allowances recognized for the net operating loss 
(NOL) and tax credit carryforwards at December 31, 2018.

Net Operating Loss and Tax Credit Carryforward Deferred
Tax Assets

(Dollars in millions)

Net operating losses -

U.S. 

Net operating losses -   

U.K. (1)

Net operating losses -

other non-U.S. 

Net operating losses - 

U.S. states (2)

Deferred
Tax Asset

Valuation
Allowance

Net
Deferred
Tax Asset

First Year
Expiring

$

592

$

— $

592

After 2027

5,294

—

5,294

None

633

(517)

116

Various

1,474

(517)

957

Various

After 2038
General business credits
n/a
Foreign tax credits
(1)  Represents U.K. broker-dealer net operating losses that may be carried forward indefinitely.
(2)  The net operating losses and related valuation allowances for U.S. states before considering 

612
11

—
(11)

612
—

the benefit of federal deductions were $1.9 billion and $654 million.

n/a = not applicable

Management  concluded  that  no  valuation  allowance  was 
necessary to reduce the deferred tax assets related to the U.K. 
NOL  carryforwards  and  U.S.  NOL  and  general  business  credit 
carryforwards  since  estimated  future  taxable  income  will  be 
sufficient  to  utilize  these  assets  prior  to  their  expiration.  The 
majority of the Corporation’s U.K. net deferred tax assets, which 

consist primarily of NOLs, are expected to be realized by certain 
subsidiaries  over  an extended  number  of  years. Management’s 
conclusion is supported by financial results, profit forecasts for 
the  relevant  entities  and  the  indefinite  period  to  carry  forward 
NOLs. However, a material change in those estimates could lead 
management to reassess such valuation allowance conclusions.
At December 31, 2018, U.S. federal income taxes had not been 
provided  on  approximately  $5  billion  of  temporary  differences 
associated  with  investments  in  non-U.S.  subsidiaries  that  are 
essentially  permanent  in  duration. If  the  Corporation  were  to 
record the associated deferred tax liability, the amount would be 
approximately $1 billion.

NOTE 20 Fair Value Measurements
Under applicable accounting standards, 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. The Corporation determines the fair values of its financial 
instruments under applicable accounting standards that require 
an entity to maximize the use of observable inputs and minimize 
the use of unobservable inputs. The Corporation categorizes its 
financial instruments into three levels based on the established 
fair value hierarchy. The Corporation conducts a review of its fair 
value hierarchy classifications on a quarterly basis. Transfers into 
or  out  of  fair  value  hierarchy  classifications  are  made  if  the 
significant inputs used in the financial models measuring the fair 
values  of  the  assets  and  liabilities  became  unobservable  or 
observable  in  the  current  marketplace.  For  more  information 
regarding  the  fair  value  hierarchy  and  how  the  Corporation 
measures  fair  value,  see  Note  1  –  Summary  of  Significant 
Accounting  Principles.  The  Corporation  accounts  for  certain 
financial instruments under the fair value option. For additional 
information, see Note 21 – Fair Value Option.

Valuation Techniques
The following sections outline the valuation methodologies for the 
Corporation’s assets and liabilities. While the Corporation believes 
its valuation methods are appropriate and consistent with other 
market  participants,  the  use  of  different  methodologies  or 
assumptions  to  determine  the  fair  value  of  certain  financial 
instruments could result in a different estimate of fair value at the 
reporting date.

During 2018, there were no changes to valuation approaches 
or techniques that had, or are expected to have, a material impact 
on the Corporation’s consolidated financial position or results of 
operations.

Trading Account Assets and Liabilities and Debt Securities
The fair values of trading account assets and liabilities are primarily 
based on actively traded markets where prices are based on either 
direct market quotes or observed transactions. The fair values of 
debt securities are generally based on quoted market prices or 
market prices for similar assets. Liquidity is a significant factor in 
the determination of the fair values of trading account assets and 
liabilities  and  debt  securities.  Market  price  quotes  may  not  be 
readily  available  for  some  positions  such  as  positions  within  a 
market  sector  where  trading  activity  has  slowed  significantly  or 
ceased. Some of these instruments are valued using a discounted 
cash flow model, which estimates the fair value of the securities 
using internal credit risk, interest rate and prepayment risk models 
that  incorporate  management’s  best  estimate  of  current  key 
assumptions such as default rates, loss severity and prepayment 

Bank of America 2018     165 

 
 
 
Loans Held-for-sale
The fair values of LHFS are based on quoted market prices, where 
available, or are determined by discounting estimated cash flows 
using  interest  rates  approximating  the  Corporation’s  current 
origination rates for similar loans adjusted to reflect the inherent 
credit risk. The borrower-specific credit risk is embedded within 
the  quoted  market  prices  or  is  implied  by  considering  loan 
performance when selecting comparables.

Short-term Borrowings and Long-term Debt
The Corporation issues structured liabilities that have coupons or 
repayment  terms  linked  to  the  performance  of  debt  or  equity 
securities, indices, currencies or commodities. The fair values of 
these  structured  liabilities  are  estimated  using  quantitative 
models for the combined derivative and debt portions of the notes. 
These  models  incorporate  observable  and,  in  some  instances, 
unobservable inputs including security prices, interest rate yield 
curves, option volatility, currency, commodity or equity rates and 
correlations among these inputs. The Corporation also considers 
the impact of its own credit spread in determining the discount 
rate used to value these liabilities. The credit spread is determined 
by reference to observable spreads in the secondary bond market.

Securities Financing Agreements
The  fair  values  of  certain  reverse  repurchase  agreements, 
repurchase agreements and securities borrowed transactions are 
determined using quantitative models, including discounted cash 
flow models that require the use of multiple market inputs including 
interest rates and spreads to generate continuous yield or pricing 
curves, and volatility factors. The majority of market inputs are 
actively  quoted  and  can  be  validated  through  external  sources, 
including  brokers,  market  transactions  and  third-party  pricing 
services.

Deposits
The  fair  values  of  deposits  are  determined  using  quantitative 
models, including discounted cash flow models that require the 
use of multiple market inputs including interest rates and spreads 
to generate continuous yield or pricing curves, and volatility factors. 
The  majority  of  market  inputs  are  actively  quoted  and  can  be 
validated  through  external  sources,  including  brokers,  market 
transactions  and  third-party  pricing  services.  The  Corporation 
considers the impact of its own credit spread in the valuation of 
these  liabilities.  The  credit  risk  is  determined  by  reference  to 
observable credit spreads in the secondary cash market.

Asset-backed Secured Financings
The fair values of asset-backed secured financings are based on 
external  broker  bids,  where  available,  or  are  determined  by 
discounting  estimated  cash 
rates 
approximating  the  Corporation’s  current  origination  rates  for 
similar loans adjusted to reflect the inherent credit risk.

flows  using 

interest 

Recurring Fair Value
Assets and liabilities carried at fair value on a recurring basis at 
December  31,  2018  and  2017,  including  financial  instruments 
which the Corporation accounts for under the fair value option, are 
summarized in the following tables. 

rates. Principal and interest cash flows are discounted using an 
observable discount rate for similar instruments with adjustments 
that management believes a market participant would consider in 
determining fair value for the specific security. Other instruments 
are valued using a net asset value approach which considers the 
value of the underlying securities. Underlying assets are valued 
using external pricing services, where available, or matrix pricing 
based on the vintages and ratings. Situations of illiquidity generally 
are  triggered  by  the  market’s  perception  of  credit  uncertainty 
regarding a single company or a specific market sector. In these 
instances,  fair  value  is  determined  based  on  limited  available 
market information and other factors, principally from reviewing 
the  issuer’s  financial  statements  and  changes  in  credit  ratings 
made by one or more rating agencies.

Derivative Assets and Liabilities
The fair values of derivative assets and liabilities traded in the 
OTC market are determined using quantitative models that utilize 
multiple market inputs including interest rates, prices and indices 
to generate continuous yield or pricing curves and volatility factors 
to value the position. The majority of market inputs are actively 
quoted and can be validated through external sources, including 
brokers,  market  transactions  and  third-party  pricing  services. 
When  third-party  pricing  services  are  used,  the  methods  and 
assumptions are reviewed by the Corporation. Estimation risk is 
greater for derivative asset and liability positions that are either 
option-based  or  have  longer  maturity  dates  where  observable 
market inputs are less readily available, or are unobservable, in 
which  case,  quantitative-based  extrapolations  of  rate,  price  or 
index scenarios are used in determining fair values. The fair values 
of derivative assets and liabilities include adjustments for market 
liquidity, counterparty credit quality and other instrument-specific 
the  Corporation 
factors,  where  appropriate. 
incorporates within its fair value measurements of OTC derivatives 
a valuation adjustment to reflect the credit risk associated with 
the  net  position.  Positions  are  netted  by  counterparty,  and  fair 
value for net long exposures is adjusted for counterparty credit 
risk while the fair value for net short exposures is adjusted for the 
Corporation’s own credit risk. The Corporation also incorporates 
FVA within its fair value measurements to include funding costs 
on  uncollateralized  derivatives  and  derivatives  where  the 
Corporation is not permitted to use the collateral it receives. An 
estimate of severity of loss is also used in the determination of 
fair value, primarily based on market data.

In  addition, 

Loans and Loan Commitments
The  fair  values  of  loans  and  loan  commitments  are  based  on 
market prices, where available, or discounted cash flow analyses 
using  market-based  credit  spreads  of  comparable  debt 
instruments  or  credit  derivatives  of  the  specific  borrower  or 
comparable borrowers. Results of discounted cash flow analyses 
may be adjusted, as appropriate, to reflect other market conditions 
or the perceived credit risk of the borrower.

Mortgage Servicing Rights
The fair values of MSRs are primarily determined using an option-
adjusted  spread  (OAS)  valuation  approach,  which  factors  in 
prepayment risk to determine the fair value of MSRs. This approach 
consists of projecting servicing cash flows under multiple interest 
rate  scenarios  and  discounting  these  cash  flows  using  risk-
adjusted discount rates. 

166     Bank of America 2018

(Dollars in millions)

Assets

Time deposits placed and other short-term investments
Federal funds sold and securities borrowed or purchased under

$

agreements to resell

Trading account assets:

U.S. Treasury and agency securities (2)
Corporate securities, trading loans and other
Equity securities
Non-U.S. sovereign debt
Mortgage trading loans, MBS and ABS:

U.S. government-sponsored agency guaranteed
Mortgage trading loans, ABS and other MBS

Total trading account assets (3)
Derivative assets
AFS debt securities:

U.S. Treasury and agency securities
Mortgage-backed securities:

Agency
Agency-collateralized mortgage obligations
Non-agency residential
Commercial

Non-U.S. securities
Other taxable securities
Tax-exempt securities
Total AFS debt securities
Other debt securities carried at fair value:
U.S. Treasury and agency securities
Mortgage-backed securities:
Non-agency residential

Non-U.S. securities
Other taxable securities

Total other debt securities carried at fair value
Loans and leases
Loans held-for-sale
Other assets (4)

Total assets (5)

Liabilities

Interest-bearing deposits in U.S. offices
Federal funds purchased and securities loaned or sold under

$

$

agreements to repurchase

Trading account liabilities:

U.S. Treasury and agency securities
Equity securities
Non-U.S. sovereign debt
Corporate securities and other

Total trading account liabilities
Derivative liabilities
Short-term borrowings
Accrued expenses and other liabilities
Long-term debt

Fair Value Measurements

December 31, 2018

Level 1

Level 2

Level 3

Netting 
Adjustments (1)

Assets/Liabilities
at Fair Value

1,214

$

— $

— $

— $

1,214

—

56,399

53,131
—
53,840
5,818

—
—
112,789
9,967

53,663

—
—
—
—
—
—
—
53,663

1,282

—
490
—
1,772
—
—
15,032
194,437

$

1,593
24,630
23,163
19,210

19,586
9,443
97,625
315,413

1,260

121,826
5,530
1,320
14,078
9,304
4,403
17,376
175,097

—

1,434
5,354
3
6,791
4,011
2,400
1,775
659,511

— $

492

$

$

—

—
1,558
276
465

—
1,635
3,934
3,466

—

—
—
597
—
2
7
—
606

—

—

—
—
—
—

—
—
—
(285,121)

—

—
—
—
—
—
—
—
—

—

172
—
—
172
338
542
2,932
11,990

$

—
—
—
—
—
—
—
(285,121)

$

56,399

54,724
26,188
77,279
25,493

19,586
11,078
214,348
43,725

54,923

121,826
5,530
1,917
14,078
9,306
4,410
17,376
229,366

1,282

1,606
5,844
3
8,735
4,349
2,942
19,739
580,817

— $

— $

492

—

28,875

—

—

28,875

7,894
33,739
7,452
—
49,085
9,931
—
18,096
—
77,112

761
4,070
9,182
5,104
19,117
303,441
1,648
1,979
26,820
382,372

—
—
—
18
18
4,401
—
—
817
5,236

—
—
—
—
—
(279,882)
—
—
—
(279,882)

$

8,655
37,809
16,634
5,122
68,220
37,891
1,648
20,075
27,637
184,838

Total liabilities (5)

$
(1)  Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties.
(2) 

$

$

$

Includes $20.2 billion of GSE obligations.
Includes securities with a fair value of $16.6 billion that were segregated in compliance with securities regulations or deposited with clearing organizations. This amount is included in the parenthetical 
disclosure on the Consolidated Balance Sheet.
Includes MSRs of $2.0 billion which are classified as Level 3 assets.

(3) 

(4) 

(5)  Total recurring Level 3 assets were 0.51 percent of total consolidated assets, and total recurring Level 3 liabilities were 0.25 percent of total consolidated liabilities.

Bank of America 2018     167 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(Dollars in millions)

Assets

Time deposits placed and other short-term investments
Federal funds sold and securities borrowed or purchased under

$

agreements to resell
Trading account assets:

U.S. Treasury and agency securities (2)
Corporate securities, trading loans and other
Equity securities
Non-U.S. sovereign debt
Mortgage trading loans, MBS and ABS:

U.S. government-sponsored agency guaranteed
Mortgage trading loans, ABS and other MBS

Total trading account assets (3)
Derivative assets
AFS debt securities:

U.S. Treasury and agency securities
Mortgage-backed securities:

Agency
Agency-collateralized mortgage obligations
Non-agency residential
Commercial

Non-U.S. securities
Other taxable securities
Tax-exempt securities
Total AFS debt securities
Other debt securities carried at fair value:

Mortgage-backed securities:
Non-agency residential

Non-U.S. securities
Other taxable securities

Total other debt securities carried at fair value
Loans and leases
Loans held-for-sale
Other assets (4)

Total assets (5)

Liabilities

Interest-bearing deposits in U.S. offices
Federal funds purchased and securities loaned or sold under

$

$

agreements to repurchase

Trading account liabilities:

U.S. Treasury and agency securities
Equity securities
Non-U.S. sovereign debt
Corporate securities and other

Total trading account liabilities
Derivative liabilities
Short-term borrowings
Accrued expenses and other liabilities
Long-term debt

Fair Value Measurements

December 31, 2017

Level 1

Level 2

Level 3

Netting 
Adjustments (1)

Assets/Liabilities
at Fair Value

2,234

$

— $

— $

— $

2,234

—

52,906

38,720
—
60,747
6,545

—
—
106,012
6,305

51,915

—
—
—
—
772
—
—
52,687

—
8,191
—
8,191
—
—
19,367
194,796

$

1,922
28,714
23,958
15,839

20,586
8,174
99,193
341,178

1,608

192,929
6,804
2,669
13,684
5,880
5,261
20,106
248,941

2,769
1,297
229
4,295
5,139
1,466
789
753,907

— $

449

$

$

—

—
1,864
235
556

—
1,498
4,153
4,067

—

—
—
—
—
25
509
469
1,003

—
—
—
—
571
690
2,425
12,909

—

—
—
—
—

—
—
—
(313,788)

—

—
—
—
—
—
—
—
—

—
—
—
—
—
—
—

$

(313,788) $

52,906

40,642
30,578
84,940
22,940

20,586
9,672
209,358
37,762

53,523

192,929
6,804
2,669
13,684
6,677
5,770
20,575
302,631

2,769
9,488
229
12,486
5,710
2,156
22,581
647,824

— $

— $

449

—

36,182

—

—

36,182

17,266
33,019
11,976
—
62,261
6,029
—
21,887
—
90,177

734
3,885
7,382
6,901
18,902
334,261
1,494
945
29,923
422,156

—
—
—
24
24
5,781
—
8
1,863
7,676

—
—
—
—
—
(311,771)
—
—
—

(311,771) $

18,000
36,904
19,358
6,925
81,187
34,300
1,494
22,840
31,786
208,238

Total liabilities (5)

$
(1)  Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties.
(2) 

$

$

$

Includes $21.3 billion of GSE obligations.
Includes securities with a fair value of $16.8 billion that were segregated in compliance with securities regulations or deposited with clearing organizations. This amount is included in the parenthetical 
disclosure on the Consolidated Balance Sheet.
Includes MSRs of $2.3 billion which are classified as Level 3 assets.

(3) 

(4) 

(5)  Total recurring Level 3 assets were 0.57 percent of total consolidated assets, and total recurring Level 3 liabilities were 0.38 percent of total consolidated liabilities.

168     Bank of America 2018

 
 
 
 
 
The following tables present a reconciliation of all assets and liabilities measured at fair value on a recurring basis using significant 
unobservable inputs (Level 3) during 2018, 2017 and 2016, including net realized and unrealized gains (losses) included in earnings 
and accumulated OCI.

Level 3 – Fair Value Measurements in 2018 (1)

Total 
Realized/
Unrealized 
Gains 
(Losses) in 
Net 
Income (2)

Gains 
(Losses)
in OCI (3)

Balance
January 1
2018

Gross

Purchases

Sales

Issuances

Settlements

Gross
Transfers
into
Level 3 

Gross
Transfers
out of
Level 3 

Balance
December 31
2018

Change in 
Unrealized 
Gains 
(Losses) in 
Net Income 
Related to 
Financial 
Instruments 
Still Held (2)

(Dollars in millions)

Trading account assets:

Corporate securities, trading loans and other $ 1,864 $
Equity securities
Non-U.S. sovereign debt
Mortgage trading loans, ABS and other MBS

235
556
1,498
4,153
(1,714)

(32) $
(17)
47
148
146
106

(1) $
—
(44)
3
(42)
—

436 $ (403) $

44
13
585

(11)
(57)
(910)
1,078 (1,381)
531 (1,179)

5 $
—
—
—
5
—

(568) $
(4)
(30)
(158)
(760)
778

Total trading account assets
Net derivative assets (4)
AFS debt securities:

Non-agency residential MBS
Non-U.S. securities
Other taxable securities
Tax-exempt securities
Total AFS debt securities (5)
Other debt securities carried at fair value –

Non-agency residential MBS

Loans and leases (6, 7)
Loans held-for-sale (6)
Other assets (5, 7, 8)
Trading account liabilities – Corporate

securities and other

—
25
509
469
1,003

—

571
690
2,425

27
—
1
—
28

(18)

(16)
44
414

(33)
(1)
(3)
—
(37)

—

—
(26)
(38)

(71)
—
(10)
—
(23)
—
—
—
— (104)

—

(8)

— (134)
—
71
(69)
2

(24)

11

—

9

(12)

—
—
—
—
—

—

—
1
96

(2)

—
(141)

(25)
(15)
(11)
(1)
(52)

(34)

(83)
(201)
(792)

—

8
486

804 $ (547) $

78
117
705
1,704
39

774
3
60
1
838

365

—
23
929

—

—
(262)

(49)
(137)
(236)
(969)
504

(75)
—
(526)
(469)
(1,070)

(133)

—
(60)
(35)

—

—
847

1,558 $
276
465
1,635
3,934
(935)

597
2
7
—
606

172

338
542
2,932

(18)

—
(817)

(117)
(22)
48
97
6
(116)

—
—
—
—
—

(18)

(9)
31
149

(7)

—
95

Accrued expenses and other liabilities (6)
Long-term debt (6)
(1)  Assets (liabilities). For assets, increase (decrease) to Level 3 and for liabilities, (increase) decrease to Level 3.
(2) 

(8)
(1,863)

—
103

—
4

—
9

—
—

Includes gains (losses) reported in earnings in the following income statement line items: Trading account assets/liabilities - predominantly trading account profits; Net derivative assets - primarily 
trading account profits and other income; Other debt securities carried at fair value - other income; Loans and leases - other income; Loans held-for-sale - other income; Other assets - primarily other 
income related to MSRs; Long-term debt - primarily trading account profits. For MSRs, the amounts reflect the changes in modeled MSR fair value due to observed changes in interest rates, volatility, 
spreads and the shape of the forward swap curve, and periodic adjustments to the valuation model to reflect changes in the modeled relationships between inputs and projected cash flows, as well 
as changes in cash flow assumptions including cost to service.
Includes unrealized gains (losses) in OCI on AFS debt securities, foreign currency translation adjustments and the impact of changes in the Corporation’s credit spreads on long-term debt accounted 
for under the fair value option. Total gains (losses) in OCI include net unrealized losses of $105 million related to financial instruments still held at December 31, 2018. For additional information, 
see Note 1 – Summary of Significant Accounting Principles. 

(3) 

(4)  Net derivative assets include derivative assets of $3.5 billion and derivative liabilities of $4.4 billion.
(5)  Transfers out of AFS debt securities and into other assets primarily relate to the reclassification of certain securities.
(6)  Amounts represent instruments that are accounted for under the fair value option.
(7) 

Issuances represent loan originations and MSRs recognized following securitizations or whole-loan sales.

(8)  Settlements primarily represent the net change in fair value of the MSR asset due to the recognition of modeled cash flows and the passage of time. 

Transfers  into  Level  3,  primarily  due  to  decreased  price 
observability, during 2018 included $1.7 billion of trading account 
assets, $838 million of AFS debt securities, $365 million of other 
debt securities carried at fair value and $262 million of long-term 
debt.  Transfers  occur  on  a  regular  basis  for  long-term  debt 
instruments due to changes in the impact of unobservable inputs 

on  the  value  of  the  embedded  derivative  in  relation  to  the 
instrument as a whole.

Transfers  out  of  Level  3,  primarily  due  to  increased  price                                                       

observability, during 2018 included $969 million of trading account 
assets, $504 million of net derivatives assets, $1.1 billion of AFS 
debt securities and $847 million of long-term debt. 

Bank of America 2018     169 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Level 3 – Fair Value Measurements in 2017 (1)

Total 
Realized/
Unrealized 
Gains 
(Losses) in 
Net 
Income (2)

Gains 
(Losses)
in OCI (3)

Balance
January 1
2017

Gross

Purchases

Sales

Issuances Settlements

Gross
Transfers
into
Level 3 

Gross
Transfers
out of 
Level 3 

Balance
December 31
2017

Change in 
Unrealized 
Gains 
(Losses) in 
Net Income 
Related to 
Financial 
Instruments 
Still Held (2)

(Dollars in millions)

Trading account assets:

Corporate securities, trading loans and other $ 2,777 $
Equity securities
Non-U.S. sovereign debt
Mortgage trading loans, ABS and other MBS

229 $ — $

547 $ (702) $

(70)
55
(59)
53
1,210
(990)
1,865 (1,821)
(979)

664

5 $
—
—
—
5
—

(666) $
(10)
(73)
(233)
(982)
949

728 $(1,054) $
146
72
218
1,164
48

(185)
(13)
(81)
(1,333)
(99)

1,864 $
235
556
1,498
4,153
(1,714)

Total trading account assets
Net derivative assets (4)
AFS debt securities:
Non-U.S. securities
Other taxable securities
Tax-exempt securities
Total AFS debt securities
Other debt securities carried at fair value –

Non-agency residential MBS

Loans and leases (5)
Loans held-for-sale (5, 6)
Other assets (6, 7)
Federal funds purchased and securities loaned 
or sold under agreements to repurchase (5)

Trading account liabilities – Corporate

securities and other

281
510
1,211
4,779
(1,313)

229
594
542
1,365

25

720
656
2,986

(359)

(27)

18
74
165
486
(984)

2
4
1
7

(1)

15
100
144

(5)

14

—
(8)
(2)
(10)
—

16
8
3
27

—

—
(3)
(57)

—

—

49
5
14
68

—

3
3
2

—

8

—
—
(70)
(70)

(21)

(34)
(189)
(214)

—
—
—
—

—

—
—
258

(271)
(42)
(11)
(324)

(3)

(126)
(346)
(758)

—
34
35
69

—

—
501
64

—
(94)
(45)
(139)

—

(7)
(32)
—

25
509
469
1,003

—

571
690
2,425

—

(12)

171

(58)

263

—

(17)

(2)

—
(288)

—

1
514

—

—
(711)

—

—
218

(24)

(8)
(1,863)

2
(1)
70
72
143
(409)

—
—
—
—

—

11
14
(226)

—

2

—
(196)

Accrued expenses and other liabilities (5)
Long-term debt (5)
(1)  Assets (liabilities). For assets, increase (decrease) to Level 3 and for liabilities, (increase) decrease to Level 3.
(2) 

(9)
(1,514)

—
(135)

—
(31)

—
84

—
—

Includes gains (losses) reported in earnings in the following income statement line items: Trading account assets/liabilities - predominantly trading account profits; Net derivative assets - primarily 
trading account profits and other income; Other debt securities carried at fair value - other income; Loans and leases - other income; Loans held-for-sale - other income; Other assets - primarily other 
income related to MSRs; Long-term debt - trading account profits. For MSRs, the amounts reflect the changes in modeled MSR fair value due to observed changes in interest rates, volatility, spreads 
and the shape of the forward swap curve, and periodic adjustments to the valuation model to reflect changes in the modeled relationships between inputs and projected cash flows, as well as 
changes in cash flow assumptions including cost to service.   
Includes unrealized gains (losses) in OCI on AFS debt securities, foreign currency translation adjustments and the impact of changes in the Corporation’s credit spreads on long-term debt accounted 
for under the fair value option. For additional information, see Note 1 – Summary of Significant Accounting Principles. 

(3) 

(4)  Net derivative assets include derivative assets of $4.1 billion and derivative liabilities of $5.8 billion.
(5)  Amounts represent instruments that are accounted for under the fair value option.
(6) 

Issuances represent loan originations and MSRs recognized following securitizations or whole-loan sales.

(7)  Settlements primarily represent the net change in fair value of the MSR asset due to the recognition of modeled cash flows and the passage of time. 

Transfers  into  Level  3,  primarily  due  to  decreased  price 
observability, during 2017 included $1.2 billion of trading account 
assets, $501 million of LHFS and $711 million of long-term debt. 
Transfers occur on a regular basis for long-term debt instruments 
due to changes in the impact of unobservable inputs on the value 
of the embedded derivative in relation to the instrument as a whole. 

Transfers  out  of  Level  3,  primarily  due  to  increased  price 
observability, during 2017 included $1.3 billion of trading account 
assets, $139 million of AFS debt securities, $263 million of federal 
funds purchased and securities loaned or sold under agreements 
to repurchase and $218 million of long-term debt.

170     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
Level 3 – Fair Value Measurements in 2016 (1)

Total 
Realized/
Unrealized 
Gains/
(Losses) in 
Net 
Income (2)

Gains/
(Losses)
in OCI (3)

Balance
January 1
2016

Gross

Purchases

Sales

Issuances Settlements

Gross
Transfers
into
Level 3 

Gross
Transfers
out of
Level 3 

Balance
December 31
2016

Change in 
Unrealized 
Gains/
(Losses) in 
Net Income 
Related to 
Financial 
Instruments 
Still Held (2)

(Dollars in millions)

Trading account assets:

(82)
(59)
120
64
43
(376)

—
—
—
—
—

—

17
70
(143)

4

4

—
—
(184)

Corporate securities, trading loans and other $ 2,838 $
Equity securities
Non-U.S. sovereign debt
Mortgage trading loans, ABS and other MBS

Total trading account assets
Net derivative assets (4)
AFS debt securities:

Non-agency residential MBS
Non-U.S. securities
Other taxable securities
Tax-exempt securities
Total AFS debt securities
Other debt securities carried at fair value –

Non-agency residential MBS

Loans and leases (5, 6)
Loans held-for-sale (5)
Other assets (6, 7)
Federal funds purchased and securities loaned 
or sold under agreements to repurchase (5)

Trading account liabilities – Corporate

securities and other

407
521
1,868
5,634
(441)

106
—
757
569
1,432

30

1,620
787
3,461

78 $
74
122
188
462
285

—
—
4
—
4

(5)

(44)
79
136

73
12

2 $ 1,508 $ (847) $
—
91
(2)
91
—

(169)
(146)
988 (1,491)
2,581 (2,653)
470 (1,155)

—
(6)
(2)
(1)
(9)

—

—
50
—

—

—

— (106)
(92)
—
—
(198)

584
—
1
585

—

69
22
38

—

—

—

(553)
(256)
(191)

(11)

(335)

(11)

(21)

5

— $
—
—
—
—
—

(725) $
(82)
(90)
(344)
(1,241)
76

728 $ (805) $

70
—
158
956
(186)

(92)
—
(154)
(1,051)
(362)

2,777 $
281
510
1,211
4,779
(1,313)

—
—
—
—
—

—

50
—
411

—
(263)
(83)
(2)
(348)

—

(194)
(93)
(872)

—
6
—
10
16

—

6
173
3

—
—
(82)
(35)
(117)

—

(234)
(106)
—

—
229
594
542
1,365

25

720
656
2,986

—

(22)

27

(19)

1

(359)

—

—
—
(521)

—

29
—
948

—

—
—
(939)

—

—
—
465

(27)

—
(9)
(1,514)

Short-term borrowings (5)
Accrued expenses and other liabilities (5)
Long-term debt (5)
(1)  Assets (liabilities). For assets, increase (decrease) to Level 3 and for liabilities, (increase) decrease to Level 3.
(2) 

(30)
(9)
(1,513)

—
—
(20)

—
—
140

1
—
(74)

—
—
—

Includes gains/losses reported in earnings in the following income statement line items: Trading account assets/liabilities - trading account profits; Net derivative assets - primarily trading account 
profits and other income; Other debt securities carried at fair value - other income; Loans and leases - other income; Loans held-for-sale - other income; Other assets - primarily other income related 
to MSRs; Long-term debt - predominantly trading account profits. For MSRs, the amounts reflect the changes in modeled MSR fair value due to observed changes in interest rates, volatility, spreads 
and the shape of the forward swap curve, and periodic adjustments to the valuation model to reflect changes in the modeled relationships between inputs and projected cash flows, as well as 
changes in cash flow assumptions including cost to service.    
Includes unrealized gains/losses in OCI on AFS debt securities, foreign currency translation adjustments and the impact of changes in the Corporation’s credit spreads on long-term debt accounted 
for under the fair value option. For more information, see Note 1 – Summary of Significant Accounting Principles.

(3) 

(4)  Net derivatives include derivative assets of $3.9 billion and derivative liabilities of $5.2 billion.
(5)  Amounts represent instruments that are accounted for under the fair value option.
(6) 

Issuances represent loan originations and MSRs recognized following securitizations or whole-loan sales.

(7)  Settlements represent the net change in fair value of the MSR asset due to the recognition of modeled cash flows and the passage of time. 

Transfers  into  Level  3,  primarily  due  to  decreased  price 
observability, during 2016 included $956 million of trading account 
assets, $186 million of net derivative assets, $173 million of LHFS 
and $939 million of long-term debt. Transfers occur on a regular 
basis for long-term debt instruments due to changes in the impact 
of unobservable inputs on the value of the embedded derivative 
in relation to the instrument as a whole.

Transfers  out  of  Level  3,  primarily  due  to  increased  price 
observability, during 2016 included $1.1 billion of trading account 
assets, $362 million of net derivative assets, $117 million of AFS 
debt securities, $234 million of loans and leases, $106 million
of LHFS and $465 million of long-term debt.

Bank of America 2018     171 

 
 
 
 
 
 
 
 
 
 
 
 
 
The following tables present information about significant unobservable inputs related to the Corporation’s material categories of 

Level 3 financial assets and liabilities at December 31, 2018 and 2017.

Quantitative Information about Level 3 Fair Value Measurements at December 31, 2018

(Dollars in millions)

Inputs

Loans and Securities (2)

Financial Instrument

Fair 
Value

Valuation 
Technique

Significant Unobservable 
Inputs

Ranges of 
Inputs

Weighted 
Average (1)

Instruments backed by residential real estate assets

$

1,536

Trading account assets – Mortgage trading loans, ABS and other MBS

Loans and leases

Loans held-for-sale

AFS debt securities, primarily non-agency residential

Other debt securities carried at fair value - Non-agency residential

Instruments backed by commercial real estate assets

$

Trading account assets – Corporate securities, trading loans and other

Trading account assets – Mortgage trading loans, ABS and other MBS

419

338

1

606

172

291

200

91

Commercial loans, debt securities and other

Trading account assets – Corporate securities, trading loans and other

Trading account assets – Non-U.S. sovereign debt

Trading account assets – Mortgage trading loans, ABS and other MBS

Loans held-for-sale

Other assets, primarily auction rate securities

$

3,489

1,358

465

1,125

541

890

$

Yield

Prepayment speed

Discounted cash
flow, Market
comparables

Default rate

Loss severity

Discounted cash
flow

Price

Yield

Price

Yield

Discounted cash
flow, Market
comparables

Prepayment speed

Default rate

Loss severity

Price

Price

Discounted cash
flow, Market
comparables

MSRs

$

2,042

Weighted-average life, fixed rate (5)

Discounted cash
flow

Weighted-average life, variable rate (5)

Option-adjusted spread, fixed rate

Option-adjusted spread, variable rate

Structured liabilities

Long-term debt

Net derivative assets

Credit derivatives

Equity derivatives

Commodity derivatives

Interest rate derivatives

$

(817)

Discounted cash 
flow, Market 
comparables, 
Industry standard 
derivative pricing (3)

$

(565)

Discounted cash
flow, Stochastic
recovery correlation
model

$

$

(348)

10

$

(32)

Industry standard 
derivative pricing (3)

Discounted cash 
flow, Industry 
standard derivative 
pricing (3)

Industry standard 
derivative pricing (4)

Total net derivative assets

$

(935)

Equity correlation

Long-dated equity volatilities

Yield

Price

Yield

Upfront points

Credit correlation

Prepayment speed

Default rate

Loss severity

Price

Equity correlation

Long-dated equity volatilities

0% to 25%

0% to 21% CPR

0% to 3% CDR

0% to 51%

$0 to $128

0% to 25%

$0 to $100

1% to 18%

10% to 20%

3% to 4%

35% to 40%

$0 to $141

$10 to $100

0 to 14 years

0 to 10 years

7% to 14%

9% to 15%

11% to 100%

4% to 84%

7% to 18%

$0 to $100

8%

12%

1%

17%

$72

7%

$79

13%

15%

4%

38%

$68

$95

5 years

3 years

9%

12%

67%

32%

16%

$72

0% to 5%

4%

0 points to 100 points

70 points

70%

15% to 20% CPR

1% to 4% CDR

35%

$0 to $138

11% to 100%

4% to 84%

n/a

15%

2%

n/a

$93

67%

32%

Natural gas forward price

$1/MMBtu to $12/MMBtu

$3/MMBtu

Correlation

Volatilities

Correlation (IR/IR)

Correlation (FX/IR)

Long-dated inflation rates

Long-dated inflation volatilities

38% to 87%

15% to 132%

15% to 70%

0% to 46%

-20% to 38%

0% to 1%

71%

38%

61%

1%

2%

1%

(1)  For loans and securities, structured liabilities and net derivative assets, the weighted average is calculated based upon the absolute fair value of the instruments. 
(2)  The categories are aggregated based upon product type which differs from financial statement classification. The following is a reconciliation to the line items in the table on page 167: Trading 
account assets – Corporate securities, trading loans and other of $1.6 billion, Trading account assets – Non-U.S. sovereign debt of $465 million, Trading account assets – Mortgage trading loans, 
ABS and other MBS of $1.6 billion, AFS debt securities of $606 million, Other debt securities carried at fair value - Non-agency residential of $172 million, Other assets, including MSRs, of $2.9 
billion, Loans and leases of $338 million and LHFS of $542 million.
Includes models such as Monte Carlo simulation and Black-Scholes.
Includes models such as Monte Carlo simulation, Black-Scholes and other methods that model the joint dynamics of interest, inflation and foreign exchange rates.

(4) 

(3) 

(5)  The weighted-average life is a product of changes in market rates of interest, prepayment rates and other model and cash flow assumptions.
CPR = Constant Prepayment Rate
CDR = Constant Default Rate
MMBtu = Million British thermal units
IR = Interest Rate
FX = Foreign Exchange
n/a = not applicable

172     Bank of America 2018

Quantitative Information about Level 3 Fair Value Measurements at December 31, 2017

(Dollars in millions)

Inputs

Financial Instrument

Loans and Securities (2)

Instruments backed by residential real estate assets

Trading account assets – Mortgage trading loans, ABS and other MBS

Loans and leases

Loans held-for-sale

Instruments backed by commercial real estate assets

Trading account assets – Corporate securities, trading loans and other

Trading account assets – Mortgage trading loans, ABS and other MBS

Commercial loans, debt securities and other

Trading account assets – Corporate securities, trading loans and other

Trading account assets – Non-U.S. sovereign debt

Trading account assets – Mortgage trading loans, ABS and other MBS

AFS debt securities – Other taxable securities

Loans and leases

Loans held-for-sale

Auction rate securities

Trading account assets – Corporate securities, trading loans and other

AFS debt securities – Other taxable securities

AFS debt securities – Tax-exempt securities

Fair
Value

Valuation
Technique

Significant Unobservable
Inputs

Ranges of
Inputs

Weighted 
Average (1)

$

$

871

298

570

3

286

244

42

$

4,023

1,613

556

1,158

$

8

1

687

977

7

501

469

Discounted cash
flow

Discounted cash
flow

Yield

Prepayment speed

Default rate

Loss severity

Yield

Price

Yield

Prepayment speed

Discounted cash
flow, Market
comparables

Default rate

Loss severity

Price

0% to 25%

0% to 22% CPR

0% to 3% CDR

0% to 53%

0% to 25%

$0 to $100

0% to 12%

10% to 20%

3% to 4%

35% to 40%

$0 to $145

6%

12%

1%

17%

9%

$67

5%

16%

4%

37%

$63

Price

$10 to $100

$94

Discounted cash
flow, Market
comparables

MSRs

$

2,302

Weighted-average life, fixed rate (5)

Discounted cash
flow

Weighted-average life, variable rate (5)

Option-adjusted spread, fixed rate

Option-adjusted spread, variable rate

Structured liabilities

Long-term debt

Net derivative assets

Credit derivatives

Equity derivatives

Commodity derivatives

Interest rate derivatives

$ (1,863)

Discounted cash 
flow, Market 
comparables, 
Industry standard 
derivative pricing (3)

$

(282)

Discounted cash
flow, Stochastic
recovery correlation
model

$ (2,059)

$

(3)

$

630

Industry standard 
derivative pricing (3)

Discounted cash 
flow, Industry 
standard derivative 
pricing (3)

Industry standard 
derivative pricing (4)

Total net derivative assets

$ (1,714)

Equity correlation

Long-dated equity volatilities

Yield

Price

Yield

Upfront points

Credit correlation

Prepayment speed

Default rate

Loss severity

Price

Equity correlation

Long-dated equity volatilities

Natural gas forward price

$1/MMBtu to $5/MMBtu

$3/MMBtu

Correlation

Volatilities

Correlation (IR/IR)

Correlation (FX/IR)

Long-dated inflation rates

Long-dated inflation volatilities

71% to 87%

26% to 132%

15% to 92%

0% to 46%

-14% to 38%

0% to 1%

81%

57%

50%

1%

4%

1%

0 to 14 years

0 to 10 years

9% to 14%

9% to 15%

15% to 100%

4% to 84%

7.5%

$0 to $100

5 years

3 years

10%

12%

63%

22%

n/a

$66

1% to 5%

3%

0 points to 100 points

71 points

35% to 83%

15% to 20% CPR

1% to 4% CDR

35%

$0 to $102

15% to 100%

4% to 84%

42%

16%

2%

n/a

$82

63%

22%

(1)  For loans and securities, structured liabilities and net derivative assets, the weighted average is calculated based upon the absolute fair value of the instruments. 
(2)  The categories are aggregated based upon product type which differs from financial statement classification. The following is a reconciliation to the line items in the table on page 168: Trading 
account assets – Corporate securities, trading loans and other of $1.9 billion, Trading account assets – Non-U.S. sovereign debt of $556 million, Trading account assets – Mortgage trading loans, 
ABS and other MBS of $1.5 billion, AFS debt securities – Other taxable securities of $509 million, AFS debt securities – Tax-exempt securities of $469 million, Loans and leases of $571 million and 
LHFS of $690 million.
Includes models such as Monte Carlo simulation and Black-Scholes.
Includes models such as Monte Carlo simulation, Black-Scholes and other methods that model the joint dynamics of interest, inflation and foreign exchange rates.

(3) 

(4) 

(5)  The weighted-average life is a product of changes in market rates of interest, prepayment rates and other model and cash flow assumptions.
CPR = Constant Prepayment Rate
CDR = Constant Default Rate
MMBtu = Million British thermal units
IR = Interest Rate
FX = Foreign Exchange
n/a = not applicable

Bank of America 2018     173 

In the previous tables, instruments backed by residential and 
commercial real estate assets include RMBS, commercial MBS, 
whole  loans  and  mortgage  CDOs.  Commercial  loans,  debt 
securities  and  other  include  corporate  CLOs  and  CDOs, 
commercial loans and bonds, and securities backed by non-real 
estate assets. Structured liabilities primarily include equity-linked 
notes that are accounted for under the fair value option.

The Corporation uses multiple market approaches in valuing 
certain of its Level 3 financial instruments. For example, market 
comparables and discounted cash flows are used together. For a 
given  product,  such  as  corporate  debt  securities,  market 
comparables may be used to estimate some of the unobservable 
inputs and then these inputs are incorporated into a discounted 
cash flow model. Therefore, the balances disclosed encompass 
both of these techniques.

The  level  of  aggregation  and  diversity  within  the  products 
disclosed in the tables results in certain ranges of inputs being 
wide and unevenly distributed across asset and liability categories. 

Uncertainty of Fair Value Measurements from 
Unobservable Inputs

Loans and Securities
A  significant  increase  in  market  yields,  default  rates,  loss 
severities or duration would have resulted in a significantly lower 
fair  value  for  long  positions.  Short  positions  would  have  been 
impacted in a directionally opposite way. The impact of changes 
in  prepayment  speeds  would  have  resulted  in  differing  impacts 
depending on the seniority of the instrument and, in the case of 
CLOs,  whether  prepayments  can  be  reinvested.  A  significant 
increase in price would have resulted in a significantly higher fair 
value  for  long  positions,  and  short  positions  would  have  been 
impacted in a directionally opposite way.

Structured Liabilities and Derivatives
For credit derivatives, a significant increase in market yield, upfront 
points (i.e., a single upfront payment made by a protection buyer 
at inception), credit spreads, default rates or loss severities would 
have resulted in a significantly lower fair value for protection sellers 
and higher fair value for protection buyers. The impact of changes 
in  prepayment  speeds  would  have  resulted  in  differing  impacts 
depending on the seniority of the instrument.

Structured credit derivatives are impacted by credit correlation. 
Default correlation is a parameter that describes the degree of 

dependence among credit default rates within a credit portfolio 
that underlies a credit derivative instrument. The sensitivity of this 
input  on  the  fair  value  varies  depending  on  the  level  of 
subordination  of  the  tranche.  For  senior  tranches  that  are  net 
purchases  of  protection,  a  significant  increase  in  default 
correlation would have resulted in a significantly higher fair value. 
Net  short  protection  positions  would  have  been  impacted  in  a 
directionally opposite way. 

For  equity  derivatives,  commodity  derivatives,  interest  rate 
derivatives and structured liabilities, a significant change in long-
dated rates and volatilities and correlation inputs (i.e., the degree 
of correlation between an equity security and an index, between 
two different commodities, between two different interest rates, 
or between interest rates and foreign exchange rates) would have 
resulted  in  a  significant  impact  to  the  fair  value;  however,  the 
magnitude  and  direction  of  the  impact  depend  on  whether  the 
Corporation is long or short the exposure. For structured liabilities, 
a  significant  increase  in  yield  or  decrease  in  price  would  have 
resulted in a significantly lower fair value. A significant decrease 
in duration would have resulted in a significantly higher fair value.

Sensitivity of Fair Value Measurements for Mortgage 
Servicing Rights
The weighted-average lives and fair value of MSRs are sensitive 
to changes in modeled assumptions. The weighted-average life is 
a product of changes in market rates of interest, prepayment rates 
and other model and cash flow assumptions. The weighted-average 
life represents the average period of time that the MSRs’ cash 
flows  are  expected  to  be  received.  Absent  other  changes,  an 
increase (decrease) to the weighted-average life would generally 
result in an increase (decrease) in the fair value of the MSRs. For 
example, a 10 percent or 20 percent decrease in prepayment rates, 
which impacts the weighted-average life, could result in an increase 
in fair value of $64 million or $133 million, while a 10 percent or 
20 percent increase in prepayment rates could result in a decrease 
in fair value of $59 million or $115 million. A 100 bp or 200 bp 
decrease in OAS levels could result in an increase in fair value of 
$63 million or $131 million, while a 100 bp or 200 bp increase 
in OAS levels could result in a decrease in fair value of $59 million
or $115 million. These sensitivities are hypothetical and actual 
amounts may vary materially.

174     Bank of America 2018

Nonrecurring Fair Value 
The  Corporation  holds  certain  assets  that  are  measured  at  fair  value,  but  only  in  certain  situations  (e.g.,  impairment)  and  these 
measurements are referred to herein as nonrecurring. The amounts below represent assets still held as of the reporting date for which 
a nonrecurring fair value adjustment was recorded during 2018, 2017 and 2016.

Assets Measured at Fair Value on a Nonrecurring Basis

(Dollars in millions)

Assets

Loans held-for-sale
Loans and leases (1)
Foreclosed properties (2, 3)
Other assets

Assets

December 31, 2018

December 31, 2017

Level 2

Level 3

Level 2

Level 3

$

274
—
—
331

$

— $

474
42
14

— $
—
—
425

2
894
83
—

2018

Gains (Losses)
2017

2016

Loans held-for-sale
Loans and leases (1)
Foreclosed properties
Other assets
Includes $83 million, $135 million and $150 million of losses on loans that were written down to a collateral value of zero during 2018, 2017 and 2016, respectively.

(202)
(24)
(64)

(18) $

$

(1) 

(6) $

(336)
(41)
(124)

(54)
(458)
(41)
(74)

(2)  Amounts are included in other assets on the Consolidated Balance Sheet and represent the carrying value of foreclosed properties that were written down subsequent to their initial classification 

as foreclosed properties. Losses on foreclosed properties include losses recorded during the first 90 days after transfer of a loan to foreclosed properties.

(3)  Excludes $488 million and $801 million of properties acquired upon foreclosure of certain government-guaranteed loans (principally FHA-insured loans) at December 31, 2018 and 2017.

The table below presents information about significant unobservable inputs related to the Corporation’s nonrecurring Level 3 financial 
assets and liabilities at December 31, 2018 and 2017. Loans and leases backed by residential real estate assets represent residential 
mortgages where the loan has been written down to the fair value of the underlying collateral. 

Quantitative Information about Nonrecurring Level 3 Fair Value Measurements

Financial Instrument

(Dollars in millions)

Fair
Value

Valuation 
Technique

Loans and leases backed by residential real estate assets $

474

Market comparables

Loans and leases backed by residential real estate assets $

894

Market comparables

Significant 
Unobservable 
Inputs

December 31, 2018

OREO discount
Costs to sell

December 31, 2017

OREO discount
Costs to sell

Inputs

Ranges of 
Inputs

13% to 59%
8% to 26%

15% to 58%
5% to 49%

Weighted
Average (1)

25%
9%

23%
7%

(1)  The weighted average is calculated based upon the fair value of the loans.

NOTE 21 Fair Value Option

Loans and Loan Commitments
The  Corporation  elects  to  account  for  certain  loans  and  loan 
commitments  that  exceed  the  Corporation’s  single-name  credit 
risk concentration guidelines under the fair value option. Lending 
commitments are actively managed and, as appropriate, credit risk 
for these lending relationships may be mitigated through the use 
of credit derivatives, with the Corporation’s public side credit view 
and market perspectives determining the size and timing of the 
hedging  activity.  These  credit  derivatives  do  not  meet  the 
requirements for designation as accounting hedges and therefore 
are carried at fair value with changes in fair value recorded in other 
income. The fair value option allows the Corporation to carry these 
loans and loan commitments at fair value, which is more consistent 
with  management’s  view  of  the  underlying  economics  and  the 
manner in which they are managed. In addition, the fair value option 
allows  the  Corporation  to  reduce  the  accounting  volatility  that 
would otherwise result from the asymmetry created by accounting 
for  the  financial  instruments  at  historical  cost  and  the  credit 
derivatives at fair value.

Loans Held-for-sale
The Corporation elects to account for residential mortgage LHFS, 
commercial mortgage LHFS and certain other LHFS under the fair 
value option with interest income on these LHFS recorded in other 
interest income. These loans are actively managed and monitored 
and,  as  appropriate,  certain  market  risks  of  the  loans  may  be 
mitigated  through  the  use  of  derivatives.  The  Corporation  has 
elected not to designate the derivatives as qualifying accounting 
hedges and therefore they are carried at fair value with changes 
in fair value recorded in other income. The changes in fair value 
of the loans are largely offset by changes in the fair value of the 
derivatives. The fair value option allows the Corporation to reduce 
the  accounting  volatility  that  would  otherwise  result  from  the 
asymmetry created by accounting for the financial instruments at 
the lower of cost or fair value and the derivatives at fair value. The 
Corporation  has  not  elected  to  account  for  certain  other  LHFS 
under  the  fair  value  option  primarily  because  these  loans  are 
floating-rate 
loans  that  are  not  hedged  using  derivative 
instruments.

Bank of America 2018     175 

 
 
 
 
 
 
Loans Reported as Trading Account Assets
The Corporation elects to account for certain loans that are held 
for the purpose of trading and are risk-managed on a fair value 
basis under the fair value option.

Other Assets
The Corporation elects to account for certain long-term fixed-rate 
margin loans that are hedged with derivatives under the fair value 
option. Election of the fair value option allows the Corporation to 
reduce the accounting volatility that would otherwise result from 
the asymmetry created by accounting for the financial instruments 
at historical cost and the derivatives at fair value.

Securities Financing Agreements
The Corporation elects to account for certain securities financing 
agreements, including resale and repurchase agreements, under 
the fair value option based on the tenor of the agreements, which 
reflects the magnitude of the interest rate risk. The majority of 
securities financing agreements collateralized by U.S. government 
securities  are  not  accounted  for  under  the  fair  value  option  as 
these  contracts  are  generally  short-dated  and  therefore  the 
interest rate risk is not significant.

Long-term Deposits
The Corporation elects to account for certain long-term fixed-rate 
and rate-linked deposits that are hedged with derivatives that do 
not  qualify  for  hedge  accounting  under  the  fair  value  option. 
Election of the fair value option allows the Corporation to reduce 

the  accounting  volatility  that  would  otherwise  result  from  the 
asymmetry created by accounting for the financial instruments at 
historical cost and the derivatives at fair value. The Corporation 
has  not  elected  to  carry  other  long-term  deposits  at  fair  value 
because they are not hedged using derivatives.

Short-term Borrowings
The  Corporation  elects  to  account  for  certain  short-term 
borrowings,  primarily  short-term  structured  liabilities,  under  the 
fair value option because this debt is risk-managed on a fair value 
basis.

The  Corporation  elects  to  account  for  certain  asset-backed 
secured  financings,  which  are  also  classified  in  short-term 
borrowings, under the fair value option. Election of the fair value 
option allows the Corporation to reduce the accounting volatility 
that  would  otherwise  result  from  the  asymmetry  created  by 
accounting for the asset-backed secured financings at historical 
cost  and  the  corresponding  mortgage  LHFS  securing  these 
financings at fair value.

Long-term Debt
The  Corporation  elects  to  account  for  certain  long-term  debt, 
primarily structured liabilities, under the fair value option. This long-
term debt is either risk-managed on a fair value basis or the related 
hedges do not qualify for hedge accounting.

Fair Value Option Elections
The table below provides information about the fair value carrying 
amount and the contractual principal outstanding of assets and 
liabilities accounted for under the fair value option at December 
31, 2018 and 2017.

Fair Value Option Elections

(Dollars in millions)

Federal funds sold and securities borrowed or

December 31, 2018

December 31, 2017

Fair Value
Carrying
Amount

Contractual
Principal
Outstanding

Fair Value
Carrying
Amount Less
Unpaid Principal

Fair Value
Carrying
Amount

Contractual
Principal
Outstanding

Fair Value
Carrying
Amount Less
Unpaid Principal

purchased under agreements to resell

$

56,399

$

56,376

$

23

$

52,906

$

52,907

$

Loans reported as trading account assets (1)
Trading inventory – other
Consumer and commercial loans
Loans held-for-sale (1)
Other assets
Long-term deposits
Federal funds purchased and securities loaned or

sold under agreements to repurchase

6,195
13,778
4,349
2,942
3
492

13,088
n/a
4,399
4,749
n/a
454

(6,893)
n/a
(50)
(1,807)
n/a
38

5,735
12,027
5,710
2,156
3
449

11,804
n/a
5,744
3,717
n/a
421

28,875

28,881

(6)

36,182

36,187

(1)

(6,069)
n/a
(34)
(1,561)
n/a
28

(5)

Short-term borrowings
Unfunded loan commitments
Long-term debt (2)
(1)  A significant portion of the loans reported as trading account assets and LHFS are distressed loans that were purchased at a deep discount to par, and the remainder are loans with a fair value near 

1,494
n/a
31,512

1,494
120
31,786

—
n/a
(1,510)

1,648
169
27,637

1,648
n/a
29,147

—
n/a
274

contractual principal outstanding.
Includes structured liabilities with a fair value of $27.3 billion and $31.4 billion, and contractual principal outstanding of $28.8 billion and $31.1 billion at December 31, 2018 and 2017.

(2) 

n/a = not applicable

176     Bank of America 2018

The following tables provide information about where changes in the fair value of assets and liabilities accounted for under the fair 

value option are included in the Consolidated Statement of Income for 2018, 2017 and 2016.

Gains (Losses) Relating to Assets and Liabilities Accounted for Under the Fair Value Option

(Dollars in millions)

Loans reported as trading account assets (1)
Trading inventory – other (2)
Consumer and commercial loans (1)
Loans held-for-sale (1, 3)
Unfunded loan commitments
Long-term debt (4, 5)
Other (6)
Total

Loans reported as trading account assets (1)
Trading inventory – other (2)
Consumer and commercial loans (1)
Loans held-for-sale (1, 3)
Unfunded loan commitments
Long-term debt (4, 5)
Other (6)
Total

Loans reported as trading account assets (1)
Trading inventory – other (2)
Consumer and commercial loans (1)
Loans held-for-sale (1, 3)
Unfunded loan commitments
Long-term debt (4, 5)
Other (6)
Total

Trading Account
Profits

Other 
Income

2018

Total

$

$

$

$

$

$

$

$

$

$

8
1,750
(422)
1
—
2,157
8
3,502

318
3,821
(9)
—
—
(1,044)
(93)
2,993

301
57
49
11
—
(489)
(85)

$

(156) $

— $
—
(53)
24
(49)
(93)
18
(153) $

— $
—
35
298
36
(146)
13
236

$

— $
—
(37)
524
487
(97)
53
930

$

2017

2016

8
1,750
(475)
25
(49)
2,064
26
3,349

318
3,821
26
298
36
(1,190)
(80)
3,229

301
57
12
535
487
(586)
(32)
774

(1)   Gains (losses) related to borrower-specific credit risk were not significant.  
(2)  The gains in trading account profits are primarily offset by losses on trading liabilities that hedge these assets.
(3)  Includes the value of IRLCs on funded loans, including those sold during the period.
(4)  The majority of the net gains (losses) in trading account profits relate to the embedded derivatives in structured liabilities and are offset by gains (losses) on derivatives and securities that hedge 

these liabilities.

(5)  For the cumulative impact of changes in the Corporation’s own credit spreads and the amount recognized in accumulated OCI, see Note 14 – Accumulated Other Comprehensive Income (Loss). For  

more information on how the Corporation’s own credit spread is determined, see Note 20 – Fair Value Measurements.

(6)  Includes gains (losses) on federal funds sold and securities borrowed or purchased under agreements to resell, other assets, long-term deposits, federal funds purchased and securities loaned or 

sold under agreements to repurchase and short-term borrowings.

NOTE 22 Fair Value of Financial Instruments
Financial instruments are classified within the fair value hierarchy 
using  the  methodologies  described  in  Note  20  –  Fair  Value 
Measurements.  Certain  loans,  deposits,  long-term  debt  and 
unfunded lending commitments are accounted for under the fair 
value option. For additional information, see Note 21 – Fair Value 
Option.  The  following  disclosures  include  financial  instruments 
that are not carried at fair value or only a portion of the ending 
balance is carried at fair value on the Consolidated Balance Sheet.

Short-term Financial Instruments 
The carrying value of short-term financial instruments, including 
cash and cash equivalents, certain time deposits placed and other 
short-term investments, federal funds sold and purchased, certain 
resale  and  repurchase  agreements  and  short-term  borrowings, 

approximates the fair value of these instruments. These financial 
instruments generally expose the Corporation to limited credit risk 
and have no stated maturities or have short-term maturities and 
carry  interest  rates  that  approximate  market.  The  Corporation 
accounts for certain resale and repurchase agreements under the 
fair value option.

Under the fair value hierarchy, cash and cash equivalents are 
classified as Level 1. Time deposits placed and other short-term 
investments, such as U.S. government securities and short-term 
commercial paper, are classified as Level 1 or Level 2. Federal 
funds sold and purchased are classified as Level 2. Resale and 
repurchase agreements are classified as Level 2 because they 
are  generally  short-dated  and/or  variable-rate  instruments 
collateralized by U.S. government or agency securities. Short-term 
borrowings are classified as Level 2.

Bank of America 2018     177 

Fair Value of Financial Instruments
The carrying values and fair values by fair value hierarchy of certain 
financial instruments where only a portion of the ending balance 
was carried at fair value at December 31, 2018 and 2017 are 
presented in the following table.

Fair Value of Financial Instruments

Fair Value

Carrying
Value

Level 2

Level 3

Total

December 31, 2018

(Dollars in millions)

Financial assets

Loans
Loans held-for-sale

$ 911,520
10,367

$

58,228
9,592

$ 859,160
775

$ 917,388
10,367

Financial liabilities

Deposits (1)
Long-term debt

Commercial 
unfunded lending 
commitments (2)

Financial assets

1,381,476
229,340

1,381,239
229,967

— 1,381,239
230,784

817

966

169

5,558

5,727

December 31, 2017

Loans
Loans held-for-sale

$ 904,399
11,430

$

68,586
10,521

$ 849,576
909

$ 918,162
11,430

Financial liabilities

Deposits (1)
Long-term debt

Commercial 
unfunded lending 
commitments (2)

1,309,545
227,402

1,309,398
235,126

— 1,309,398
236,989

1,863

897

120

3,908

4,028

(1)  Includes demand deposits of $531.9 billion and $519.6 billion with no stated maturities at 

December 31, 2018 and 2017.

(2)  The  carrying  value  of  commercial  unfunded  lending  commitments  is  included  in  accrued 
expenses and other liabilities on the Consolidated Balance Sheet. The Corporation does not 
estimate the fair value of consumer unfunded lending commitments because, in many instances, 
the Corporation can reduce or cancel these commitments by providing notice to the borrower. 
For more information on commitments, see Note 12 – Commitments and Contingencies.

NOTE 23 Business Segment Information
The  Corporation  reports  its  results  of  operations  through  the 
following  four  business  segments:  Consumer  Banking,  GWIM, 
Global Banking and Global Markets, with the remaining operations 
recorded in All Other. 

Consumer Banking
Consumer Banking offers a diversified range of credit, banking and 
investment  products  and  services  to  consumers  and  small 
businesses.  Consumer  Banking  product  offerings 
include 
traditional savings accounts, money market savings accounts, CDs 
and  IRAs,  checking  accounts,  and  investment  accounts  and 
products, as well as credit and debit cards, residential mortgages 
and home equity loans, and direct and indirect loans to consumers 
and small businesses in the U.S. Consumer Banking includes the 
impact of servicing residential mortgages and home equity loans 
in the core portfolio. 

Global Wealth & Investment Management
GWIM provides a high-touch client experience through a network 
of  financial  advisors  focused  on  clients  with  over  $250,000  in 
total  investable  assets,  including  tailored  solutions  to  meet 
clients’  needs  through  a  full  set  of  investment  management, 
brokerage, banking and retirement products. GWIM also provides 
comprehensive wealth management solutions targeted to high net 
worth  and  ultra  high  net  worth  clients,  as  well  as  customized 
solutions  to  meet  clients’  wealth  structuring,  investment 

178     Bank of America 2018

management, trust and banking needs, including specialty asset 
management services.

Global Banking
Global Banking provides a wide range of lending-related products 
and services, integrated working capital management and treasury 
solutions,  and  underwriting  and  advisory  services  through  the 
Corporation’s  network  of  offices  and  client  relationship  teams. 
Global  Banking  also  provides  investment  banking  products  to 
clients.  The  economics  of  certain  investment  banking  and 
underwriting activities are shared primarily between Global Banking 
and  Global  Markets  under  an 
revenue-sharing 
arrangement.  Global  Banking  clients  generally  include  middle-
market  companies,  commercial  real  estate  firms,  not-for-profit 
companies,  large  global  corporations,  financial  institutions, 
leasing  clients,  and  mid-sized  U.S.-based  businesses  requiring 
customized and integrated financial advice and solutions.

internal 

Global Markets
Global  Markets  offers  sales  and  trading  services  and  research 
services  to  institutional  clients  across  fixed-income,  credit, 
currency,  commodity  and  equity  businesses.  Global  Markets 
provides market-making, financing, securities clearing, settlement 
and  custody  services  globally  to  institutional  investor  clients  in 
support  of  their  investing  and  trading  activities.  Global Markets 
product coverage includes securities and derivative products in 
both  the  primary  and  secondary  markets.  Global  Markets  also 
works  with  commercial  and  corporate  clients  to  provide  risk 
management  products.  As  a  result  of  market-making  activities, 
Global Markets may be required to manage risk in a broad range 
of  financial  products.  In  addition,  the  economics  of  certain 
investment banking and underwriting activities are shared primarily 
between  Global  Markets  and  Global  Banking  under  an  internal 
revenue-sharing arrangement.

All Other
All Other consists of ALM activities, equity investments, non-core 
mortgage loans and servicing activities, the net impact of periodic 
revisions to the MSR valuation model for core and non-core MSRs 
and the related economic hedge results, liquidating businesses 
and  residual  expense  allocations.  ALM  activities  encompass 
certain residential mortgages, debt securities, interest rate and 
foreign currency risk management activities, the impact of certain 
allocation methodologies and hedge ineffectiveness. The results 
of certain ALM activities are allocated to the business segments. 
Equity investments include the merchant services joint venture as 
well  as  a  portfolio  of  equity,  real  estate  and  other  alternative 
investments. 

Basis of Presentation
The  management  accounting  and  reporting  process  derives 
segment  and  business 
results  by  utilizing  allocation 
methodologies for revenue and expense. The net income derived 
for the businesses is dependent upon revenue and cost allocations 
using an activity-based costing model, funds transfer pricing, and 
other methodologies and assumptions management believes are 
appropriate to reflect the results of the business.

Total revenue, net of interest expense, includes net interest 
income on an FTE basis and noninterest income. The adjustment 
of net interest income to an FTE basis results in a corresponding 
increase in income tax expense. The segment results also reflect 
certain revenue and expense methodologies that are utilized to 
determine net income. The net interest income of the businesses 
includes  the  results  of  a  funds  transfer  pricing  process  that 

 
 
matches assets and liabilities with similar interest rate sensitivity 
and  maturity  characteristics.  In  segments  where  the  total  of 
liabilities and equity exceeds assets, which are generally deposit-
taking  segments,  the  Corporation  allocates  assets  to  match 
liabilities.  Net  interest  income  of  the  business  segments  also 
includes an allocation of net interest income generated by certain 
of the Corporation’s ALM activities. 

The Corporation’s ALM activities include an overall interest rate 
risk  management  strategy  that  incorporates  the  use  of  various 
derivatives  and  cash  instruments  to  manage  fluctuations  in 
earnings and capital that are caused by interest rate volatility. The 
Corporation’s goal is to manage interest rate sensitivity so that 
movements in interest rates do not significantly adversely affect 
earnings and capital. The results of a majority of the Corporation’s 
ALM  activities  are  allocated  to  the  business  segments  and 

fluctuate based on the performance of the ALM activities. ALM 
activities  include  external  product  pricing  decisions  including 
deposit pricing strategies, the effects of the Corporation’s internal 
funds transfer pricing process and the net effects of other ALM 
activities.

Certain  expenses  not  directly  attributable  to  a  specific 
business segment are allocated to the segments. The costs of 
certain  centralized  or  shared  functions  are  allocated  based  on 
methodologies that reflect utilization.

The  following  table  presents  net  income  (loss)  and  the 
components thereto (with net interest income on an FTE basis for 
the business segments, All Other and the total Corporation) for 
2018, 2017 and 2016, and total assets at December 31, 2018 
and 2017 for each business segment, as well as All Other.

Results of Business Segments and All Other

At and for the year ended December 31
(Dollars in millions)

Net interest income
Noninterest income

Total revenue, net of interest expense

Provision for credit losses
Noninterest expense

Income before income taxes

Income tax expense

Net income

Year-end total assets

Net interest income
Noninterest income

Total revenue, net of interest expense

Provision for credit losses
Noninterest expense

Income before income taxes

Income tax expense

Net income

Year-end total assets

Net interest income
Noninterest income

Total revenue, net of interest expense

Provision for credit losses
Noninterest expense

Income (loss) before income taxes

Income tax expense (benefit)

Net income (loss)
Year-end total assets
(1)  There were no material intersegment revenues.

$

6,294
13,044
19,338
86
13,777
5,475
1,396
$
4,079
$ 305,906

2018

$

3,171
12,892
16,063
—
10,686
5,377
1,398
$
3,979
$ 641,922

$

6,173
12,417
18,590
56
13,556
4,978
1,885
$
3,093
$ 284,321

Global Markets
2017

$

3,744
12,207
15,951
164
10,731
5,056
1,763
$
3,293
$ 629,013

$

$

$

$

Total Corporation (1)
2017

2018

2016

2018

Consumer Banking
2017

2016

$

48,042
43,815
91,857
3,282
53,381
35,194
7,047
28,147
$
$ 2,354,507

$

45,592
42,685
88,277
3,396
54,743
30,138
11,906
18,232
$
$ 2,281,234

$

$

41,996
42,605
84,601
3,597
55,083
25,921
8,099
17,822

$

27,123
10,400
37,523
3,664
17,713
16,146
4,117
12,029
$
$ 768,877

$

24,307
10,214
34,521
3,525
17,795
13,201
4,999
8,202
$
$ 749,325

Global Wealth &
Investment Management

Global Banking

2018

2017

2016

2018

2017

$

$

$

$

21,290
10,441
31,731
2,715
17,664
11,352
4,186
7,166

2016

9,471
8,974
18,445
883
8,486
9,076
3,347
5,729

5,759
11,891
17,650
68
13,166
4,416
1,635
2,781

$

10,881
8,763
19,644
8
8,591
11,045
2,872
8,173
  $ 441,477

$

$

10,504
9,495
19,999
212
8,596
11,191
4,238
$
6,953
$ 424,533

2016

2018

All Other
2017

2016

4,557
11,533
16,090
31
10,171
5,888
2,071
3,817

$

$

573
(1,284)
(711)
(476)
2,614
(2,849)
(2,736)

(113) $

$
$ 196,325

$

864
(1,648)
(784)
(561)
4,065
(4,288)
(979)
(3,309) $

919
(234)
685
(100)
5,596
(4,811)
(3,140)
(1,671)

$ 194,042

Bank of America 2018     179 

 
 
 
 
 
 
 
The table below presents noninterest income and the components thereto for 2018, 2017 and 2016 for each business segment, 
as well as All Other. For more information, see Note 1 – Summary of Significant Accounting Principles and Note 2 – Noninterest Income.

Noninterest Income by Business Segment and All Other

$

$

$

(Dollars in millions)

Card income

Interchange fees
Other card income

Total card income

Service charges

Deposit-related fees
Lending-related fees

Total service charges

Investment and brokerage services

Asset management fees
Brokerage fees

Total investment and brokerage

services

Investment banking income

Underwriting income
Syndication fees
Financial advisory services

Total investment banking income

Trading account profits
Other income

Total noninterest income

Card income

Interchange fees
Other card income

Total card income

Service charges

Deposit-related fees
Lending-related fees

Total service charges

Investment and brokerage services

Asset management fees
Brokerage fees

Total investment and brokerage

services

Investment banking income

Total investment banking income

Underwriting income
Syndication fees
Financial advisory services

502
1,237
1,152
2,891
260
1,950
8,763
(1)  All Other includes eliminations of intercompany transactions.

Trading account profits
Other income

Total noninterest income

$

Total Corporation

Consumer Banking

2018

2017

2016

2018

2017

2016

Global Wealth &
Investment Management
2017

2016

2018

$

$

4,093
1,958
6,051

6,667
1,100
7,767

10,189
3,971

3,942
1,960
5,902

6,708
1,110
7,818

9,310
4,526

3,960
1,891
5,851

6,545
1,093
7,638

8,328
5,021

14,160

13,836

13,349

2,722
1,347
1,258
5,327
8,540
1,970
43,815

2,821
1,499
1,691
6,011
7,277
1,841
$ 42,685

2,585
1,388
1,268
5,241
6,902
3,624
$ 42,605

Global Banking
2017

2016

2018

$

$

3,383
1,906
5,289

4,300
—
4,300

147
172

319

3,224
1,846
5,070

4,266
—
4,266

133
184

317

3,271
1,664
4,935

4,142
—
4,142

120
200

320

$

$

82
46
128

73
—
73

$

109
44
153

76
—
76

106
44
150

74
—
74

10,042
1,917

9,177
2,217

8,208
2,666

11,959

11,394

10,874

(1)
—
—
(1)
8
485
10,400

—
—
—
—
3
558
$ 10,214

2
—
—
2
—
1,042
$ 10,441

335
—
2
337
112
435
$ 13,044

Global Markets
2017

2018

2016

2018

316
—
2
318
144
332
$ 12,417

All Other (1)
2017

225
1
1
227
175
391
$ 11,891

2016

$

533
8
541

$

506
12
518

$

95
(2)
93

$

94
(2)
92

$

79
(5)
74

— $
—
—

483
20
503

2,170
924
3,094

—
74

74

426
1,302
1,156
2,884
133
2,286
8,974

161
184
345

—
1,780

1,780

2,084
109
103
2,296
7,932
446
12,892

2,111
916
3,027

—
94

94

2,197
928
3,125

—
97

97

511
1,403
1,557
3,471
134
2,150
9,495

$

$

147
182
329

—
2,049

143
169
312

—
2,102

2,049

2,102

22
—
22

—
8

8

2,249
95
132
2,476
6,710
551
$ 12,207

2,100
85
111
2,296
6,550
199
$ 11,533

$

(198)
1
1
(196)
228
(1,346)
(1,284) $

(255)
1
—
(254)
286
(1,750)
(1,648) $

$

9
60
69

22
—
22

—
(21)

(21)

21
168
189

16
—
16

—
(21)

(21)

(168)
—
—
(168)
44
(294)
(234)

$

$

$

$

The tables below present a reconciliation of the four business segments’ total revenue, net of interest expense, on an FTE basis, 

and net income to the Consolidated Statement of Income, and total assets to the Consolidated Balance Sheet.

(Dollars in millions)

Segments’ total revenue, net of interest expense
Adjustments (1):
ALM activities
Liquidating businesses, eliminations and other
FTE basis adjustment

Consolidated revenue, net of interest expense

Segments’ total net income
Adjustments, net-of-tax (1):

ALM activities
Liquidating businesses, eliminations and other

Consolidated net income

(1)  Adjustments include consolidated income, expense and asset amounts not specifically allocated to individual business segments.

180     Bank of America 2018

2018

2017

2016

$

92,568

$

89,061

$

83,916

588
(1,299)
(610)
91,247
28,260

(46)
(67)
28,147

$

$

312
(1,096)
(925)
87,352
21,541

(355)
(2,954)
18,232

$

$

(299)
984
(900)
83,701
19,493

(651)
(1,020)
17,822

$

$

 
(Dollars in millions)

Segments’ total assets
Adjustments (1):

ALM activities, including securities portfolio
Elimination of segment asset allocations to match liabilities
Other

Consolidated total assets

December 31

2018
2,158,182

670,057
(540,801)
67,069
2,354,507

$

$

2017
2,087,192

625,483
(520,448)
89,007
2,281,234

$

$

(1)  Adjustments include consolidated income, expense and asset amounts not specifically allocated to individual business segments.

NOTE 24 Parent Company Information
The following tables present the Parent Company-only financial information. This financial information is presented in accordance with 
bank regulatory reporting requirements.

Condensed Statement of Income

(Dollars in millions)

Income
Dividends from subsidiaries:

Bank holding companies and related subsidiaries
Nonbank companies and related subsidiaries

Interest from subsidiaries
Other income (loss)
Total income

Expense
Interest on borrowed funds from related subsidiaries
Other interest expense
Noninterest expense
Total expense
Income (loss) before income taxes and equity in undistributed earnings of subsidiaries

Income tax expense (benefit)
Income before equity in undistributed earnings of subsidiaries
Equity in undistributed earnings (losses) of subsidiaries:

Bank holding companies and related subsidiaries
Nonbank companies and related subsidiaries

Total equity in undistributed earnings of subsidiaries
Net income

Condensed Balance Sheet

(Dollars in millions)

Assets
Cash held at bank subsidiaries (1)
Securities
Receivables from subsidiaries:

Bank holding companies and related subsidiaries
Banks and related subsidiaries
Nonbank companies and related subsidiaries

Investments in subsidiaries:

Bank holding companies and related subsidiaries
Nonbank companies and related subsidiaries

Other assets

Total assets

Liabilities and shareholders’ equity
Accrued expenses and other liabilities
Payables to subsidiaries:

Banks and related subsidiaries
Nonbank companies and related subsidiaries

Long-term debt

Total liabilities
Shareholders’ equity

Total liabilities and shareholders’ equity

(1)  Balance includes third-party cash held of $389 million and $193 million at December 31, 2018 and 2017.

2018

2017

2016

$

$

28,575
91
8,425
(1,025)
36,066

235
6,425
1,600
8,260
27,806
(281)
28,087

306
(246)
60
28,147

$

$

$

$

$

$

$

12,088
202
7,043
28
19,361

189
5,555
1,672
7,416
11,945
950
10,995

8,725
(1,488)
7,237
18,232

$

4,127
77
2,996
111
7,311

969
5,096
2,704
8,769
(1,458)
(2,311)
853

16,817
152
16,969
17,822

December 31

2018

2017

$

5,141
628

4,747
596

152,905
195
969

293,045
3,432
14,696
471,011

8,828

349
13,301
183,208
205,686
265,325
471,011

$

$

$

146,566
146
4,745

296,506
5,225
14,554
473,085

10,286

359
9,341
185,953
205,939
267,146
473,085

Bank of America 2018     181 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Condensed Statement of Cash Flows

(Dollars in millions)

Operating activities
Net income
Reconciliation of net income to net cash used in operating activities:

Equity in undistributed earnings of subsidiaries
Other operating activities, net

Net cash provided by (used in) operating activities

Investing activities
Net sales of securities
Net payments to subsidiaries
Other investing activities, net

Net cash used in investing activities

Financing activities
Net decrease in short-term borrowings
Net increase (decrease) in other advances
Proceeds from issuance of long-term debt
Retirement of long-term debt
Proceeds from issuance of preferred stock
Redemption of preferred stock
Common stock repurchased
Cash dividends paid

Net cash used in financing activities

Net increase (decrease) in cash held at bank subsidiaries
Cash held at bank subsidiaries at January 1

Cash held at bank subsidiaries at December 31

2018

2017

2016

$

28,147

$

18,232

$

17,822

(60)
(3,706)
24,381

51
(2,262)
48
(2,163)

—
3,867
30,708
(29,413)
4,515
(4,512)
(20,094)
(6,895)
(21,824)
394
4,747
5,141

$

(7,237)
(2,593)
8,402

312
(7,087)
(1)
(6,776)

—
(6,672)
37,704
(29,645)
—
—
(12,814)
(5,700)
(17,127)
(15,501)
20,248
4,747

$

(16,969)
(2,860)
(2,007)

—
(65,481)
(308)
(65,789)

(136)
(44)
27,363
(30,804)
2,947
—
(5,112)
(4,194)
(9,980)
(77,776)
98,024
20,248

$

NOTE 25 Performance by Geographical Area
The Corporation’s operations are highly integrated with operations in both U.S. and non-U.S. markets. The non-U.S. business activities 
are largely conducted in Europe, the Middle East and Africa and in Asia. The Corporation identifies its geographic performance based 
on the business unit structure used to manage the capital or expense deployed in the region as applicable. This requires certain 
judgments related to the allocation of revenue so that revenue can be appropriately matched with the related capital or expense deployed 
in the region. Certain asset, liability, income and expense amounts have been allocated to arrive at total assets, total revenue, net of 
interest expense, income before income taxes and net income by geographic area as presented below.

(Dollars in millions)

U.S. (3)

Asia

Europe, Middle East and Africa

Latin America and the Caribbean

Total Non-U.S. 

Total Consolidated

Total Assets at 
Year End (1)

Total Revenue, 
Net of Interest 
Expense (2)

Income Before
Income Taxes

Net Income

2018
2017
2016
2018
2017
2016
2018
2017
2016
2018
2017
2016
2018
2017
2016
2018
2017
2016

$

2,051,182
1,965,490

$

94,865
103,255

185,285
189,661

23,175
22,828

303,325
315,744

$

2,354,507
2,281,234

$

$

$

81,004
74,830
72,418
3,507
3,405
3,365
5,632
7,907
6,608
1,104
1,210
1,310
10,243
12,522
11,283
91,247
87,352
83,701

$

$

31,904
25,108
22,282
865
676
674
1,543
2,990
1,705
272
439
360
2,680
4,105
2,739
34,584
29,213
25,021

26,407
15,550
16,183
520
464
488
1,126
1,926
925
94
292
226
1,740
2,682
1,639
28,147
18,232
17,822

(1)  Total assets include long-lived assets, which are primarily located in the U.S.
(2)  There were no material intercompany revenues between geographic regions for any of the periods presented.
(3)  Substantially reflects the U.S.

182     Bank of America 2018

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Glossary

Alt-A Mortgage – A type of U.S. mortgage that is considered riskier 
than  A-paper,  or  “prime,”  and  less  risky  than  “subprime,”  the 
riskiest category. Typically, Alt-A mortgages are characterized by 
borrowers with less than full documentation, lower credit scores 
and higher LTVs.

Assets  Under  Management  (AUM)  –  The  total  market  value  of 
assets under the investment advisory and/or discretion of GWIM 
which generate asset management fees based on a percentage 
of  the  assets’  market  values.  AUM  reflects  assets  that  are 
generally  managed  for  institutional,  high  net  worth  and  retail 
clients, and are distributed through various investment products 
including mutual funds, other commingled vehicles and separate 
accounts.

Banking Book – All on- and off-balance sheet financial instruments 
of  the  Corporation  except  for  those  positions  that  are  held  for 
trading purposes.

Brokerage  and  Other  Assets  –  Non-discretionary  client  assets 
which are held in brokerage accounts or held for safekeeping.

Committed Credit Exposure – Any funded portion of a facility plus 
the unfunded portion of a facility on which the lender is legally 
bound to advance funds during a specified period under prescribed 
conditions.

Credit  Derivatives  –  Contractual  agreements  that  provide 
protection  against  a  specified  credit  event  on  one  or  more 
referenced obligations. 

Credit Valuation Adjustment (CVA) – A portfolio adjustment required 
to properly reflect the counterparty credit risk exposure as part of 
the fair value of derivative instruments. 

Debit Valuation Adjustment (DVA) – A portfolio adjustment required 
to properly reflect the Corporation’s own credit risk exposure as 
part of the fair value of derivative instruments and/or structured 
liabilities.

Funding  Valuation  Adjustment  (FVA)  –  A  portfolio  adjustment 
required to include funding costs on uncollateralized derivatives 
and derivatives where the Corporation is not permitted to use the 
collateral it receives. 

Interest Rate Lock Commitment (IRLC) – Commitment with a loan 
applicant in which the loan terms are guaranteed for a designated 
period of time subject to credit approval.

Letter of Credit – A document issued on behalf of a customer to 
a third party promising to pay the third party upon presentation of 
specified documents. A letter of credit effectively substitutes the 
issuer’s credit for that of the customer. 

Loan-to-value (LTV) – A commonly used credit quality metric. LTV 
is calculated as the outstanding carrying value of the loan divided 
by the estimated value of the property securing the loan. 

Margin  Receivable  –  An  extension  of  credit  secured  by  eligible 
securities in certain brokerage accounts.

Matched Book – Repurchase and resale agreements or securities 
borrowed  and  loaned  transactions  where  the  overall  asset  and 
liability position is similar in size and/or maturity. Generally, these 
are  entered  into  to  accommodate  customers  where  the 
Corporation earns the interest rate spread.

Mortgage Servicing Rights (MSR) – The right to service a mortgage 
loan  when  the  underlying  loan  is  sold  or  securitized.  Servicing 
includes collections for principal, interest and escrow payments 
from  borrowers  and  accounting  for  and  remitting  principal  and 
interest payments to investors.

Net Interest Yield – Net interest income divided by average total 
interest-earning assets.

Nonperforming Loans and Leases – Includes loans and leases that 
have  been  placed  on  nonaccrual  status,  including  nonaccruing 
loans whose contractual terms have been restructured in a manner 
that  grants  a  concession  to  a  borrower  experiencing  financial 
difficulties. 

Operating Margin – Income before income taxes divided by total 
revenue, net of interest expense.

Prompt Corrective Action (PCA) – A framework established by the 
U.S. banking regulators requiring banks to maintain certain levels 
of  regulatory  capital  ratios,  comprised  of  five  categories  of 
capitalization:  “well  capitalized,”  “adequately  capitalized,” 
“undercapitalized,” “significantly undercapitalized” and “critically 
undercapitalized.” Insured depository institutions that fail to meet 
certain  of  these  capital  levels  are  subject  to  increasingly  strict 
limits  on  their  activities,  including  their  ability  to  make  capital 
distributions, pay management compensation, grow assets and 
take other actions. 

Subprime  Loans  –  Although  a  standard  industry  definition  for 
subprime  loans  (including  subprime  mortgage  loans)  does  not 
exist, the Corporation defines subprime loans as specific product 
offerings for higher risk borrowers. 

Troubled Debt Restructurings (TDRs) – Loans whose contractual 
terms have been restructured in a manner that grants a concession 
to a borrower experiencing financial difficulties. Certain consumer 
loans for which a binding offer to restructure has been extended 
are also classified as TDRs.

Value-at-Risk (VaR) – VaR is a model that simulates the value of 
a  portfolio  under  a  range  of  hypothetical  scenarios  in  order  to 
generate  a  distribution  of  potential  gains  and  losses.  VaR 
represents the loss the portfolio is expected to experience with a 
given confidence level based on historical data. A VaR model is 
an effective tool in estimating ranges of potential gains and losses 
on our trading portfolios. 

Bank of America 2018     183 

Acronyms

ABS
AFS
ALM
AUM
AVM
BANA
BHC
bps
CCAR
CDO
CDS
CET1
CGA
CLO
CLTV
CVA
DVA
EAD
EPS
ERC
EU
FCA
FDIC
FHA
FHLB
FHLMC
FICC
FICO
FLUs
FNMA
FTE
FVA
GAAP

Asset-backed securities
Available-for-sale
Asset and liability management
Assets under management
Automated valuation model
Bank of America, National Association
Bank holding company
basis points
Comprehensive Capital Analysis and Review
Collateralized debt obligation
Credit default swap
Common equity tier 1
Corporate General Auditor
Collateralized loan obligation
Combined loan-to-value
Credit valuation adjustment
Debit valuation adjustment
Exposure at default
Earnings per common share
Enterprise Risk Committee
European Union
Financial Conduct Authority
Federal Deposit Insurance Corporation
Federal Housing Administration
Federal Home Loan Bank
Freddie Mac
Fixed-income, currencies and commodities
Fair Isaac Corporation (credit score)
Front line units
Fannie Mae
Fully taxable-equivalent
Funding valuation adjustment
Accounting principles generally accepted in the
United States of America

GLS
GM&CA
GNMA
GSE
G-SIB
GWIM
HELOC
HQLA

Global Liquidity Sources
Global Marketing and Corporate Affairs
Government National Mortgage Association
Government-sponsored enterprise
Global systemically important bank
Global Wealth & Investment Management
Home equity line of credit
High Quality Liquid Assets

HTM
ICAAP
IRM
IRLC
ISDA

LCR
LGD
LHFS
LIBOR
LTV
MBS
MD&A

Held-to-maturity
Internal Capital Adequacy Assessment Process
Independent Risk Management
Interest rate lock commitment
International Swaps and Derivatives Association,
Inc.
Liquidity Coverage Ratio
Loss given default
Loans held-for-sale
London InterBank Offered Rate
Loan-to-value
Mortgage-backed securities
Management’s Discussion and Analysis of
Financial Condition and Results of Operations

MLGWM Merrill Lynch Global Wealth Management
MLI
MLPCC
MLPF&S Merrill Lynch, Pierce, Fenner & Smith

Merrill Lynch International
Merrill Lynch Professional Clearing Corp

MRC
MSA
MSR
NSFR
OAS
OCC
OCI
OREO
OTC
OTTI
PCA
PCI
RMBS
RSU
SBLC
SCCL
SEC
SLR
TDR
TLAC
VA
VaR
VIE

Incorporated
Management Risk Committee
Metropolitan Statistical Area
Mortgage servicing right
Net Stable Funding Ratio
Option-adjusted spread
Office of the Comptroller of the Currency
Other comprehensive income
Other real estate owned
Over-the-counter
Other-than-temporary impairment
Prompt Corrective Action
Purchased credit-impaired
Residential mortgage-backed securities
Restricted stock unit
Standby letter of credit
Single-counterparty credit limits 
Securities and Exchange Commission
Supplementary leverage ratio
Troubled debt restructurings
Total loss-absorbing capacity
U.S. Department of Veterans Affairs
Value-at-Risk
Variable interest entity

184     Bank of America 2018

 
Disclosure Controls and Procedures
Disclosure Controls and Procedures

Bank of America Corporation and Subsidiaries
Bank of America Corporation and Subsidiaries

As of the end of the period covered by this report and pursuant to Rule 13a-15 of the Securities Exchange Act of 1934, as amended 
As of the end of the period covered by this report and pursuant to Rule 13a-15 of the Securities Exchange Act of 1934, as amended 
(Exchange Act), Bank of America’s management, including the Chief Executive Officer and Chief Financial Officer, conducted an evaluation 
(Exchange Act), Bank of America’s management, including the Chief Executive Officer and Chief Financial Officer, conducted an evaluation 
of the effectiveness and design of our disclosure controls and procedures (as that term is defined in Rule 13a-15(e) of the Exchange 
of the effectiveness and design of our disclosure controls and procedures (as that term is defined in Rule 13a-15(e) of the Exchange 
Act). Based upon that evaluation, Bank of America’s Chief Executive Officer and Chief Financial Officer concluded that Bank of America’s 
Act). Based upon that evaluation, Bank of America’s Chief Executive Officer and Chief Financial Officer concluded that Bank of America’s 
disclosure controls and procedures were effective, as of the end of the period covered by this report.
disclosure controls and procedures were effective, as of the end of the period covered by this report.

Bank of America 2018     185 
Bank of America 2018     185 

Executive Management Team and Management Committee
Bank of America Corporation
Executive Management Team and Management Committee
Bank of America Corporation

Executive Management Team and Management Committee
Bank of America Corporation

Paul M. Donofrio* 
Chief Financial Officer

Executive Management Team
Brian T. Moynihan* 
Executive Management Team
Executive Management Team
Chairman of the Board and  
Brian T. Moynihan* 
Brian T. Moynihan* 
Chief Executive Officer
Chairman of the Board and  
Chairman of the Board and  
Dean C. Athanasia* 
Chief Executive Officer
Chief Executive Officer
President, Retail and Preferred  
Dean C. Athanasia* 
Dean C. Athanasia* 
& Small Business Banking
President, Retail and Preferred  
President, Retail and Preferred  
Catherine P. Bessant* 
& Small Business Banking
& Small Business Banking
Chief Operations and  
Catherine P. Bessant* 
Catherine P. Bessant* 
Technology Officer 
Chief Operations and  
Chief Operations and  
Sheri B. Bronstein* 
Technology Officer 
Technology Officer 
Chief Human Resources Officer
Sheri B. Bronstein* 
Sheri B. Bronstein* 
Paul M. Donofrio* 
Chief Human Resources Officer
Chief Human Resources Officer
Chief Financial Officer
Paul M. Donofrio* 
Anne M. Finucane 
Chief Financial Officer
Vice Chairman,  
Anne M. Finucane 
Anne M. Finucane 
Bank of America
Vice Chairman,  
Vice Chairman,  
Geoffrey S. Greener* 
Bank of America
Bank of America
Chief Risk Officer
Geoffrey S. Greener* 
Geoffrey S. Greener* 
Christine P. Katziff 
Chief Risk Officer
Chief Risk Officer
Chief Audit Executive
Christine P. Katziff 
Kathleen A. Knox* 
Chief Audit Executive
President, U.S. Trust 
Kathleen A. Knox* 
David G. Leitch* 
President, U.S. Trust 
Global General Counsel
David G. Leitch* 
David G. Leitch* 
Thomas K. Montag* 
Global General Counsel
Global General Counsel
Chief Operating Officer
Thomas K. Montag* 
Thomas K. Montag* 
Thong M. Nguyen* 
Chief Operating Officer
Chief Operating Officer
Vice Chairman, 
Thong M. Nguyen* 
Thong M. Nguyen* 
Bank of America
Vice Chairman, 
Vice Chairman, 
Andrew M. Sieg* 
Bank of America
Bank of America
President, Merrill Lynch 
Andrew M. Sieg* 
Andrew M. Sieg* 
Wealth Management 
President, Merrill Lynch 
President, Merrill Lynch 
Andrea B. Smith* 
Wealth Management 
Wealth Management 
Chief Administrative Officer 
Andrea B. Smith* 
Andrea B. Smith* 
Bruce R. Thompson 
Chief Administrative Officer 
Chief Administrative Officer 
Vice Chairman
Bruce R. Thompson 
Bruce R. Thompson 
Vice Chairman
Vice Chairman

Christine P. Katziff 
Chief Audit Executive

Kathleen A. Knox* 
President, U.S. Trust 

Rudolf A. Bless 
Chief Accounting Officer

Management Committee**
Michael C. Ankrom Jr. 
Management Committee**
Management Committee**
Global Banking Chief Risk Officer  
Michael C. Ankrom Jr. 
Michael C. Ankrom Jr. 
and Enterprise Credit Risk Executive
Global Banking Chief Risk Officer  
Global Banking Chief Risk Officer  
Keith T. Banks 
and Enterprise Credit Risk Executive
and Enterprise Credit Risk Executive
Vice Chairman, Wealth  
Keith T. Banks 
Keith T. Banks 
Management and Head  
Vice Chairman, Wealth  
Vice Chairman, Wealth  
of Investment Solutions Group
Management and Head  
Management and Head  
Alexandre Bettamio 
of Investment Solutions Group
of Investment Solutions Group
President, Latin America
Alexandre Bettamio 
Alexandre Bettamio 
Rudolf A. Bless 
President, Latin America
President, Latin America
Chief Accounting Officer
Rudolf A. Bless 
D. Steve Boland 
Chief Accounting Officer
Head of Consumer Lending
D. Steve Boland 
D. Steve Boland 
Alastair M. Borthwick 
Head of Consumer Lending
Head of Consumer Lending
Head of Global Commercial Banking
Alastair M. Borthwick 
Alastair M. Borthwick 
Candace E. Browning-Platt 
Head of Global Commercial Banking
Head of Global Commercial Banking
Head of Global Research
Candace E. Browning-Platt 
Candace E. Browning-Platt 
James P. DeMare 
Head of Global Research
Head of Global Research
Co-Head of Global Fixed Income, 
James P. DeMare 
James P. DeMare 
Currencies & Commodities Trading
Co-Head of Global Fixed Income, 
Co-Head of Global Fixed Income, 
Fabrizio Gallo 
Currencies & Commodities Trading
Currencies & Commodities Trading
Head of Global Equities
Fabrizio Gallo 
Fabrizio Gallo 
Matthew M. Koder 
Head of Global Equities
Head of Global Equities
Head of Global Corporate  
Matthew M. Koder 
Matthew M. Koder 
and Investment Banking
Head of Global Corporate  
Head of Global Corporate  
Aron D. Levine 
and Investment Banking
and Investment Banking
Head of Consumer Banking  
Aron D. Levine 
Aron D. Levine 
and Investments
Head of Consumer Banking  
Head of Consumer Banking  
Bernard A. Mensah 
and Investments
and Investments
President of Europe, Middle East  
Bernard A. Mensah 
Bernard A. Mensah 
and Asia and Co-Head of Global 
President of Europe, Middle East  
President of Europe, Middle East  
Fixed Income, Currencies & 
and Asia and Co-Head of Global 
and Asia and Co-Head of Global 
Commodities Trading
Fixed Income, Currencies & 
Fixed Income, Currencies & 
Sharon L. Miller 
Commodities Trading
Commodities Trading
Head of Small Business
Sharon L. Miller 
Sharon L. Miller 
Andrei Magasiner 
Head of Small Business
Head of Small Business
Treasurer
Andrei Magasiner 
Andrei Magasiner 
E. Lee McEntire 
Treasurer
Treasurer
Investor Relations Executive
E. Lee McEntire 
E. Lee McEntire 
Investor Relations Executive
Investor Relations Executive

Robert A. Schleusner 
Head of Wholesale Credit

Lorna R. Sabbia 
Head of Retirement and  
Personal Wealth Solutions.

Lauren A. Mogensen 
Global Compliance and  
Lauren A. Mogensen 
Lauren A. Mogensen 
Operational Risk Executive
Global Compliance and  
Global Compliance and  
Tram V. Nguyen 
Operational Risk Executive
Operational Risk Executive
Global Corporate Strategy  
Tram V. Nguyen 
Tram V. Nguyen 
Executive and Head of Wealth 
Global Corporate Strategy  
Global Corporate Strategy  
Management Banking Products
Executive and Head of Wealth 
Executive and Head of Wealth 
Lorna R. Sabbia 
Management Banking Products
Management Banking Products
Head of Retirement and  
Lorna R. Sabbia 
Personal Wealth Solutions
Head of Retirement and  
Robert A. Schleusner 
Personal Wealth Solutions.
Head of Wholesale Credit
Robert A. Schleusner 
Thomas M. Scrivener 
Head of Wholesale Credit
Global Real Estate and  
Thomas M. Scrivener 
Thomas M. Scrivener 
Enterprise Initiative Executive
Global Real Estate and  
Global Real Estate and  
Jiro Seguchi 
Enterprise Initiative Executive
Enterprise Initiative Executive
Co-President, Asia Pacific and  
Jiro Seguchi 
Jiro Seguchi 
Head of Asia Pacific Corporate  
Co-President, Asia Pacific and  
Co-President, Asia Pacific and  
and Investment Banking;  
Head of Asia Pacific Corporate  
Head of Asia Pacific Corporate  
Country Executive, Japan
and Investment Banking;  
and Investment Banking;  
Jin Su 
Country Executive, Japan
Country Executive, Japan
Co-President, Asia Pacific and  
Jin Su 
Jin Su 
Co-Head of Asia Pacific  
Co-President, Asia Pacific and  
Co-President, Asia Pacific and  
Fixed Income, Currencies & Commodities
Co-Head of Asia Pacific  
Co-Head of Asia Pacific  
David C. Tyrie 
Fixed Income, Currencies & Commodities
Fixed Income, Currencies & Commodities
Head of Advanced Solutions  
David C. Tyrie 
David C. Tyrie 
and Digital Banking
Head of Advanced Solutions  
Head of Advanced Solutions  
Anne Walker 
and Digital Banking
and Digital Banking
CFO Chief Operating Officer  
Anne Walker 
Anne Walker 
and Corporate Financial  
CFO, Chief Operating Officer  
CFO, Chief Operating Officer  
Planning Executive
and Corporate Financial  
and Corporate Financial  
Ather Williams III 
Planning Executive
Planning Executive
Head of Business Banking
Ather Williams III 
Ather Williams III 
Sanaz Zaimi 
Head of Business Banking
Head of Business Banking
Head of Global  
Sanaz Zaimi 
Sanaz Zaimi 
Fixed Income, Currencies & Commodities 
Head of Global  
Head of Global  
Sales and Country Executive, France
Fixed Income, Currencies & Commodities 
Fixed Income, Currencies & Commodities 
Sales and Country Executive, France
Sales and Country Executive, France

  * Executive Officer

**  All members of the Executive Management Team are also members of the Management Committee
  * Executive Officer

  * Executive Officer

**  All members of the Executive Management Team are also members of the Management Committee

**  All members of the Executive Management Team are also members of the Management Committee

186  Bank of America 2018

186  Bank of America 2018

186  Bank of America 2018

Disclosure Controls and Procedures
Board of Directors
Bank of America Corporation and Subsidiaries
Bank of America Corporation
Board of Directors
As of the end of the period covered by this report and pursuant to Rule 13a-15 of the Securities Exchange Act of 1934, as amended 
Bank of America Corporation
(Exchange Act), Bank of America’s management, including the Chief Executive Officer and Chief Financial Officer, conducted an evaluation 
Board of Directors
of the effectiveness and design of our disclosure controls and procedures (as that term is defined in Rule 13a-15(e) of the Exchange 
Act). Based upon that evaluation, Bank of America’s Chief Executive Officer and Chief Financial Officer concluded that Bank of America’s 
Brian T. Moynihan 
Board of Directors
disclosure controls and procedures were effective, as of the end of the period covered by this report.
Chairman of the Board and 
Brian T. Moynihan 
Chief Executive Officer, 
Chairman of the Board and 
Bank of America Corporation
Chief Executive Officer, 
Jack O. Bovender, Jr. 
Bank of America Corporation
Lead Independent Director, 
Jack O. Bovender, Jr. 
Bank of America Corporation; 
Lead Independent Director, 
Former Chairman  
Bank of America Corporation; 
and Chief Executive Officer, 
Former Chairman  
HCA Inc.
and Chief Executive Officer, 
Sharon L. Allen 
HCA Inc.
Former Chairman, 
Sharon L. Allen 
Deloitte LLP
Former Chairman, 
Susan S. Bies 
Deloitte LLP
Former Member, 
Susan S. Bies 
Board of Governors of the 
Former Member, 
Federal Reserve System
Board of Governors of the 
Frank P. Bramble, Sr. 
Federal Reserve System
Former Executive Vice Chairman, 
Frank P. Bramble, Sr. 
MBNA Corporation
Former Executive Vice Chairman, 
Pierre J.P. de Weck 
MBNA Corporation
Former Chairman and 
Pierre J.P. de Weck 
Global Head of Private 
Former Chairman and 
Wealth Management, 
Global Head of Private 
Deutsche Bank AG
Wealth Management, 
Arnold W. Donald 
Deutsche Bank AG
President and  
Arnold W. Donald 
Chief Executive Officer,  
President and  
Carnival Corporation and  
Chief Executive Officer,  
Carnival plc
Carnival Corporation and  
Linda P. Hudson 
Carnival plc
Chairman and Chief Executive Officer, 
Linda P. Hudson 
The Cardea Group, LLC; 
Chairman and Chief Executive Officer, 
Former President and 
The Cardea Group, LLC; 
Chief Executive Officer, 
Former President and 
BAE Systems, Inc.
Chief Executive Officer, 
BAE Systems, Inc.

Monica C. Lozano 
Chief Executive Officer,  
Monica C. Lozano 
College Futures Foundation;  
Chief Executive Officer,  
Former Chairman,  
College Futures Foundation;  
US Hispanic Media Inc.
Former Chairman,  
Thomas J. May 
US Hispanic Media Inc.
Chairman, Viacom, Inc.; 
Thomas J. May 
Former Chairman, President,  
Chairman, Viacom, Inc.; 
and Chief Executive Officer, 
Former Chairman, President,  
Eversource Energy
and Chief Executive Officer, 
Lionel L. Nowell, III 
Eversource Energy
Former Senior Vice President  
Lionel L. Nowell, III 
and Treasurer, PepsiCo, Inc.
Former Senior Vice President  
Clayton S. Rose 
and Treasurer, PepsiCo, Inc.
President, Bowdoin College
Clayton S. Rose 
Michael D. White 
President, Bowdoin College
Former Chairman, President, and 
Michael D. White 
Chief Executive Officer, DIRECTV
Former Chairman, President, and 
Thomas D. Woods 
Chief Executive Officer, DIRECTV
Chairman, Hydro One Limited; 
Thomas D. Woods 
Former Vice Chairman and 
Chairman, Hydro One Limited; 
Senior Executive Vice President, 
Former Vice Chairman and 
Canadian Imperial Bank of Commerce
Senior Executive Vice President, 
R. David Yost 
Canadian Imperial Bank of Commerce
Former Chief Executive Officer, 
R. David Yost 
AmerisourceBergen Corporation
Former Chief Executive Officer, 
Maria T. Zuber 
AmerisourceBergen Corporation
Vice President for Research and 
Maria T. Zuber 
E.A. Griswold Professor of Geophysics, 
Vice President for Research and 
Massachusetts Institute of Technology
E.A. Griswold Professor of Geophysics, 
Massachusetts Institute of Technology

  * Executive Officer

  * Executive Officer

Bank of America 2018  187

Bank of America 2018  187
Bank of America 2018     185 

Corporate Information
Bank of America Corporation

Corporate Information
Corporate Information
Bank of America Corporation
Bank of America Corporation

Headquarters
The principal executive offices of Bank of America Corporation 
Headquarters
Headquarters
(the Corporation) are located in the Bank of America Corporate 
The principal executive offices of Bank of America Corporation 
The principal executive offices of Bank of America Corporation 
Center, 100 North Tryon Street, Charlotte, NC 28255.
(the Corporation) are located in the Bank of America Corporate 
(the Corporation) are located in the Bank of America Corporate 
Center, 100 North Tryon Street, Charlotte, NC 28255.
Center, 100 North Tryon Street, Charlotte, NC 28255.

Stock Listing
The Corporation’s common stock is listed on the New York 
Stock Exchange (NYSE) under the symbol BAC. The stock is 
typically listed as BankAm in newspapers. As of December 31, 
2018, there were 171,372 registered holders of the Corporation’s 
common stock.

Stock Listing
Stock Listing
The Corporation’s common stock is listed on the New York 
The Corporation’s common stock is listed on the New York 
Stock Exchange (NYSE) under the symbol BAC. The stock is 
Stock Exchange (NYSE) under the symbol BAC. The stock is 
typically listed as BankAm in newspapers. As of December 31, 
typically listed as BankAm in newspapers. As of December 31, 
2018, there were 171,372 registered holders of the Corporation’s 
2018, there were 171,372 registered holders of the Corporation’s 
common stock.
common stock.

Investor Relations
Analysts, portfolio managers and other investors seeking 
Investor Relations
Investor Relations
additional information about Bank of America stock should 
Analysts, portfolio managers and other investors seeking 
Analysts, portfolio managers and other investors seeking 
contact our Equity Investor Relations group at 1.704.386.5681 
additional information about Bank of America stock should 
additional information about Bank of America stock should 
or i_r@bankofamerica.com. For additional information about 
contact our Equity Investor Relations group at 1.704.386.5681 
contact our Equity Investor Relations group at 1.704.386.5681 
Bank of America from a credit perspective, including debt and 
or i_r@bankofamerica.com. For additional information about 
or i_r@bankofamerica.com. For additional information about 
preferred securities, contact our Fixed Income Investor Relations 
Bank of America from a credit perspective, including debt and 
Bank of America from a credit perspective, including debt and 
group at 1.866.607.1234 or fixedincomeir@bankofamerica.com. 
preferred securities, contact our Fixed Income Investor Relations 
preferred securities, contact our Fixed Income Investor Relations 
Visit the Investor Relations area of the Bank of America website, 
group at 1.866.607.1234 or fixedincomeir@bankofamerica.com. 
group at 1.866.607.1234 or fixedincomeir@bankofamerica.com. 
http://investor.bankofamerica.com, for stock and dividend 
Visit the Investor Relations area of the Bank of America website, 
Visit the Investor Relations area of the Bank of America website, 
information, financial news releases, links to Bank of America 
http://investor.bankofamerica.com, for stock and dividend 
http://investor.bankofamerica.com, for stock and dividend 
SEC filings, electronic versions of our annual reports and other 
information, financial news releases, links to Bank of America 
information, financial news releases, links to Bank of America 
items of interest to the Corporation’s shareholders.
SEC filings, electronic versions of our annual reports and other 
SEC filings, electronic versions of our annual reports and other 
items of interest to the Corporation’s shareholders.
items of interest to the Corporation’s shareholders.

Customers
For assistance with Bank of America products and services, 
call 1.800.432.1000, or visit the Bank of America website 
at www.bankofamerica.com. Additional toll-free numbers for 
specific products and services are listed on our website at 
www.bankofamerica.com/contact.

Customers
Customers
For assistance with Bank of America products and services, 
For assistance with Bank of America products and services, 
call 1.800.432.1000, or visit the Bank of America website 
call 1.800.432.1000, or visit the Bank of America website 
at www.bankofamerica.com. Additional toll-free numbers for 
at www.bankofamerica.com. Additional toll-free numbers for 
specific products and services are listed on our website at 
specific products and services are listed on our website at 
www.bankofamerica.com/contact.
www.bankofamerica.com/contact.

News Media
News media seeking information should visit our online 
News Media
News Media
newsroom at http://newsroom.bankofamerica.com for news 
News media seeking information should visit our online 
News media seeking information should visit our online 
releases, press kits and other items relating to the Corporation, 
newsroom at http://newsroom.bankofamerica.com for news 
newsroom at http://newsroom.bankofamerica.com for news 
including a complete list of the Corporation’s media relations 
releases, press kits and other items relating to the Corporation, 
releases, press kits and other items relating to the Corporation, 
specialists grouped by business specialty or geography.
including a complete list of the Corporation’s media relations 
including a complete list of the Corporation’s media relations 
specialists grouped by business specialty or geography.
specialists grouped by business specialty or geography.

Annual Report on Form 10-K
The Corporation’s 2018 Annual Report on Form 10-K is available 
at http://investor.bankofamerica.com. The Corporation also will 
provide a copy of the 2018 Annual Report on Form 10-K (without 
exhibits) upon written request addressed to:

Annual Report on Form 10-K
Annual Report on Form 10-K
The Corporation’s 2018 Annual Report on Form 10-K is available 
The Corporation’s 2018 Annual Report on Form 10-K is available 
at http://investor.bankofamerica.com. The Corporation also will 
at http://investor.bankofamerica.com. The Corporation also will 
provide a copy of the 2018 Annual Report on Form 10-K (without 
provide a copy of the 2018 Annual Report on Form 10-K (without 
exhibits) upon written request addressed to:
Bank of America Corporation  
exhibits) upon written request addressed to:
Office of the Corporate Secretary 
Hearst Tower, 214 North Tryon Street  
NC1-027-20-05 
Charlotte, NC 28255

Bank of America Corporation  
Bank of America Corporation  
Office of the Corporate Secretary 
Office of the Corporate Secretary 
Hearst Tower, 214 North Tryon Street  
Hearst Tower, 214 North Tryon Street  
NC1-027-20-05 
NC1-027-20-05 
Charlotte, NC 28255
Charlotte, NC 28255

Shareholder Inquiries
For inquiries concerning dividend checks, electronic deposit of 
dividends, dividend reinvestment, tax statements, electronic 
delivery, transferring ownership, address changes or lost or 
stolen stock certificates, contact Bank of America Shareholder 
Services at Computershare Trust Company, N.A., via the Internet 
at www.computershare.com/bac; call 1.800.642.9855; or write 
to P.O. Box 505005, Louisville, KY 40233. For general shareholder 
information, contact Bank of America Office of the Corporate 
Secretary at 1.800.521.3984. Shareholders outside of the United 
States and Canada may call 1.781.575.2621.

Shareholder Inquiries
Shareholder Inquiries
For inquiries concerning dividend checks, electronic deposit of 
For inquiries concerning dividend checks, electronic deposit of 
dividends, dividend reinvestment, tax statements, electronic 
dividends, dividend reinvestment, tax statements, electronic 
delivery, transferring ownership, address changes or lost or 
delivery, transferring ownership, address changes or lost or 
stolen stock certificates, contact Bank of America Shareholder 
stolen stock certificates, contact Bank of America Shareholder 
Services at Computershare Trust Company, N.A., via the Internet 
Services at Computershare Trust Company, N.A., via the Internet 
at www.computershare.com/bac; call 1.800.642.9855; or write 
at www.computershare.com/bac; call 1.800.642.9855; or write 
to P.O. Box 505005, Louisville, KY 40233. For general shareholder 
to P.O. Box 505005, Louisville, KY 40233. For general shareholder 
information, contact Bank of America Office of the Corporate 
information, contact Bank of America Office of the Corporate 
Secretary at 1.800.521.3984. Shareholders outside of the United 
Secretary at 1.800.521.3984. Shareholders outside of the United 
States and Canada may call 1.781.575.2621.
States and Canada may call 1.781.575.2621.

Electronic Delivery
As part of our ongoing commitment to reduce paper 
Electronic Delivery
Electronic Delivery
consumption, we offer electronic methods for customer 
As part of our ongoing commitment to reduce paper 
As part of our ongoing commitment to reduce paper 
communications and transactions. Customers can sign up to 
consumption, we offer electronic methods for customer 
consumption, we offer electronic methods for customer 
receive online statements through their Bank of America or 
communications and transactions. Customers can sign up to 
communications and transactions. Customers can sign up to 
Merrill Lynch account website. In 2012, we adopted the SEC’s 
receive online statements through their Bank of America or 
receive online statements through their Bank of America or 
Notice and Access rule, which allows certain issuers to inform 
Merrill Lynch account website. In 2012, we adopted the SEC’s 
Merrill Lynch account website. In 2012, we adopted the SEC’s 
shareholders of the electronic availability of Proxy materials, 
Notice and Access rule, which allows certain issuers to inform 
Notice and Access rule, which allows certain issuers to inform 
including the Annual Report, which significantly reduced the 
shareholders of the electronic availability of Proxy materials, 
shareholders of the electronic availability of Proxy materials, 
number of printed copies we produce and mail to shareholders. 
including the Annual Report, which significantly reduced the 
including the Annual Report, which significantly reduced the 
Shareholders still receiving printed copies can join our efforts 
number of printed copies we produce and mail to shareholders. 
number of printed copies we produce and mail to shareholders. 
by electing to receive an electronic copy of the Annual Report 
Shareholders still receiving printed copies can join our efforts 
Shareholders still receiving printed copies can join our efforts 
and Proxy materials. If you have an account maintained in your 
by electing to receive an electronic copy of the Annual Report 
by electing to receive an electronic copy of the Annual Report 
name at Computershare Investor Services, you may sign up 
and Proxy materials. If you have an account maintained in your 
and Proxy materials. If you have an account maintained in your 
for this service at www.computershare.com/bac. If your shares 
name at Computershare Investor Services, you may sign up 
name at Computershare Investor Services, you may sign up 
are held by a broker, bank or other nominee, you may elect 
for this service at www.computershare.com/bac. If your shares 
for this service at www.computershare.com/bac. If your shares 
to receive an electronic copy of the Proxy materials online at 
are held by a broker, bank or other nominee, you may elect 
are held by a broker, bank or other nominee, you may elect 
www.proxyvote.com, or contact your broker.
to receive an electronic copy of the Proxy materials online at 
to receive an electronic copy of the Proxy materials online at 
www.proxyvote.com, or contact your broker.
www.proxyvote.com, or contact your broker.

188  Bank of America 2018

188  Bank of America 2018
188  Bank of America 2018

Investment products: 

Are Not FDIC Insured

Are Not Bank Guaranteed

May Lose Value

“Bank of America Merrill Lynch” is the marketing name for the global banking and global markets businesses of Bank of America Corporation. 
Lending, derivatives and other commercial banking activities are performed globally by banking affiliates of Bank of America Corporation, 
including Bank of America, N.A., Member FDIC. Securities, strategic advisory, and other investment banking activities are performed globally 
by investment banking affiliates of Bank of America Corporation (“Investment Banking Affiliates”), including, in the United States, Merrill 
Lynch, Pierce, Fenner & Smith Incorporated and Merrill Lynch Professional Clearing Corp., both of which are registered as broker-dealers and 
Members of SIPC, and, in other jurisdictions, by locally registered entities. Merrill Lynch, Pierce, Fenner & Smith Incorporated and Merrill 
Lynch Professional Clearing Corp. are registered as futures commission merchants with the CFTC and are members of the NFA.

Global Wealth and Investment Management is a division of Bank of America Corporation (“BofA Corp.”). Merrill Lynch Wealth Management, 
Merrill Edge®, U.S. Trust, and Bank of America Merrill Lynch are affiliated sub-divisions within Global Wealth and Investment Management.

Merrill Lynch makes available products and services offered by Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) and other 
subsidiaries of BofA Corp. Merrill Edge is available through MLPF&S, and consists of the Merrill Edge Advisory Center (investment guid-
ance) and self-directed online investing.

U.S. Trust, Bank of America Private Wealth Management operates through Bank of America, N.A., and other subsidiaries of BofA Corp.

Bank of America Merrill Lynch is a marketing name for the Retirement Services businesses of BofA Corp. Banking products are provided 
by Bank of America, N.A., and affiliated banks, Members FDIC and wholly owned subsidiaries of BofA Corp.

Please review the Merrill Guided Investing Program Brochure (PDF) at merrilledge.com/guided-investingprogram-brochure (PDF) for import-
ant information including pricing, rebalancing and the details of the investment advisory program. Your recommended invest ment strategy 
will be based solely on the information you provide to us for this specific investment goal and is separate from any other advisory program 
offered with us. If there are multiple owners on this account, the information you provide should reflect the views and circumstances of all 
owners on the account. If you are the custodian of this account for the benefit of another person, please keep in mind that these assets will 
be invested for the benefit of the other person. Guided Investing is offered with and without an advisor. Merrill, Merrill Lynch, and/or Merrill 
Edge investment advisory programs are offered by Merrill Lynch, Pierce, Fenner and Smith Incorporated (“MLPF&S”). MLPF&S and Managed 
Account Advisors LLC (“MAA”) are registered investment advisors. Investment advisor registration does not imply a certain level of skill or 
training. https://www.merrilledge.com/guided-investing

BofA Merrill Lynch Global Research is research produced by Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) and/or one  
or more of its affiliates.

Case studies are intended to illustrate brokerage products and services available at Merrill and banking products and services available  
at Bank of America. You should not consider these as an endorsement of Merrill as an investment adviser or as a testimonial about a 
client’s experiences with us as an investment adviser. Case Studies do not necessarily represent the experiences of other clients, nor do 
they indicate future performance. Investment results may vary. The investment strategies discussed are not appropriate for every inves-
tor and should be considered given a person’s investment objectives, financial situation and particular needs. Clients should review with 
their Merrill Lynch Wealth Management Advisor the terms, conditions and risks involved with specific products and services.

Zelle should only be used to send money to friends, family or others you trust.

We recommend that you do not use Zelle to send money to persons that you do not know. Transfers require enrollment in the service and 
must be made from an eligible Bank of America consumer deposit account to a domestic bank account or debit card. Recipients have  
14 days to enroll to receive money or the transfer will be canceled. Transactions typically occur in minutes when the recipient’s email address 
or U.S. mobile number is already enrolled with Zelle. We will send you an email alert with delivery details immediately after you schedule 
the transfer. Dollar and frequency limits apply. See the Online Banking Service Agreement at bankofamerica.com/ serviceagreement for 
details, including cut-off and delivery times. Payment requests to persons not already enrolled in Zelle must be sent to a U.S. email address. 
Data connection required. Message and data rates may apply. Neither Bank of  America nor Zelle offers a protection program for any 
authorized payments made with Zelle. 

Zelle and the Zelle related marks are wholly owned by Early Warning Services, LLC and are used herein under license.

The ranking or ratings shown herein may not be representative of all client experiences because they reflect an average or sampling of 
the client experiences. These rankings or ratings are not indicative of any future performance or investment outcome.

Please recycle. The annual report is printed on 30% post-consumer waste (PCW) recycled paper.

© 2019 Bank of America Corporation. All rights reserved.

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© 2019 Bank of America Corporation
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